Civitas Capital Management LLC

Item 5: Fees and Compensation

We or our affiliates are compensated as described in the governing documents for each Real Estate
Fund we advise. Our compensation typically consists of both (i) an asset-based management fee and
(ii) carried interest based on the performance achieved by the relevant Real Estate Fund. The asset-
based management fees from each Real Estate Fund vary, but typically range from 1% to 3% per
annum and are generally based on the aggregate or unreturned capital contributions of the individual
investors. The share of profits constituting our carried interest from our Loan Funds can be zero,
based on a specified sharing ratio or, with respect to our EB-5 Funds, include all distributions in
excess of a return of capital and a specified preferred return hurdle. Carried interest with respect to
our Equity Funds and Diversified Funds is calculated based on a specified percentage of profit after
certain preferred return thresholds are met (which specified percentages of profit may increase as
one or more additional preferred return hurdles are met).

We deduct all asset-based management fees automatically in accordance with each Real Estate
Fund’s governing documents. The asset-based management fees are generally payable quarterly in
advance and prorated appropriately for partial quarters, but, in some instances may be payable more
or less often. The management fee rate does not vary with size of the capital contribution made by
each individual investor to the applicable Real Estate Fund, although the asset-based management
fees for our Real Estate Funds vary and, with respect to our larger Real Estate Funds, are sometimes
negotiated with such Real Estate Fund’s investors during the fund-raising period of the Real Estate
Fund. For investors admitted after an initial closing of the Real Estate Fund, their allocable portion
of the asset-based management fee is calculated as though such investor was admitted at the initial
fund closing. For our EB-5 Funds, unlike our non-EB-5 Funds where the asset-based management
fee is paid currently and may be paid out of capital contributions, the asset-based management fee is
generally paid out of net cash flow or accumulates until sufficient net cash flow exists to pay the
asset-based management fee. The asset-based management fee may exceed the expenses borne by
our firm on behalf of the applicable Real Estate Fund.

We receive performance-based compensation (carried interest) from our Real Estate Funds when
distributions are made to underlying investors, subject to a distribution waterfall as provided in the
Real Estate Fund’s governing documents. The distribution waterfall is typically structured such that
carried interest is received at the level of the Real Estate Fund (or at the level of a wholly-owned
subsidiary for tax reasons). However, when our Real Estate Funds are participating directly or
indirectly in joint venture arrangements with third parties, we may receive carried interest at the level
of the joint venture, which is often shared by the third-party sponsor. For one Real Estate Fund,
which was formed to co-invest alongside our firm to provide “general partner” capital, we do not
charge any carried interest, as this fund shares in the carried interest generated by the Real Estate
Fund in which it co-invests.

Where the underlying Real Estate Assets consist of a real estate development or project sponsored
by us or our affiliates, we or our affiliates typically receive additional compensation for managing
such development. In such cases, we are compensated based on a percentage of overall development
costs. The project cost-based fees vary but are typically 3-4% of the cost of the project and may be
split with other parties depending on each party’s involvement.

We or our affiliates are generally compensated for the origination, modification or prepayment of
loans made by our Loan Funds. Where these fees are payable by third parties, these fees are
negotiated with the relevant borrowers and typically range from 0.25% to 3.00% of the applicable
loan amount or portion thereof. Where such fees are payable or borne by one or more of our other
Real Estate Funds, such arrangements and the relative amounts of such fees are disclosed in advance

prior to the time the investors in such Real Estate Funds (both the borrower and the relevant Loan
Fund) make their investment.

We or our affiliates may “bridge” investment positions during a syndication process and charge
interest (or similar) to the Real Estate Fund recipient in exchange for providing such temporary
capital. The form of the bridge investment can be debt or equity. The amount of bridge investment
compensation can vary and is disclosed to investors bearing such cost in advance of their
investments. Typically, the stated interest rate or return on equity is between 3% and 12% with a 1%
to 2% origination fee. However, in cases where the bridge investment is provided as equity, while
unexpected, it is possible that our returns will be greater if the underlying investment is disposed of
at a profit in advance of the time the bridge equity is repaid.

We or our affiliates may be compensated for accounting services provided to our Real Estate Funds.
These fees typically range from $1,000 to $1,750m per investor per year for EB-5 Funds, subject to
a minimum annual fee of $12,000 and a maximum annual fee of $84,000 per Real Estate Fund. For
other Real Estate Funds, the fees can be charged as a percentage of the Real Estate Fund’s capital or
calculated on some other basis (e.g., per investor or per year), in each case, as set forth in the relevant
Real Estate Fund’s offering documents.

As consideration for assisting individual investors and their advisors to comply with U.S.
immigration regulations as it relates to investing in our EB-5 Funds, each prospective investor in an
EB-5 Fund is generally required at the time of subscription to pay directly to our firm an
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Item 7: Types of Clients

Our firm manages investment portfolios exclusively for privately offered Real Estate Funds
investing in Real Estate Assets, some of which are private funds, and currently expects this to
continue to be our primary business. The Real Estate Funds are structured as limited partnerships or
limited liability companies that do not fall into the definition of, or are each exempt from registration
as, an “investment company” under U.S. law (in the latter case, by virtue of Section 3(c)(1), 3(c)(5)
and/or Section 3(c)(7) of the Investment Company Act).

Investors in these funds include a variety of investors, such as high net worth individuals and their
associated holding vehicles as well as institutional investors such as trusts, corporations and other
types of entities, including private funds of funds. All investors must satisfy the investor qualification
requirements set forth in the applicable fund governing documents in order to satisfy applicable
securities laws.