ZAIS Group LLC

Item 5 – Fees and Compensation

ZAIS Group earns management fees for funds and separately managed accounts based on (i)
the net asset value of these funds and separately managed accounts before the accrual of
uncrystallized incentive fees or allocations or (ii) drawn capital during the commitment period.
ZAIS Group earns management fees for the Vehicles generally based on the principal value of
the collateral and cash held in the Vehicles.

ZAIS Group typically collects management fees monthly or quarterly, as specified in each
investment management agreement, by (i) preparing a calculation and invoicing its clients of
separately managed accounts and (ii) reviewing and approving the calculation of management
fees prepared by the administrator, in the case of funds. Funds and separately managed
accounts may either prepay their management fees or pay in arrears. Should a management
agreement terminate for any prepaying client before the end of a billing period, a refund will be
calculated, and the refund will be applied to the final accounting for the client.

Senior management fees and subordinated management fees earned from the Vehicles are
calculated by the Vehicle’s Trustee, in accordance with the collateral management agreement,
reviewed and approved by ZAIS and external auditors, and paid to ZAIS Group on the
quarterly waterfall date which is specific to each Vehicle. The subordinated management fee
is an additional payment for the same service as the senior management fees but has a lower
priority in the Vehicles’ cash flows and is contingent upon the economic performance of each
Vehicle. If the Vehicles experience failures in certain tests that require cashflows to be diverted

FORM ADV, PART 2A

from the interest waterfall, these fees may be deferred. If the Vehicle subsequently passes
these tests, the deferred fees may be recovered. There is no recovery by the Vehicles of
previously paid subordinated fees.

The following table presents the range of management fee rates generally charged on the
entities ZAIS manages (“ZAIS Managed Entities”) during the year ended December 31, 2025:

Management Fee Income(1)
Funds and accounts                       0.50% - 1.25%
Vehicles(2)                              0.30% - 0.50%

(1)   Certain management fees have been and may in the future be adjusted or waived;
       therefore, the actual fees may be different from those reflected in the range.
(2)   Includes collateral management fee income. Certain circumstances may arise in which
       clients or investors have fee arrangements that are outside of the stated range.
Where expressly contemplated by the relevant fund offering documents or investment
management agreement, some ZAIS-managed funds and/or accounts will invest in ZAIS-
managed Vehicles, with fees charged at both levels. ZAIS will not charge such dual fees
without appropriate disclosure in the fund offering documents or authorizing provisions in the
investment management agreement.

Expense Allocation
ZAIS limits the expenses that may be charged to clients to conform, first, with each client’s
investment management agreement, collateral management agreement and/or disclosure
documents, as applicable, and second, absent client-specific provisions, with ZAIS’s internal
policy. Allocable expenses generally include:
         Fund (or other vehicle) formation expenses, including related legal counsel fees;
         Product-specific research subscriptions, e.g., Intex, Markit; and
         Independent third-party valuation sources.

Fund clients (or other Vehicles) also pay certain expenses that are directly billed, such as
Administrators, custodians, transaction costs, e.g., brokerage commissions, exchange
transaction fees, margin interest and the like and annual fund audits and tax filing preparation,
to the extent applicable.

Overhead Expenses will not be charged to clients, absent specific authorization, and generally
include:

FORM ADV, PART 2A

      Staff salaries;
      Rent, utilities, office supplies and equipment including corporate information technology;
      General market data services, e.g., Bloomberg;
      Other manager-related operating expenses, e.g., legal (other than fund specific or asset
       specific legal expenses) and consulting expenses, general liability and other insurance
       premiums; and
      Travel and entertainment.

Item 7 – Types of Clients

ZAIS Group provides investment advisory services to pooled private investment funds and
other vehicles, and to private accounts. Investors in the pooled vehicles are accredited and
qualified; separately managed account clients are institutional investors.

Minimum investment amounts for private accounts are negotiated at the time an account is
established, and the initial commitments will depend on the complexity of the separately
managed account. Pooled investment vehicles have minimum investment amounts that are
set out in their offering documents. These amounts are dictated in some cases by the
regulatory authority with jurisdiction over the investment vehicle.

Minimum investments in feeder funds for the pooled vehicles ZAIS currently offers is $5
million. ZAIS reserves the right to waive or modify these minimums, in its sole discretion.
Additionally, eligible ZAIS personnel may invest in a fund in amounts below the stated
minimums.

FORM ADV, PART 2A