Roosevelt Management Company LLC (“Roosevelt”), a Delaware limited liability company, is a New York-based firm with an advisory business that is focused on investments, directly or indirectly, in, and the management of, U.S. (including Puerto Rico) residential mortgage loans (“Loans”), foreclosed real estate (“REO”), excess mortgage servicing rights related to Loans (“Excess MSRs”), residential mortgage-backed securities (“RMBS”) and interests therein (collectively, “Real Estate Related Assets”), generally specializing in distressed or credit impaired residential mortgage assets. Roosevelt was founded in 2008 by a team of veteran mortgage professionals with experience in pricing, due diligence, asset management, servicing oversight, and restructuring of distressed mortgage assets. Roosevelt’s wholly-owned subsidiary Rushmore Loan Management Services LLC (“Rushmore”) provides residential mortgage loan servicing throughout the United States (including Puerto Rico), and Rushmore’s subsidiary, Dakota Asset Services LLC (“Dakota”), provides REO management and disposition services. Rushmore also operates a correspondent mortgage loan division through which it acquires closed Loans originated by third party lenders. Such Loans are pooled and delivered into Fannie Mae, Freddie Mac or Ginnie Mae or sold to third party aggregators. Loans acquired by Rushmore through its correspondent channel are not sold to Clients. Roosevelt also owns captive software and technology development companies which provide development services primarily to Roosevelt and its subsidiaries. Roosevelt’s principal owner is Roosevelt Senior Professional LLC, whose members are Michael O’Hanlon and Alan Waxman. Roosevelt provides investment management and advisory services to investment entities, typically pooled investment vehicles (“Clients”) investing primarily in Real Estate Related Assets. Typically, the Clients are owned or controlled by large, sophisticated, institutional investment managers and their managed investment funds or other sophisticated financial institutions. To date, except with respect to certain Loan-level loss mitigation strategies, Roosevelt’s investment acquisition/disposition advisory services have been provided on a non- discretionary basis. Roosevelt focuses on asset categories that utilize Roosevelt’s experience in the U.S. residential mortgage market, leveraging Roosevelt’s relationships with mortgage industry participants, including its subsidiary Rushmore, and its substantial analytical, due diligence, risk management (such as credit risk and counterparty risk), asset valuation and asset management capabilities to identify, acquire and manage Real Estate Related Asset investments. Roosevelt typically identifies Real Estate Related Assets available for sale from select relationships with banks, broker-dealers, governmental and quasi-governmental agencies and other financial institutions, including Clients, as well as in certain circumstances, referral agents, and analyzes and values such Real Estate Related Assets using various quantitative econometric variables and qualitative data internally generated and obtained from third parties. Roosevelt may perform functions related to risk management and due diligence, both in conjunction with and/or subsequent to identifying and recommending potential investment opportunities to its Clients. Roosevelt may perform asset level due diligence of the Real Estate Related Assets, including legal/compliance reviews, title and lien reviews, property valuation reviews, collateral and credit underwriting reviews, as appropriate and as requested by the Client. Roosevelt also may negotiate the terms of each such investment transaction on behalf of its Clients as directed and requested by the Client. Each of Roosevelt’s Clients determines the Real Estate Related Assets it will acquire and the price at, and the material terms under, which those assets will be acquired. Currently, Roosevelt does not have discretion to make investment decisions on behalf of its Clients. Its advisory services are limited to (a) sourcing and recommending Real Estate Related Assets for investment, (b) due diligence and asset value analysis, (c) services related to structuring an investment, which may include the use of certain entities, vehicles or trusts (collectively, “Vehicles”) to acquire, hold and/or finance certain Real Estate Related Assets, on behalf of the Clients, and (d) ongoing services, which may include the monitoring, management and valuation of certain Real Estate Related Assets, each as and to the extent requested and directed by the Client. From time to time, Roosevelt may provide additional services requested by Clients in connection with Real Estate Related Assets on a negotiated basis. Roosevelt may act as administrator of a Client or a Client Vehicle, and as such, may perform administrative corporate functions for such Client or Vehicle, including cash management and tax accounting services, and/or select and direct the loan servicer (which may be or include Rushmore), the document custodian, the paying agent, the trustee and other agents for a Client or Client Vehicle and/or the Real Estate Related Assets. Upon request, Roosevelt will also assist Clients wanting to leverage their investment to obtain financing of such positions and may provide administrative services in connection with any financing arrangements. In providing asset management services, Roosevelt may make certain asset level decisions related to the Real Estate Related Assets. In performing such services, Roosevelt seeks to maximize return objectives on Real Estate Related Assets by leveraging its expertise in developing loss mitigation and asset resolution strategies and overseeing the servicer in its implementation of individual asset resolution plans to resolve Real Estate Related Assets through, among other things, modifications, payoffs, foreclosures, sales and refinancing. Roosevelt provides advisory services to its Clients in accordance with the investment objectives specified by each Client in its management agreement with Roosevelt and other written directives from the Client, and not to the investors of each Client. Clients may impose restrictions on the type of Real Estate Related Assets in which it will invest and/or provide guidelines with respect to asset level mitigation or disposition strategies. While Roosevelt’s Clients typically request the full range of investment advisory services provided by Roosevelt, if requested and upon mutual agreement, Roosevelt may provide Clients with only limited services. As of December 31, 2019, Roosevelt managed approximately $3,287,443,477 (fair market value) of Real Estate Related Assets for its Clients on a non-discretionary basis. As of December 31, 2019, Roosevelt did not manage any Client assets on a discretionary basis. please register to get more info

For its investment advisory services, Roosevelt may receive one or more of the following types of fees: (i) an asset acquisition fee, (ii) a fee based on the value of assets under management, a fee based on the amount of assets under management, or a fee based on invested capital of assets under management, and (iii) incentive compensation or profits interests entitling Roosevelt or its affiliates or related persons to a percentage of distributions made by a Client in excess of a specified preferred return. It may also receive a fixed fee for certain specified investment advisory related services, such as due diligence, in each case as set forth in the applicable Client’s management agreement, statement of work or other governing documents. Asset acquisition fees are generally payable upon the acquisition by the Client of Real Estate Related Assets. Fees based on the value of assets under management are generally payable monthly in arrears and fees based on the amount of assets under management are generally payable monthly in advance. Distributions in connection with profits interests are generally received periodically when the Clients make distributions and only if the specified preferred return has been met. The amount of any investment advisory fees (other than asset acquisition fees) may be prorated for periods of less than the full applicable billing cycle. Fees are negotiable and the type and amount of fees may vary based on the Client and the type and acquisition date of Real Estate Related Assets in which the Client invests and the nature of the services provided. In the event of the termination of its management agreement, the Client may obtain a refund of any prepaid fees as set forth in its management agreement. Further, in the event of a termination of the management agreement, Roosevelt (or its affiliates or related persons) may remain entitled to payment of incentive compensation with respect to managed Real Estate Related Assets acquired by the Client prior to the date of termination as specified in the applicable Client’s management agreement. Clients generally are billed for fees and expenses. Clients also bear, directly or indirectly, other fees and expenses related to the establishment, administration and dissolution of the Vehicles and the acquisition, management, servicing, disposition and valuation of the Real Estate Related Assets, in each case as set forth in the Client’s management agreement or other governing documents. These fees and expenses typically include, but are not limited to, (a) Vehicle operating expenses, including transaction- related expenses (i.e., referral agent fees and due diligence expenses), custodial fees, bank service fees, legal fees and trustee fees, (b) costs and expenses (including due diligence expenses and legal fees) related to potential investments in or sales of Real Estate Related Assets (whether or not consummated); (c) Vehicle legal, accounting, insurance and other administrative expenses, including the costs and expenses of any audit, investigation or governmental inquiry and the costs and expenses of any indemnification or litigation relating to the activities or operations of the Vehicles and the amount of any judgments or settlements paid in connection therewith; (d) Vehicle entity-level taxes (including any tax liabilities relating to the ownership of Real Estate Related Assets); (e) servicer fees for servicing the Real Estate Related Assets (including servicer fees to Roosevelt’s subsidiary Rushmore and REO management and disposition fees to Dakota) and (f) reimbursement of certain servicer, depositor and Roosevelt costs and advances (including costs and advances to Roosevelt’s subsidiaries). If a Client leverages its investments, it bears all financing related costs and expenses. For information regarding brokerage practices, please see “Item 12 - Brokerage Practices” below. please register to get more info

As described in “Item 5 – Fees and Compensation” above, Roosevelt or its affiliates or related persons may receive incentive compensation or profits interests entitling them to a percentage of distributions made by certain Clients in excess of a specified preferred return. The fact that a portion of Roosevelt’s compensation (or its affiliates’ or related persons’, including its investment professionals, compensation) is directly tied to profit distributions made by Clients may create an incentive for Roosevelt and Roosevelt’s investment professionals to recommend investments that are riskier or more speculative or to take more risks in managing Client Real Estate Related Assets than would be the case in the absence of such compensation. Additionally, the payment by some but not all Clients of profits interest distributions, or the payment of profits interest distributions at varying rates, may create an incentive for Roosevelt or its professionals to disproportionately allocate time, services or functions to Clients making profits interest distributions or Clients making profits interest distributions at a higher rate. Roosevelt has adopted policies and procedures that among other things, seek to ensure in good faith that investment opportunities are offered fairly to its Clients. In determining which Client or Clients will be offered a potential investment opportunity it has identified, Roosevelt considers a variety of factors, including, stated investment objectives, type and amount of desired investments, risk profile, pricing assumptions, desired investment returns and Client fee arrangements. However, Roosevelt may offer potential investment opportunities in Real Estate Related Assets it identifies first to Clients who are related to Roosevelt or its affiliates. If such Clients decline the opportunity or wish to acquire less than all of the Real Estate Related Assets offered, Roosevelt will offer the opportunity to its other Clients based on the factors described above. Such preferential treatment is disclosed to Roosevelt’s Clients and Roosevelt Clients understand that certain investment opportunities may be presented to them only to the extent that Roosevelt related Clients determine not to pursue such opportunities or wish to acquire less than all of the Real Estate Related Assets offered. In some cases, the Client itself may decide to offer a co- investment opportunity to other Clients or other investors it identifies with respect to a specific investment opportunity. please register to get more info

See “Item 4 – Advisory Business” for a description of Roosevelt’s Clients. Roosevelt has no minimum account size. please register to get more info

General
Roosevelt seeks investments, directly or indirectly, in Real Estate Related Assets, including sub- performing, non-performing, re-performing and performing Loans, REO, RMBS and Excess MSRs. Roosevelt focuses on asset categories that utilize Roosevelt’s experience in the U.S. residential mortgage market, leveraging Roosevelt’s relationships with mortgage industry participants, including its subsidiary mortgage servicer Rushmore, and its substantial analytical, asset valuation, risk management and asset management capabilities to identify, acquire and manage Real Estate Related Asset investments on behalf of Clients. Roosevelt typically identifies Real Estate Related Assets available for sale from select relationships with banks, broker dealers, governmental and quasi-governmental agencies and other financial institutions, including Clients, as well as in certain circumstances referral agents, and analyzes and values such Real Estate Related Assets using various quantitative econometric variables and qualitative data internally generated and obtained from third parties. Roosevelt may perform functions related to risk management and due diligence, both in conjunction with and/or subsequent to, recommending investment opportunities to its Clients. Roosevelt may perform asset level due diligence of the Real Estate Related Assets, including legal/compliance review, title and lien searches, property valuation reviews and collateral credit underwriting reviews, as appropriate and as requested by the Client. Roosevelt also may negotiate the terms of each such investment transaction on behalf of its Clients as directed and requested by the Client. Each of Roosevelt’s Clients determines the Real Estate Related Assets it will acquire and the price at, and the material terms under, which those assets will be acquired. Currently, Roosevelt does not have discretion to make investment decisions on behalf of its Clients. Roosevelt seeks to enhance the value of its Clients’ investments in Real Estate Related Assets thought optimal acquisition pricing and successful execution of asset level mitigation strategies. By applying the operational expertise of the management team on an asset-by-asset basis, and overseeing loss mitigation decisions on a case-by-case basis, Roosevelt believes it is better able to achieve Clients’ objectives.

Roosevelt collaborates with servicers of its Clients’ Real Estate Related Assets (including its subsidiary, Rushmore) to formulate asset-level resolution strategies consistent with the Clients investment goals and guidelines, and oversees servicers’ implementation of asset-level resolution strategies designated by Roosevelt. Loss mitigation strategies for acquired Loans include, but are not limited to, short-term payment plans, permanent loan modifications (which may include interest rate reduction, principal forgiveness, extension of maturity and/or reduction or forgiveness of accrued charges and interest), deeds in lieu, and short sales. The manner in which a subperforming or nonperforming loan is resolved will impact the amount and timing of revenue received. The servicer, on behalf of Roosevelt as the asset manager, may negotiate with a sub or non-performing borrower to modify the terms of his or her Loan, and once the modification has occurred, the Loan will become a reperforming loan as the borrower resumes payments. A Client may hold onto select reperforming loans to earn long-term yield and cash flow. In certain circumstances, a borrower may choose to refinance its loan or a Client may also consider selling the modified loans. A portion of the Loans will enter into foreclosure or similar proceedings, ultimately becoming REO. REO property can be converted into single-family rental properties that may generate long-term returns for a Client or they may be sold through REO liquidation and short sale processes. Roosevelt may use various proprietary models and applications to support its businesses. These include models and applications which analyze, monitor performance of and value of certain Real Estate Related Assets, models and applications which analyze and maintain information related to assets and asset resolution strategies and applications which communicate information and decisions to servicers. Upon request, Roosevelt also assists Clients wanting to leverage their investment to obtain financing of such positions and may provide administrative services in connection with any financing arrangements. Conflicts related to Investment Strategies At times, Roosevelt may identify and recommend to Clients Real Estate Related Assets available for sale by other Clients. In such instance, Roosevelt will disclose the material aspects of its role in such transactions, including any sourcing or transaction fees payable to it, and obtain appropriate Client consents prior to the close of any such transaction. Conflict in these types of cross-Client transactions are mitigated by such disclosures, the fact that Roosevelt’s Clients are each sophisticated and experienced investors, and the fact that each Client makes its own sale or investment decision. Generally, Roosevelt does not sell securities to or purchase securities form any Client, except with respect to Excess MSRs sourced by Roosevelt and offered to Clients. Excess MSRs may be related to MSRs owned by or to be owned by Roosevelt’s subsidiary, Rushmore. In any such principal transaction, in addition to disclosing its ownership of Rushmore, Roosevelt will obtain appropriate Client consents prior to the close of any such transaction. Conflicts of this type are mitigated by such disclosures, and the fact that the Clients investing in Excess MSRs are sophisticated and experienced investors, each of which makes its own investment decision and each of which has the opportunity to obtain valuations provided by unaffiliated third parties prior to making an investment decision. Roosevelt’s subsidiary, Rushmore, may facilitate the refinancing of Loans owned by and serviced for a Client or with respect to which a Client holds an interest in the related Excess MSRs, unless such facilitation is prohibited or otherwise restricted by the Client. Refinancing may be inconsistent with the Client’s investment strategy for the Real Estate Related Asset. Roosevelt believes this potential conflict is mitigated by the fact that the Client knows that refinance is an accepted risk of investing in Loans and Excess MSRs and Rushmore will be prohibited from facilitating such refinancings if restricted by Client. Roosevelt has adopted policies and procedures designed to identify and properly disclose, mitigate, and/or eliminate applicable conflicts of interest. Conflicts of interest that involve Roosevelt, and/or Roosevelt affiliates on one hand, and its Clients on the other hand, will generally be fully disclosed and resolved in accordance with the applicable Clients’ management agreements. Conflicts are mitigated through full and fair disclosure coupled with Roosevelt’s non-discretionary investment authority.
Material Risks of Roosevelt’s Strategies:
The investment strategies described above involve a substantial degree of risk and Clients may lose all or a substantial portion of the value of their investments. Material risks relating to the investment strategies and methods of analysis described above include the following: Distressed Assets. Distressed Real Estate Related Assets are acquired using risk adjusted pricing metrics and as such may result in significant returns to the Client. However, returns are highly dependent on successful execution of resolution strategies, and both resolution strategies and timelines are highly dependent on (x) overall market conditions and other factors that may impact a borrower’s ability to repay the debt, (y) significant regulatory requirements and (z) he overall ability of the servicer (and other service providers) to execute its services. As a result, investment in portfolios of distressed Real Estate Related Assets involve a substantial degree of risk. The level of analytical sophistication, both financial and legal, necessary for successful investment in distressed assets is unusually high. Market and Regulatory Conditions. Real Estate Related Assets will be materially affected by conditions in the financial markets and economic conditions in the United States, including interest rates, availability of and terms of credit, housing supply and demand, employment rates, inflation rates, economic uncertainty, natural disasters, changes in laws, regulation and policy, particularly those affecting the U.S. housing and real estate markets. Disease Outbreaks and Public Health Concerns

Certain illnesses spread rapidly and have the potential to significantly adversely affect the global economy. The outbreak of infectious diseases and other serious public health concerns, including, but not limited to, outbreaks such as the severe acute respiratory syndrome, avian influenza, H1N1/09 influenza, and, most recently, SARS-CoV-2 and the related COVID-19, or other similarly infectious diseases, together with any resulting restrictions on travel or impositions of quarantines, may have a material and adverse impact on the economic and business activities of Roosevelt and the value and performance of any existing and potential investments in Real Estate Related Assets, and further may negatively impact Roosevelt’s ability to effectively conduct and manage the affairs of its Clients. Roosevelt cannot predict the likelihood of disease outbreaks occurring in the future or how such outbreaks may affect the performance of investments in Real Estate Related Assets.

For example, beginning in late 2019, a public health pandemic related to the COVID-19 outbreak prompted government-imposed closures of many businesses, significant disruption to financial markets, supply chains, and consumer demands for goods and services. In addition, such closures and other disruptions and related precautionary measures and restrictions have led to significantly increased volatility and uncertainty in the economy, affecting interest rates, unemployment, and other macroeconomic factors, all of which could have a material impact on the value of an investment in Real Estate Related Assets. It is unknown how long such closures, other disruptions, and related precautionary measures and restrictions will persist, but they are likely to have material adverse effects on many businesses and industries, including those involving Real Estate Related Assets. Further, federal and state legislation and rules enacted in response to the COVID-19 outbreak allow for the deferment of payments under Loans and impose a moratorium on foreclosures or evictions for at least sixty days. These rules and regulations, as well as any additional federal and/or state legislation or rules that may be enacted, which may affect the price, liquidity and/ or marketability of Real Estate Related Assets, and may affect the price, liquidity and/or marketability materially. Roosevelt will continue to evaluate the effect of the COVID-19 outbreak on investments in Real Estate Related Assets, but given the fluid and worldwide nature of the outbreak, no meaningful prediction of its impact can be made at this time. Federal and State Policy Considerations As a result of the credit crisis and subsequent financial turmoil, the federal government put in place statutory and regulatory frameworks and policies (including the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) enacted in 2010) providing for extensive supervision and regulation of financial firms, as well as various state and local laws and regulations. Many of these laws, regulations and rules address servicing practices generally, and the foreclosure process specifically, including imposing significant procedural requirements prior to proceeding with the foreclosure process, imposing mandatory mediation on the part of servicers and mortgagors, formalizing new defenses to foreclosure, insulating servicers from liability for modification of mortgage loans, limiting otherwise applicable provisions of mortgage loans and encouraging permanent forgiveness of debt. These laws, regulations and rules are likely to result in delays and increased servicing costs and may result in reduction in payments on Real Estate Related Assets. In addition, several courts and state and local governments and their officials also have taken unprecedented steps to slow the foreclosure process or prevent foreclosure altogether. Federal regulators and state attorneys general have brought enforcement actions against a number of large servicers resulting in consent and settlement agreements related to alleged foreclosure abuses. The Dodd-Frank Act and other recent federal and state legislation and rules have also affected residential mortgage loan origination, including underwriting, practices. These include rules prohibiting lenders from originating residential mortgage loans unless the lender determines that the borrower has a reasonable ability to repay the loan. Loans originated meeting certain criteria, including a determination of the borrower’s ability to repay the loan, may be denominated as a “qualified mortgage.” Purchasers of qualified mortgages have limited assignee liability and securitizers of such mortgages are not subject to the risk retention rules described under “Liquidity” below. If a loan is not originated in compliance with the “qualified mortgage” requirements (such loans being commonly referred to as “non-QM loans”), purchasers are not afforded the enhanced protections from legal liability associated with qualified mortgages, which, in addition to the risk retention requirements described below, increases the risk of investment in these types of Loans. These laws and regulations may affect the price and/or marketability of Loans and Excess MSRs. Clients bear the risk that future regulatory and legal developments and the attendant increase in servicing costs may result in situations where proceeds received in respect of Real Estate Related Assets are less than anticipated. Housing Market Cyclicality Beginning in the second quarter of 2007, the residential mortgage market in the United States, and the United States economy as a whole, experienced a variety of difficulties and negative economic conditions that adversely affected the performance and market value of Real Estate Related Assets, which rebounded starting in 2012. Between 2007 and 2012, residential real estate values declined often severely, after extended periods of significant appreciation. Similarly, delinquencies and losses with respect to Real Estate Related Assets increased during this period, leaving many mortgagors with little or no equity in their mortgaged properties. The lack of equity gives borrowers less incentive to cure delinquencies and avoid foreclosure and hinders their ability to refinance in an environment of increasingly restrictive lending standards. Since 2012, however, the U.S. economy and the U.S. real estate market has seen gradual improvement with real estate prices increasing in certain markets, resulting in the restoration of some or all of certain borrowers lost equity. However, there can be no assurance that market conditions will remain or improve further in the near future. As a result of market conditions and legislation, lenders initially adjusted their loan programs and underwriting standards to be generally more conservative, thereby reducing the availability of mortgage credit to prospective mortgagors and mortgagors seeking to refinance their mortgage loans. More recently, as the market has improved and the legislative requirements have become more mature and established, lenders have begun to offer loan products to borrowers across a broader credit spectrum. Even as market conditions have continued to improve, the depressing effect of the above adverse conditions and increased regulations on the market value and liquidity of Real Estate Related Assets generally may continue for some time. This may adversely affect a Client’s ability to leverage its investments or achieve profitable returns and may delay return of capital or result in a loss in invested capital. The above market conditions may also affect the availability of certain types of Real Estate Related Assets for investment. As market conditions have improved, fewer distressed Real Estate Related Assets are being offered for sale. Management Risk. The successful acquisition and management of Real Estate Related Assets depends in part upon the skill and expertise of Roosevelt management. There can be no assurance that any individual professional will continue to be associated with Roosevelt. Should certain key Roosevelt management members leave Roosevelt, it could adversely affect Roosevelt’s ability to perform investment advisory services to Clients, and thus, the performance or value of a Client’s investment in Real Estate Related Assets. Model Assumptions. Although updated periodically to reflect changing or additional assumptions or data, reliance on analytic models like those used by Roosevelt entails significant risk, particularly if the assumptions or the data on which such models rely prove to be incorrect, misleading, or incomplete. In such case, reliance on models may lead Roosevelt to recommend the purchase of Real Estate Related Assets at prices that are too high, the sale of such assets at prices that are too low, or cause Clients to miss favorable opportunities altogether. In addition, Roosevelt stores the majority of the data upon which these models rely in computer databases. The failure of such computer systems could adversely affect Client accounts for whom such models are used. Competition for Investments. Roosevelt expects to encounter competition from entities having similar investment strategies and objectives. Certain of these entities may possess competitive advantages over Roosevelt or its Clients in pursuing investment opportunities, including greater financial or other resources, higher risk tolerances, different risk assessments, better connections, lower return thresholds, lower cost of capital and access to funding sources not available to Clients. Liquidity; Yield. Investments in Real Estate Related Assets are relatively illiquid, and such illiquidity may limit Roosevelt’s ability to optimally execute on loss mitigation or asset resolution strategies. Real Estate Related Assets acquired by Clients may be subject to legal and other restrictions on transfer and a liquid market for such Real Estate Related Assets may not exist. The market prices, if any, for such investments tend to be volatile and may not be readily ascertainable and a Client may not be able to sell them when it desires to do so or to realize what it perceives to be their fair value in the event of a sale. Prices for such Real Estate Related Assets may fluctuate due to a variety of factors, including market and regulatory conditions, type of pool and composition of Real Estate Related Assets and whether the Real Estate Related Assets are performing or not. The ability to securitize Real Estate Related Assets may be adversely affected by the risk retention rules enacted by the federal bank regulatory agencies, HUD and the SEC pursuant to the Dodd Frank Act which become effective December 24, 2015. Such rules generally require securitizers to retain not less than 5% of the credit risk of the mortgage loans (other than qualified mortgage loans) securitized. In addition, since 2007 the public Loan securitization market has been significantly disrupted, and as a result securitizations of Real Estate Related Assets have been accomplished with a limited number of institutional investors through the private market. The private market is a less liquid market, and generally affords investors more input into the price and other terms of the securitization. The sale of such Real Estate Related Assets may require significant time. Such risk retention rules may also adversely affect the availability or terms of financing of Real Estate Related Assets. The rate and timing of Loan prepayments as well as Loan delinquencies will affect the investment’s yield. In addition, the ability of the servicer to modify the terms of Loans that are in default or for which default is likely foreseeable in a timely and efficient manner may affect the yield on investments in Loans. Concentration. Roosevelt targets investment in a limited group of assets - Real Estate Related Assets. Investment in limited asset types generally involves more risk than investment in diversified asset types. In addition, specific portfolios of Real Estate Related Assets may be or become concentrated in certain geographic areas, and as a result, may be adversely affected by economic, political, regulatory or natural events only affecting those limited regions. Loss Mitigation Alternatives. Roosevelt directs the servicers to utilize a variety of different loss mitigation alternatives in resolving distressed Real Estate Related Assets. This may include short-term payment plans, permanent loan modifications (which may include interest rate reduction, principal forgiveness, extension of maturity and/or reduction or forgiveness of accrued charges and interest), deeds in lieu, short sales (involving principal forgiveness), short refinances (involving principal forgiveness) and foreclosures. The specific circumstances surrounding each distressed Real Estate Related Asset (such as financial situation of the borrower, current market value of property in relation to amount of the debt owed and lien position) will determine which loss mitigation alternative is selected by Roosevelt for such Real Estate Related Asset and such decision will impact the profitability or return on such Real Estate Related Asset. Federal and state laws, regulations and practices may also affect the nature, terms and timing of loss mitigation alternatives offered. Collection Risk. The ability of a servicer to enforce ownership rights in Real Estate Related Assets may be limited, delayed or prevented by a number of different circumstances. These include missing or defective documents evidencing the debt and mortgage or ownership thereof, litigation challenging the validity or legality of the initial loan transaction and litigation challenging the foreclosure or eviction process and borrower bankruptcy. In addition, certain cities, counties and states have imposed obligations and liabilities on the owners of vacant REO which could delay, prevent or increase the cost of selling the REO. Real Estate Related Assets have risks above and beyond those discussed above. These include “special hazard” risk (property damage caused by hazards, such as earthquakes or environmental hazards, not covered by standard property insurance policies), and to bankruptcy risk (reduction in a borrower’s mortgage debt by a bankruptcy court). In addition, claims may be assessed against the Vehicle on account of its position as mortgage holder or property owner, including responsibility for tax payments, environmental hazards and other liabilities. Owners of REO may also be liable for environmental problems. While delays will increase the cost of realizing on the Real Estate Related Asset, if the servicer is unable to enforce the owner’s rights with respect to a Real Estate Related Asset or sell an REO, the owner will be unable to recoup its investment. Leverage. A Client may borrow funds to pay expenses, make or facilitate new investments or for other purposes. The use of borrowed funds created the opportunity for greater total returns, but at the same time involves certain risks. A Client may not be successful without the use of significant leverage in its portfolio investments and leverage may be costly or unavailable. See “Liquidity” above. The inability of a client to obtain desired amounts of leverage may limit the Client’s overall investment exposure, thereby reducing total returns. Borrowed funds are subject to interest, transaction and other costs, which may not be recovered by portfolio returns and therefore decrease investment returns. Servicer Risk. The insolvency of the servicer or the failure of the servicer to properly service the Loans and REO or to execute asset resolution plans in a timely and efficient manner may adversely affect the collection of principal and interest on the Loans and the enforcement of rights involving the Loans and REO. The owner of Excess MSRs generally does not control the servicing of the underlying Loans or the actions of the MSR owner. Actions or inactions by the MSR owner or a subservicer can adversely affect the performance of the underlying Loans and consequently the value of or income from the Excess MSRs. In addition, if the underlying Loans are owned by Fannie Mae, Freddie Mac or Ginnie Mae, adverse changes in the MSR owner’s or subservicer’s approval status or condition as well as actions by the applicable agency can adversely affect the value of or income from the Excess MSRs, and may substantially impact or eliminate the value of the Excess MSR. Interest Rate Risk. Changes in market interest rates can affect the value of Real Estate Related Assets. The value of re-performing Loans are generally adversely affected as interest rates rise and the value of Excess MSRs are generally adversely affected as interest rates decrease. please register to get more info

Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would be materials to a Client’s or potential Client’s evaluation of the advisor or the integrity of the advisor’s management in this Item. Roosevelt has no legal or disciplinary events to report. please register to get more info

In providing services to its Clients, Roosevelt may engage or use certain services of its affiliated service providers, including the entities listed below. Rushmore, a subsidiary of Roosevelt, is authorized to provide loan servicing throughout the United States (including Puerto Rico). Rushmore provides loan servicing services to a significant portion of the Real Estate Related Assets managed by Roosevelt and may on occasion acquire certain Real Estate Related Assets on behalf of and deposit such Real Estate Related Assets into the Vehicles or hold certain Real Estate Related Assets as nominee for a Vehicle. Servicing fees (including fees payable for Dakota services) received by Rushmore are believed to be at market rates. Rushmore also operates a correspondent mortgage loan division through which it acquires closed Loans originated by third party lenders. Such Loans are pooled and delivered into Fannie Mae, Freddie Mac or Ginnie Mae or sold to third party aggregators. Loans acquired by Rushmore through its correspondent channel are not sold to Clients. Rushmore’s subsidiary, Dakota, may provide REO management and disposition services for Real Estate Related Assets. Fees for Dakota services are believed to be at market rates. Elkhorn Depositor LLC (“Depositor”), a Delaware limited liability company, may acquire Real Estate Related Assets on behalf of certain affiliated Clients and deposit such Real Estate Related Assets into the Vehicles. Roosevelt is the sole member of Depositor. Depositor receives fees from Roosevelt for such services. Monticello GenPar LLC (“General Partner”), a Delaware limited liability company, has been appointed to act as the general partner of certain limited liability Vehicles acquiring Real Estate Related Assets on behalf of certain affiliated Clients. Roosevelt is the sole member of the General Partner. The General Partner does not receive any fees in connection with providing such services. Conflicts of Interest The use of Rushmore and Dakota may create a potential conflict of interest. However, Roosevelt believes such conflict is mitigated by the fact that Rushmore is required to service Real Estate Related Assets in accordance with generally accepted servicing practices, is subject to examination and/or regulation by federal and state regulators, HUD, Fannie Mae, Freddie Mac and Ginnie Mae, and its servicing contract terms, including price, are believed to be consistent with market practice, and generally consistent with servicing contract terms offered by Rushmore to third party non-Client servicing customers, In addition, material servicing contract terms, including price, are generally subject to the prior approval of the Client. Roosevelt has adopted policies and procedures designed to identify and properly disclose, mitigate, and/or eliminate applicable conflicts of interest. Conflicts of interest that involve Roosevelt, and/or Roosevelt affiliates on one hand, and its Clients on the other hand, will generally be fully and fairly disclosed and resolved in accordance with the applicable Clients’ management agreements. please register to get more info

Transactions, and Personal Trading
Roosevelt has adopted a comprehensive Regulatory Compliance program which includes a Code of Ethics and Personal Investment Policy (“Code”) that is applicable to its officers, directors, and employees. The Code, which is designed to comply with Rule 204A-1 under the Investment Advisers Act of 1940, as amended, establishes guidelines for professional conduct and personal trading procedures. The Code, among other things, requires compliance with the federal securities law, reflects Roosevelt’s fiduciary responsibilities and those of its advisory personnel, prohibits certain personal securities transactions, requires certain personnel to periodically report and/or pre-clear personal securities transactions and addresses prevention of the misuse of confidential or material nonpublic information. Roosevelt requires that all employees observe the applicable standards of care set forth in the Code and not seek to evade the provisions of the Code or the “spirit” of its requirements, including by way of indirect acts of family members. The Code is distributed to Roosevelt employees at hire and annually thereafter. On an annual basis, Roosevelt requires all employees to certify that they are in compliance with the Code. Roosevelt conducts ongoing monitoring of employee activity. Except as described below, neither Roosevelt nor employees are permitted to invest in the Real Estate Related Assets recommended to Clients without the prior approval of the Roosevelt Chief Compliance Officer. Certain Roosevelt management members and non-management directors have made capital contributions to, and have continuing capital commitments to, certain Clients or their related parties. In the event such Clients make an investment in certain Real Estate Related Assets, such management members and non-management directors are obligated to contribute to such Clients’ or their affiliates a portion of the capital required for such investments. In addition, such management members or non-management directors indirectly hold or may acquire profits interests in certain Clients, Vehicles or affiliates that entitle them to a share of the profits distributions made by such Clients or Vehicles. Also, on occasion, such management members or non-management directors may co-invest with Clients in Real Estate Related Asset acquisition transactions. These arrangements may create a potential conflict of interest with respect to investments recommended or not recommended. However, neither Roosevelt nor such management members or non-management directors have discretion to make investment decisions on behalf of these Clients. Roosevelt will provide a copy of the Code to any existing or prospective Client upon request. please register to get more info

Roosevelt is not affiliated with any broker-dealer. Due to the unique nature of the Vehicle structure and the fact that Clients directly or indirectly acquire specific pools of Real Estate Related Assets or interests therein, investment transactions are generally not executed through a broker-dealer or on an exchange. RMBS transactions, however, will be executed through a broker-dealer selected or approved by the Client. Certain Real Estate Related Assets which are available for purchase may be identified to Roosevelt by unaffiliated referral agents that may be broker-dealers. If certain Real Estate Related Assets are offered for sale by one or more Clients, Roosevelt may utilize the services of unaffiliated sales agents that may be broker-dealers. If the Clients determine to acquire or sell such Real Estate Related Assets, the Clients will bear the cost of any negotiated fees. All such agents and fees are identified to the Client by Roosevelt prior to the Client’s decision to make or dispose of an investment. please register to get more info

Roosevelt closely monitors the Real Estate Related Asset portfolios on behalf of Clients. Roosevelt management and professional staff continually review and analyze portfolio performance, concentrations, duration, valuations and other relevant portfolio metrics, as well as monitor, review and modify workout plans for Real Estate Related Assets to maximize Client return objectives. Roosevelt provides periodic written reports to Clients covering various matters to the extent applicable to the type of services requested. Such reports may include portfolio and servicing reviews, cash source and use reports, financial statements, tax reports, asset value, income projections and other matters required by law or regulation. Roosevelt management is also available to meet with Clients to discuss their accounts. please register to get more info

To date, Roosevelt has not engaged third party solicitors for its advisory business but it may in the future. Any arrangements with third party solicitors for new advisory business will comply with Rule 206(4)-3 under the Investment Advisers Act of 1940, as amended, pursuant to which persons introducing new Client accounts to Roosevelt may receive a portion of the advisory fee generated by the account for a period of time that varies on a case by case basis. please register to get more info

Roosevelt will generally not take or maintain physical custody of any Client’s cash or securities, and will conduct all business operations in such a way that the C lients’ cash and securities will be preserved in the safekeeping of independent Qualified Custodians. Any certificated securities shall be maintained by a Qualified Custodian. All Client funds are held by a Qualified Custodian in a manner designed to meet the requirements of the exceptions to Rule 206-(4) under the Investment Advisers Act of 1940 (the “Custody Rule”). However, in certain limited circumstances, Roosevelt may have the right to authorize payments from bank accounts of Clients to third parties. Payments authorized by Roosevelt are subject to the prior approval of the Client and compliance with any such Client’s cash management policy. Client approval is deemed to have been received if the payment is required in accordance with a contractual agreement entered into by the Client with a third party (such as margin calls pursuant to financing agreements entered into by Client with a third party lender). In addition, Roosevelt has the right to give release and delivery instructions to Custodians which have physical custody of Client Loan documents and files to facilitate proper servicing and servicing transfer of the Loans. Servicers, including Rushmore, law firms and certain others may from time to time have short term-temporary physical custody under bailment of certain Client Loan documents and files in order to enforce Client rights and perform servicing related functions. In addition, Roosevelt may occasionally have short term temporary physical custody of certain Client Loan documents, including trailing documents and assignments, in connection with Loan acquisitions and servicing transfers. please register to get more info

Roosevelt currently does not have discretion to make investment decisions on behalf of its Clients. please register to get more info

Roosevelt currently does not have authority to vote proxies for its Clients and does not advise its Clients with respect to any investments in voting securities. please register to get more info

Roosevelt is not aware of any financial condition affecting it that is reasonably likely to impair its ability to meet its contractual commitments to Clients. please register to get more info