Annaly Credit Opportunities Management LLC

Annaly Credit Opportunities Management LLC is a registered investment adviser specializing in providing advisory services on a discretionary basis to clients, including pooled investment vehicles and separately managed accounts focused on residential mortgage loans and residential mortgage-backed securities. The firm, established in Delaware in 2017, is a wholly-owned subsidiary of Annaly Capital Management, Inc. With approximately $2,777,581,000 in regulatory assets under management as of December 31, 2024, all managed on a discretionary basis, the Adviser offers tailored advisory services based on specific investment objectives and strategies. Fees are negotiable and typically based on a percentage of assets under management, billed quarterly in arrears. The Adviser's investment strategy aims to generate income while preserving capital through investments in residential mortgage whole loans and securitized securities. The firm discloses various risks associated with its strategies, including cybersecurity risks, inflation risk, and risks related to disease outbreaks and public health concerns. The Adviser has a Code of Ethics in place to ensure high standards of business conduct and fiduciary duty to clients. The firm has disclosed potential conflicts of interest related to its business relationship with Annaly and its affiliates, as well as its brokerage practices and investment discretion. Clients are provided with regular account reviews and reports, and the Adviser complies with custody and voting client securities regulations.