Legal, Privacy & Compliance

Compliance

Last updated: 9 August 2026

Gallantree operates in a regulated environment and is committed to meeting the obligations imposed by US federal and state securities laws and related regimes. This page summarizes the key compliance frameworks we maintain.

Regulatory framework

Gallantree's operations are governed by, among others:

• the US Securities Act of 1933 (including Rule 144A and Regulation D 506(c)) and the Securities Exchange Act of 1934;
• the Investment Advisers Act of 1940 (including the SEC Marketing Rule);
• FINRA rules applicable to broker-dealers (including Rules 2210, 3110, 4511, and 4530);
• the Bank Secrecy Act, the USA PATRIOT Act, and OFAC sanctions programs;
• SEC Regulation S-P (privacy) and Regulation S-ID (identity-theft red flags);
• Reg AB II and Rule 17g-7 disclosure obligations for issuers of asset-backed securities; and
• the California Consumer Privacy Act (CCPA/CPRA) and other applicable US state privacy laws.

Anti-money laundering, BSA, and OFAC

Gallantree has implemented an AML Program in accordance with the Bank Secrecy Act, the USA PATRIOT Act, and applicable FinCEN and FINRA rules. The Program includes a Customer Identification Program (CIP) and Customer Due Diligence (CDD), beneficial-owner identification, sanctions and OFAC screening, transaction monitoring, suspicious activity reporting (SAR / CTR), staff training, and independent testing. Before accepting a new investor, we are required to verify identity and, where relevant, beneficial ownership.

Sanctions

Gallantree complies with US sanctions laws administered by the Office of Foreign Assets Control (OFAC) and, where applicable, sanctions imposed by other jurisdictions. We do not provide services to persons or entities subject to applicable sanctions.

Conflicts of interest

We maintain a Conflicts of Interest Policy and Code of Ethics under the Investment Advisers Act Rule 204A-1 and FINRA supervisory rules. All directors, officers, and employees are required to identify, disclose, and manage actual or potential conflicts. Material conflicts relating to a particular product are disclosed in the offering documents for that product and in Form ADV Part 2A for advisory services.

Related party transactions

Any transaction between a Gallantree fund or program and a related party is undertaken on arm's length terms, is subject to independent review, and is disclosed in the program's reporting in accordance with applicable law and the program's constituent documents.

Whistleblower protections

Gallantree maintains a Whistleblower Policy consistent with Section 21F of the Securities Exchange Act and Rule 21F-17. Eligible whistleblowers can make protected disclosures about misconduct or an improper state of affairs, and are afforded the protections provided by law, including confidentiality of identity and protection from retaliation.

Record keeping and reporting

Gallantree maintains records in accordance with SEA Rule 17a-4 (WORM-compliant retention), FINRA Rule 4511, and Investment Advisers Act Rule 204-2. Regulatory reporting obligations — including FOCUS reports, Form ADV / ADV-E, Form CRS, Form PF, Reg AB II filings, blue-sky notices, and CRD filings — are monitored and met by our Compliance team.

Governance and independent review

Our governance arrangements include a Board with independent oversight, dedicated Risk and Compliance functions, an appointed Chief Compliance Officer for each of Gallantree Securities LLC and Gallantree Advisors LLC, and periodic independent review of our BD / RIA obligations, AML Program, and operational controls. Programs are supported by independent indenture trustees, custodians, administrators, and auditors.

No agency affiliation

Gallantree is not affiliated with, sponsored by, endorsed by, or acting on behalf of Fannie Mae, Freddie Mac, Ginnie Mae, the Federal Housing Finance Agency, the Federal Home Loan Bank system, or any US federal agency or government-sponsored enterprise. Gallantree programs are not guaranteed by any such entity or by the US government.