MESIROW FINANCIAL INVESTMENT MANAGEMENT, INC.

June 24, 2025 Mesirow Financial Investment Management, Inc. Wealth Management 353 North Clark Street, Chicago, Illinois 60654 Telephone: 312-595-6000 | Email: inquiries@mesirow.com ITEM 1 | Cover Part 2A of Form ADV Firm Brochure This brochure provides information about the qualifications and business practices of the Wealth Management division of Mesirow Financial Investment Management, Inc. (“MFIM”). If you have any questions about the contents of this brochure, please contact 312.595.6000 or inquiries@mesirow.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about Mesirow Financial Investment Management, Inc., is also available on the SEC’s website at www.adviserinfo.sec.gov. The site may be searched by a unique identifying number known as a “CRD number.” MFIM’s CRD number is 111135. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved.  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Wealth Management ITEM 2 | Material Changes Mesirow Financial Investment Management, Inc. (“MFIM”) Form ADV Part 2A, currently dated June 24, 2025, as amended from time to time, is MFIM’s client disclosure document prepared based on the Securities and Exchange Commission’s regulatory requirements. MFIM is required to update this document at least annually, or when an event occurs that may be deemed to have a material impact on MFIM’s Wealth Management and related investment management business and/or on its clients. After a thorough and thoughtful review, MFIM has made the decision to close the Microcap Strategy in a gradual wind-down process beginning in May and continuing through June. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 2  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Wealth Management ITEM 3 | Table of Contents ITEM 1 | Cover ...................................................................................................................................... 1 ITEM 2 | Material Changes .................................................................................................................... 2 ITEM 3 | Table of Contents .................................................................................................................... 3 ITEM 4 | Advisory Business ................................................................................................................... 4 ITEM 5 | Fees and Compensation ......................................................................................................... 5 ITEM 6 | Performance-Based Fees and Side-by-Side Management ...................................................... 8 ITEM 7 | Types of Clients ...................................................................................................................... 8 ITEM 8 | Methods of Analysis, Investment Strategies and Risk of Loss ................................................. 8 ITEM 9 | Disciplinary Information ......................................................................................................... 10 ITEM 10 | Other Financial Industry Activities and Affiliations ............................................................... 10 ITEM 11 | Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......... 11 ITEM 12 | Brokerage Trading Practices ............................................................................................... 13 ITEM 13 | Review of Accounts ............................................................................................................. 14 ITEM 14 | Client Referrals and Other Compensation ........................................................................... 14 ITEM 15 | Custody ............................................................................................................................... 14 ITEM 16 | Investment Discretion .......................................................................................................... 15 ITEM 17 | Voting Client Securities ....................................................................................................... 15 ITEM 18 | Financial Information ........................................................................................................... 15 Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 3  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Wealth Management ITEM 4 | Advisory Business MFIM, an Illinois corporation formed in 1986, is an investment adviser registered with the SEC with its principal place of business located in Illinois. Registration with the SEC does not imply any level of skill or training. MFIM’s sole shareholder is Mesirow Financial Services, Inc., which is a wholly owned subsidiary of Mesirow Financial Holdings, Inc. MFIM does not provide tax or legal advice. Clients should consult with an expert on tax or legal issues. WEALTH MANAGEMENT CLIENTS MFIM Wealth Management assists clients with both investment management and financial planning services. For private clients, MFIM Wealth Management offers both discretionary and non-discretionary services. MFIM Wealth Management primarily assists in preparing an Investment Policy Statement based on a particular client’s investment objectives and sets asset allocation targets based on these objectives. MFIM Wealth Management then constructs an investment portfolio based on asset allocation targets. Quantitative and qualitative measures are used to evaluate the portfolio on an ongoing basis, as well as to evaluate the performance of the portfolio in relation to the client’s Investment Policy Statement. MFIM Wealth Management can engage third-party investment managers or sub- advisors specializing in distinct objectives as part of implementing an overall investment strategy. MFIM can also utilize proprietary products, including private investment funds and private alternative investment products. A client will pay management fees to affiliates of MFIM if proprietary products are included in the client’s investment line-up, which are in addition to the fees paid to MFIM, subject to any fee offsets or credits that may be required for accounts subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), or similar laws. MFIM also internally manages a Quality Dividend Strategy. This strategy is designed to primarily invest in the equities of companies generating regular dividend income with the potential for capital appreciation. Additionally, MFIM Wealth Management offers access to qualified clients to various private investments, some of which are proprietary and others which are third-party funds. First, MFIM Wealth Management acts as investment manager to an affiliated private fund, the Wealth Advisors Feeder Fund I, L.P. (herein referred to as “WA Feeder Fund”), a Delaware Limited Partnership. Investment in the WA Feeder Fund is not open to the general public and is offered only to a limited number of MFIM qualified investors. The WA Feeder Fund was formed for the purpose of investing substantially all of its assets in the Acacia Conservation Fund, L.P. (the “Underlying Fund”), a Delaware Limited Partnership. As Investment Manager of the WA Feeder Fund, MFIM Wealth Management manages the fund’s investments and certain administrative matters. Moreover, MFIM Wealth Management offers investment to qualified clients in the Mesirow Real Estate Value Fund IV Feeder, L.P. and Mesirow Real Estate Value Fund V Feeder, L.P. (herein referred to as the “Real Estate Feeder Funds”). The Real Estate Feeder Funds are not open to the general public and are offered only to qualified MFIM Wealth Management clients. The Real Estate Feeder Funds were formed for the purpose of investing substantially all of its assets in the Mesirow Financial Real Estate Value Funds managed by an affiliated MFIM entity and available to institutional investors. The Real Estate Feeder Funds are managed by an affiliated MFIM entity and has been established for the purpose of investing exclusively by MFIM Wealth Management clients. Lastly, MFIM Wealth Management offers investment to qualified clients in the Mesirow Private Equity Fund VIII-B Feeder, L.P. (the “Private Equity Feeder Fund”). The Private Equity Feeder Fund is not open to the general public and is offered only to qualified MFIM Wealth Management clients. The Private Equity Feeder Fund was formed for the purpose of investing substantially all of its assets in the Mesirow Financial Private Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 4  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Wealth Management Equity Fund VIII-B, L.P., managed by an affiliated entity, Mesirow Financial Private Equity Advisors, Inc., and available to institutional investors. The Private Equity Feeder Fund is managed by an affiliated MFIM entity and has been established for the purpose of investing exclusively by MFIM Wealth Management clients. Feeder funds incur the master fund manager’s associated fees and expenses, and such fees and expenses are generally allocated to investors, which include the feeder fund, on a pro-rata basis. This means that clients invested in the feeder funds indirectly bear such costs, in addition to MFIM’s consulting fee. In addition to the proprietary private funds listed herein, MFIM Wealth Management can make available certain other private investment funds, private investments in companies or alternative investment strategies either directly or through allocations into other funds investing in those strategies. WEALTH MANAGEMENT As of March 31, 2025, MFIM Wealth Management managed approximately $9.31 billion in assets on a discretionary basis and $1.15 billion in assets on a non-discretionary basis, with an additional $876 million in assets under advisement. ITEM 5 | Fees and Compensation WEALTH MANAGEMENT CLIENTS MFIM Wealth Management provides investment advisory services to clients for an annual fee. Clients generally pay an investment advisory fee based on a percentage of assets under management and under advisement. Fees based on either AUM or AUA typically are established at a rate of 1%, but can deviate based on account size, client’s aggregate assets under management/advisement, depth of the client relationship, complexity of financial planning services provided, and other reasons not listed. Alternatively, some clients may pay a flat annual rate as negotiated with MFIM Wealth Management for planning and/or investment advisory services. MFIM Wealth Management charges a minimum annual fee of $4,000, which can be reduced or waived at MFIM’s discretion. Sub-advisors and third-party investment managers charge a separate management fee in addition to MFIM’s management fee. The separate fee is determined by the sub-advisor and is only applied to assets managed in a segregated separately managed account. The specific sub-advisor fees are disclosed to clients at the time of onboarding and will depend on the specific third-party manager being used to execute a specific investment strategy. Certain sub- advisors may be accessed through third-party platforms which also contain certain additional administrative or platform fees. Those additional fees are disclosed at the time of onboarding and will depend on the specific third-party platform used to execute the investment strategy. MFIM Wealth Management’s Quality Dividend Strategy generally charges a fee consistent with the client’s annual advisory fee. Mutual funds, private investment funds and other alternative investments offered will contain investment advisory fees as well as other expenses, such as accounting, tax and audit expenses, legal fees, and ongoing administrative expenses. Private investment funds that invest in an underlying fund managed by an affiliated or unaffiliated fund manager typically will also incur the underlying fund manager’s associated fees and expenses, and such fees and expenses are generally allocated to clients on a pro-rata basis. MFIM Wealth Management will receive compensation for advisory services relating to mutual funds, private investment funds, private investments in companies or alternative investments, including investments in proprietary products where MFIM Wealth Management or an affiliate thereof Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 5  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Wealth Management serves as the general partner and/or investment manager. Additional details on fees relating to mutual funds, private investment funds, private investments in companies and/or alternative investments can be found in relevant offering memorandum and other governing documents. For investments in proprietary products, MFIM Wealth Management will receive compensation for advisory services while an affiliate receives separate compensation as investment manager, subject to any fee offsets or credits that may be required for accounts subject to ERISA or similar laws. This creates a conflict of interest, as MFIM has an economic incentive to recommend proprietary investment products to clients, over products managed by third party advisers. WEALTH MANAGEMENT SERVICES Management fees are generally to be paid quarterly in advance. However, there may be instances when fees are billed in arrears, including certain alternative investments and third-party managers or sub-advisors. For purposes of determining the management fees, the value of the assets under management is based on information provided by the custodian of the assets. In the event an account terminates, the unearned management fee will be refunded based upon the number of days during the quarter the account was not under management. For non-retirement advisory services, management fees are typically deducted from the custodial account and paid directly to MFIM. For funds or securities which MFIM or an affiliate manage or originate, MFIM or the affiliate may set the valuation, or have significant input into the valuation. In these instances, MFIM or the affiliate has a conflict in that it is incentivized to overstate the value of the asset. As with all assets, clients are encouraged to review and question any valuation provided by MFIM, or its affiliates. Mesirow Financial, Inc. (“MFI”) is an affiliated broker-dealer of MFIM. In connection with the purchase or recommendation of mutual funds, in the event MFI is appointed as the broker-dealer of record, MFI will receive Rule 12b-1 fees from certain mutual funds. In those instances, the client’s advisory fees will be reduced and offset by the amount of the Rule 12b-1 fees received by MFI to mitigate any conflict of interest. MFI will also receive and retain fees received in connection with such mutual fund transactions for performing services related to shareholder accounting and related communications. In addition, some mutual fund companies pay revenue on amounts invested in non-transaction fee funds. As part of its agreement with its clearing firm, MFI will receive some of this revenue. As not all mutual funds pay revenues on non- transaction fee funds, MFI is incentivized to purchase shares of mutual funds that pay revenue on amounts invested in such funds. Limited Negotiability of Advisory Fees MFIM retains the discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances and needs will be considered in determining the fee schedule. These facts, circumstances and needs may include, among other factors, the complexity of the client; assets to be placed under management; anticipated future additional assets; related accounts; portfolio style; account composition; and reporting requirements. The specific annual fee schedule will be identified in the contract between MFIM and each client. Discounts, not generally available to our advisory clients, are offered to employees, family members and friends of associated persons of MFIM. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 6  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Wealth Management Termination of the Advisory Relationship Clients may generally terminate their investment management agreement upon providing five (5) days’ prior written notice. Certain fees are paid in advance of services provided. Upon termination of any account, any prepaid, unearned fees are generally refunded. In calculating a client’s reimbursement of fees, MFIM will prorate the reimbursement according to the number of days remaining in the billing period. For those clients that utilize outside managers that bill in arrears, such as sub-advisors or third-party managers, if the account is terminated before the end of a calendar quarter or if the account is transferred from MFIM in its entirety before the end of a calendar quarter, the outside manager fee will be charged calculated based on the amount of time the account was opened during the quarter prior to account termination. MFIM has authority in its sole discretion, and without notice, terminate a client relationship, to freeze or restrict client accounts or to limit activity in a client’s account. Additional Fees and Expenses In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker/dealers (including MFI or NFS), including, but not limited to, any transaction charges imposed by a broker/dealer with which an independent investment manager effects transactions for the client’s account(s). Different products and services are offered at various custodians, and therefore such fees and expenses vary between clients. Additionally, some fees listed on the Wealth Management Fee sheet are marked up from the cost to Mesirow, or are additional fees not specifically tied to any Mesirow cost, and the additional revenue is retained by Mesirow and used to offset costs of business operations. MFIM’s affiliated broker, MFI, receives revenue based on client’s free credit balances, debit balances, margin balances, money market sweep funds, trading and will receive revenue based on other clearing or custody related fees, and therefore, is incented to recommend that a client use MFI as its introducing broker and NFS as its custodian. Clients will also pay additional underlying fund fees, including, but not limited to, fees to MFIM or its affiliates for investments in propriety products. Please see "Mesirow Propriety Products" below for more information. ERISA Accounts In certain circumstances, MFIM is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to ERISA. As such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include, among other things, restrictions concerning certain forms of compensation. Mesirow Proprietary Products MFIM offers private investment funds and private alternative investment products that are managed by different MFIM business units. Clients who invest in the MFIM funds will pay fees to both their Mesirow advisor and to the Mesirow business unit that manages the fund, subject to any fee offsets or credits that may be required for accounts subject to ERISA or similar laws. Due to collecting multiple fees from wealth advisor clients invested in Mesirow proprietary products, Mesirow is highly incentivized to have MFIM choose Mesirow proprietary products for clients’ investment lineup and to encourage clients to invest in Mesirow proprietary products because MFIM or its affiliates will receive additional compensation in connection with such clients' investments in these products as compared to unaffiliated products. Advisory Fees in General Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 7  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Wealth Management Limited Prepayment of Fees Under no circumstances do we require or solicit payment of fees in excess of $1,200 six months or more in advance of services rendered. Educational Events MFIM employees benefit from educational events sponsored by service providers to MFIM, such as law firms, audit firms, record keepers and other professional services firms. ITEM 6 | Performance-Based Fees and Side-by-Side Management MFIM Wealth Management does not charge performance-based fees, but other MFIM divisions do charge performance fees. So, clients that invest in other Mesirow sponsored products with performance fees will pay said performance fees. ITEM 7 | Types of Clients MFIM provides advisory services to the following types of clients: • Individuals • Corporations or other businesses • Pension and profit sharing plans • Non-qualified plans • State or municipal government entities • Charitable organizations ITEM 8 | Methods of Analysis, Investment Strategies and Risk of Loss METHOD OF ANALYSIS Wealth Management In developing an Investment Policy Statement for clients, MFIM Wealth Management typically considers the following factors: • Short- and long-term objectives for asset growth, income, liquidity, tax efficiency • Risk tolerance and time horizon • Asset allocation targets • Specific guidelines and preferences about investments that will be included in or excluded from a client’s portfolio MFIM Wealth Management analyzes a vast universe of data in order to select investments that meet our standards of quality and fit within the client’s risk profile. Investments are typically made in mutual funds, equities, fixed income products, ETF’s, closed-end funds, and alternative investments. The focus of the due diligence process is to identify investments with integrity, strong organizations, consistent style and a successful track record. To do this, the following issues are typically evaluated: Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 8  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Wealth Management • Historical performance • Company fundamentals • Investment style • Historical taxability • Manager incentives • Fixed-income creditworthiness • Trading liquidity MFIM Quality Dividend Strategy performs due diligence to create portfolios of the equities of companies generating regular dividend income with the potential for capital appreciation. The following factors are considered when evaluating a potential holding in the portfolio: • Business quality • Financial health • Valuation FORMS OF RISK Mutual Fund and Private Investment Fund Investing Investments in mutual funds and private investment funds are subject to market risks such as absence of liquidity in markets or fluctuations in market prices beyond the control of the managers, resulting in investment objectives of the fund not being achieved. Past Performance Past performance of a particular investment is not indicative of the future performance. Asset Allocation Models While asset allocation models are believed to result in a diversified portfolio of investments, diversification does not protect against market risks and does not assume profit. Risks for All Forms of Analysis MFIM’s analysis methods rely on publicly-available sources of information, which may not be reliable and are assumed to be accurate and unbiased data. While MFIM is confident that the data is accurate, there is always a risk that MFIM’s analysis may be compromised by limited, inaccurate or misleading information. Market Risk All investments have market risk, in that the value of assets may materially decrease. Investments are not guaranteed and can lose some or all of its value. Clients should review all investments to ensure that their portfolio is invested consistent with their suitability and risk profile, and should be prepared to lose all or a significant amount of their investment. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 9  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Wealth Management Additionally, proposed target returns or anticipated results may not be achieved. Liquidity Risk A secondary market often does not exist for a client’s assets when the client wants to sell their holdings, or that market may be very limited with few buyers. Consequently, there is a liquidity risk that clients may not be able to sell their holdings or that a client will have to accept a substantial discount in price in order to liquidate holdings. This is especially true for complex products, private investments and Regulation D offerings. The above risks are a summary of some of the key risks. Clients should review the risk section of any offering documents carefully to fully understand the risks of investments. ITEM 9 | Disciplinary Information On July 22, 2022, MFIM entered into a settlement with the SEC, the details of which are available here: https://www.sec.gov/litigation/admin.htm. As described in more detail in the Order, the settlement was related primarily to insufficient disclosure related to purchases of non-affiliated mutual fund shares (No Transaction Fee or NTF funds). Specifically, prior to June 2019, the disclosure outlined in MFIM’s Form ADV allegedly did not adequately disclose the receipt of NTF revenue sharing by Mesirow Financial, Inc. (MFI), MFIM’s affiliated broker-dealer, or the conflicts this created for MFIM. Without admitting or denying the underlying findings, MFIM agreed to pay affected investors disgorgement of $487,862 prejudgment interest of $94,972; and pay a civil penalty of $170,000. MFIM subsequently notified affected investors of the settlement terms. ITEM 10 | Other Financial Industry Activities and Affiliations Clients should be aware that the receipt of additional compensation by MFIM and its management persons or employees creates a conflict of interest that potentially impairs the objectivity of MFIM and these individuals when making advisory recommendations. MFIM endeavors at all times to put the interests of its clients first as part of our fiduciary duty as a registered investment advisor. MFIM typically takes the following steps to address and to mitigate any potential conflicts: • MFIM discloses to clients the existence of all material conflicts of interest; • MFIM collects, maintains and documents accurate, complete and relevant client background information, including the client’s investment mandates, financial goals, objectives and risk tolerance; • MFIM’s management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable for the client’s needs and circumstances; • MFIM requires that our employees seek prior approval of any outside employment activity to ensure that any conflicts of interest in such activities are properly addressed; • MFIM periodically monitors outside employment activities of its employees to verify that any conflicts of interest continue to be properly addressed; and • MFIM educates its employees regarding the responsibilities of a fiduciary, including the need to have a reasonable and independent basis for the investment advice provided to clients. MFIM’s affiliate has a clearing relationship with National Financial Services, a Fidelity company (“NFS”). Certain employees of MFIM may be separately licensed as registered representatives of MFI. These individuals, in their separate capacity, can and do at certain times, effect securities transactions for which they will receive separate, yet customary compensation. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 10  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Wealth Management Many mutual fund companies offer one or more retirement share classes specifically for the use by employer-sponsored retirement plans as investment options, (some share classes pay compensation to third parties, such as commissions, 12b- 1 fees, and other administrative fees, while other share classes do not). The retirement share classes that are available to a client is generally determined by specific criteria set by the mutual fund company, such as plan asset size and/or the number of participants in the retirement plan. The available share classes may factor into the fee structure and how the investment advisory fees and expenses are paid. For particular share class information, please refer to the investment product prospectus. Depending on the share class, companies affiliated with MFIM may receive various forms of compensation from providers of services that MFIM recommends. This compensation is not directly received by MFIM, but contributes to the revenue of the overall organization. This compensation may come in the form of commissions paid to an affiliated broker-dealer by a mutual fund company, insurance company, or other organization for the sale of an investment product; 12b-1 fees paid by a mutual fund company to a broker-dealer for distribution and servicing of mutual funds; commissions/fees paid to a broker/dealer by a trust company; sub-transfer agent fees paid to an affiliated retirement plan administrator or recordkeeper by a mutual fund company, insurance company, or other organization for servicing and administering various investment options; fees paid for non-advisory third-party administrative services by clients; and/or fees paid by an employee benefits provider to an affiliated company for sales of various products or services. The existence of these payments may or may not affect MFIM’s recommendations. The existence of this additional compensation will be taken into consideration in the negotiation of investment advisory fees for the services offered by MFIM. Commissions/compensation received by affiliated companies in relation to securities recommended by advisory personnel of MFIM will represent a material conflict of interest. In many (but not all) cases, this conflict of interest is mitigated through the “off-setting” of investment advisory fees by any such commission/compensation received by the affiliate. For example, a client’s advisory fees will be reduced and offset by the amount of any Rule 12b-1 fees received by MFI. MFIM Wealth Management Director of Research currently participates on the advisory board of Grubb Properties Qualified Opportunity Zone Fund, a private investment in which MFIM Wealth Management recommends certain clients invest. This is an unpaid outside business activity. ITEM 11 | Code of Ethics, Participation or Interest in Client Transactions and Personal Trading MFIM has adopted a Code of Ethics that sets forth the ethical standards of business conduct that MFIM requires of its employees, including compliance with applicable federal securities laws. MFIM and its personnel owe a duty of loyalty, fairness and good faith towards clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics, but also to the general principles that guide the Code of Ethics. MFIM’s Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by MFIM’s access persons. MFIM has additional policies and procedures relating to the preclearance of all employee trades (other than securities deemed exempt from this obligation). MFIM’s Code of Ethics also provides for oversight, enforcement and recordkeeping provisions. MFIM’s Code of Ethics further includes policies and procedures governing gifts and entertainment, outside business activities, confidentiality of information and information barriers, and charitable and political contributions. The Code of Ethics also prohibits the misuse of material non-public information and emphasizes the avoidance of conflicts of Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 11  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Wealth Management interest with investors. Each employee must acknowledge the terms of the Code of Ethics on an annual basis. Any employee who violates the Code of Ethics may be subject to possible actions, which may include enhanced supervision, censure, suspension or termination. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email (maryjo.hayes@mesirow.com) or by phone (312.595.6512). MFIM is part of a group of affiliated financial services companies that perform a number of different services for a client. MFIM is mindful of the conflicts or potential conflicts that such relationships create. Consequently, MFIM has adopted a Code of Conduct that prescribes standards of conduct required of all employees, regardless of their position or affiliation in the group. The Code prohibits self-dealing and other improper activities, the misuse of material non-public information, and it emphasizes the avoidance of conflicts of interest with clients. Some specific areas of potential conflict are discussed below. MFIM and/or individuals associated with it can buy or sell for their personal accounts securities identical to or different from those recommended to our clients. In addition, any related person(s) can have an interest or position in certain securities that may also be recommended to a client. Accounts owned by MFIM or persons associated with MFIM may participate in aggregated trading with client accounts; however, such accounts will not be given preferential treatment. MFIM, through MFI, can direct the purchase or sale in securities on a principal basis in accordance with Section 206(3) under the Investment Advisers Act of 1940, as amended. As these situations represent actual or potential conflicts of interest to clients, MFIM has established the following policies and procedures for implementing its Code of Ethics, to ensure our firm complies with its regulatory obligations and provides clients and potential clients with full and fair disclosure of such conflicts of interest: 1. No principal or employee of MFIM can put his or her own interest above the interest of an advisory client. 2. No principal or employee of MFIM can buy or sell securities for their personal portfolio(s) based on information received as a result of his or her employment unless the information is also available to the investing public. 3. MFIM requires prior approval for any IPO or private placement investments. 4. MFIM maintains a list of all reportable securities holdings for our firm and anyone associated with this advisory practice that has access to advisory recommendations (“access person”). These holdings are reviewed on a regular basis by the appropriate designated supervisor. 5. MFIM has established procedures for the maintenance of all required books and records. 6. All of MFIM’s principals and employees must act in accordance with all applicable federal and state regulations governing registered investment advisory practices. 7. MFIM requires delivery and acknowledgement of the Code of Ethics by each access person. 8. MFIM has established policies requiring the reporting of Code of Ethics violations to senior management. Any individual who violates any of the above restrictions may be subject to possible actions, which may include enhanced supervision, censure, suspension or termination. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 12  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Wealth Management ITEM 12 | Brokerage Trading Practices For equity and fixed income securities, MFIM will endeavor to select those brokers/dealers that will provide the best services at the lowest potential commission rates possible. The reasonableness of commissions is based on the broker’s stability, reputation, ability to provide professional services, access to relevant markets, expertise in particular securities markets, competitive commission rates and prices, research, trading platform, and other services that will help MFIM in providing investment management services to clients. The authority to select brokers/dealers is set forth in the investment advisory agreement signed by the client to establish an account. Where MFIM selects MFI to execute transactions, the client should consider the following: (i) although MFIM believes that MFI’s commission rates are competitive with other full service brokers, there has been no arms-length negotiation to receive the lowest possible commission rate; and (ii) for some accounts there will be an incentive on MFIM’s part to engage in or recommend more trading with respect to investment management services (or conversely less trading). Additionally, some fees listed on the Mesirow Financial Wealth Management Fee sheet are marked up from the cost to MFI, or are additional fees not specifically tied to any Mesirow cost, and the additional revenue is retained by Mesirow and used to offset costs of business operations. MFIM’s affiliated broker, MFI, receives revenue based on client’s free credit balances, debit balances, margin balances, money market sweep funds and will receive revenue based on other clearing or custody related fees. MFIM does not usually engage in agency cross transactions whereby it has discretion over two accounts, or MFI, acts simultaneously as a broker for accounts (which may be an advisory or brokerage account) and buys from or sells to another account. However, under certain circumstances, MFIM can determine that it is beneficial to both accounts to transact in the same security with each other. Depending on the size of the transaction and the volume and liquidity of the market, MFIM can decide that crossing the two orders will bring a better price or facilitate the time of an execution, as where, for example, one account may be selling to fulfill a withdrawal request and, simultaneously, another account buying to invest a contribution of funds. We generally do not sell securities to, nor purchase securities from, our advisory clients’ accounts as principal (which are commonly referred to as “principal trades”). With authorization by our clients, in very limited circumstances and in accordance with applicable laws and the rules and regulations promulgated by the SEC, we will engage in a principal trade. Similarly, an agency cross transaction will be made only with the prior and informed consent of our advisory clients. Agency cross transactions will not be permitted for ERISA clients. MFIM will block trade where possible and when advantageous to clients. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client accounts, so long as transaction costs are shared equally and on a pro-rated basis between all accounts included in any such block. Clients should be aware that when MFIM places a blocked order, or an order aggregating the trades for a number of advisory accounts, if multiple fills are obtained, such orders are executed at an average daily price calculated by the broker/dealer. Likewise, in the event that a blocked order results in a partial execution, MFIM will allocate the securities bought or sold on a pro rata basis unless limited due to size constraints. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 13  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Wealth Management ITEM 13 | Review of Accounts INVESTMENT SUPERVISORY SERVICES PORTFOLIO MANAGEMENT MFIM Wealth Management has dedicated supervisors, as well as compliance, operational and internal audit staff, who monitor and provide oversight to the investment activities of supervised personnel. The supervisors, or their designees, review and monitor the activities of wealth advisors. Such activities include, but are not limited to, adhering to client guidelines and objectives, trading and best execution, employee trading, investment product due diligence, and marketing and advertising. ITEM 14 | Client Referrals and Other Compensation CLIENT REFERRALS MFIM does not receive an economic benefit from anyone other than its clients. MFIM and its affiliates may enter into Referral Agreements with a promoter such as a broker-dealer or an investment adviser. MFIM or its affiliates generally pay the promoter a percentage of the management fee and/or performance-based fee collected from the client. Regardless of how it is calculated, any such referral fee will be paid solely from MFIMs’ investment management fee and will not result in any additional charge to the client. See Item 5 for additional information on advisory fees. MFIM has entered into arrangements with unaffiliated third parties for their assistance in referring business to MFIM or providing advice to MFIM with respect to the expansion of the firm’s distribution of products or services in various U.S. and non-U.S. markets and distribution channels. MFIM may pay cash compensation under these arrangements based on a monthly flat fee as well as, in the sole discretion of the firm, a bonus at the conclusion of the arrangements. The fees paid to the unaffiliated third party are not passed on to any introduced clients, but the presence of these arrangements may affect MFIMs’ willingness to negotiate below its standard investment advisory fees and, therefore, may affect the overall fees paid by referred clients. It is MFIM’s policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services we provide to clients. MFIM also compensates affiliated personnel that work in other business units for referrals. ITEM 15 | Custody Clients choose which custodians will custody their assets. It is our understanding that certain such custodial agreements or other agreements or documents may contain provisions that could result in MFIM having inadvertent custody of client account assets as a result of language permitting us, as investment adviser, to withdraw client assets upon instruction to the custodian. Our agreements with our clients, however, are not intended to give us broad authority to withdraw client assets, and we disclaim such authority to the extent applicable. With respect to these concerns, our authority as it relates to custody should be considered to be limited in the ordinary course to customary trading and settlement of securities and investment transactions in the client’s account, typically on a “delivery vs payment” basis for securities transactions, as well as fee deductions in certain cases, as applicable. Most of MFIM Wealth Management clients custody their assets at NFS, since MFIM Wealth Management’s affiliate has a clearing relationship with NFS. Clients are not required to use NFS for these services and clients are free to work with other custodians. MFIM has obtained and continues to obtain certain revenues from NFS and receives various operational and supervisory efficiencies when clients choose NFS as its custodian. In addition, MFIM’s affiliated broker-dealer also receives revenues, including Correspondent Business Development Credits from NFS for maintaining its business relationships and customer accounts at NFS. Consequently, MFIM is incentivized to have clients choose NFS as their custodian over other custodians. MFI marks up NFS brokerage and custodial fees charged by NFS and retains that Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 14  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Wealth Management revenue. This creates an incentive for MFIM to encourage clients to use NFS since MFI does not have the ability to mark- up other broker’s fees. MFIM has custody of client accounts since some clients authorize their custodian, including NFS, to deduct MFIM’s advisory fees from their client account. In addition, pursuant to a standing letter of authorization (“SLOA”) some clients grant MFIM limited discretion to disburse funds to one or more third parties, as specifically designated by the client. After granting MFIM with this limited authorization, the client then instructs the qualified custodian for the client's account to accept MFIM’s direction on the client's behalf to move money to the third party designated by the client on the SLOA. We are authorized to act merely as an agent for the client. The client retains full power to change or revoke the arrangement. MFIM does NOT have discretion as to the amount, payee or timing of transfers under the SLOA. You should receive at least quarterly statements from the broker-dealer, bank or other qualified custodian that holds and maintains your investment assets. Our investment account statements will vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. For tax and other purposes, your custodial statement is the official record of your account(s) and assets. We urge you to carefully review your custodian statements and compare them to the account statements that we provide to you as your investment manager. If you have any questions with respect to your custodial statement and account statements, please contact your MFIM Advisor. ITEM 16 | Investment Discretion Clients may engage MFIM to provide discretionary and non-discretionary asset management services. Clients give MFIM discretionary authority when they sign a discretionary investment management agreement with MFIM and may in certain circumstances limit or change/amend such limitations by giving MFIM written instructions. ITEM 17 | Voting Client Securities MFIM does not vote proxies for clients. MFIM will exercise discretion as it relates to corporate actions in any legal proceedings, including bankruptcies or class actions, involving securities included in or previously included in the Account. ITEM 18 | Financial Information MFIM has no additional financial circumstances to report. MFIM has not been the subject of a bankruptcy petition at any time during the past 10 years. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 15 

June 24, 2025 Mesirow Financial Investment Management, Inc. Currency Management 353 North Clark Street, Chicago, Illinois 60654 Telephone: 312.595.6000 | Email: inquiries@mesirow.com mesirow.com ITEM 1 | Cover Part 2A of Form ADV Firm Brochure This brochure provides information about the qualifications and business practices of Currency Management (“MFIM Currency”), a division of Mesirow Financial Investment Management, Inc. If you have any questions about the contents of this brochure, please contact 312.595.6000 or inquiries@mesirow.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about Mesirow Financial Investment Management, Inc. (“MFIM”) also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. MFIM’s CRD number is 111135. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved.  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management ITEM 2 | Material Changes Mesirow Financial Investment Management, Inc. (“MFIM”) Form ADV Part 2A, currently dated June 24, 2025, as amended from time to time, is MFIM’s client disclosure document prepared based on the Securities and Exchange Commission’s regulatory requirements. MFIM is required to update this document at least annually, or when an event occurs that can be deemed to have a material impact on MFIM’s Currency Management and related investment management business and/or on its clients. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 2  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management ITEM 3 | Table of Contents ITEM 1 | Cover ........................................................................................................................................... 1 ITEM 2 | Material Changes ....................................................................................................................... 2 ITEM 3 | Table of Contents ....................................................................................................................... 3 ITEM 4 | Advisory Business ...................................................................................................................... 4 ITEM 5 | Fees and Compensation ............................................................................................................ 5 ITEM 6 | Performance-Based Fees and Side-By-Side Management ...................................................... 7 ITEM 7 | Types of Clients .......................................................................................................................... 7 ITEM 8 | Methods of Analysis, Investment Strategies and Risk of Loss ................................................. 8 ITEM 9 | Disciplinary Information ............................................................................................................ 10 ITEM 10 | Other Financial Industry Activities and Affiliations ................................................................ 10 ITEM 11 | Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....... 11 ITEM 12 | Brokerage Practices ............................................................................................................... 12 ITEM 13 | Review of Accounts ................................................................................................................ 13 ITEM 14 | Client Referrals and Other Compensation............................................................................. 13 ITEM 15 | Custody ................................................................................................................................... 13 ITEM 16 | Investment Discretion ............................................................................................................. 14 ITEM 17 | Voting Client Securities .......................................................................................................... 14 ITEM 18 | Financial Information .............................................................................................................. 14 Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 3  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management ITEM 4 | Advisory Business MFIM, an Illinois corporation formed in 1986, is an investment advisor registered with the SEC with its principal place of business located in Illinois. MFIM does not provide tax or legal advice. Clients should consult with an expert on matters pertaining to tax or legal matters. MFIM's principal shareholder is Mesirow Financial Services, Inc., which is a wholly-owned subsidiary of Mesirow Financial Holdings, Inc. (“MFHI” or “Firm”). MFIM Currency offers Currency Advisory and other exposure management services solely for eligible contract participants ("ECP"), as defined by the Commodities Exchange Act, through separately managed accounts and funds. MFIM Currency also provides Collateral Management Support Services to existing Currency Advisory Services clients. CURRENCY ADVISORY SERVICE MFIM Currency provides three types of risk management overlay services for ECPs with portfolios that are exposed to currency exchange rate exposures. These services are called active, passive, and passive-plus. These services isolate the currency component from the underlying asset base and manages the associated risks independently. The goal of currency overlay is to reduce volatility and risk within the portfolio, while enhancing the overall return. In addition to the risk management overlay services, MFIM Currency offers currency return strategies. These strategies are called Intelligent Currency Factor Strategy, Emerging Markets Currency Alpha, Asian Markets Currency Alpha, Extended Markets Alpha and Systematic Macro. The Intelligent Currency Factor Strategy aims to capture currency returns via three distinct risk premia existing in the currency markets (i.e. carry, value, and momentum). Emerging Markets Currency Alpha, Asian Markets Currency Alpha, and Extended Markets Alpha are primarily systematic investment processes with a discretionary risk overlay. The Systematic Macro is a purely systematic investment process with no discretionary risk overlay. MFIM Currency does not provide currency services to any affiliated business unit. MFIM’s other business units also serve as general partner to a number of private investment vehicles structured as limited partnerships. As of March 31, 2025, MFIM Currency manages approximately $177.1 billion1 in client assets on a discretionary basis and no client assets on a non-discretionary basis. FIDUCIARY EXECUTION In addition to the currency overlay services described above, MFIM Currency offers a non-discretionary investment management service focused on high quality execution called Fiduciary Execution. Fiduciary Execution is a full-service execution service where MFIM Currency executes trades on clients’ behalf as an agent. In connection with the execution service MFIM Currency can also evaluate and make recommendations to clients, on a non-discretionary basis, with respect to the type, structure, time horizon and size of instruments to be traded in order to provide efficient hedging and risk mitigation strategies. 1 Currency assets under management includes AUM associated with (i) active and passive currency risk management products $174.7 billion, (ii) non-fx overlay strategies such as equitization and beta overlays $873.6 million, and (iii) alpha strategies $1.5 billion. In all such cases, AUM is calculated based on notional value of currency investments. Additionally, AUM for alpha strategies is adjusted because clients can select a volatility target (generally between 2% and 12% annualized), which is normalized to 2% in order to create a consistent depiction of alpha strategy AUM. This results in a “scaled” AUM, which is higher than the actual aggregate notional value of all alpha strategy portfolios if clients have selected a volatility target higher than 2%. As of 03.31.25, the “unscaled” AUM for alpha strategies was $448 million. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 4  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management COLLATERAL MANAGEMENT SUPPORT SERVICE MFIM Currency provides a Collateral Management Support Service for certain clients of its Currency Advisory Service. The Collateral Management Support Service manages and effectuates the calculation and exchange of collateral between clients and counterparty banks. The Collateral Management Support Service is typically performed in connection with satisfying regulatory margin requirements; however, clients can utilize the service for purposes other than satisfying regulatory requirements. EXPOSURE MANAGEMENT MFIM offers a rules-based overlay investment advisory service using foreign exchange and other instruments solely for ECPs through separately managed accounts and non-sponsored funds. These services include cash overlays, policy implementation, and other custom hedges. ITEM 5 | Fees and Compensation All advisory fee schedules are negotiable and vary by investment strategy, product type, account size, customization requirements and required service levels. The standard annual fee ranges are as follows: • MFIM’s annual fee for passive overlay currency can range up to 10 basis points per annum for the average market value of the client’s portfolio. • MFIM’s annual fee for active overlay currency can range up to 40 basis points per annum for the average market value of the client’s portfolio • MFIM’s annual fee for passive-plus overlay currency can range up to 25 basis points per annum for the average market value of the client’s portfolio • MFIM’s annual fee for the currency for return strategies can range up to 200 basis points per annum for the average market value of the client’s portfolio plus a performance fee. • MFIM’s annual fee for exposure management can range up to 20 basis points per annum for the average market value of the client’s portfolio The upper range of these fees are based on small accounts that are offered a minimum flat fee. In certain instances, the index used as a client’s performance benchmark carries additional fees for individual client use. These fees are passed on to individual clients. These fees are charged on a percentage of client portfolio AUM or a flat fee depending on the index or indexes chosen. Additional fees can also be charged for other bespoke services. The management fee is typically payable in arrears on the 30th business day after the end of each quarter. Because the management fee is paid in arrears, refunds for fees paid are not given. In the event an account terminates, fees will be prorated for the number of days the account was under management. Fees are typically billed to the client or client's custodian. MFIM Currency charges a volume-based fee for its Fiduciary Execution service. These fees can range up to 10 basis points on the volume executed for a client. The fee for this service can be either embedded in the price of each trade or invoiced at the client’s discretion. If the fees are invoiced, the client will typically be invoiced on a quarterly basis. For fees Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 5  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management that are embedded in the price, the bank counterparty or liquidity provider will collect the fees and remit them to MFIM Currency periodically. Limited Negotiability of Advisory Fees Although MFIM Currency has established the aforementioned fee schedule(s), it retains the discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances and needs will be considered in determining the fee schedule. These facts, circumstances and needs include, among other factors, the complexity of the client; assets to be placed under management; anticipated future additional assets; related accounts; portfolio style; account composition; and reporting requirements. The specific annual fee schedule will be identified in the contract between the advisor and each client. Termination of the Advisory Relationship Clients that invest in separately managed accounts are typically able to terminate their investment management agreement upon providing 30 days prior written notice. Certain fees could be paid in advance of services provided. Upon termination of any account, any prepaid, unearned fees are generally refunded. In calculating a client's reimbursement of fees, MFIM Currency can prorate the reimbursement according to the number of days remaining in the billing period. In certain situations, other terms are made available to clients. No penalty will be charged for any termination. Fees due for the final period of the agreement will be adjusted proportionally to the number of days in the period and will be due and payable no later than 30 days after the date of termination. Additional Fees and Expenses In addition to MFIM Currency's advisory fees, clients are also responsible for the fees and expenses charged by custodians, including, but not limited to, any transaction charges imposed such as commissions, electronic platform fees and prime brokerage fees. Custodian fees are not reflected or segregated on MFIM Currency’s invoices. There can be instances where MFIM Currency refers its clients to affiliated entities, which may perform other services. In those instances, MFIM Currency and/or its employees receive referral compensation in exchange for such referral. Similarly, MFIM and/or their employees can refer clients to MFIM Currency for which MFIM Currency pays referral compensation to such affiliates and/or their employees. MFHI, a Delaware corporation, is the owner of Mesirow Financial Services, Inc. ("MFS"), the parent of MFIM. MFIM is affiliated with numerous MFS and MFHI subsidiaries, which constitute or are registered as one or more of the following: an investment advisor, a broker/dealer, an insurance agency, and/or entities creating or packaging private investment vehicles. MFIM does not currently have any material arrangements with any of these entities other than as described in Item 10. Grandfathering of Minimum Account Requirements Pre-existing advisory clients are subject to MFIM Currency's minimum account requirements and advisory fees in effect at the time the client entered into the advisory relationship. Therefore, minimum account requirements can differ among clients. ERISA Accounts In certain circumstances MFIM is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act of 1974 ("ERISA"). As such, Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 6  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management MFIM is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include among other things, restrictions concerning certain forms of compensation. Commissions or Markups With the exception of the Fiduciary Execution service, in the event that MFIM receives commissions or markups, advisory fees will be reduced to offset the commissions or markups. Advisory Fees in General Clients should note that similar advisory services could be available from other registered (or unregistered) investment advisors for similar or lower fees. Limited Prepayment of Fees Under no circumstances does MFIM require or solicit payment of fees in excess of $1,200 six months or more in advance of services rendered. Educational Events MFIM employees benefit from educational events sponsored by service providers to MFIM, such as law firms, audit firms and other professional service firms. ITEM 6 | Performance-Based Fees and Side-By-Side Management MFIM Currency can accept a performance-based fee from the client. Such a performance-based fee is calculated based on gains of the portfolio of the client. Pursuant to the Investment Advisers Act of 1940 Rule 205-3, to qualify for a performance-based fee arrangement, a client (or Fund investor, as applicable) must either demonstrate a net worth of more than $2,200,000 or must have at least $1,100,000 under management with MFIM at the time of entering into a management agreement with MFIM Currency. Clients should be aware that a performance-based fee arrangement creates an incentive to recommend investments that could be riskier or more speculative than those that might be recommended under a different fee arrangement. Furthermore, MFIM Currency has clients who do not pay performance-based fees, MFIM Currency has an incentive to favor accounts that do pay such fees because compensation received from these clients is more directly tied to the performance of their accounts. ITEM 7 | Types of Clients MFIM Currency provides advisory and collateral management services to ECPs, which may include: • Investment companies and private funds • Pension and profit-sharing plans • Charitable organizations • Corporations or other businesses Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 7  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management ITEM 8 | Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS Passive Currency Overlay For each client portfolio, MFIM Currency tailors passive management programs to meet specific currency exposures and other objectives and applies global best practices in passive management to ensure fair value execution, provide optimal program efficiency and offer comprehensive risk management controls and policies. Active Currency Overlay MFIM Currency’s investment philosophy maintains that currency movements are driven by the impact of numerous factors (i.e. market news, capital flows, trade deficits and central bank reserve policies) and these drivers can impact currency valuations over specific time horizons. In addition, the factors that drive the markets change over time and the duration and direction of the impact also varies. MFIM Currency believes that it is much more important to understand the impact of the market drivers on currency prices, regardless of what they are, rather than forecasting the drivers themselves. MFIM Currency’s quantitative investment process attempts to measure the statistical impact of market drivers over various timeframes, and across directional and mean reverting market environments. Despite a changing array of factors, the process is adaptive in nature in that it works to identify the impact of these factors on currency prices to capitalize on both mean reverting and directional environments, across various time periods. Due to each client’s unique set of underlying exposures and objectives, MFIM Currency applies a custom solution for each client portfolio utilizing MFIM Currency’s core investment philosophy. Specific models, investment decisions, trade execution and positions may vary across client portfolios to reflect these differences in exposures, custom benchmarks and portfolio objectives. In select regions where MFIM Currency partners with local experts (such as Perreard Partners Investment SA in Switzerland) MFIM Currency will also utilize the local expertise and market analysis of its partnerships to make investment decisions. If MFIM Currency determines that it is in the best interests of clients, MFIM Currency will use its fundamental decision-making authority to override its quantitative approach. In some cases, MFIM Currency will operate purely on a discretionary basis. Passive Plus Currency Overlay Passive plus management is a hybrid of MFIM Currency’s passive and active strategies. MFIM Currency primarily incorporates valuation metrics in assessing significant movements for a client’s passive plus framework. Valuation metrics are supplemented with signals from MFIM Currency’s long-term trend and momentum views to identify longer-term movements and seek to provide downside protection by increasing hedges in this environment. The objective of the passive plus application is to efficiently hedge significant, long-term currency movements and to insulate the portfolio from a portion of this risk. MFIM Currency partners with clients and their consultants to evaluate the respective international portfolios and design a custom passive plus application to best fit their objectives by applying the program’s core philosophies. Exposure Management Exposure Management is set of overlay strategies designed to achieve investment objectives through adherence to the investment management guidelines. The program objectives typically include increasing expected portfolio returns, improving fund liquidity, limiting the performance cost caused by holding cash in a portfolio and reducing performance risk relative to policy benchmarks. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 8  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management Leverage is not employed unless desired by the client. Clients can use Exposure Management for cash securitization, rebalancing, and other exposure management as needed based on client objectives. Policy implementation utilizes exchange-traded instruments, including futures, over-the-counter (OTC) instruments, and other financial products to achieve its objective. Some exposure strategies which are intended to mitigate cash drag and/or increase or decrease the beta of a portfolio use financial instruments designed to track specific benchmarks. Since the strategies use futures, rather than cash instruments, the strategy will not be correlated to the reference benchmark in certain market situations. In addition to OTC instruments, Exchange-Traded Funds (“ETFs”) may be utilized. ETFs are publicly traded investment vehicles such as unit investment trusts, open-end funds, or depository receipts that seek to track the performance and dividend yield of specific indexes, sectors, or groups of companies. These indexes may be broad-based, sector-specific, or international in nature. Investing in ETFs generally exposes shareholders to risks similar to those of the underlying securities the ETF is designed to replicate. However, ETFs also involve additional risks, including but not limited to: (1) The risk that the market price of an ETF may not perfectly correlate with the net asset value or price movements of the underlying securities it tracks, potentially resulting in tracking error. (2) The risk that trading in an ETF may be halted or suspended due to market conditions, regulatory actions, or other factors, which could impair the ability to buy or sell shares promptly or at favorable prices. (3) Liquidity risk, particularly for ETFs that invest in less liquid markets or securities, which may affect the ETF’s pricing and ability to execute transactions efficiently. (4) Potential tax implications unique to ETFs, depending on their structure and underlying holdings. Clients should understand that although ETFs offer certain diversification and trading flexibility benefits, they remain subject to the risks of the markets and assets in which they invest, and market conditions can adversely affect ETF performance. Currency for Return • Mesirow Intelligent Factor Strategy: This strategy aims to capture currency returns via three distinct risk premia existing in the currency markets (i.e. carry, value, and momentum). • Emerging Markets Currency Alpha, Asian Markets Currency Alpha, and Extended Markets Currency Alpha: These strategies aim to profit from short and medium term moves in currency pairs. The programs are primarily systematic with a discretionary risk overlay. • Systematic Macro: This is a purely systematic managed account structure that invests in the systematic components of the three Alpha Programs: Extended, Asia, and Emerging. Fiduciary Execution Fiduciary Execution is a full-service execution service where MFIM Currency executes trades on clients’ behalf as an agent. This service is designed to help clients manage and minimize their transaction costs. MFIM Currency always acts as an agent within a market that has historically been traded on a principal basis. In connection with the execution service, MFIM Currency may also evaluate and make recommendations to clients, on a non-discretionary basis, with respect to the type, structure, time horizon and size of instruments to be traded in order to provide efficient hedging and risk mitigation strategies. Risks For All Forms of Analysis MFIM Currency's analysis depends on publicly-available sources of data relating to foreign exchange and transactions, providing accurate and unbiased data. While MFIM Currency is alert to indications that data may be incorrect, there is always a risk that MFIM Currency's analysis can be compromised by limited, inaccurate or misleading information. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 9  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management Strategies with a discretionary component bear additional risk that individuals exercising discretion will not analyze data in an accurate manner. RISK OF LOSS Investments are not guaranteed and clients may lose all invested funds. Clients may implement loss limits to mitigate losses. ITEM 9 | Disciplinary Information On July 22, 2022, MFIM entered into a settlement with the SEC, the details of which are available here: https://www.sec.gov/litigation/admin.htm. As described in more detail in the Order, the settlement was related primarily to insufficient disclosure related to purchases of non-affiliated mutual fund shares (No Transaction Fee or NTF funds). Specifically, prior to June 2019, the disclosure outlined in MFIM’s Form ADV allegedly did not adequately disclose the receipt of NTF revenue sharing by Mesirow Financial, Inc. (MFI), MFIM’s affiliated broker-dealer, or the conflicts this created for MFIM. Without admitting or denying the underlying findings, MFIM agreed to pay affected investors disgorgement of $487,862 prejudgment interest of $94,972; and pay a civil penalty of $170,000. MFIM subsequently notified affected investors of the settlement terms. ITEM 10 | Other Financial Industry Activities and Affiliations Certain employees of MFIM are separately licensed as registered representatives of Mesirow Financial, Inc. (“MFI”). These individuals, in their separate capacity, can effect securities transactions for which they will receive separate, yet customary compensation. While MFIM and these individuals endeavor at all times to fulfill their fiduciary responsibilities to clients, clients should be aware that the receipt of additional compensation itself creates a conflict of interest and can affect the judgment of these individuals when making recommendations. As part of its services, MFIM Currency may utilize various instruments depending on the service provided and client’s underlying portfolio. Such instruments may include spot, forward or futures contracts, swaps, and options. In addition, non-deliverable forwards can be used only at the explicit request of the client. MFIM and its affiliates are not restricted from forming additional investment funds, entering into other investment advisory relationships or engaging in other business activities, even though such activities can be in competition with the funds. Potentially, such activities could be viewed as creating a conflict of interest in that the time and effort of MFIM management personnel and employees will not be devoted exclusively to the business of the funds, but could be allocated between the business of the funds and other business activities. As noted in Item 4 and 5, MFIM’s other business units can act as a general partner or sponsor of various private investment vehicles that MFIM may recommend or sell to its advisory clients. Prior to the sale of any such investments, MFIM will have disclosed any potential conflicts of interest and will recommend the investment only if it appears suitable for the client. Clients should be aware that the receipt of additional compensation by MFIM and its management persons or employees creates a conflict of interest that can impair the objectivity of MFIM and these individuals when making advisory recommendations. MFIM endeavors at all times to put the interests of its clients first as part of its fiduciary duty as a registered investment advisor. MFIM typically takes the following steps to address any potential conflicts: Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 10  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management • MFIM discloses to clients the existence of all material conflicts of interest; • MFIM collects, maintains and documents accurate, complete and relevant client background information, including the client's investment mandates, financial goals, objectives and risk tolerance; • MFIM's management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable for the client's needs and circumstances; • MFIM requires that its employees seek prior approval of any outside employment activity to ensure that any conflicts of interests in such activities are properly addressed; • MFIM periodically monitors outside employment activities of its employees to verify that any conflicts of interest continue to be properly addressed; and • MFIM educates its employees regarding the responsibilities of a fiduciary, including the need to have a reasonable and independent basis for the investment advice provided to clients. ITEM 11 | Code of Ethics, Participation or Interest in Client Transactions and Personal Trading MFIM has adopted a Code of Ethics, which sets forth the ethical standards of business conduct that MFIM requires of its employees, including compliance with applicable federal securities laws. MFIM and its personnel owe a duty of loyalty, fairness and good faith towards clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code of Ethics. MFIM's Code of Ethics includes policies and procedures for the review of securities transactions as well as initial and annual securities holdings reports that must be submitted by MFIM's access persons. MFIM also has additional policies and procedures relating to the preclearance of all employee trades (other than securities deemed exempt from this obligation). MFIM's Code of Ethics also provides for oversight, enforcement and recordkeeping provisions. MFIM's Code of Ethics further includes policies and procedures governing gifts and entertainment, outside business activities, confidentiality of information and information barriers, and charitable and political contributions. The Code of Ethics also prohibits the misuse of material non-public information and emphasizes the avoidance of conflicts of interest with investors. Each employee must acknowledge the terms of the Code of Ethics on an annual basis. Any employee who violates the Code of Ethics may be subject to possible actions, which may include enhanced supervision, censure, suspension or termination. A copy of MFIM's Code of Ethics is available to its advisory clients and prospective clients. You may request a copy by email sent to maryjo.hayes@mesirow.com, or by calling us at 312.595.6512. MFIM is part of a group of affiliated financial services companies that perform a number of different services for a client. MFIM is mindful of the conflicts or potential conflicts that such relationships create. Consequently, MFIM has adopted a Code of Conduct, which prescribes standards of conduct required of all employees, regardless of their position or affiliation in the group. The Code prohibits self-dealing and other improper activities, the misuse of material non-public information, and it emphasizes the avoidance of conflicts of interest with clients. Some specific areas of potential conflict are discussed below. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 11  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management MFIM and/or individuals associated with it may buy or sell for their personal account’s securities identical to or different from those recommended to its clients. In addition, any related person(s) can have an interest or position in certain securities, which can also be recommended to a client. Employees of other divisions of MFIM can sell interests in investment companies which the MFIM Currency division subadvises. Those employees can be compensated separately. MFIM, through MFI, can direct the purchase or sale in securities on a principal basis in accordance with Section 206 (3) under the Investment Advisers Act of 1940, as amended. As these situations represent actual or potential conflicts of interest to clients, MFIM has established the following policies and procedures for implementing its Code of Ethics, to ensure the firm complies with its regulatory obligations and provides clients and potential clients with full and fair disclosure of such conflicts of interest: 1. No principal or employee of MFIM can put his or her own interest above the interest of an advisory client. 2. No principal or employee of MFIM can buy or sell securities, foreign exchange forward or a related derivative, for their personal portfolio(s) where their decision is because of information received as a result of his or her employment unless the information is also available to the investing public. 3. MFIM requires prior approval for any IPO or private placement investments. 4. MFIM maintains a list of all reportable securities holdings for the firm and anyone associated with this advisory practice that has access to advisory recommendations ("access person"). These holdings are reviewed on a regular basis by the appropriate designated supervisor. 5. MFIM has established procedures for the maintenance of all required books and records. 6. All of MFIM's principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 7. MFIM requires delivery and acknowledgement of the Code of Ethics by each access person. 8. MFIM has established policies requiring the reporting of Code of Ethics violations to senior management. Any individual who violates any of the above restrictions may be subject to possible actions, which may include enhanced supervision, censure, suspension or termination. Other Participation or Interest in Client Transactions Due to the fact that MFIM is compensated based on AUM, MFIM employees are incentivized to have clients open accounts and to add to assets to new and existing accounts. ITEM 12 | Brokerage Practices MFIM Currency will endeavor to select those banks and counterparties that will provide the best services at the best rates possible. MFIM Currency's decision as to which bank or counterparty to trade with is based on various factors including, but not limited to the counterparties' stability, reputation, creditworthiness, ability to provide professional services, and access to relevant markets. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 12  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management ITEM 13 | Review of Accounts INVESTMENT SUPERVISORY SERVICES PORTFOLIO MANAGEMENT While the underlying holdings within Individual Portfolio Management Services accounts are continually monitored, these accounts are reviewed at least quarterly. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews can be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. These accounts are reviewed by Portfolio Management or another designated person. Reports in addition to the monthly statements and confirmations of transactions that clients receive from their custodians and/or broker/dealer, MFIM Currency regularly provides reports summarizing account performance, balances and holdings. MFIM Currency urges clients to carefully compare the information provided on these statements to ensure that all account transactions, holdings and values are correct and current. ITEM 14 | Client Referrals and Other Compensation CLIENT REFERRALS MFIM does not receive an economic benefit from anyone other than its clients. MFIM and its affiliates may enter into Referral Agreements with a promoter such as a broker-dealer or an investment adviser. MFIM or its affiliates generally pay the promoter a percentage of the management fee and/or performance-based fee collected from the client. Regardless of how it is calculated, any such referral fee will be paid solely from MFIM’s investment management fee and will not result in any additional charge to the client. See Item 5 for additional information on advisory fees. MFIM has entered into arrangements with unaffiliated third parties for their assistance in referring business to MFIM or providing advice to MFIM with respect to the expansion of the firm’s distribution of products or services in various U.S. and non-U.S. markets and distribution channels. MFIM may pay cash compensation under these arrangements based on a monthly flat fee as well as, in the sole discretion of the firm, a bonus at the conclusion of the arrangements. The fees paid to the unaffiliated third party are not passed on to any introduced clients, but the presence of these arrangements may affect MFIM’s willingness to negotiate below its standard investment advisory fees and, therefore, may affect the overall fees paid by referred clients. MFIM Currency acts as a sub-advisor or provide other services to other investment advisors or mutual funds and as such will be paid a fee based on a percentage of the assets of the fund. MFIM, or an affiliate, may also sell the fund to its clients and will receive compensation from the investment advisor or fund family. It is MFIM's policy not to accept or allow its related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services it provides to clients. MFIM compensates affiliate personnel that work in other business units for referrals. ITEM 15 | Custody As part of the billing process, the client is invoiced for the amount of the fee. Clients typically hold funds at banks or other custodians and fund accounts on an as needed basis. Generally, MFIM does not custody client assets. In limited instances, MFIM is deemed to have custody of client assets under the SEC’s Custody Rule, 206(4)-2, due to the fact that a related person, as defined by the rule, serves as the general partner for certain private funds. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 13  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Currency Management In addition to the periodic performance statements that clients receive directly from their banks or custodians, MFIM Currency also sends account statements directly to its clients on a monthly basis. As noted above, MFIM Currency urges clients to carefully compare the information provided on these statements to ensure that all account transactions, holdings and values are correct and current. ITEM 16 | Investment Discretion Clients can engage MFIM to provide discretionary and non-discretionary asset management services. Clients can in certain circumstances limit such authority by giving MFIM written instructions. Clients give MFIM discretionary authority when they sign an investment management agreement with MFIM or complete the subscription documents for a fund. ITEM 17 | Voting Client Securities PROXY VOTING POLICIES AND PROCEDURES: MFIM does not vote proxies for clients. MFIM will exercise discretion as it relates to corporate actions in any legal proceedings, including bankruptcies or class actions, involving securities included in or previously included in the Account. ITEM 18 | Financial Information MFIM has no additional financial circumstances to report. MFIM has not been the subject of a bankruptcy petition at any time during the past ten years. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 14 

June 24, 2025 Mesirow Financial Investment Management, Inc. Fiduciary Solutions 353 North Clark Street, Chicago, Illinois 60654 Telephone: 312.595.6000 | Email: inquiries@mesirow.com mesirow.com ITEM 1 | Cover Part 2A of Form ADV Firm Brochure This brochure provides information about the qualifications and business practices of Fiduciary Solutions (“Fiduciary Solutions”), a division of Mesirow Financial Investment Management, Inc. If you have any questions about the contents of this brochure, please contact 312.595.6000 or inquiries@mesirow.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about Mesirow Financial Investment Management, Inc. (“MFIM”) is also available on the SEC’s website at www.adviserinfo.sec.gov. The site may be searched by a unique identifying number known as a “CRD number.” MFIM’s CRD number is 111135. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved.  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Fiduciary Solutions ITEM 2 | Material Changes MFIM’s Form ADV Part 2A, currently dated June 24, 2025, as amended from time to time, is MFIM’s client disclosure document prepared based on the Securities and Exchange Commission’s regulatory requirements. MFIM is required to update this document at least annually, or when an event occurs that may be deemed to have a material impact on Fiduciary Solutions, a business group of MFIM, and related investment management business and/or on its clients. Fiduciary Solutions has no disciplinary events to report or disclose since its last annual update. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 2  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Fiduciary Solutions ITEM 3 | Table of Contents ITEM 1 | Cover ......................................................................................................................................... 1 ITEM 2 | Material Changes ...................................................................................................................... 2 ITEM 3 | Table of Contents ...................................................................................................................... 3 ITEM 4 | Advisory Business ..................................................................................................................... 4 ITEM 5 | Fees and Compensation ........................................................................................................... 4 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 ............................................................................................................. 6 ITEM 10 | Other Financial Industry Activities and Affiliations ................................................................. 6 ITEM 11 | Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......... 7 ITEM 12 | Brokerage Practices ................................................................................................................ 8 ITEM 13 | Review of Accounts ................................................................................................................ 9 ITEM 14 | Client Referrals and Other Compensation ............................................................................. 9 ITEM 15 | Custody ................................................................................................................................... 9 ITEM 16 | Investment Discretion ............................................................................................................. 9 ITEM 17 | Voting Client Securities ......................................................................................................... 10 ITEM 18 | Financial Information ............................................................................................................. 10 Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 3  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Fiduciary Solutions ITEM 4 | Advisory Business MFIM, an Illinois corporation formed in 1986, is an investment advisor registered with the SEC with its principal place of business located in Illinois. Fiduciary Solutions is a business division within MFIM. MFIM’s sole shareholder is Mesirow Financial Services, Inc., which is a wholly-owned subsidiary of Mesirow Financial Holdings, Inc. (“MFHI” or “Firm”). Fiduciary Solutions provides consulting services, fund advisory services, sub-advisory services, and investment management services to institutional clients. Such services include: manager selection and due diligence; asset class models, portfolio construction, related marketing support; and the selection and oversight of investment options for retirement plans as a fiduciary (discretionary or non-discretionary). In addition to services provided to its institutional clients, Fiduciary Solutions may also provide continuous and regular investment supervisory services (discretionary or non-discretionary) as a fiduciary under the Advisors Act to IRA and HSA accountholders. With respect to ERISA qualified plans, Fiduciary Solutions serves as a "fiduciary" as defined by §3(21)(A)(ii) of the Employee Retirement Income Security Act of 1974 ("ERISA"); or if on a discretionary basis, Fiduciary Solutions serves as an "investment manager" as defined by §3(38) of ERISA. In either case, Fiduciary Solutions provides specific investment advice to the client with regard to (i) the selection of investment manager(s) and/or investment vehicles available to the client within the platform provided by the client's administrator and/or custodian and/or (ii) the construction and maintenance of asset allocation models and portfolios. MFIM does not provide tax or legal advice. Clients should consult with an expert on matters pertaining to tax or legal issues. As of March 31, 2025, Fiduciary Solutions had $67.83 billion in assets under advisement and $28.50 billion in assets under management. ITEM 5 | Fees and Compensation The fee for any such service is negotiated based on the complexity of the client’s particular situation and overall needs and the role taken by Fiduciary Solutions, and typically ranges between 0.01% to 0.75% on the assets for Fiduciary Solutions’ consulting services, fund advisory services, sub-advisory services, and investment management services. In addition, a minimum annual fee or flat fee may be charged. Generally, with consulting services such as asset allocation models, we charge a flat fee. For investment advisory and management services, total fees can be a combination of flat and/or asset based fees. Fees are generally to be paid quarterly in arrears. For purposes of determining fees, the value of the assets is based on information provided by the recordkeeper of the assets. Limited Negotiability of Advisory Fees MFIM retains the discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances and needs will be considered in determining the fee schedule. These facts, circumstances and needs can include, among other factors, the complexity of the client; assets to be placed under management; anticipated future additional assets; related accounts; portfolio style; account composition; and reporting requirements. The specific annual fee schedule will be identified in the contract between MFIM and each client. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 4  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Fiduciary Solutions Advisory Fees in General Fees charged by Fiduciary Solutions can be lower or higher than otherwise available elsewhere. Fiduciary Solutions’ fees are exclusive of other related costs and expenses which shall be incurred by the client. For example, clients may incur certain charges imposed by custodians, brokers, and other third parties such as fees charged by managers, record- keeping/custodial fees, sales charges, redemption fees, wire transfer and electronic fund fees, and other fees and/or taxes. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to Fiduciary Solutions’ fee, and Fiduciary Solutions will not receive any portion of these other fees or costs. Limited Prepayment of Fees Under no circumstances do we require or solicit payment of fees in excess of $1,200 six months or more in advance of services rendered. Educational Events MFIM employees benefit from educational events sponsored by service providers to MFIM, such as law firms, audit firms and other professional service firms. ITEM 6 | Performance-Based Fees and Side-By-Side Management MFIM does not charge performance-based fees for its Fiduciary Solutions products and services. ITEM 7 | Types of Clients Fiduciary Solutions provides advisory services to client types that include, but are not limited to, the following: • Retirement and pension plans, recordkeepers, or custodians • Insurance companies • Broker/dealers • Mutual fund companies • Collective investment trusts (“CITs”) or their trustees • Financial advisory firms • Individuals such as IRA and HSA accountholders ITEM 8 | Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS Fiduciary Solutions provides asset allocation and fund selection strategies by conducting quantitative and qualitative analyses on mutual funds and other investment vehicles. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 5  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Fiduciary Solutions FORMS OF RISK Mutual Fund and Other Investment Vehicles Investments in mutual funds and other investment vehicles, including but not limited to collective investment trusts, are subject to market risks such as absence of liquidity in markets or fluctuations in market prices beyond the control of the managers, resulting in investment objectives of the fund not being achieved. Past Performance Past performance of a particular fund, product, or service is not indicative of the future performance of the fund, product or service. Asset Allocation Models While asset allocation models are believed to result in a diversified portfolio of investments, diversification does not protect against market risks and does not assume profit. Risks For All Forms of Analysis MFIM’s analysis methods rely on publicly-available sources of information which are assumed to be accurate and unbiased data. While MFIM is alert to indications that data may be incorrect, there is always a risk that MFIM’s analysis can be compromised by limited, inaccurate or misleading information. Risk of Loss Securities investments are not guaranteed and clients can lose all invested funds. ITEM 9 | Disciplinary Information While there have been no disciplinary actions directly related to Fiduciary Solutions, on July 22, 2022, with respect to certain other business groups within MFIM, MFIM entered into a settlement with the SEC, the details of which are available here: https://www.sec.gov/litigation/admin.htm. As described in more detail in the Order, the settlement was related primarily to insufficient disclosure related to purchases of non-affiliated mutual fund shares (No Transaction Fee or NTF funds). Specifically, prior to June 2019, the disclosure outlined in MFIM’s Form ADV allegedly did not adequately disclose the receipt of NTF revenue sharing by Mesirow Financial, Inc. (MFI), MFIM’s affiliated broker-dealer, or the conflicts this created for MFIM. Without admitting or denying the underlying findings, MFIM agreed to pay affected investors disgorgement of $487,862, prejudgment interest of $94,972 and pay a civil penalty of $170,000. MFIM subsequently notified affected investors of the settlement terms. ITEM 10 | Other Financial Industry Activities and Affiliations Employees of Fiduciary Solutions do not engage in any financial industry activities or affiliations that would result in any additional compensation to MFIM or MFI aside from compensation that has been previously disclosed to, and agreed upon by their clients. However, certain employees of MFIM outside of the Fiduciary Solutions group, that are separately licensed as registered representatives of Mesirow Financial, Inc. (“MFI”), can and do at certain times, effect securities transactions for which they will receive separate, yet customary compensation. While MFIM and these individuals endeavor at all times to fulfill their fiduciary responsibilities to clients, clients should be aware that the receipt of additional compensation itself creates a conflict of interest, and can affect the judgment of these individuals when making recommendations. Certain employees outside of the Fiduciary Solutions group, in their individual capacities, can be agents for various insurance companies. As such, these individuals are able to receive separate, yet customary commission compensation resulting from implementing product transactions on behalf of clients. Clients, however, are not under any obligation to Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 6  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Fiduciary Solutions engage these individuals when considering implementation of advisory recommendations. The implementation of any or all recommendations is solely at the discretion of the client. Clients should be aware that the receipt of additional compensation by MFIM and its management persons or employees creates a conflict of interest that potentially impairs the objectivity of MFIM and these individuals when making advisory recommendations. MFIM endeavors at all times to put the interest of its clients first as part of its fiduciary duty as a registered investment advisor. MFIM typically takes the following steps to address and to mitigate any potential conflicts: • MFIM discloses to clients the existence of all material conflicts of interest; • MFIM collects, maintains and documents accurate, complete and relevant client background information, including the client’s investment mandates, financial goals, objectives and risk tolerance; • MFIM’s management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable for the client’s needs and circumstances; • MFIM requires that employees seek prior approval of any outside employment activity to ensure that any conflicts of interests in such activities are properly addressed; • MFIM periodically monitors outside employment activities of its employees to verify that any conflicts of interest continue to be properly addressed; and • MFIM educates its employees regarding the responsibilities of a fiduciary, including the need to have a reasonable and independent basis for the investment advice provided to clients. ITEM 11 | Code of Ethics, Participation or Interest in Client Transactions and Personal Trading MFIM has adopted a Code of Ethics that sets forth the ethical standards of business conduct that MFIM requires of its employees, including compliance with applicable federal securities laws. MFIM and its personnel owe a duty of loyalty, fairness and good faith towards clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code of Ethics. MFIM’s Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by MFIM’s access persons. MFIM has additional policies and procedures relating to the preclearance of all employee trades (other than securities deemed exempt from this obligation). MFIM’s Code of Ethics also provides for oversight, enforcement and recordkeeping provisions. MFIM’s Code of Ethics further includes policies and procedures governing gifts and entertainment, outside business activities, confidentiality of information and information barriers, and charitable and political contributions. The Code of Ethics also prohibits the misuse of material non-public information and emphasizes the avoidance of conflicts of interest with investors. Each employee must acknowledge the terms of the Code of Ethics on an annual basis. Any employee who violates the Code of Ethics may be subject to possible actions, which may include enhanced supervision, censure, suspension or termination. A copy of the Code of Ethics is available to clients and prospective clients. To request a copy, email maryjo.hayes@mesirow.com, or call 312.595.6512. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 7  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Fiduciary Solutions MFIM is part of a group of affiliated financial services companies that perform a number of different services for a client. MFIM is mindful of the conflicts or potential conflicts that such relationships create. Consequently, MFIM has adopted a Code of Conduct, which prescribes standards of conduct required of all employees, regardless of their position or affiliation in the group. The Code prohibits self-dealing and other improper activities, the misuse of material non-public information and it emphasizes the avoidance of conflicts of interest with clients. Some specific areas of potential conflict are discussed below. MFIM and/or individuals associated with it can buy or sell for their personal accounts securities identical to or different from those recommended to its clients. In addition, any related person(s) can have an interest or position in securities that may also be recommended to a client. Employees of the Fiduciary Solutions group do not trade client accounts and cannot aggregate personal trading with client accounts. Accounts owned by MFIM or persons associated with MFIM outside of the Fiduciary Solutions group may participate in aggregated trading with client accounts; however, such accounts will not be given preferential treatment. MFIM, through MFI, can direct the purchase or sale in securities on a principal basis in accordance with Section 206 (3) under the Investment Advisers Act of 1940, as amended. As these situations represent actual or potential conflicts of interest to clients, MFIM has established the following policies and procedures for implementing its Code of Ethics, to ensure the firm complies with its regulatory obligations and provides clients and potential clients with full and fair disclosure of such conflicts of interest: 1. No principal or employee of MFIM can put his or her own interest above the interest of a client. 2. No principal or employee of MFIM can buy or sell securities for their personal portfolio(s) where their decision is based on information received as a result of his or her employment unless the information is also available to the investing public. 3. MFIM requires prior approval for any IPO or private placement investments. 4. MFIM maintains a list of all reportable securities holdings for the firm and anyone associated with this advisory practice that has access to advisory recommendations (“access person”). These holdings are reviewed on a regular basis by the appropriate designated supervisor. 5. MFIM has established procedures for the maintenance of all required books and records. 6. All of MFIM’s principals and employees must act in accordance with all applicable federal and state regulations governing registered investment advisory practices. 7. MFIM requires delivery and acknowledgement of the Code of Ethics by each access person. 8. MFIM has established policies requiring the reporting of Code of Ethics violations to senior management. Any individual who violates any of the above restrictions may be subject to possible actions, which may include enhanced supervision, censure, suspension or termination. ITEM 12 | Brokerage Practices Generally, Fiduciary Solutions’ business model does not involve transactional business and, consequently, Fiduciary Solutions does not currently engage brokers in any transactional capacity. To the extent that Fiduciary Solutions does engage brokers in a transactional capacity, Fiduciary Solutions is required to describe the factors considered in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). When Fiduciary Solutions is being engaged by a client in connection with certain self-directed non- discretionary accounts, client assets that are the subject of these self-directed non-discretionary accounts are held at Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 8  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Fiduciary Solutions third-party custodians as to which the client executes separate agreements and receives separate fee disclosures. Fiduciary Solutions has no interest or conflict to disclose in connection with any of these arrangements. ITEM 13 | Review of Accounts INVESTMENT SUPERVISORY SERVICES PORTFOLIO MANAGEMENT Fiduciary Solutions has dedicated supervisors, as well as compliance, operational and internal audit staff, which monitor and provide oversight to the investment activities of supervised personnel. The supervisors, or their designees, review and monitor the activities of the portfolio managers and/or investment advisor representatives. Such activities include, but are not limited to, adhering to client guidelines and objectives, employee trading, investment product due diligence and marketing and advertising. ITEM 14 | Client Referrals and Other Compensation CLIENT REFERRALS Fiduciary Solutions does not enter into solicitor’s arrangements. The following information on client referrals is only applicable to MFIM and its affiliates outside of the Fiduciary Solutions group. MFIM does not receive an economic benefit from anyone other than its clients. MFIM and its affiliates may enter into Referral Agreements with a promoter such as a broker-dealer or an investment adviser. MFIM or its affiliates generally pay the promoter a percentage of the management f ee and/or performance-based fee collected from the client. Regardless of how it is calculated, any such referral fee will be paid solely from MFIM’s investment management fee and will not result in any additional charge to the client. MFIM has entered into arrangements with unaffiliated third parties for their assistance in referring business to MFIM or providing advice to MFIM with respect to the expansion of the firm’s distribution of products or services in various U.S. and non-U.S. markets and distribution channels. MFIM may pay cash compensation under these arrangements based on a monthly flat fee as well as in the sole discretion of the firm, a bonus at the conclusion of the arrangements. The fees paid to the unaffiliated third party are not passed on to any introduced clients, but the presence of these arrangements may affect MFIMs ’ willingness to negotiate below its standard investment advisory fees and, therefore, may affect the overall fees paid by referred clients. It is MFIM’s policy not to accept or allow its related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services provided to clients. MFIM also periodically compensates affiliate personnel that work in other business units for referrals. ITEM 15 | Custody All clients of Fiduciary Solutions custody their assets at an outside custodian. Clients are urged to carefully compare the information provided on these statements to ensure that all account transactions, holdings and values are correct and current. ITEM 16 | Investment Discretion Clients may engage MFIM to provide discretionary and non-discretionary advisory services. Clients give MFIM discretionary authority when they sign an investment management agreement with MFIM, and may, in certain circumstances, limit or change/amend such limitations by giving MFIM written instructions. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 9  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Fiduciary Solutions ITEM 17 | Voting Client Securities PROXY VOTING POLICIES AND PROCEDURES: Except as otherwise agreed to in writing with a client, Fiduciary Solutions has no authority or obligation to take any action or render any advice with respect to the voting of proxies on behalf of a client. In certain instances, Fiduciary Solutions has agreed to vote proxies on behalf of certain Collective Investment Trust (CITs) or their trustees and specifically has agreed to vote mutual fund proxies received by the CIT. To the extent the Fiduciary Solutions group is required to vote on a proxy, it does so in accordance with its best judgment of the client’s interest. Proxy materials as well as a copy of the Proxy Voting Policy will be made available upon request by contacting fiduciaryinquiries@mesirow.com. ITEM 18 | Financial Information MFIM has no additional no financial circumstances to report. MFIM has not been the subject of a bankruptcy petition at any time during the past ten years. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 10 

June 24, 2025 Mesirow Financial Investment Management, Inc. Front Barnett, a division of Wealth Management 353 North Clark Street, Chicago, Illinois 60654 Telephone: 312-595-6000 | Email: inquiries@mesirow.com ITEM 1 | Cover Part 2A of Form ADV Firm Brochure This brochure provides information about the qualifications and business practices of the Front Barnett, a division of the Wealth Management business of Mesirow Financial Investment Management, Inc. (“MFIM”). The Practices of Front Barnett may differ from other MFIM business division’s practices. If you have any questions about the contents of the brochure supplement or did not receive a copy of the ADV Part 2A brochure, please contact 312.595.6000 or inquiries@mesirow.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about Mesirow Financial Investment Management, Inc., is also available on the SEC’s website at www.adviserinfo.sec.gov. The site may be searched by a unique identifying number known as a “CRD number.” MFIM’s CRD number is 111135. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved.  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management ITEM 2 | Material Changes Mesirow Financial Investment Management Inc. (“MFIM”), Front Barnett division of Wealth Management (“Front Barnett” and/or “the firm”), Form ADV Part 2A, currently dated June 24,2025, as amended from time to time, is MFIM’s client disclosure document prepared based on the Securities and Exchange Commission’s regulatory requirements. MFIM is required to update this document at least annually, or when an event occurs that may be deemed to have a material impact on MFIM Wealth Management and related investment management business and/or on its clients. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 2  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management ITEM 3 | Table of Contents ITEM 1 | Cover ........................................................................................................................................................................ 1 ITEM 2 | Material Changes ..................................................................................................................................................... 2 ITEM 3 | Table of Contents ..................................................................................................................................................... 3 ITEM 4 | Advisory Business .................................................................................................................................................... 4 ITEM 5 | Fees and Compensation .......................................................................................................................................... 5 ITEM 6 | Performance-Based Fees ......................................................................................................................................... 7 ITEM 7 | Types of Clients ........................................................................................................................................................ 7 ITEM 8 | Methods of Analysis, Investment Strategies and Risk of Loss ................................................................................. 7 ITEM 9 | Disciplinary Information .......................................................................................................................................... 12 ITEM 10 | Other Financial Industry Activities and Affiliations................................................................................................ 12 ITEM 11 | Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....................................... 13 ITEM 12 | Brokerage Practices ............................................................................................................................................. 15 ITEM 13 | Review of Accounts .............................................................................................................................................. 21 ITEM 14 | Client Referrals and Other Compensation ........................................................................................................... 21 ITEM 15 | Custody................................................................................................................................................................. 22 ITEM 16 | Investment Discretion ........................................................................................................................................... 23 ITEM 17 | Voting Client Securities ........................................................................................................................................ 23 ITEM 18 | Financial Information ............................................................................................................................................ 23 Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 3  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management ITEM 4 | Advisory Business Front Barnett is a division of the Wealth Management business of Mesirow Financial Investment Management, Inc. (“MFIM”). MFIM, an Illinois corporation formed in 1986, is an investment adviser registered with the SEC with its principal place of business located in Illinois. Registration with the SEC does not imply any level of skill or training. MFIM’s sole shareholder is Mesirow Financial Services, Inc., which is a wholly owned subsidiary of Mesirow Financial Holdings, Inc. MFIM does not provide tax or legal advice. Clients should consult with an expert on tax or legal issues. ADVISORY SERVICES OFFERED Front Barnett provides discretionary asset management services to individuals and high-net worth individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations, and other legal entities. Front Barnett’s goal is to achieve above-average after-tax returns on client portfolios over a market cycle. Front Barnett may open non- discretionary advisory accounts under certain limited circumstances, such as where the firm has an established discretionary portfolio management arrangement with a related family member or where the client requests the firm implements transactions according to his or her direction on a non-discretionary basis and provide portfolio accounting. Each client relationship is under the direct, continuous management of a team of professionals led by an officer of the firm. In addition to its asset management services, Front Barnett provides a broad range of informal collateral financial advice to clients in connection with estate planning, tax considerations, and general business matters as more fully described below. In addition to providing Front Barnett with information regarding their personal financial circumstances, investment objectives, and tolerance for risk, clients are obligated to provide Front Barnett with any reasonable investment restrictions that should be imposed on the management of their portfolio, and to promptly notify Front Barnett in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals, and tolerance for risk. On a quarterly basis, Front Barnett’s reports to clients will remind clients of their obligation to inform Front Barnett of any such changes or any restrictions that should be imposed on the management of the client’s account. Front Barnett will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives, and tolerance for risk. DISCRETIONARY ASSET MANAGEMENT SERVICES – CORE EQUITY PORTFOLIOS Front Barnett’s core equity portfolio employs a growth- and value-blended investment strategy. The firm believes this approach is likely to produce more consistent returns over the long term than either style on a stand-alone basis. Front Barnett’s equity portfolios are diversified with large-, mid-, and small-capitalization securities composed of domestic and foreign domiciled common stocks, index funds, mutual funds, exchange-traded funds, and exchange-traded notes. Front Barnett utilizes a disciplined approach, intensely monitoring its proprietary Economic Model and employing a wide range of thoroughly researched investment choices. DISCRETIONARY ASSET MANAGEMENT SERVICES – FIXED INCOME PORTFOLIOS Front Barnett manages its fixed income portfolios through active management, duration control, broad sector diversification, maintenance of issues with maturities of generally 10 years or less, and continuity of income streams ordinarily through use of investment-grade instruments. FINANCIAL ADVISORY SERVICES As an adjunct to its discretionary asset management services, Front Barnett provides clients with informal advice concerning financial and estate planning issues as well as on general business matters based upon each client’s unique Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 4  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management needs. Such advice, provided without charge and in the context of the firm’s asset management activities, is not intended to be a stand-alone service subject to separate fees. Front Barnett charges an asset-based fee for all of its services as more fully described in Item 5 of this Brochure. CLIENT-TAILORED SERVICES AND CLIENT-IMPOSED RESTRICTIONS Client relationships are managed on the basis of the individual client’s financial situation and investment objectives, and in accordance with any reasonable restrictions imposed by the client on the management of his or her account. WRAP FEE PROGRAMS Front Barnett does not participate in wrap fee programs. (Wrap fee programs offer services for one all-inclusive fee.) CLIENT ASSETS UNDER MANAGEMENT As of March 31, 2025, Front Barnett managed approximately $1.23 billion in assets on a discretionary basis and $6.09 million in assets on a non-discretionary basis. ITEM 5 | Fees and Compensation METHODS OF COMPENSATION AND FEE SCHEDULE Front Barnett’s advisory fees are based solely upon the fee schedule contained in the investment advisory agreement between the client and the firm as agreed to at the outset of the relationship. The annual recommended fee for services provided by Front Barnett will be charged as a percentage of assets under supervision by the firm, billed quarterly in advance. Front Barnett’s current asset-based fee schedule for new accounts is detailed below: Portfolio Value First $1,000,000 Next $4,000,000 Next $10,000,000 All amounts over $15,000,000 Annual Fee 1.00% 0.75% 0.60% 0.50% Front Barnett generally requires a minimum account fee of $17,500 for accounts it manages. For accounts with portfolio assets less than $2,000,000, clients may be able to obtain more favorable pricing elsewhere. Front Barnett, in its sole discretion, may waive the required minimum or aggregate related accounts to meet the minimum fee. Client Fees can vary based on various factors. Advisory fees are always subject to the investment advisory agreement between the client and Front Barnett. Asset-based fees are payable quarterly in advance. The client and the client’s custodian or broker-dealer will be invoiced at the beginning of each calendar quarter, based upon the market value (market value plus any credit balance or minus any debit balance) of the client's account at the end of the previous quarter, as mutually agreed upon by the client and Front Barnett. The fees will be prorated if the investment advisory relationship commences otherwise than at the beginning of a calendar quarter. There will be no fee adjustments for contributions to and distributions from a client’s portfolio. The client authorizes the custodian of client’s securities to automatically deduct Front Barnett’s advisory fee payable to the adviser from the assets in the account when due, with such payments to be reflected on the next custodian’s account Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 5  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management statement sent to the client. If insufficient cash is available to pay such fees, sufficient securities will be liquidated to pay for the unpaid balance. Front Barnett can modify the fee at any time upon 30 days’ written notice to the client. Client Fees can vary based on various factors. CLIENT PAYMENT OF FEES Front Barnett generally requires clients to authorize the direct debit of fees from their accounts. Exceptions will be granted subject to the firm’s consent for clients to be billed directly for our fees. For directly debited fees, the custodian’s periodic statements will show each fee deduction from the account. Clients can withdraw this authorization for direct billing of these fees at any time by notifying us or their custodian in writing. Front Barnett will deduct advisory fees directly from the client’s account provided that (i) the client provides written authorization to the qualified custodian, and (ii) the qualified custodian sends the client a statement, at least quarterly, indicating all amounts disbursed from the account. The client is responsible for verifying the accuracy of the fee calculation, as the client’s custodian will not verify the calculation. ADDITIONAL CLIENT FEES CHARGED All fees paid for investment advisory services are separate and distinct from the fees and expenses charged by exchange- traded funds, mutual funds, broker-dealers, and custodians retained by clients. Such fees and expenses are described in each exchange-traded fund and mutual fund’s prospectus, and by any broker-dealer or custodian retained by the client. Clients are advised to read these materials carefully before investing. If a mutual fund also imposes sales charges, a client will pay an initial or deferred sales charge as further described in the mutual fund’s prospectus. A client using Front Barnett can be precluded from using certain mutual funds or separate account managers because they may not be offered by the client's custodian. Please refer to the Brokerage Practices section (Item 12) for additional information regarding the firm’s brokerage practices. LIMITED PREPAYMENT OF CLIENT FEES Under no circumstances do we require or solicit payment of fees in excess of $1,200 six months or more in advance of services rendered. TERMINATION OF THE ADVISORY RELATIONSHIP A client investment advisory agreement can be terminated by either party at any time upon written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. COMPENSATION Front Barnett’s financial advisors are compensated solely through a salary and bonus structure. Front Barnett is not paid any sales, service, or administrative fees for the sale of mutual funds or any other investment products. EDUCATIONAL EVENTS MFIM employees benefit from educational events sponsored by service providers to MFIM, such as law firms, audit firms, recordkeepers and other professional services firms. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 6  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management ITEM 6 | Performance-Based Fees Front Barnett does not charge performance-based fees and therefore has no economic incentive to manage clients’ portfolios in any way other than what it believes to be in the clients’ best interests. ITEM 7 | Types of Clients Front Barnett offers personalized investment management services to individuals and high-net worth individuals and related trusts, charitable organizations, pension and profit sharing plans, corporations, and other entities. Although Front Barnett provides investment services to the various types of clients mentioned, the services are conditioned upon meeting the following certain minimum criteria established by the firm. Front Barnett requires a minimum account fee of $17,500 for accounts it manages. For accounts with portfolio assets less than $2,000,000, clients may be able to obtain more favorable pricing elsewhere. Front Barnett, in its sole discretion, can waive the required minimum or aggregate related accounts to meet the minimum fee. ITEM 8 | Methods of Analysis, Investment Strategies and Risk of Loss METHOD OF ANALYSIS AND INVESTMENT STRATEGIES Front Barnett is responsible for identifying and implementing analytical methodologies used in formulating investment recommendations to clients. The methods of research may include fundamental analysis, quantitative methods for optimizing client portfolios, computer-based risk/return analysis, and statistical and/or computer models utilizing long-term economic criteria. Front Barnett can retain independent third parties to work in conjunction with its management team to provide input and guidance for the investment direction communicated by the firm. Front Barnett may utilize third-party software to assist in formulating investment recommendations to clients. Based upon the client’s investment objectives, portfolios under the supervision of Front Barnett will include cash equivalents, fixed income securities, and equity securities. Equity Portfolios Front Barnett invests in domestic and foreign large-, mid-, and small-capitalization companies and other vehicles as described below. The methods of analysis for these investments will include: • fundamental and technical analysis • input from portfolio managers • economic models • quantitative methods for optimizing client portfolios • computer-based risk/return analysis • statistical and/or computer models utilizing long-term economic criteria In addition, Front Barnett continually reviews its proprietary Economic Model, research material prepared by others, corporate filings, corporate rating services, corporate press releases, and a variety of financial publications to develop insights useful in securities selection. A description of the factors to be used in formulating investment advice and recommendations are as follows: Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 7  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management • economic outlook • capital markets • political, social, and demographic trends • international conditions • supply/demand considerations Front Barnett will utilize independent third parties to assist in recommending and monitoring individual equity securities and other investment vehicles to clients as appropriate under the circumstances. Fixed Income Portfolios Front Barnett recognizes that clients generally assume market risk in the equity portion of their portfolio and, as a result, the firm ordinarily limits its fixed income risk exposure by investing in investment-grade bonds and by controlling the bond portfolio’s duration. Duration is defined as the weighted average time until cash flows are received and is measured in years. The methods of analysis for these investments will include: • fundamental and technical analysis • input from portfolio managers • economic models • quantitative methods for optimizing client portfolios • computer-based risk/return analysis • statistical and/or computer models utilizing long-term economic criteria • reports of outside bond specialists and rating services Material Risks of Investment Instruments Front Barnett typically invests in equity securities, corporate and bank-sponsored debt instruments, municipal fixed income instruments, government securities including asset-backed securities, and other securities as detailed below: • Equity securities • Warrants and rights • Mutual fund securities • Exchange-traded funds • Exchange-traded notes • Corporate debt securities, commercial paper, and certificates of deposit • Municipal securities • U.S. government securities Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 8  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management • Government and agency mortgage-backed securities • Corporate debt obligations • Mortgage-backed securities • Collateralized obligations Equity Securities Investing in individual companies involves inherent risk. The major risks relate to the company’s capitalization, quality of the company’s management, quality and cost of the company’s services, the company’s ability to manage costs, efficiencies in the manufacturing or service delivery process, management of litigation risk, and the company’s ability to create shareholder value (i.e., increase the value of the company’s stock price). Foreign securities, in addition to the general risks of equity securities, have geopolitical risk, financial transparency risk, currency risk, regulatory risk and liquidity risk. Warrants and Rights Warrants are securities, typically issued with preferred stock or bonds, that give the holder the right to purchase a given number of shares of common stock at a specified price and time. The price of the warrant usually represents a premium over the applicable market value of the common stock at the time of the warrant’s issuance. Warrants have no voting rights with respect to the common stock, receive no dividends, and have no rights with respect to the assets of the issuer. Investments in warrants and rights involve certain risks, including the possible lack of a liquid market for the resale of the warrants and rights, potential price fluctuations due to adverse market conditions or other factors, and failure of the price of the common stock to rise. If the warrant is not exercised within the specified time period, it becomes worthless. Mutual Fund Securities Investing in mutual funds carries inherent risk. The major risks of investing in a mutual fund include the quality and experience of the portfolio management team and its ability to create fund value by investing in securities that have positive growth, the amount of individual company diversification, the type and amount of industry diversification, and the type and amount of sector diversification within specific industries. In addition, mutual funds tend to be tax inefficient and therefore investors will pay capital gains taxes on fund investments while not having yet sold the fund. Exchange-Traded Funds (“ETFs”) ETFs are investment companies whose shares are bought and sold on a securities exchange. An ETF holds a portfolio of securities designed to track a particular market segment or index. Some examples of ETFs are SPDRs®, streetTRACKS®, DIAMONDSSM, NASDAQ 100 Index Tracking StockSM (“QQQsSM”), iShares® and VIPERs®. The funds could purchase an ETF to gain exposure to a portion of the U.S. or foreign market. The funds, as a shareholder of another investment company, will bear their pro rata portion of the other investment company’s advisory fee and other expenses, in addition to their own expenses. Investing in ETFs involves risk. Specifically, ETFs, depending on the underlying portfolio and its size, can have wide price (bid and ask) spreads, thus diluting or negating any upward price movement of the ETF or enhancing any downward price movement. Also, ETFs require more frequent portfolio reporting by regulators and are thereby more susceptible to actions by hedge funds that could have a negative impact on the price of the ETF. Certain ETFs may employ leverage, which creates additional volatility and price risk depending on the amount of leverage utilized, the collateral and the liquidity of the supporting collateral. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 9  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management Further, the use of leverage (i.e., employing the use of margin) generally results in additional interest costs to the ETF. Certain ETFs are highly leveraged and therefore have additional volatility and liquidity risk. Volatility and liquidity can severely and negatively impact the price of the ETF’s underlying portfolio securities, thereby causing significant price fluctuations of the ETF. Corporate Debt, Commercial Paper, and Certificates of Deposit Fixed income securities carry additional risks than those of equity securities described above. These risks include the company’s ability to retire its debt at maturity, the current interest rate environment, the coupon interest rate promised to bondholders, legal constraints, jurisdictional risk (U.S or foreign) and currency risk. If bonds have maturities of 10 years or greater, they will likely have greater price swings when interest rates move up or down. The shorter the maturity the less volatile the price swings. Foreign bonds also have liquidity and currency risk. Commercial paper and certificates of deposit are generally considered safe instruments, although they are subject to the level of general interest rates, the credit quality of the issuing bank and the length of maturity. With respect to certificates of deposit, depending on the length of maturity there can be prepayment penalties if the client needs to convert the certificate of deposit to cash prior to maturity. Municipal Securities Municipal securities carry additional risks than those of corporate and bank-sponsored debt securities described above. These risks include the municipality’s ability to raise additional tax revenue or other revenue (in the event the bonds are revenue bonds) to pay interest on its debt and to retire its debt at maturity. Municipal bonds are generally tax-free at the federal level but may be taxable in individual states other than the state in which both the investor and municipal issuer is domiciled. U.S. Government Securities U.S. government securities include securities issued by the U.S. Treasury and by U.S. government agencies and instrumentalities. U.S. government securities may be supported by the full faith and credit of the United States. Government and Agency Mortgage-Backed Securities The principal issuers or guarantors of mortgage-backed securities are the Government National Mortgage Association (“GNMA”), Fannie Mae (“FNMA”) and the Federal Home Loan Mortgage Corporation (“FHLMC”). GNMA, a wholly owned U.S. government corporation within the Department of Housing and Urban Development (“HUD”), creates pass-through securities from pools of government-guaranteed (Farmers’ Home Administration, Federal Housing Authority or Veterans Administration) mortgages. The principal and interest on GNMA pass- through securities are backed by the full faith and credit of the U.S. government. FNMA, which is a U.S. government-sponsored corporation owned entirely by private stockholders that is subject to regulation by the secretary of HUD, and FHLMC, a corporate instrumentality of the U.S. government, issue pass-through securities from pools of conventional and federally insured and/or guaranteed residential mortgages. FNMA guarantees full and timely payment of all interest and principal, and FHMLC guarantees timely payment of interest and ultimate collection of principals of its pass-through securities. Mortgage-backed securities from FNMA and FHLMC are not backed by the full faith and credit of the U.S. government. Corporate Debt Obligations Corporate debt obligations include corporate bonds, debentures, notes, commercial paper, and other similar corporate debt instruments. Companies use these instruments to borrow money from investors. The issuer pays the investor a fixed Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 10  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management or variable rate of interest and must repay the amount borrowed at maturity. Commercial paper (short-term unsecured promissory notes) is issued by companies to finance their current obligations and normally has a maturity of less than nine months. Front Barnett may also invest in corporate debt securities registered and sold in the United States by foreign issuers (Yankee bonds) and those sold outside the U.S. by foreign or U.S. issuers (Eurobonds). Mortgage-Backed Securities Mortgage-backed securities represent interests in a pool of mortgage loans originated by lenders such as commercial banks, savings associations, and mortgage bankers and brokers. Mortgage-backed securities may be issued by governmental or government-related entities, or by non-governmental entities such as special-purpose trusts created by commercial lenders. Pools of mortgages consist of whole mortgage loans or participations in mortgage loans. The majority of these loans are made to purchasers of between one and four family homes. The terms and characteristics of the mortgage instruments are generally uniform within a pool but may vary among pools. For example, in addition to fixed-rate, fixed-term mortgages, Front Barnett will purchase pools of adjustable-rate mortgages, growing equity mortgages, graduated payment mortgages and other types. Mortgage poolers apply qualification standards to lending institutions, which originate mortgages for the pools as well as credit standards and underwriting criteria for individual mortgages included in the pools. In addition, many mortgages included in pools are insured through private mortgage insurance companies. Mortgage-backed securities differ from other forms of fixed income securities, which normally provide for periodic payment of interest in fixed amounts with principal payments at maturity or on specified call dates. Most mortgage-backed securities, however, are pass-through securities, which means that investors receive payments consisting of a pro rata share of both principal and interest (less servicing and other fees), as well as unscheduled prepayments as loans in the underlying mortgage pool are paid off by the borrowers. Additional prepayments to holders of these securities are caused by prepayments resulting from the sale or foreclosure of the underlying property or refinancing of the underlying loans. As prepayment rates of individual pools of mortgage loans vary widely, it is not possible to accurately predict the average life of a particular mortgage-backed security. Although mortgage-backed securities are issued with stated maturities of up to 40 years, unscheduled or early payments of principal and interest on the mortgages may shorten considerably the securities’ effective maturities. Collateralized Obligations Collateralized mortgage obligations (“CMOs”) are collateralized by mortgage-backed securities issued by GNMA, FHLMC or FNMA (“mortgage assets”). CMOs are multiple-class debt obligations. Payments of principal and interest on the mortgage assets are passed through to the holders of the CMOs as they are received, although certain classes (often referred to as “tranches”) of CMOs have priority over other classes with respect to the receipt of mortgage prepayments. Each tranch is issued at a specific or floating coupon rate and has a stated maturity or final distribution date. Interest is paid or accrues in all tranches on a monthly, quarterly or semi-annual basis. Payments of principal and interest on mortgage assets are commonly applied to the tranches in the order of their respective maturities or final distribution dates, so that generally no payment of principal will be made on any tranche until all other tranches with earlier stated maturity or distribution dates have been paid in full. Collateralized debt obligations ("CDOs") include collateralized bond obligations ("CBOs"), collateralized loan obligations ("CLOs") and other similarly structured securities. CBOs and CLOs are types of asset-backed securities. A CBO is a trust that is backed by a diversified pool of high-risk, below-investment-grade fixed income securities. A CLO is a trust typically collateralized by a pool of loans, which may include, among others, domestic and foreign senior secured loans, senior Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 11  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management unsecured loans and subordinate corporate loans, including loans that may be rated below investment grade or equivalent unrated loans. Each investment listed above also has specific risks. Investors should review the risk section of any offering document. INVESTMENT STRATEGY AND METHOD OF ANALYSIS OR MATERIAL RISKS Short-Term Trading Although Front Barnett, as a general business practice, does not utilize short-term trading, there may be instances in which short-term trading will be necessary or an appropriate strategy. In this regard, please read the following: There is an inherent risk for clients who trade frequently in that high-frequency trading creates substantial transaction costs that in the aggregate could negatively impact account performance. DISCRETIONARY ASSET MANAGEMENT SERVICES – FIXED INCOME PORTFOLIOS Although Front Barnett employs a broad diversification strategy, there may be times when one industry, sector, or company is more heavily weighted than others. In such cases, there is the possibility that negative performance of the heavily weighted security will have a greater impact on the overall performance of the portfolio. Clients who have broadly diversified portfolios, as a general rule, incur less volatility and therefore less fluctuation in portfolio value than those who have concentrated holdings. Concentrated holdings can offer the potential for higher gain, but also offer the potential for significant loss. ITEM 9 | Disciplinary Information On July 22, 2022, MFIM entered into a settlement with the SEC, the details of which are available here: https://www.sec.gov/litigation/admin.htm. As described in more detail in the Order, the settlement was related primarily to insufficient disclosure related to purchases of non-affiliated mutual fund shares (No Transaction Fee or NTF funds). Specifically, prior to June 2019, the disclosure outlined in MFIM’s Form ADV allegedly did not adequately disclose the receipt of NTF revenue sharing by Mesirow Financial, Inc. (MFI), MFIM’s affiliated broker-dealer, or the conflicts this created for MFIM. Without admitting or denying the underlying findings, MFIM agreed to pay affected investors disgorgement of $487,862 prejudgment interest of $94,972; and pay a civil penalty of $170,000. MFIM subsequently notified affected investors of the settlement terms. ITEM 10 | Other Financial Industry Activities and Affiliations Clients should be aware that the receipt of additional compensation by MFIM and its management persons or employees creates a conflict of interest that potentially impairs the objectivity of MFIM and these individuals when making advisory recommendations. MFIM endeavors at all times to put the interests of its clients first as part of our fiduciary duty as a registered investment advisor. MFIM typically takes the following steps to address and to mitigate any potential conflicts: • MFIM discloses to clients the existence of all material conflicts of interest; • MFIM collects, maintains and documents accurate, complete and relevant client background information, including the client’s investment mandates, financial goals, objectives and risk tolerance; • MFIM’s management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable for the client’s needs and circumstances; Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 12  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management • MFIM requires that our employees seek prior approval of any outside employment activity to ensure that any conflicts of interest in such activities are properly addressed; • MFIM periodically monitors outside employment activities of its employees to verify that any conflicts of interest continue to be properly addressed; and • MFIM educates its employees regarding the responsibilities of a fiduciary, including the need to have a reasonable and independent basis for the investment advice provided to clients. MFIM’s affiliate has a clearing relationship with National Financial Services, a Fidelity company (“NFS”). Certain employees of MFIM are separately licensed as registered representatives of MFI. These individuals, in their separate capacity, can and do at certain times, effect securities transactions for which they will receive separate, yet customary compensation. Many mutual fund companies offer one or more retirement share classes specifically for the use by employer-sponsored retirement plans as investment options, (some share classes pay compensation to third parties, such as commissions, 12b-1 fees, and other administrative fees, while other share classes do not). The retirement share classes that are available to a client is generally determined by specific criteria set by the mutual fund company, such as plan asset size and/or the number of participants in the retirement plan. The available share classes may factor into the fee structure and how the investment advisory fees and expenses are paid. For particular share class information, please refer to the investment product prospectus. Depending on the share class, companies affiliated with MFIM may receive various forms of compensation from providers of services that MFIM recommends. This compensation is not directly received by MFIM, but contributes to the revenue of the overall organization. This compensation may come in the form of commissions paid to an affiliated broker-dealer by a mutual fund company, insurance company, or other organization for the sale of an investment product; 12b-1 fees paid by a mutual fund company to a broker-dealer for distribution and servicing of mutual funds; commissions/fees paid to a broker/dealer by a trust company; sub-transfer agent fees paid to an affiliated retirement plan administrator or recordkeeper by a mutual fund company, insurance company, or other organization for servicing and administering various investment options; fees paid for non-advisory third-party administrative services by clients; and/or fees paid by an employee benefits provider to an affiliated company for sales of various products or services. The existence of these payments may or may not affect MFIM’s recommendations. The existence of this additional compensation will be taken into consideration in the negotiation of investment advisory fees for the services offered by MFIM. Commissions/compensation received by affiliated companies in relation to securities recommended by advisory personnel of MFIM will represent a material conflict of interest. In many (but not all) cases, this conflict of interest is mitigated through the “off-setting” of investment advisory fees by any such commission/compensation received by the affiliate. For example, a client’s advisory fees will be reduced and offset by the amount of any Rule 12b-1 fees received by MFI. MFIM Wealth Management Director of Research currently participates on the advisory board of Grubb Properties Qualified Opportunity Zone Fund, a private investment in which MFIM Wealth Management recommends certain clients invest. This is an unpaid outside business activity. ITEM 11 | Code of Ethics, Participation or Interest in Client Transactions and Personal Trading MFIM has adopted a Code of Ethics that sets forth the ethical standards of business conduct that MFIM requires of its employees, including compliance with applicable federal securities laws. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 13  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management MFIM and its personnel owe a duty of loyalty, fairness and good faith towards clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics, but also to the general principles that guide the Code of Ethics. MFIM’s Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by MFIM’s access persons. MFIM has additional policies and procedures relating to the preclearance of all employee trades (other than securities deemed exempt from this obligation). MFIM’s Code of Ethics also provides for oversight, enforcement and recordkeeping provisions. MFIM’s Code of Ethics further includes policies and procedures governing gifts and entertainment, outside business activities, confidentiality of information and information barriers, and charitable and political contributions. The Code of Ethics also prohibits the misuse of material non-public information and emphasizes the avoidance of conflicts of interest with investors. Each employee must acknowledge the terms of the Code of Ethics on an annual basis. Any employee who violates the Code of Ethics may be subject to possible actions, which may include enhanced supervision, censure, suspension or termination. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email (maryjo.hayes@mesirow.com) or by phone (312.595.6512). MFIM is part of a group of affiliated financial services companies that perform a number of different services for a client. MFIM is mindful of the conflicts or potential conflicts that such relationships create. Consequently, MFIM has adopted a Code of Conduct that prescribes standards of conduct required of all employees, regardless of their position or affiliation in the group. The Code prohibits self-dealing and other improper activities, the misuse of material non-public information, and it emphasizes the avoidance of conflicts of interest with clients. Some specific areas of potential conflict are discussed below. MFIM and/or individuals associated with it can buy or sell for their personal accounts securities identical to or different from those recommended to our clients. In addition, any related person(s) can have an interest or position in certain securities that may also be recommended to a client. Accounts owned by MFIM or persons associated with MFIM may participate in aggregated trading with client accounts; however, such accounts will not be given preferential treatment. MFIM, through MFI, can direct the purchase or sale in securities on a principal basis in accordance with Section 206(3) under the Investment Advisers Act of 1940, as amended. As these situations represent actual or potential conflicts of interest to clients, MFIM has established the following policies and procedures for implementing its Code of Ethics, to ensure our firm complies with its regulatory obligations and provides clients and potential clients with full and fair disclosure of such conflicts of interest: 1. No principal or employee of MFIM can put his or her own interest above the interest of an advisory client. 2. No principal or employee of MFIM can buy or sell securities for their personal portfolio(s) based on information received as a result of his or her employment unless the information is also available to the investing public. 3. MFIM requires prior approval for any IPO or private placement investments. 4. MFIM maintains a list of all reportable securities holdings for the firm and anyone associated with this advisory practice that has access to advisory recommendations (“access person”). These holdings are reviewed on a regular basis by the appropriate designated supervisor. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 14  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management 5. MFIM has established procedures for the maintenance of all required books and records. 6. All of MFIM’s principals and employees must act in accordance with all applicable federal and state regulations governing registered investment advisory practices. 7. MFIM requires delivery and acknowledgement of the Code of Ethics by each access person. 8. MFIM has established policies requiring the reporting of Code of Ethics violations to senior management. Any individual who violates any of the above restrictions may be subject to possible actions, which may include enhanced supervision, censure, suspension or termination. ITEM 12 | Brokerage Practices FACTORS USED TO SELECT BROKER-DEALERS FOR CLIENT TRANSACTIONS Custodian Recommendations Front Barnett will, at the client’s request, recommend and assist the client in establishing accounts with Bank of America, U.S. Trust, or with the Schwab Advisor Services division of Charles Schwab & Co., Inc., (“Schwab”), a FINRA-registered broker-dealer, member SIPC, or with another custodian to maintain custody of clients’ assets and to effect trades for their accounts (herein collectively referred to as “custodian”). Although Front Barnett may be asked to recommend a custodian, it is the client’s decision to custody assets with the custodian. A custodian may or may not charge separately for custody services, and may be compensated by account holders through commissions and other transaction-related or asset-based fees for securities trades that are executed through the custodian or that settle into custodian accounts. In making recommendations with respect to custodial services, Front Barnett will take into account the needs of the individual client, the nature of the services required, the experience of the broker-dealer or custodian, the cost and quality of the services, and the reputation of the broker-dealer or custodian. The final determination to engage a broker-dealer or custodian recommended by Front Barnett shall be made by and in the sole discretion of the client. The client recognizes that broker-dealers and/or custodians have different cost and fee structures and trade execution capabilities. As a result, there may be disparities with respect to the cost of services and/or the transaction prices for securities transactions executed on behalf of the client. Clients are responsible for assessing the commissions and other costs charged by broker-dealers and/or custodians. How We Select Brokers/Custodians to Recommend Front Barnett seeks to recommend a custodian/broker who will hold client assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others, the following: • combination of transaction execution services along with asset custody services (generally without a separate fee for custody) • capability to execute, clear, and settle trades (buy and sell securities for client accounts) • capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • breadth of investment products made available (stocks, bonds, mutual funds, exchange- traded funds (ETFs), etc.) Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 15  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management • availability of investment research and tools that assist us in making investment decisions • quality of services • competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them • reputation, financial strength, and stability of the provider • their prior service to us and our other clients • availability of other products and services that benefit us, as discussed below • economic models Front Barnett is incentivized to recommend custodian or brokers in which it has a relationship and can assist in facilitating obtaining and maintaining clients. Soft Dollar Arrangements Front Barnett does not utilize soft dollar arrangements for direct brokerage transactions to executing brokers for research and brokerage services. Front Barnett does not have any formal soft dollar arrangements requiring a soft dollar budget. Institutional Trading and Custody Services The custodian provides Front Barnett with access to its institutional trading and/or custody services, which are typically not available to the custodian’s retail investors. These services are generally available to independent investment advisors on an unsolicited basis, at no charge to them. The custodian’s brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or that would require a significantly higher minimum initial investment. Other Products and Services The custodian also makes available to Front Barnett other products and services that benefit Front Barnett but don’t directly benefit its clients’ accounts. Many of these products and services can be used to service all or some substantial number of Front Barnett's accounts, including accounts not maintained at the custodian. The custodian may also make available to Front Barnett managing and administering software and other technology that • provide access to client account data (such as trade confirmations and account statements) • facilitate trade execution and allocate aggregated trade orders for multiple client accounts • provide research, pricing, and other market data • facilitate payment of Front Barnett’s fees from its clients’ accounts • assist with back-office functions, recordkeeping, and client reporting Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 16  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management The custodian also offers other services intended to help Front Barnett manage and further develop its business enterprise. These services may include • compliance, legal, and business consulting • publications and conferences on practice management and business succession • access to employee benefits providers, human capital consultants, and insurance providers The custodian may also provide other benefits, such as educational events or occasional business entertainment of Front Barnett personnel. In evaluating whether to recommend that clients custody their assets at a certain custodian, Front Barnett may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors it considers, and not solely the nature, cost, or quality of custody and brokerage services provided by the custodian, which may create a potential conflict of interest. Independent Third Parties The custodian can make available, arrange, and/or pay third-party vendors for the types of services rendered to Front Barnett. The custodian can discount or waive fees it would otherwise charge for some of these services or all or a part of the fees of a third party providing these services to Front Barnett. Additional Compensation Received from Custodians Front Barnett will participate in institutional customer programs sponsored by broker-dealers or custodians. Front Barnett will recommend these broker-dealers or custodians to clients for custody and brokerage services. There is no direct link between Front Barnett’s participation in such programs and the investment advice it gives to its clients, although Front Barnett receives economic benefits through its participation in the programs that are typically not available to retail investors. These benefits may include the following products and services (provided without cost or at a discount): • Receipt of duplicate client statements and confirmations • Research-related products and tools • Consulting services • Access to a trading desk serving Front Barnett participants • Access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts) • The ability to have advisory fees deducted directly from client accounts • Access to an electronic communications network for client order entry and account information • Access to mutual funds with no transaction fees and to certain institutional money managers • Discounts on compliance, marketing, research, technology, and practice management products or services provided to Front Barnett by third-party vendors The custodian will also pay for business consulting and professional services received by Front Barnett’s related persons, and can pay or reimburse expenses (including travel, lodging, meals and entertainment expenses for Front Barnett’s personnel to attend conferences). Some of the products and services made available by such custodian through its Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 17  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management institutional customer programs may benefit Front Barnett but will not benefit its client accounts. These products or services can assist Front Barnett in managing and administering client accounts, including accounts not maintained at the custodian as applicable. Other services made available through the programs are intended to help Front Barnett manage and further develop its business enterprise. The benefits received by Front Barnett or its personnel through participation in these programs do not depend on the amount of brokerage transactions directed to the broker-dealer. Front Barnett also participates in similar institutional advisor programs offered by other independent broker-dealers or trust companies, and its continued participation may require Front Barnett to maintain a predetermined level of assets at such firms. In connection with its participation in such programs, Front Barnett will typically receive benefits similar to those listed above, including research, payments for business consulting and professional services received by Front Barnett’s related persons, and reimbursement of expenses (including travel, lodging, meals and entertainment expenses for Front Barnett’s personnel to attend conferences sponsored by the broker-dealer or trust company). As part of its fiduciary duties to clients, Front Barnett endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by Front Barnett or its related persons in and of itself creates a potential conflict of interest and may indirectly influence Front Barnett’s recommendation of broker-dealers for custody and brokerage services. Brokerage for Client Referrals Front Barnett does not engage in the practice of directing brokerage commissions in exchange for the referral of advisory clients. Directed Brokerage Client-Directed Brokerage Occasionally, clients can direct Front Barnett to use a particular broker-dealer to execute portfolio transactions for their accounts or request that certain types of securities not be purchased for their accounts. Clients who designate the use of a particular broker-dealer should be aware that they will lose any possible advantage Front Barnett derives from aggregating transactions. Such client trades are typically effected after the trades of clients who have not directed the use of a particular broker-dealer. Front Barnett loses the ability to aggregate trades with other Front Barnett advisory clients, potentially subjecting the client to inferior trade execution prices as well as higher commissions. TRADING PRACTICES Best Execution Front Barnett will, if the client requests, recommend that clients establish brokerage accounts with Bank of America, U.S. Trust, or with the Schwab Advisor Services division of Charles Schwab & Co., Inc., (“Schwab”), a FINRA-registered broker-dealer, member SIPC, or with other custodians to maintain custody of clients’ assets and to effect trades for their accounts (herein collectively referred to as “custodian”). Such accounts will be prime broker eligible so that if and when the need arises to effect securities transactions at broker-dealers ("executing brokers") other than with the client’s current custodian, such custodian will accept delivery or deliver the applicable security from/to the executing broker. The custodian charges a “trade away” fee, which is charged against the client’s account for each trade away occurrence. Other custodians have their own policies concerning prime broker accounts and trade away fees. Clients will consult their current custodian for their policies and fees. Front Barnett, pursuant to the terms of its investment advisory agreement with clients, has discretionary authority to determine which securities are to be bought and sold, the price of such securities, the executing broker, and the commission rates to be paid to effect such transactions. Front Barnett recognizes that the analysis of execution quality Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 18  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management involves a number of factors, both qualitative and quantitative. Front Barnett will follow a process in an attempt to ensure that it is seeking to obtain the most favorable execution under the prevailing circumstances when placing client orders. These factors include but are not limited to the following: • The financial strength, reputation, and stability of the broker • The efficiency with which the transaction is effected • The ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any) • The availability of the broker to stand ready to effect transactions of varying degrees of difficulty in the future • The efficiency of error resolution, clearance, and settlement • Block trading and positioning capabilities • The ability to borrow securities for short sale • Performance measurement • Online access to computerized data regarding customer accounts • Availability, comprehensiveness, and frequency of brokerage and research services • Commission rates • The economic benefit to the client • Related matters involved in the receipt of brokerage services Security Allocation Since Front Barnett manages accounts with similar investment objectives, the firm may aggregate orders for securities for such accounts. In such event, allocation of the securities so purchased or sold, as well as expenses incurred in the transaction, is made by Front Barnett in the manner it considers to be the most equitable and consistent with its fiduciary obligations to such accounts. Front Barnett’s allocation procedures seek to allocate investment opportunities among clients in the fairest possible way, taking into account clients’ best interests. Front Barnett will follow procedures to ensure that allocations do not involve a practice of favoring or discriminating against any client or group of clients. Account performance is never a factor in trade allocations. Front Barnett’s advice to certain clients and entities and the action of Front Barnett for those and other clients are frequently premised not only on the merits of a particular investment but also on the suitability of that investment for the particular client in light of his or her applicable investment objective, guidelines and circumstances. Thus, any action of Front Barnett with respect to a particular investment can, for a particular client, differ or be opposed to the recommendation, advice, or actions of the firm to or on behalf of other clients. Order Aggregation Orders for the same security entered on behalf of more than one client will generally be aggregated (i.e., blocked or bunched) subject to the aggregation being in the best interests of all participating clients. Subsequent orders for the same security entered during the same trading day can be aggregated with any previously unfilled orders. Subsequent orders Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 19  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management may or may not also be aggregated with filled orders. All clients participating in each aggregated order will receive the average price and, subject to minimum ticket charges and possible step outs, pay a pro rata portion of commissions. To minimize performance dispersion, “strategy” trades should be aggregated and average priced. However, when a trade is to be executed for an individual account and the trade is not in the best interests of other accounts, then the trade will only be performed for that account. This is true even if Front Barnett believes that a larger size block trade would lead to best overall price for the security being transacted. Allocation of Trades Equities All equity trades are pre-allocated by Portfolio Managers (“PMs”); blocks are created in a bottom-up fashion and no trades are executed before all initial allocations are made, as evidenced by time-stamped “block detail” vs. time-stamped sending of trades via Bloomberg. Partial fills are allocated at random by our trading system Moxy until shares are exhausted (this function is built into Advent [Moxy]). Partial fills are fairly rare, but are indicated by a mismatch in the trade ticket reports between the “block detail” (pre-trade allocations) and “block execution detail” (post-trade allocations) reports. In the event that an error is made in an allocation, details of the error will be noted on the trade correction form or order ticket as applicable, along with the correct allocation. Fixed Income Allocation percentages applied to fixed income assets are made by the PM assigned to the respective account. This allocation is communicated to the Fixed Income PM/Trader. A list of accounts for which bonds are to be purchased is maintained either by the fixed income trader or the PM. Once a specific bond is identified for purchase, the PMs determine which clients are to be included based on clients’ needs. If a sufficient amount of the bond is available for all accounts, the Fixed Income PM/Trader solicits offerings from brokers. The trade is awarded on the basis of the lowest offering price for best execution on behalf of the client(s). If a limited amount of the bond is available and is insufficient to fill the total amount of orders, the Fixed Income PM/Trader considers the following factors when allocating a specific bond: • Overall fit with the existing portfolio • Amount of cash available as a percentage of the total fixed-income portfolio • Sector/industry/issuer-specific diversification • Effect on weighted average portfolio duration • Fit within existing maturity ladder • In addition: Municipals – yield net of state and local income taxes, geographic and bond backing (general obligation vs. revenue) diversification within the existing portfolio Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 20  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management ITEM 13 | Review of Accounts SCHEDULE FOR PERIODIC REVIEW OF CLIENT ACCOUNTS OR FINANCIAL PLANS AND ADVISORY PERSONS INVOLVED Client accounts under the supervision of Front Barnett are continually reviewed by the portfolio manager servicing the client relationship. Such professionals are subject to the general authority of Front Barnett’s Manager. The Manager or his designee(s) must review and approve the opening of each new advisory relationship and oversee reviews of client accounts. The Manager or designee(s) is also responsible for ensuring that any significant change in a client's investment strategy or in the concentration of a client's assets is appropriate for and has been reviewed with the client. REVIEW OF CLIENT ACCOUNTS ON NON-PERIODIC BASIS Front Barnett may perform ad hoc reviews on an as-needed basis if there have been material changes in the client’s investment objectives or risk tolerance, a change in the firm’s investment policy, or a material change in how Front Barnett formulates investment advice. CONTENT OF CLIENT-PROVIDED REPORTS AND FREQUENCY Front Barnett continually reviews all managed accounts. The firm can provide periodic reports at the client’s request that reflect gains and loss summaries and evaluations. Reviews for managed accounts consist of an analysis of the following factors: • client investment objectives • industry issues • credit issues • information concerning individual holdings in portfolios • review of performance versus benchmark and performance attribution The client’s independent custodian also provides regular account statements directly to the client no less frequently than quarterly. The custodian’s statement is the official record of the client’s account and supersedes any statements or reports created on behalf of the client by Front Barnett. MFIM Wealth Management has dedicated supervisors, as well as compliance, operational and internal audit staff, who monitor and provide oversight to the investment activities of supervised personnel. ITEM 14 | Client Referrals and Other Compensation MFIM does not receive an economic benefit from anyone other than its clients. MFIM and its affiliates may enter into Referral Agreements with a promoter such as a broker-dealer or an investment adviser. MFIM or its affiliates generally pay the promoter a percentage of the management fee and/or performance-based fee collected from the client. Regardless of how it is calculated, any such referral fee will be paid solely from MFIMs’ investment management fee and will not result in any additional charge to the client. See Item 5 for additional information on advisory fees. MFIM has entered into arrangements with unaffiliated third parties for their assistance in referring business to MFIM or providing advice to MFIM with respect to the expansion of the firm’s distribution of products or services in various U.S. and non-U.S. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 21  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management markets and distribution channels. MFIM may pay cash compensation under these arrangements based on a monthly flat fee as well as, in the sole discretion of the firm, a bonus at the conclusion of the arrangements. The fees paid to the unaffiliated third party are not passed on to any introduced clients, but the presence of these arrangements may affect MFIMs’ willingness to negotiate below its standard investment advisory fees and, therefore, may affect the overall fees paid by referred clients. It is MFIM’s policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services we provide to clients. MFIM also compensates affiliated personnel that work in other business units for referrals. ITEM 15 | Custody Clients choose which custodians will custody their assets. It is our understanding that certain such custodial agreements or other agreements or documents may contain provisions that could result in MFIM having inadvertent custody of client account assets as a result of language permitting us, as investment adviser, to withdraw client assets upon instruction to the custodian. Our agreements with our clients, however, are not intended to give us broad authority to withdraw client assets, and we disclaim such authority to the extent applicable. With respect to these concerns, our authority as it relates to custody should be considered to be limited in the ordinary course to customary trading and settlement of securities and investment transactions in the client’s account, typically on a “delivery vs payment” basis for securities transactions, as well as fee deductions in certain cases, as applicable. Most of MFIM Wealth Management clients custody their assets at NFS, since MFIM Wealth Management’s affiliate has a clearing relationship with NFS. Clients are not required to use NFS for these services and clients are free to work with other custodians. MFIM has obtained and continues to obtain certain revenues from NFS and receives various operational and supervisory efficiencies when clients choose NFS as its custodian. In addition, MFIM’s affiliated broker-dealer also receives revenues, including Correspondent Business Development Credits from NFS for maintaining its business relationships and customer accounts at NFS. Consequently, MFIM is incentivized to have clients choose NFS as their custodian over other custodians. MFI marks up NFS brokerage and custodial fees charged by NFS and retains that revenue. This creates an incentive for MFIM to encourage clients to use NFS since MFI does not have the ability to mark- up other broker’s fees. MFIM has custody of client accounts since some clients authorize their custodian, including NFS, to deduct MFIM’s advisory fees from their client account. In addition, pursuant to a standing letter of authorization (“SLOA”) some clients grant MFIM limited discretion to disburse funds to one or more third parties, as specifically designated by the client. After granting MFIM with this limited authorization, the client then instructs the qualified custodian for the client's account to accept MFIM’s direction on the client's behalf to move money to the third party designated by the client on the SLOA. We are authorized to act merely as an agent for the client. The client retains full power to change or revoke the arrangement. MFIM does NOT have discretion as to the amount, payee or timing of transfers under the SLOA. You should receive at least quarterly statements from the broker-dealer, bank or other qualified custodian that holds and maintains your investment assets. Our investment account statements will vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. For tax and other purposes, your custodial statement is the official record of your account(s) and assets. We urge you to carefully review your custodian statements and compare them to the account statements that we provide to you as your investment manager. If you have any questions with respect to your custodial statement and account statements, please contact your MFIM Advisor. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 22  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Front Barnett, a division of Wealth Management ITEM 16 | Investment Discretion Clients are required to grant a limited power of attorney to Front Barnett with respect to trading activity in their accounts by signing the appropriate custodian limited power of attorney form. In those cases, Front Barnett will exercise full discretion as to the nature and type of securities to be purchased and sold, the amount of securities for such transactions, the commissions to be paid, and the executing broker to be used. Investment limitations may be designated by the client as outlined in the investment advisory agreement. ITEM 17 | Voting Client Securities Front Barnett does not vote proxies for clients. Front Barnett will exercise discretion as it relates to corporate actions in any legal proceedings, including bankruptcies or class actions, involving securities included in or previously included in the Account. ITEM 18 | Financial Information MFIM has no additional financial circumstances to report. MFIM has not been the subject of a bankruptcy petition at any time during the past 10 years. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 23 

June 24, 2025 Mesirow Financial Investment Management, Inc. Institutional Real Estate, Direct Investments 353 North Clark Street, Chicago, Illinois 60654 Telephone: 312.595.6000 | Email: inquiries@mesirow.com mesirow.com ITEM 1 | Cover Part 2A of Form ADV Firm Brochure This brochure provides information about the qualifications and business practices of Institutional Real Estate, Direct Investments (“MIRED”), a division of Mesirow Financial Investment Management, Inc. If you have any questions about the contents of this brochure, please contact 312.595.6000 or inquiries@mesirow.com. The information in this brochure has not been approved verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about Mesirow Financial Investment Management, Inc. (“MFIM”) is also available on the SEC’s website at www.adviserinfo.sec.gov. The site can be searched by a unique identifying number known as a “CRD number.” MFIM’s CRD number is 111135. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved.  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Institutional Real Estate, Direct Investments ITEM 2 | Material Changes Mesirow Financial Investment management, Inc. (“MFIM”) Form ADV Part 2A, currently dated June 24, 2025, as amended from time to time, is MFIM’s client disclosure document prepared based on the Securities and Exchange Commission’s regulatory requirements. MFIM is required to update this document at least annually, or when an event occurs that may be deemed to have a material impact on MFIM’s Institutional Real Estate, Direct Investments and related investment management business and/or on its clients. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 2  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Institutional Real Estate, Direct Investments ITEM 3 | Table of Contents ITEM 1 | Cover ...................................................................................................................................... 1 ITEM 2 | Material Changes ................................................................................................................... 2 ITEM 3 | Table of Contents ................................................................................................................... 3 ITEM 4 | Advisory Business .................................................................................................................. 4 ITEM 5 | Fees and Compensation ........................................................................................................ 4 ITEM 6 | Performance-Based Fees and Side-By-Side Management .................................................... 6 ITEM 7 | Types of Clients ...................................................................................................................... 7 ITEM 8 | Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 7 ITEM 9 | Disciplinary Information .......................................................................................................... 7 ITEM 10 | Other Financial Industry Activities and Affiliations ................................................................ 7 ITEM 11 | Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......... 8 ITEM 12 | Brokerage Trading Practices .............................................................................................. 10 ITEM 13 | Review of Accounts ............................................................................................................ 10 ITEM 14 | Client Referrals and Other Compensation .......................................................................... 10 ITEM 15 | Custody .............................................................................................................................. 10 ITEM 16 | Investment Discretion ......................................................................................................... 11 ITEM 17 | Voting Client Securities ...................................................................................................... 11 ITEM 18 | Financial Information .......................................................................................................... 11 Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 3  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Institutional Real Estate, Direct Investments ITEM 4 | Advisory Business Mesirow Financial Investment Management, Inc. (“MFIM”), an Illinois corporation formed in 1986, is an investment advisor registered with the SEC with its principal place of business located in Illinois. MFIM does not provide tax or legal advice. Clients should consult with an expert on matters pertaining to tax or legal issues. MFIM’s sole shareholder is Mesirow Financial Services, Inc., a wholly-owned subsidiary of Mesirow Financial Holdings, Inc. (“MFHI” or “Firm”). Mesirow Financial Institutional Real Estate, Direct Investments’ (“MIRED”) division offers investment advisory services and products to clients relating to MIRED investments on a discretionary basis. MIRED provides institutional investors with access to direct investment opportunities in the real estate market structured as limited partnerships. Mesirow Financial REVF II-GP, LLC, Mesirow Financial REVF III- GP, LLC, and Mesirow Financial REVF IV-GP, LLC, each an affiliate of MFIM, serve as the general partner to Mesirow Financial Real Estate Value Fund II, L.P., Mesirow Financial Real Estate Value Fund III, L.P., and Mesirow Financial Real Estate Value Fund IV, L.P., respectively (collectively, the “Funds”). The Funds are institutional real estate value-added funds structured as Delaware limited partnerships. MFIM serves as an investment advisor to the value- added funds. The value-added funds are diverse real estate funds targeting domestic U.S. investments, primarily in the multi-family sector. The general partner is responsible for sourcing, acquiring, managing, financing, developing, selling, repositioning, re-tenanting commercial real estate assets that meet the fund’s investment strategy and objectives. The Funds can utilize one or more parallel funds or feeder funds to accommodate investors with special legal, regulatory, tax or other needs. The parallel funds, if any, will invest with the Funds on a side-by-side basis and will be treated as part of the Funds. The feeder funds, if any, will invest in the Funds, giving their investors an indirect interest in the Funds. At the general partner’s discretion, the Funds can hold REIT qualifying assets through a real estate investment trust (the “REIT Subsidiary”). MFIM, or an affiliate entity, serves as general partner to a number of other private investment vehicles structured as limited partnerships. MFIM, or an affiliate, serves as investment advisor to those limited partnerships. As of March 31, 2025, MIRED managed approximately $3.14 billion in client assets on a discretionary basis and $0 on a non-discretionary basis. ITEM 5 | Fees and Compensation The general fee structure for MFIM’s MIRED division is as follows: MESIROW FINANCIAL REAL ESTATE VALUE FUND II, L.P.* Effective January 1, 2025, the General Partner of Mesirow Financial Real Estate Value Fund II, L.P. (“Fund II”) has elected to suspend and stop charging an asset management fee to its clients. MESIROW FINANCIAL REAL ESTATE VALUE FUND III, L.P.* Fees Annual asset management fee, paid quarterly in arrears, based upon the greater of 1.1% of committed capital or 1.5% of invested capital during the investment period, and then 1.5% of invested capital thereafter, subject to the current basic fee structure as follows: Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 4  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Institutional Real Estate, Direct Investments • 150 basis points per year of invested capital or 110 basis points per year of committed capital on commitments less than $15 million. • 135 basis points per year of invested capital or 100 basis points per year of committed capital on commitments between $15 million and $50 million. • 100 basis points per year of invested capital or 80 basis points per year of committed capital on commitments of $50 million or more. MESIROW FINANCIAL REAL ESTATE VALUE FUND IV, L.P.* Fees Annual asset management fee, paid quarterly in arrears, based upon the greater of 1.1% of committed capital or 1.5% of invested capital during the investment period, and then 1.5% of invested capital thereafter, subject to the current basic fee structure as follows: • 150 basis points per year of invested capital or 110 basis points per year of committed capital on commitments less than $25 million. • 135 basis points per year of invested capital or 100 basis points per year of committed capital on commitments between $25 million and $50 million. • 100 basis points per year of invested capital or 80 basis points per year of committed capital on commitments between $50 million and $75 million. • 85 basis points per year of invested capital or 70 basis points per year of committed capital on commitments of $75 million or more. The fees are generally paid quarterly in arrears. In the event an account terminates, fees will be prorated for the number of days the account was under management. Fees are typically billed to the client or client’s custodian. *Minimum Investment: $5 million subject to General Partner discretion to accept investments from qualified investors below this amount. Limited Negotiability of Advisory Fees Although MIRED has established the aforementioned fee schedule(s), the Firm retains the discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances and needs will be considered in determining the fee schedule. These facts, circumstances and needs include, among other factors, the complexity of the client; assets to be placed under management; anticipated future additional assets; related accounts; portfolio style; account composition; and reporting requirements. The specific annual fee schedule will be identified in the contract between the advisor and each client. Discounts, not generally available to advisory clients, are offered to employees, family members and friends of associated persons of MFIM. Termination of the Advisory Relationship Clients have limited liquidity and termination rights, which is based primarily on obtaining a significant majority of the other investors consent. Essentially, a Limited Partner cannot voluntarily withdraw any amount from the Fund or voluntarily withdraw from the Fund except in limited circumstances. Additional Fees and Expenses Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 5  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Institutional Real Estate, Direct Investments In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians. Clients that invest in MFIM’s private investment vehicles structured as limited partnerships are typically responsible for certain expenses relating to the partnership including, but not limited to, the cost of audits, reporting and certain legal expenses. Grandfathering of Minimum Account Requirements Pre-existing advisory clients are subject to MIRED’s minimum account requirements and advisory fees in effect at the time the client entered into the advisory relationship. Therefore, minimum account requirements differ among clients. ERISA Accounts In certain circumstances, MFIM is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act of 1974 (“ERISA”). As such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include, among other things, restrictions concerning certain forms of compensation. Commissions or Markups In the event that MFIM receives commissions or markups, advisory fees will be reduced to offset the commissions or markups. Advisory Fees in General Clients should note that similar advisory services are available from other registered (or unregistered) investment advisors. Limited Prepayment of Fees Under no circumstances do we require or solicit payment of fees in excess of $1,200 six months or more in advance of services rendered. Educational Events MFIM employees participate in educational events sponsored by service providers to MFIM, such as law firms, audit firms and other professional service firms. ITEM 6 | Performance-Based Fees and Side-By-Side Management MIRED accepts performance-based allocations from clients. Such a performance-based allocation is calculated based on a share of capital gains on or capital appreciation of the invested assets of the client. To qualify for a performance-based allocation arrangement, a client (or Fund investor, as applicable) must either demonstrate a net worth of more than $2,200,000 or must have at least $1,100,000 under management at the time of entering into a management agreement with MIRED. A client should pay particular attention to the fee section in any offering document. Clients should be aware that a performance-based allocation arrangement creates an incentive for MIRED to recommend investments that are riskier or more speculative than those that may be recommended under a different fee arrangement. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 6  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Institutional Real Estate, Direct Investments ITEM 7 | Types of Clients MIRED provides advisory services to qualified purchasers and accredited investors, including, but not limited to: • Pension and profit-sharing plans • Charitable organizations • Corporations or other businesses • State or municipal government entities ITEM 8 | Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS MIRED uses a fundamental analysis to select opportune investments. In order to take advantage of the current market environment, the Funds will emphasize opportunities in the multifamily sector. Investments will also be geographically diverse, using the National Council of Real Estate Investment Fiduciaries’ (NCREIF) geographic weightings (West-35%, Midwest-10%, East-34% and South-21%) as a guideline with a slight bias towards the West Region based upon projected population and job growth trends. ITEM 9 | Disciplinary Information On July 22, 2022, MFIM entered into a settlement with the SEC, the details of which are available here: https://www.sec.gov/litigation/admin.htm. As described in more detail in the Order, the settlement was related primarily to insufficient disclosure related to purchases of non-affiliated mutual fund shares (No Transaction Fee or NTF funds). Specifically, prior to June 2019, the disclosure outlined in MFIM’s Form ADV allegedly did not adequately disclose the receipt of NTF revenue sharing by Mesirow Financial, Inc. (MFI), MFIM’s affiliated broker-dealer, or the conflicts this created for MFIM. Without admitting or denying the underlying findings, MFIM agreed to pay affected investors disgorgement of $487,862 prejudgment interest of $94,972; and pay a civil penalty of $170,000. MFIM subsequently notified affected investors of the settlement terms. ITEM 10 | Other Financial Industry Activities and Affiliations Certain employees of MFIM are separately licensed as registered representatives of Mesirow Financial, Inc. (“MFI”). These individuals, in their separate capacity, can and do at certain times, effect securities transactions for which they will receive separate, yet customary compensation. While MFIM and these individuals endeavor at all times to fulfill their fiduciary responsibilities to clients, clients should be aware that the receipt of additional compensation itself creates a conflict of interest and can affect the judgment of these individuals when making recommendations. The principals of MFIM are principals of the general partner of the funds named above. The general partner has designated MFIM as having primary responsibility for investment management and administrative matters, such as accounting tax and periodic reporting, pertaining to the Fund. MFIM and its members, officers and employees will devote to the funds as much time as it deems necessary and appropriate to manage the business. MFIM and its affiliates are not restricted from forming additional investment funds, entering into other investment advisory relationships or engaging in other business activities, even though such activities can be in competition with the funds. Potentially, such activities could be viewed as creating a conflict of interest in that the time and effort of MFIM management personnel and employees will Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 7  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Institutional Real Estate, Direct Investments not be devoted exclusively to the business of the funds but could be allocated between the business of the funds and other business activities. As noted in Items 4 and 5, MFIM or its affiliates act as a general partner or sponsor of various private investment vehicles that MFIM recommends or sells to its advisory clients. Prior to the sale of any such investments, MFIM will have disclosed any material potential conflicts of interest and will recommend the investment only if it appears suitable for the client. Clients should be aware that the receipt of additional compensation by MFIM and its management persons or employees creates a conflict of interest that potentially impairs the objectivity of MFIM and these individuals when making advisory recommendations. MFIM endeavors at all times to put the interest of its clients first as part of our fiduciary duty as a registered investment advisor. MFIM typically takes the following steps to address and to mitigate any potential conflict: • MFIM discloses to clients the existence of all material conflicts of interest; • MFIM collects, maintains and documents accurate, complete and relevant client background information, including the client’s investment mandates, financial goals, objectives and risk tolerance; • MFIM’s management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable for the client’s needs and circumstances; • MFIM requires that our employees seek prior approval of any outside employment activity to ensure that any conflicts of interests in such activities are properly addressed; • MFIM periodically monitors outside employment activities of its employees to verify that any conflicts of interest continue to be properly addressed; and • MFIM educates its employees regarding the responsibilities of a fiduciary, including the need to have a reasonable and independent basis for the investment advice provided to clients. ITEM 11 | Code of Ethics, Participation or Interest in Client Transactions and Personal Trading MFIM has adopted a Code of Ethics that sets forth the ethical standards of business conduct that MFIM requires of its employees, including compliance with applicable federal securities laws. MFIM and its personnel owe a duty of loyalty, fairness and good faith towards clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code of Ethics. MFIM’s Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by MFIM’s access persons. MFIM also has additional policies and procedures relating to the preclearance of all employee trades (other than securities deemed exempt from this obligation). MFIM’s Code of Ethics also provides for oversight, enforcement and recordkeeping provisions. MFIM’s Code of Ethics further includes policies and procedures governing gifts and entertainment, outside business activities, confidentiality of information and information barriers, and charitable and political contributions. The Code of Ethics also prohibits the misuse of material non-public information and emphasizes the avoidance of conflicts of interest with investors. Each employee must acknowledge the terms of the Code of Ethics on an annual basis. Any employee who violates the Code of Ethics may be subject to possible actions, which may include enhanced supervision, censure, suspension or termination. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 8  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Institutional Real Estate, Direct Investments A copy of the Code of Ethics is available to advisory clients and prospective clients. To request a copy, e- mail maryjo.hayes@mesirow.com, or call 312.595.6512. MFIM is part of a group of affiliated financial services companies that perform a number of different services for a client. MFIM is mindful of the conflicts or potential conflicts that such relationships create. Consequently, MFIM has adopted a Code of Conduct, which prescribes standards of conduct required of all employees, regardless of their position or affiliation in the group. The Code prohibits self-dealing and other improper activities, the misuse of material non-public information, and it emphasizes the avoidance of conflicts of interest with clients. Some specific areas of potential conflict are discussed below. MFIM and/or individuals associated with it can buy or sell for their personal accounts securities identical to, or different from, those recommended to our clients. In addition, any related person(s) can have an interest or position in a certain security that may also be recommended to a client. Accounts owned by MFIM or persons associated with MFIM may participate in aggregated trading with client accounts; however, such accounts will not be given preferential treatment. MFIM, through MFI, may direct the purchase or sale in securities on a principal basis in accordance with Section 206 (3) under the Investment Advisers Act of 1940, as amended. As these situations represent actual or potential conflicts of interest to clients, MFIM has established the following policies and procedures for implementing its Code of Ethics, to ensure our firm complies with its regulatory obligations and provides clients and potential clients with full and fair disclosure of such conflicts of interest: 1. No principal or employee of MFIM can put his or her own interest above the interest of an advisory client. 2. No principal or employee of MFIM can buy or sell securities for their personal portfolio(s) where their decision is due to information received as a result of his or her employment unless the information is also available to the investing public. 3. MFIM requires prior approval for any IPO or private placement investments. 4. MFIM maintains a list of all reportable securities holdings for the firm and anyone associated with this advisory practice that has access to advisory recommendations (“access person”). These holdings are reviewed on a regular basis by the appropriate designated supervisor. 5. MFIM has established procedures for the maintenance of all required books and records. 6. All of MFIM’s principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 7. MFIM requires delivery and acknowledgement of the Code of Ethics by each access person. 8. MFIM has established policies requiring the reporting of Code of Ethics violations to senior management. Any individual who violates any of the above restrictions may be subject to possible actions, which may include enhanced supervision, censure, suspension or termination. Other Participation or Interest in Client Transactions Due to the fact that MFIM is compensated based on AUM, MFIM employees are incentivized to have clients open accounts and to add to assets to new and existing accounts. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 9  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Institutional Real Estate, Direct Investments ITEM 12 | Brokerage Trading Practices MIRED only offers private investments to Qualified Purchasers and Accredited Investors. It does not trade securities or otherwise involve brokers. ITEM 13 | Review of Accounts INVESTMENT SUPERVISORY SERVICES PORTFOLIO MANAGEMENT MIRED ensures that each investor has the appropriate risk tolerance, financial support, investment time horizon and liquidity profile to invest in the funds. MIRED does substantial due diligence on each investment opportunity and each investment is approved by an investment committee, which consists of employees assigned to MIRED and other affiliate’s employees. Reviews While the underlying investments within Individual Portfolio Management Services accounts are continually monitored, these accounts are reviewed at least quarterly. Reports MIRED sends quarterly reports to investors, which includes the various investments in the Fund. Clients are urged to carefully compare the information provided on these statements to any custodial statement the investor receives to ensure that all account transactions, holdings and values are correct and current. ITEM 14 | Client Referrals and Other Compensation CLIENT REFERRALS MFIM does not receive an economic benefit from anyone other than its clients. MFIM and its affiliates may enter into Referral Agreements with a promoter such as a broker-dealer or an investment adviser. MFIM or its affiliates generally pay the promoter a percentage of the management fee and/or performance-based fee collected from the client. Regardless of how it is calculated, any such referral fee will be paid solely from MFIMs’ investment management fee and will not result in any additional charge to the client. See Item 5 for additional information on advisory fees. MFIM has entered into arrangements with unaffiliated third parties for their assistance in referring business to MFIM or providing advice to MFIM with respect to the expansion of the firm’s distribution of products or services in various U.S. and non-U.S. markets and distribution channels. MFIM may pay cash compensation under these arrangements based on a monthly flat fee as well as, in the sole discretion of the firm, a bonus at the conclusion of the arrangements. The fees paid to the unaffiliated third party are not passed on to any introduced clients, but the presence of these arrangements may affect MFIMs’ willingness to negotiate below its standard investment advisory fees and, therefore, may affect the overall fees paid by referred clients. It is MFIM’s policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services we provide to clients. MFIM also compensates affiliated personnel that work in other business units for referrals. ITEM 15 | Custody MIRED is deemed to have custody of client assets under the SEC’s Custody Rule, 206(4)-2, due to the fact that a related person, as defined by the rule, serves as the general partner for MIRED funds. MIRED complies with the Custody Rule requirements by annually sending audited financial statements to its investors. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 10  Part 2A of Form ADV | Firm Brochure Mesirow Financial Investment Management, Inc. | Institutional Real Estate, Direct Investments ITEM 16 | Investment Discretion Clients can engage MFIM to provide discretionary and non-discretionary asset management services. Clients can, in certain circumstances, limit such authority by giving MFIM written instructions. Clients give MFIM discretionary authority when they sign an investment management agreement with MFIM or complete the subscription documents for a fund. ITEM 17 | Voting Client Securities PROXY VOTING POLICIES AND PROCEDURES: Due to the nature of its investment program, the Adviser does not generally trade in individual publicly-traded securities that would require the Adviser to vote traditional proxies. Moreover, Adviser’s general policy is not to accept the authority to vote proxies on behalf of Clients. If the Adviser is asked to vote on a proxy or corporate action, it will make a determination, in its opinion, as to what vote is in the best interest of the Funds and Fund investors (as applicable). The Adviser will maintain a written record of any proxy/corporate action on which it votes. ITEM 18 | Financial Information MFIM has no additional financial circumstances to report. MFIM has not been the subject of a bankruptcy petition at any time during the past ten years. Mesirow refers to Mesirow Financial Holdings, Inc. and its divisions, subsidiaries and affiliates. The Mesirow name and logo are registered service marks of Mesirow Financial Holdings, Inc. © 2025. All rights reserved. 11