Community Capital Management, LLC

ITEM 1 – Cover Page Investment Adviser Brochure Community Capital Management, LLC 261 North University Drive, Suite 520 Fort Lauderdale, Florida 33324 (877) 272-7999 www.ccminvests.com June 30, 2026 This brochure provides information about the qualifications and business practices of Community Capital Management, LLC. If you have any questions about the contents of this brochure, please contact us at (877) 272-1977 or agreenspan@ccminvests.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Community Capital Management, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. Registration does not imply a certain level of skill or training.  Community Capital Management, LLC Investment Adviser Brochure This page discusses only the material changes to this brochure since the last annual update on March 17, 2026. Those changes include: • Item 8 was updated to reflect revisions to CCM's Impact Policy, including disclosure regarding bondholder engagement practices and updates to the description of CCM's impact investment framework. ii  Community Capital Management, LLC Investment Adviser Brochure ITEM 3. Table of Contents Table of Contents ITEM 4. Advisory Business ........................................................................................................................- 1 - ITEM 5. Fees and Compensation ................................................................................................................- 2 - ITEM 6. Performance-Based Fees and Side-By-Side Management ...........................................................- 5 - ITEM 7. Types of Clients ...........................................................................................................................- 5 - ITEM 8. Methods of Analysis, Investment Strategies and Risk of Loss ....................................................- 5 - ITEM 9. Disciplinary Information ..............................................................................................................- 9 - ITEM 10. Other Financial Industry Activities and Affiliations ..................................................................- 9 - ITEM 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............- 9 - ITEM 12. Brokerage Practices ..................................................................................................................- 10 - ITEM 13. Review of Accounts .................................................................................................................- 12 - ITEMS 14. Client Referrals and Other Compensation .............................................................................- 12 - ITEM 15. Custody ....................................................................................................................................- 13 - ITEM 16. Investment Discretion ..............................................................................................................- 13 - ITEM 17. Voting Client Securities ...........................................................................................................- 13 - ITEM 18. Financial Information ...............................................................................................................- 14 - iii  Community Capital Management, LLC Investment Adviser Brochure ITEM 4. Advisory Business Community Capital Management, LLC (“CCM”) was founded in 1998. CCM is majority owned by CCM Holding Company, LLC, a principal owner of which is Todd Cohen and minority owned by Impact Analytics LLC, the owner of which is Todd Cohen. CCM is an investment adviser providing investment supervisory services on a discretionary or non-discretionary basis. Investment management is guided by the objectives articulated by the client (i.e., preservation of capital, growth, income, growth and income) and clients can impose reasonable restrictions on investing in certain securities or types of securities. CCM also provides investment supervisory services on a discretionary basis to two series trusts, the Community Capital Trust and the Quaker Investment Trust (the “Registered Trusts”) including, respectively, the CCM Community Impact Bond Fund and the CCM Affordable Housing MBS ETF (the “Registered Funds”), all open-end management investment companies. In addition to offering direct accounts, CCM also offers investment advisory services to clients through “wrap programs” offered by broker‐dealers, investment advisers and other financial institutions (“sponsors”). Through these wrap programs, clients are offered a program of services, including comprehensive brokerage, custodial, and advisory services. These programs typically offer these bundled services for an all‐inclusive wrapped fee; however, the clients are charged an SEC fee and may be charged other fees. The fees for these programs are typically based on a percentage of assets under management. Under some program arrangements, the fees are not bundled. In such a case, the sponsor and CCM each charge a separate fee for the services provided. Please read Item 5 of this brochure for more information on fees. CCM offers advisory services through wrap programs to individuals, trusts, estates, corporations, pension and profit-sharing plans, and others. CCM is chosen by the client to act as a sub‐adviser through a pre‐selection process administered by the introducing broker‐dealer or financial consultant. Although CCM does not normally have direct client contact, the pre‐selection process is sufficiently detailed that CCM is able to provide individualized investment services. In most of these accounts, CCM is hired for specific investment models or strategies. Although investment restrictions are allowed in these accounts, CCM is usually given full investment discretion, and CCM exercises discretionary authority for the securities to be bought and sold, and the timing of the transactions. CCM’s ongoing contact with the introducing broker‐dealer or financial consultant ensures the ability to maintain individualized investment services. CCM engages in Fixed Income Impact Strategies, which is described in greater detail in Item 8 below and may offer other customized fixed income strategies. Private Lending and Credit Related Advisory Services. In addition to its investment advisory services, CCM offers discretionary and non-discretionary advisory services to certain clients in connection with private lending arrangements, and other credit solutions for impact oriented and - 1 -  Community Capital Management, LLC Investment Adviser Brochure emerging fund managers. These services are provided pursuant to client authorization and are offered as part of programs involving a joint venture between Mission Driven Finance (MDF) and CCM Strategic Solutions, LLC an affiliated entity described in Item 10 below. CRA‑Related Non‑Investment Advice. In addition to its investment advisory services, CCM may provide certain non‑investment advisory services related to Community Reinvestment Act (“CRA”) considerations. These services may include education and support regarding the potential CRA implications of certain investments. Such services are ancillary to CCM’s investment advisory business and do not constitute legal, accounting, or regulatory advice. CRA‑related services are provided only where authorized by the client and pursuant to the terms of the applicable agreement. Compensation for any CRA‑related non‑investment advisory services is disclosed in Item 5 of this brochure. As of December 31, 2025, CCM managed $6,995,782,784 in assets on a discretionary basis. ITEM 5. Fees and Compensation CCM’s impact core fixed income strategy, impact securitized strategy, and impact tax-exempt municipals strategy annual fees for direct (non-sub-advisory) separately managed accounts are payable quarterly in arrears or pre-paid in advance (depending upon the custodian) and based upon the calendar quarter market value either as provided by the pricing agencies utilized by CCM or by the custodian when mandated by contract according to the following standard schedule: Assets under Management Annual Fee as a Percentage of Assets First $25,000,000 0.40% Next $25,000,000 0.30% Next $50,000,000 0.25% Balance 0.20% The minimum for direct separately managed accounts is $10 million. Minimums may be waived in certain circumstances. CCM’s impact mortgage-backed securities strategy annual fees for direct (non-sub-advisory) separately managed accounts are payable quarterly in arrears or pre-paid in advance (depending upon the custodian) and based upon the calendar quarter market value either as provided by the pricing agencies utilized by CCM or by the custodian when mandated by contract according to the following standard schedule: Assets under Management Annual Fee as a Percentage of Assets First $25,000,000 0.30% Next $25,000,000 0.25% - 2 -  Community Capital Management, LLC Investment Adviser Brochure Next $50,000,000 0.20% Balance 0.15% The minimum for direct separately managed accounts is $25 million. Minimums may be waived in certain circumstances. CCM’s impact core fixed income strategy annual fees for sub-advisory and dual contract separately managed accounts are payable monthly in arrears or pre-paid in advance (depending upon the custodian) and based upon the calendar quarter market value provided by the custodian (including wrap sponsors) according to the following standard schedule: Assets under Management Annual Fee as a Percentage of Assets First $25,000,000 0.40% Next $25,000,000 0.30% Next $50,000,000 0.25% Balance 0.20% The minimums for sub-advisory and dual contract SMAs are $5 million. Minimums may be waived in certain circumstances. CCM’s impact core fixed income strategy annual fees for separately managed wrap accounts in UMA Unified Managed Accounts are payable monthly in arrears or pre-paid in advance (depending upon the custodian) and based upon the calendar quarter market value provided by the wrap sponsors according to the following standard schedule: Annual Fee 0.30% The minimum for UMA accounts is $5 million for single-style accounts or $5 million for multi-style accounts. Fees for providing investment advisory services to wrap program accounts are determined by an agreement between CCM and the introducing broker dealer, program sponsor, or financial consultant. The introducing program sponsors typically collect the total wrap fee on a quarterly basis and remit CCM’s portion. However, under some contractual agreements, the introducing broker and CCM each charge and collect a separate fee for their services. Fees are due on a pro rata basis upon termination of the agreement by the client. A client may terminate the contract at will, and there is usually a requirement to file thirty days written notice. Termination clauses provided by the program master agreements may vary. Lower fees for services comparable to those offered by CCM may be available from other firms. CCM provides additional advisory services on a discretionary and non-discretionary basis to - 3 -  Community Capital Management, LLC Investment Adviser Brochure accounts which have opted to participate in private lending arrangement(s) for impact and emerging funds through Bold Line Capital, LLC. Fees for participation are: Assets under Management Annual Fee as a Percentage of Assets First $100,000,000 0.30% Next $100,000,000 to 200,000,000 0.25% Amounts Over $200,000,000 0.20% In addition to AUM fees listed, an access/operations fee of 0.05% shall be charged by CCM on all assets allocated to the Bold Line strategy. Fees for partial periods are prorated. Prorated amounts will be calculated based on the number of days during which assets were under CCM’s management. In the case of any fees paid in advance, unearned portions thereof will be returned to the client via check or wire automatically upon termination of the investment advisory agreement. CCM can negotiate fees. CCM can offer fees that differ from its published rates for charitable clients, for employees and their families, for clients with unusual portfolios or service needs, and as required for competitive reasons. All deviations from published rates are subject to review and must be approved in advance by CCM’s President. Fees for separate accounts are charged according to the above schedules and are either deducted from client’s assets or invoiced as directed by each client on a quarterly basis, or as described above with respect to wrap program account fees. To the extent that a client’s assets are invested in mutual funds, including ETFs, the client will indirectly incur any investment management fees that are charged to the mutual funds by their investment managers. Separate account assets are not invested in any funds managed by CCM. For the affiliated Registered Funds, fees are computed daily and paid monthly and are calculated at annual rates based on the average daily net asset value of the Registered Funds. Currently, CCM is paid investment advisory fees in arrears. See each Registered Fund’s prospectus and SAI for associated fee information on file with the SEC. A client can terminate an investment advisory agreement at any time on written notice and CCM can terminate the agreement after thirty days’ written notice. Upon such notification, the portfolio will be valued, and the fee prorated for the period elapsed since the last billing. CCM or the affiliated Registered Funds can terminate the investment advisory agreement on 60 days’ written notice to the other party. From time to time, CCM will provide non-investment-related advice and education with regard to the implications of the Community Reinvestment Act of 1977. CCM has a special servicing agreement with respect to a particular share class (“CRA Shares”) of the CCM Community Impact Bond Fund whereby it charges an additional fee for this type of advice and education. - 4 -  Community Capital Management, LLC Investment Adviser Brochure In addition to CCM’s fees discussed above, clients might incur transaction costs. See the section titled “Brokerage Practices” below. During the second quarter of 2024, the SEC instituted a “T+1” (trade date plus one day) settlement time frame for certain types of securities. As a result, most custodians have instituted cutoff times to ensure same-day affirmation of trade instructions, resulting in a potentially shorter window within which CCM can trade, regardless of the time of market closings. Fees and costs may be incurred within client accounts in the event that market considerations warrant that CCM place trades after the custodian-imposed cut-off times. ITEM 6. Performance-Based Fees and Side-By-Side Management CCM does not receive performance-based fees. ITEM 7. Types of Clients CCM provides investment supervisory services to financial advisors, banks or thrift institutions, investment companies, pooled investment vehicles, pension and profit-sharing plans, trusts, estates or charitable organizations, corporations or other business entities and individuals. CCM requires a minimum investment of $10,000,000 for a direct (non-sub-advisory) separate account, which might be waived in certain circumstances. CCM can accept accounts which are lower than its published minimums for charitable clients, for employees and their families, for clients with unusual portfolios or service needs, and as required for competitive reasons. All deviations from published rates are subject to review and must be approved in advance by CCM’s President. Account minimums for wrap programs are determined by the wrap sponsor and will likely be lower than CCM’s direct (non-sub-advisory) separate account minimum. ITEM 8. Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS & INVESTMENT STRATEGIES CCM IMPACT POLICY CCM integrates impact considerations into its fixed income investment process with the goal of achieving competitive risk‑adjusted returns while supporting positive societal outcomes aligned with one or more of its impact themes. Fixed Income Impact Approach CCM invests in bonds where the investment team has a high degree of confidence that the use of or intent of proceeds will generate positive societal outcomes aligned with one or more of our impact themes, or that the issuing entity supports at least one of these themes. Such determinations are based on internal research, issuer disclosures, and third party information where available. 1. Use of Proceeds Due Diligence ➢ Impact bonds where the capital is financing positive societal outcomes at time of issuance. The - 5 -  Community Capital Management, LLC Investment Adviser Brochure investment team must have a high degree of confidence with: • The use of proceeds and how it is supporting one or more of CCM’s impact themes. • The use of proceeds and how it is having positive societal outcomes to people and communities. Impact bonds where the capital is financing positive societal outcomes tied to future projects. The ➢ investment team must have a high degree of confidence with: • The use-of-proceeds intent and how it supports one or more of CCM’s impact themes. • The project selection criteria and process. • The use of proceeds meeting its original intent and that the issuing entity is reporting in the stated time frame. 2. Issuer Due Diligence ➢ The investment team must have a high degree of confidence with: • The issuer and its track record. • The issuer reporting and/or any supplemental third party research. • How the entity supports one or more of CCM’s impact themes. Bondholder Engagement CCM may conduct bondholder engagement with public fixed income issuers on matters including disclosure quality and use-of-proceeds integrity. Our bondholder engagement serves as a proactive tool to enhance transparency and address long-term risks including meaningful societal impacts that traditional financial materiality frameworks may overlook. CCM’s investment team leads bondholder engagement efforts, engaging with sales desks or, when needed, escalating directly to issuers, including investor relations, treasurers, and bankers. Fossil Fuel Free Framework CCM applies a fossil‑fuel‑free framework that is focused primarily on the use of proceeds of fixed income securities. • We may invest in a bond whose use of proceeds will be used to finance activities or projects in clean and renewable energy or other activities that may contribute to the transition to a more sustainable economy, even if the issuer’s revenue or profits are partially derived from the fossil fuel sector. • We do not invest in bonds where the use of proceeds supports extracting, producing, processing, or refining the fossil fuels of oil, gas, and coal. • We do not invest in bonds where the use of proceeds supports storage, transportation, exploration, or production of carbon-related fuels or energy sources - 6 -  Community Capital Management, LLC Investment Adviser Brochure CCM’s impact policy is for clients incorporating impact investing into their portfolios. Not all advisory accounts advised by CCM incorporate impact investing considerations. The application of CCM’s impact policy is governed by the client’s investment management agreement, which may not include its considerations. RISK OF LOSS Noteworthy portfolio risks include the following: FIXED INCOME RISKS: • Interest Rate Risk. Generally, the prices of fixed-income debt securities tend to move in the opposite direction of interest rates. When rates are rising, the prices of debt securities tend to fall. When rates are falling, the prices of debt securities tend to rise. • Credit Risk. The value of debt securities also depends on the ability of issuers to make principal and interest payments. If an issuer cannot meet its payment obligations or if its credit rating is lowered, the value of its debt securities will fall. The ability of a state or local government issuer to make payments can be affected by many factors, including economic conditions, the flow of tax revenues and changes in the level of federal, state, or local aid. Some municipal obligations are payable only from limited revenue sources or private entities. • Prepayment Risk. Prepayments of principal on mortgage-backed securities may tend to increase due to refinancing of mortgages as interest rates decline. When this occurs, the portfolios may lose a portion of its principal investment to the extent the portfolio paid any premium for a security. In addition, the portfolio’s yield may be affected by reinvestment of prepayments at lower rates than the original investment. The portfolio may sell securities that it has held for less than one year. When it does so, the portfolio may realize short-term capital gains, which are taxed at higher rates than long-term capital gains. • Futures Risk. Futures contracts, swaps and certain other derivatives provide the economic effect of financial leverage by creating additional investment exposure, as well as the potential for greater loss. If the strategy uses leverage through activities such as borrowing, entering into short sales, purchasing securities on margin or on a “when-issued” basis or purchasing derivative instruments in an effort to increase its returns, it has the risk of magnified capital losses that occur when losses affect an asset base, enlarged by borrowings or the creation of liabilities. Leverage may involve the creation of a liability that requires the portfolio to pay interest. • Commodities Risk. Exposure to the commodities markets may subject the strategies to greater volatility than investments in traditional securities. The value of commodity-linked derivative investments may be affected by changes in overall market movements, commodity index volatility, changes in interest rates, or sectors affecting a particular industry or commodity. • Liquidity in Financial Markets. The financial markets in the United States and elsewhere may - 7 -  Community Capital Management, LLC Investment Adviser Brochure experience a variety of difficulties and changed economic conditions over time. Reduced liquidity in equity, credit and fixed-income markets may adversely affect many issuers worldwide. This reduced liquidity also may result in more difficulty in obtaining financing by issuers. In addition, these conditions could lead to reduced demand for the securities in which CCM invests, which may in turn decrease the value of managed assets. Because the securities held by CCM are marked to market and fluctuate in value based on supply and demand, reduced liquidity in the markets for certain securities could depress the value of the assets managed by CCM to less than their intrinsic value and may also make it difficult for the security or instrument to be valued. • Private Placement Risk: Investments in unlisted securities have a higher level of risk than exchange-listed securities due to a number of factors, including but not limited to, the age of the issuer, its financial history, the industry in which it operates, the experience of management, limited or nonexistent liquidity, restrictions on resale of the investment, and many other factors. • Private Lending and Collateral Risk. Advisory services related to private lending arrangements involve additional risks, including borrower default risk, collateral valuation risk, liquidity constraints, and potential conflicts among creditors. In stressed market conditions, pledged collateral may decline in value or become insufficient to cover outstanding obligations, which could result in losses to participating clients. OTHER POTENTIAL RISKS: Cybersecurity. With the increased use of technology, CCM is susceptible to operational, information security and related risks. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyber-attacks include, but are not limited to, gaining unauthorized access to digital systems for purposes of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cyber incidents impacting CCM have the ability to cause disruptions and impact business operations, potentially resulting in the inability to transact business, financial losses, violations of applicable privacy and other laws, regulatory fines, penalties, or reputational damage. While CCM has established a business continuity plan, risk management systems, and an Information Security program, including a cyber risk assessment and information security policies and procedures (all intended to identify and mitigate cyber incidents), there are inherent limitations in such plans and systems including the possibility that certain risks have not been identified. Furthermore, CCM cannot control the cybersecurity plans and systems put in place by third party service providers and issuers in which client portfolios invest. As a result, clients could be negatively impacted. Market Risk. All investment portfolios are affected by changes in the economy and swings in investment markets. Investing in securities involves a risk of loss that clients should be prepared to bear. Fair Valuation. It is CCM’s policy to ensure the proper valuation of all securities purchased and held - 8 -  Community Capital Management, LLC Investment Adviser Brochure for the benefit of its clients. In general, when the market value of a security is readily available, CCM shall rely on pricing services to determine the value of securities. In this connection, CCM is authorized to engage the services of one or more qualified independent pricing services to value securities. Differing pricing services for each type of security may be selected. When market value is not readily available, the value obtained is deemed to be unreliable, or there is a significant event affecting the value of a security, the “fair value” of a security is determined by the Valuation Designee Representative and reviewed by the Investment, Trading & Valuation Committee, taking into account various factors as recommended by applicable regulatory authorities, including the SEC. The fair value of a security may differ from its actual sales price at the time of sale. Use of Artificial Intelligence Tools. CCM may use artificial intelligence (“AI”) enabled tools in various areas of our business, such as research, data aggregation, operational efficiency, compliance support, and document review and we expect to expand its use over time. CCM does not rely on artificial intelligence tools to make autonomous investment decisions or to override human portfolio management judgment. While AI can improve efficiency, it also presents risks, including inaccurate or biased outputs, data security, privacy, intellectual property, regulatory compliance, and potential reputational harm. These tools require ongoing oversight and controls. Limitations or failures in AI systems could affect our analysis and recommendations and result in compliance or operational risks to our firm. ITEM 9. Disciplinary Information There are no material legal or disciplinary events. ITEM 10. Other Financial Industry Activities and Affiliations CCM has engaged PINE Distributors, LLC (“PINE”) to carry registered representative or principal licenses of those supervised persons of CCM who will service or assist in the offering of the shares of a Registered Fund. Currently there are 9 CCM supervised persons who are Registered Representatives with PINE. Bold Line Partners, LLC is a joint venture between Mission Driven Finance (MDF) and CCM Strategic Solutions, LLC (CCMSS, a wholly owned subsidiary of CCM’s parent company, CCM Holding Company, LLC). Bold Line Capital, LLC is a wholly owned subsidiary of Bold Line Partners, LLC. CCM manages separately managed accounts which may authorize it to enter into direct lending investments to impact and emerging funds on a discretionary and non-discretionary basis. CCM receives the compensation described in Item 5 in relation to these accounts. Because CCM has an indirect affiliation with Bold Line Capital, LLC, CCM has adopted policies and procedures designed to identify, disclose, and address potential conflicts of interest, including through client disclosure and consent. ITEM 11. Code of Ethics, Participation or Interest in Client Transactions and - 9 -  Community Capital Management, LLC Investment Adviser Brochure Personal Trading CCM and its supervised persons owe a fiduciary duty that client interests be placed ahead of personal or business interests. In an effort to ensure that CCM develops and maintains a reputation for integrity and high ethical standards it has adopted a Code of Ethics that establishes the standard of business conduct that all supervised persons must follow. The Code of Ethics also addresses personal trading and investments by access persons. Specifically, before transacting in any securities (other than those considered exempt pursuant to SEC guidance and industry standard practices), access persons must obtain pre-clearance. Absent extraordinary circumstances, pre- clearance is denied in instances where a trade order has been placed for a client account in the same issuer for the day of the trade. In addition, pre-clearance is required for any private placements, initial public offerings, or initial coin offerings to ensure that opportunities of limited availability are first afforded to clients where appropriate. Access persons are required to acknowledge at hire and annually thereafter that they have received, read, and understood the Code of Ethics and that they agree to comply with it in all respects. Additionally, access persons submit a report of their personal transactions on a quarterly basis and arrange for electronic feeds of their personal trading holdings and transactions to be submitted to CCM’s personal trading database. A copy of the Code of Ethics is available to any client or prospective client upon request. ITEM 12. Brokerage Practices The Chief Investment Officer oversees the determinations of the Investment, Trading & Valuation Committee, which is responsible for the oversight of brokerage practices, among other functions described in this document. CCM requests that discretionary clients provide it with written authorization to determine which securities are bought or sold and the amounts thereof as well as the broker or dealer to be utilized. CCM will select those brokers or dealers that will provide the best price and execution under the circumstances. Best price is normally an important factor in this decision, but the selection also takes into account the quality of brokerage services, including such factors as acting as originator, underwriter or market maker for relevant issues; quality of overall execution services provided by the broker-dealer; commission and transaction fees charged by the broker-dealer; promptness of execution; creditworthiness and business reputation of the broker-dealer; research (if any) provided by the broker-dealer; promptness and accuracy of oral, hard copy or electronic reports of execution; ability and willingness to correct errors; promptness and accuracy of confirmation statements; ability to access various market centers; the broker-dealer's facilities, including any software or hardware provided to CCM; any expertise the broker-dealer might have in executing trades for the particular type of security; reliability of the broker-dealer; if applicable, the ability of the broker-dealer to use electronic trading networks to gain liquidity, price improvement, lower commission rates and anonymity; and review of financial reports of the broker-dealer. Accordingly, transactions might not always be executed at the lowest available price or commission. Typically, commissions are not - 10 -  Community Capital Management, LLC Investment Adviser Brochure generated on fixed income transactions and transaction costs are built into the execution price. CCM has engaged a third-party execution monitoring firm to ensure that it continuously assesses its execution quality against industry metrics. Transaction cost reporting is reviewed on at least a quarterly basis by the Investment, Trading & Valuation Committee. CCM’s fiduciary duty to clients is especially evident when it comes to correcting errors made in placing trades for clients. A trade error is considered to have occurred if the order executed for a client materially differs from the trade instructions for that client (for reasons other than customary allocation of unfilled or partially filled orders) to the detriment of that client. It is CCM’s policy that when correcting a trading error, the client cannot be disadvantaged, therefore they must be made “whole.” CCM is authorized to purchase or sell securities between client accounts (known as a cross transaction) in accordance with applicable law. Clients are notified and provided with the transaction details in the event their account is either the purchaser or seller in a cross transaction on a quarterly basis. Upon written notice to CCM, clients can revoke their consent to cross transactions at any time. Generally, CCM will engage in cross trades when securities that are no longer warranted within one portfolio would benefit another client, thus reducing trading costs for both sides of the transactions. CCM from time to time might purchase securities with a forward settlement date, including most mortgage-backed securities. These securities might not have a recognizable CUSIP or pool number and might not be reflected in a client’s portfolio by its custodian until the settlement date. The securities are reflected within CCM’s records which are based upon trade-date accounting principles. These forward settling securities might require the provision of collateral, usually in the form of margining. On occasion, a security might be purchased for multiple accounts with the order for said security aggregating the accounts into a single trade. Such trades are generally allocated on a pro rata basis, unless circumstances (e.g., a partially filled order) warrant a different approach. Allocations on a basis other than pro rata are performed as required in CCM’s compliance manual. These activities are overseen by the Investment, Trading & Valuation Committee, and the Chief Investment Officer. Other than as noted below with respect to wrap programs, CCM does not accept brokerage direction from advisory clients due to the inherent limitations on trading venues given certain security types in which the Adviser transacts. When CCM is hired to manage assets through a wrap program, CCM is generally encouraged to direct account brokerage transactions to the sponsor or another broker‐dealer designated by the sponsor, except where CCM believes trading away is warranted. The sponsor’s goals for directed brokerage are to streamline trade execution and prevent additional transaction charges outside of the wrapped fee. Although CCM seeks to achieve the best trade execution for all of our accounts, in the case of directed brokerage accounts, CCM has less control and there is no guarantee that CCM can achieve optimal execution when trading within wrap programs. Also, CCM may not be able to obtain the ideal pricing for these types of accounts, as CCM is unable to aggregate the trades from these - 11 -  Community Capital Management, LLC Investment Adviser Brochure accounts with those of other clients of CCM. Trading away from directed brokerages is allowed and CCM trades away in situations where there are inherent limitations on trading venues given certain security types in which the Adviser transacts. Wrap program clients should consult with the sponsor of their particular wrap program to determine that the direction of brokerage provided for under the wrap program is reasonable in relation to the benefits received. ITEM 13. Review of Accounts Accounts are monitored by the Chief Investment Officer and the Investment, Trading & Valuation Committee on at least a quarterly basis. Portfolio valuations, portfolio holdings, portfolio changes and reports on investment policies are provided in writing at least quarterly and more frequently if requested by the client. Dual contract clients receive standard separate account quarterly reports (or if requested monthly). Reporting for traditional wrap accounts is provided by the wrap sponsor. ITEMS 14. Client Referrals and Other Compensation CCM can enter into written agreements with unaffiliated promoters. Promoters for governmental plans must be registered as a Broker-Dealer or an Investment Adviser Representative in order to do business with CCM. CCM will generally pay the promoter a percentage of all fees received by CCM from an investment advisory client for a period of twelve quarters following the date that the client retained CCM assuming that such retention occurred during the term of the agreement between CCM and the promoter. Such payment will not reduce the amount invested by a solicited investor. CCM is also reimbursed for its marketing efforts made on behalf of the CCM Community Impact Bond Fund under the 12b-1 Plans for the Community Capital Trust. - 12 -  Community Capital Management, LLC Investment Adviser Brochure ITEM 15. Custody U. S. Bank National Association serves as the custodian to the Registered Funds. All other separate account clients designate their own custodian and set up their own custodial accounts. Wrap program accounts are custodied with the broker-dealer wrap sponsor and receive all statements from them. Non-wrap separate account custodians supply quarterly statements. Clients should carefully review those statements and compare them with separate account statements sent by CCM. Differences might arise on account of variation in the pricing sources as well as differences in accounting (trade date versus settlement date) utilized by the custodians and CCM. ITEM 16. Investment Discretion CCM accepts discretionary authority to manage securities accounts on behalf of clients and requests that discretionary clients provide it with written authorization to determine which securities are bought or sold. Clients can impose guidelines or restrictions on this authority, subject to CCM’s ability to effectively manage the portfolio. Management of an account is contingent on the receipt of an executed investment management agreement and various documentation indicating authorized signatories depending on an account’s legal structure. ITEM 17. Voting Client Securities CCM has adopted a written proxy voting policy and established an Investment, Trading & Valuation Committee with authority to supervise the implementation and administration of the proxy policy, among other functions. For non-ERISA separate account clients, CCM states in its advisory agreement whether or not it is responsible for voting proxies. For traditional wrap or dual contract accounts, proxy voting responsibility is set forth within the associated agreements. If CCM undertakes to vote proxies, its fiduciary duty requires CCM to vote proxies in the best interest of its clients. It is CCM’s policy, where it has accepted responsibility to vote proxies on behalf of a particular client, to vote such proxies in the best interests of its clients and ensure that the vote is not the product of an actual or potential conflict of interest. For clients that are subject to ERISA, it is CCM’s policy to follow the provisions of the plan’s governing documents in the voting of plan securities, unless CCM determines that to do so would breach its fiduciary duties under ERISA. Additionally, with respect to securities held in any of the Registered Funds' portfolios, CCM will vote proxies related to such securities in a manner that is consistent with the interests of the Registered Funds. CCM will comply with the Registered Fund’s proxy policies if the Board of Trustees has adopted such policies. Clients can obtain a copy of CCM’s proxy voting policies and procedures upon request. Except for the Registered Funds, CCM will not take action or render advice involving legal action on behalf of a Client with respect to securities or other investments held in a Client's account or the issuers thereof, which become the subject of legal notices or proceedings, including securities class - 13 -  Community Capital Management, LLC Investment Adviser Brochure actions and bankruptcies. ITEM 18. Financial Information CCM does not require or solicit prepayments of more than $1,200 in fees per client six months or more in advance. There is no financial condition that is reasonably likely to impair CCM’s ability to meet contractual commitments to clients. CCM has not been the subject of a bankruptcy petition within the past 10 years. - 14 -