Exemption Application under Investment Company Act (Form 40-APP)

File No. 812-

U.S. SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

In the Matter of the Application of:

BC PARTNERS LENDING CORPORATION, BCP INVESTMENT CORPORATION, BCP SPECIAL OPPORTUNITIES FUND II LP, ALTERNATIVE CREDIT INCOME FUND, OPPORTUNISTIC CREDIT INTERVAL FUND, MOUNT LOGAN CAPITAL INC., BC PARTNERS ADVISORS L.P., SIERRA CREST INVESTMENT MANAGEMENT LLC, MOUNT LOGAN MANAGEMENT, LLC, BCP SPECIAL OPPORTUNITIES FUND II EUR HOLDINGS LP, BCP SPECIAL OPPORTUNITIES FUND II HOLDINGS LP, BCP SPECIAL OPPORTUNITIES FUND II ORIGINATIONS LP, BCP SPECIAL OPPORTUNITIES FUND III HOLDINGS LP, GARRISON MML CLO 2019-1 LLC, GREAT LAKES SENIOR MLC I LLC, MOUNT LOGAN FUNDING 2018-1 LP, MOUNT LOGAN MML CLO 2019-1 LP, ABILITY INSURANCE COMPANY, BLUE SKY CREDIT FUND LP, GREAT LAKES BCPL FUNDING LTD., BCPL SUB HOLDINGS LLC, KOHLBERG CAPITAL FUNDING LLC I, PTMN SUB HOLDINGS LLC, GARRISON CAPITAL EQUITY HOLDINGS II LLC, GARRISON CAPITAL EQUITY HOLDINGS VIII LLC, GARRISON CAPITAL EQUITY HOLDINGS XI LLC, GIG ROOSTER HOLDINGS I LLC, KCAP FREEDOM 3, LLC, HCAP EQUITY HOLDINGS, LLC, CPTA MASTER BLOCKER, INC., CAPITALA BUSINESS LENDING, LLC, ACIF MASTER BLOCKER, LLC, CIF INVESTMENTS LLC, SOFIX MASTER BLOCKER, LLC, GREAT LAKES KCAP FUNDING I, LLC, GREAT LAKES FUNDING II LLC, GREAT LAKES PORTMAN RIDGE FUNDING I, LLC, RUNWAY GROWTH FINANCE CORP., RUNWAY GROWTH FINANCE L.P., RUNWAY GROWTH CAPITAL LLC, RUNWAY GROWTH FINANCE OPPORTUNITIES FUND I LP, CORNHUSKER FUNDING 1A LLC, CORNHUSKER FUNDING 1B LLC, CORNHUSKER FUNDING 1C LLC, SPARROWHAWK RE SPC

650 Madison Avenue

New York, New York 10022

(212) 891-2880

APPLICATION FOR AN ORDER PURSUANT TO SECTIONS 17(d) AND 57(i) OF THE INVESTMENT COMPANY ACT OF 1940 AND RULE 17d-1 UNDER THE INVESTMENT COMPANY ACT OF 1940 PERMITTING CERTAIN JOINT TRANSACTIONS OTHERWISE PROHIBITED BY SECTIONS 17(d) AND 57(a)(4) OF AND RULE 17d-1 UNDER THE INVESTMENT COMPANY ACT OF 1940

All Communications, Notices and Orders to:

Ted Goldthorpe

BC Partners Lending Corporation

650 Madison Avenue

New York, New York 10022

(212) 891-2880

Copies to:

September 12, 2025

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UNITED STATES OF AMERICA

BEFORE THE

SECURITIES AND EXCHANGE COMMISSION

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The following entities hereby request an order (the "Order") of the U.S. Securities and Exchange Commission (the "SEC" or "Commission") under Sections 17(d) and 57(i) of the Investment Company Act of 1940, as amended (the "1940 Act"),¹ and Rule 17d-1, permitting certain joint transactions otherwise prohibited by Sections 17(d) and 57(a)(4) of the 1940 Act and Rule 17d-1 thereunder. The Order would supersede the exemptive order issued by the Commission on April 10, 2023 (the "Prior Order")² that was granted pursuant to Sections 17(d) and 57(i) and Rule 17d-1, with the result that no person will continue to rely on the Prior Order if the Order is granted.

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The relief requested in this application for the Order (the "Application") would allow a Regulated Fund⁵ and one or more Affiliated Entitie⁶to engage in Co-Investment Transactions⁷ subject to the terms and conditions described herein. The Regulated Funds and Affiliated Entities that participate in a Co-Investment

The term Regulated Fund also includes (a) any Wholly-Owned Investment Sub (as defined below) of a Regulated Fund, (b) any Joint Venture (as defined below) of a Regulated Fund, and (c) any BDC Downstream Fund (as defined below) of a Regulated Fund that is a business development company. "Wholly-Owned Investment Sub" means an entity: (a) that is a "wholly-owned subsidiary" (as defined in Section 2(a)(43) of the 1940 Act) of a Regulated Fund; (b) whose sole business purpose is to hold one or more investments and which may issue debt on behalf or in lieu of such Regulated Fund; and (c) is not a registered investment company or a business development company. "Joint Venture" means an unconsolidated joint venture subsidiary of a Regulated Fund, in which all portfolio decisions, and generally all other decisions in respect of such joint venture, must be approved by an investment committee consisting of representatives of the Regulated Fund and the unaffiliated joint venture partner (with approval from a representative of each required). "BDC Downstream Fund" means an entity (a) directly or indirectly controlled by a Regulated Fund that is a business development company, (b) that is not controlled by any person other than the Regulated Fund (except a person that indirectly controls the entity solely because it controls the Regulated Fund), (c) that would be an investment company but for Section 3(c)(1) or 3(c)(7) of the 1940 Act, (d) whose investment adviser is an Adviser and (e) that is not a Wholly-Owned Investment Sub.

In the case of a Wholly-Owned Investment Sub that does not have a chief compliance officer or a Board, the chief compliance officer and Board of the Regulated Fund that controls the Wholly-Owned Investment Sub will be deemed to serve those roles for the Wholly-Owned Investment Sub. In the case of a Joint Venture or a BDC Downstream Fund (as applicable) that does not have a chief compliance officer or a Board, the chief compliance officer of the Regulated Fund will be deemed to be the Joint Venture's or BDC Downstream Fund's chief compliance officer, and the Joint Venture's or BDC Downstream Fund's investment committee will be deemed to be the Joint Venture's or BDC Downstream Fund's Board.

To the extent that an entity described in clause (b) is not advised by an Adviser, such entity shall be deemed to be an Adviser for purposes of the conditions.

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Transaction are collectively referred to herein as "Participants."⁸ The Applicants do not seek relief for transactions effected consistent with Commission staff no-action positions.⁹

BCPL was formed on December 22, 2017 as a corporation under the laws of the State of Maryland and commenced operations on October 2, 2019. BCPL is a closed-end management investment company that has elected to be regulated as a BDC under the 1940 Act. BCPL intends to qualify annually as a regulated investment company under Sub-Chapter M of the Internal Revenue Code of 1986, as amended. BCPL's principal place of business is 650 Madison Avenue, 3rd Floor, New York, New York 10022.

BCPL's investment objective is to generate current income and, to a lesser extent, capital appreciation. BCPL has a four-member board, of which three members are not "interested persons" of the BCPL within the meaning of Section 2(a)(19) of the 1940 Act.¹⁰

BCIC was formed as a Delaware limited liability company on August 8, 2006 and, prior to the issuance of shares of BCIC's common stock in its initial public offering, converted to a corporation incorporated in Delaware on December 11, 2006. BCIC is an externally managed, non-diversified, closed-end management investment company that has elected to be regulated as a BDC under the 1940 Act. BCIC intends to qualify annually as a regulated investment company under Sub-Chapter M of the Internal Revenue Code of 1986, as amended. BCIC's principal place of business is 650 Madison Avenue, 3rd Floor, New York, New York 10022.

BCIC's investment objective is to generate current income and capital appreciation by lending directly to privately-held middle market companies. BCIC has a nine-member board, of which seven are not "interested persons" of BCIC within the meaning of Section 2(a)(19) of the 1940 Act.

ACIF was organized as a Delaware statutory trust on December 11, 2014 and commenced operations on April 20, 2015. ACIF is a continuously offered, diversified, closed-end management investment company that is operated as an interval fund. ACIF intends to qualify annually as a regulated investment company under Sub-Chapter M of the Internal Revenue Code of 1986, as amended. ACIF's principal place of business is 650 Madison Avenue, 3rd Floor, New York, New York 10022.

ACIF's investment objectives are to produce current income and achieve capital preservation with moderate volatility and low to moderate correlation to the broader equity markets. ACIF has a four-member board, of which three are not "interested persons" of ACIF within the meaning of Section 2(a)(19) of the 1940 Act.

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OCIF was organized as a Delaware statutory trust on January 21, 2022 and commenced operations on July 5, 2022. OCIF is a continuously offered, non-diversified, closed-end management investment company that is operated as an interval fund. OCIF intends to qualify annually as a regulated investment company under Sub-Chapter M of the Internal Revenue Code of 1986, as amended. OCIF's principal place of business is 650 Madison Avenue, 3rd Floor, New York, New York 10022.

OCIF's investment objectives are to produce current income and capital appreciation. OCIF has a four-member board, of which three are not "interested persons" of OCIF within the meaning of Section 2(a)(19) of the 1940 Act.

RWAY was organized as a Maryland corporation on August 31, 2015 and is a non-diversified, closed-end management investment company that has elected to be regulated as a BDC under the 1940 Act. RWAY intends to qualify annually as a regulated investment company under Sub-Chapter M of the Internal Revenue Code of 1986, as amended. RWAY's principal place of business is 205 N. Michigan Ave., Suite 4200 Chicago, Illinois 60601.

RWAY's investment objective is to maximize the total return to its stockholders primarily through current income on its loan portfolio, and secondarily through capital gains on its warrants and other equity positions. RWAY has an eight-member board, of which six are not "interested persons" of RWAY within the meaning of Section 2(a)(19) of the 1940 Act.

BCPA, a Delaware limited partnership formed on March 29, 2017 and an investment adviser registered with the Commission under the Advisers Act, serves as investment adviser to BCPL pursuant to an investment advisory agreement with such entity.

Sierra Crest, a Delaware limited liability company formed on December 4, 2019 and an investment adviser registered with the Commission under the Advisers Act, is an affiliate of BCPA and serves as investment adviser to BCIC and ACIF, in each case, pursuant to an investment advisory agreement with such entity.

RGC, a Delaware limited liability company organized in 2015 and an investment adviser registered with the Commission under the Advisers Act, serves as investment adviser to RWAY pursuant to an investment advisory agreement with such entity.

MLM, a Delaware limited liability company organized in 2020 and registered with the Commission under the Advisers Act, is a wholly-owned subsidiary of MLC and serves as investment adviser to OCIF, to certain Existing Affiliated Funds and an Existing Proprietary Account pursuant to investment advisory agreements.

Pursuant to a servicing agreement, BC Partners LLP ("BC Partners") provides MLM with various resources and services. The individuals who handle investment management operations for MLM are the same individuals who serve in similar roles for BCPA and Sierra Crest. BC Partners owns controlling interests in BCPA and Sierra Crest, and an investment fund affiliated with BCPA owns controlling interests in RGC.

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Under the terms of an investment advisory agreement with each Existing Regulated Fund and each Existing Affiliated Fund, respectively, BCPA, Sierra Crest, MLM and RGC will, among other things, manage the investment portfolio, direct purchases and sales of portfolio securities and report thereon to each Existing Regulated Fund's and the Existing Affiliated Fund's officers and directors/managers/trustees regularly.

Each of the Existing Wholly-Owned Subsidiaries is a direct or indirect wholly-owned subsidiary of an Existing Regulated Fund whose sole business purpose is to hold one or more investments on behalf of such Existing Regulated Fund. Each Existing Wholly-Owned Subsidiary is a separate and distinct legal entity. The Existing Wholly-Owned Subsidiaries have investment objectives and strategies that are substantially the same as, or a subset of, those of the applicable Existing Regulated Fund. A list of the Existing Wholly-Owned Subsidiaries is included on Schedule A hereto.

Each of the Existing Joint Ventures is an unconsolidated joint venture subsidiary of an Existing Regulated Fund, in which all portfolio decisions, and generally all other decisions in respect of such joint venture, must be approved by an investment committee consisting of representatives of the respective Regulated Fund and the unaffiliated joint venture partner (with approval from a representative of each required). A list of the Existing Joint Ventures is included on Schedule A hereto.

The Existing Proprietary Accounts will, from time to time, hold various financial assets in a principal capacity. The Existing Proprietary Accounts are included on Schedule B hereto.

The Existing Affiliated Funds are investment funds each of whose investment adviser is an Existing Adviser and each of which would be an "investment company" (a) but for Section 3(c)(1), 3(c)(5)(C) or 3(c)(7) of the 1940 Act or (b) relies on Rule 3a-7 under the 1940 Act.¹¹ A list of the Existing Affiliated Funds and their respective investment advisers is included on Schedule C hereto.

The Applicants request an Order of the Commission under Sections 17(d) and 57(i) of the 1940 Act and Rule 17d-1 thereunder to permit, subject to the terms and conditions set forth below in this Application (the "Conditions"), each Regulated Fund to be able to participate with one or more Affiliated Entities in Co-Investment Transactions otherwise prohibited by Sections 17(d) and 57(a)(4) of the 1940 Act and Rule 17d-1 thereunder.

Section 17(d), in relevant part, prohibits an affiliated person, or an affiliated person of such affiliated person, of a registered investment company, acting as principal, from effecting any transaction in which the registered investment company is "a joint or a joint and several participant with such person" in contravention of such rules as the Commission may prescribe "for the purpose of limiting or preventing participation by such [fund] on a basis different from or less advantageous than that of such other participant."

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Rule 17d-1 prohibits an affiliated person, or an affiliated person of such affiliated person, of a registered investment company, acting as principal, from participating in, or effecting any transaction in connection with, any "joint enterprise or other joint arrangement or profit-sharing plan"¹² in which the fund is a participant without first obtaining an order from the Commission.

Section 57(a)(4), in relevant part, prohibits any person related to a business development company in the manner described in Section 57(b), acting as principal, from knowingly effecting any transaction in which the business development company is a joint or a joint and several participant with such persons in contravention of such rules as the Commission may prescribe for the purpose of limiting or preventing participation by the business development company on a basis less advantageous than that of such person. Section 57(i) provides that, until the Commission prescribes rules under Section 57(a), the Commission's rules under Section 17(d) applicable to registered closed-end investment companies will be deemed to apply to persons subject to the prohibitions of Section 57(a). Because the Commission has not adopted any rules under Section 57(a), Rule 17d-1 applies to persons subject to the prohibitions of Section 57(a).

Rule 17d-1(b) provides, in relevant part, that in passing upon applications under the rule, the Commission will consider whether the participation of a registered investment company in a joint enterprise, joint arrangement or profit-sharing plan on the basis proposed is consistent with the provisions, policies and purposes of the 1940 Act and the extent to which such participation is on a basis different from or less advantageous than that of other participants.

Each Regulated Fund may be deemed to be an affiliated person of each other Regulated Fund within the meaning of Section 2(a)(3) if it is deemed to be under common control because an Adviser is or will be either the investment adviser or sub-adviser to each Regulated Fund. Section 17(d) and Section 57(b) apply to any investment adviser to a closed-end fund or a business development company, respectively, including a sub-adviser. Thus, an Adviser and any Affiliated Entities that it advises could be deemed to be persons related to Regulated Funds in a manner described by Sections 17(d) and 57(b). The Existing Advisers are under common control, and are thus affiliated persons of each other. Accordingly, with respect to the Existing Advisers and any other Advisers that are deemed to be affiliated persons of each other, Affiliated Entities advised by any of them could be deemed to be persons related to Regulated Funds (or a company controlled by a Regulated Fund) in a manner described by Sections 17(d) and 57(b). In addition, any entities or accounts controlled by or under common control with the Existing Advisers and/or any other Advisers that are deemed to be affiliated persons of each other that may, from time to time, hold various financial assets in a principal capacity, could be deemed to be persons related to Regulated Funds (or a company controlled by a Regulated Fund) in a manner described by Sections 17(d) and 57(b). Finally, with respect to any Wholly-Owned Investment Sub, Joint Venture, or BDC Downstream Fund of a Regulated Fund, such entity would be a company controlled by its parent Regulated Fund for purposes of Section 57(a)(4) of the 1940 Act and Rule 17d-l under the 1940 Act.

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Applicants agree that any Order granting the requested relief will be subject to the following Conditions.

1. Same Terms. With respect to any Co-Investment Transaction, each Regulated Fund, and Affiliated Entity participating in such transaction will acquire, or dispose of, as the case may be, the same class of securities, at the same time, for the same price and with the same conversion, financial reporting and registration rights, and with substantially the same other terms (provided that the settlement date for an Affiliated Entity may occur up to ten business days after the settlement date for the Regulated Fund, and vice versa). If a Participant, but not all of the Regulated Funds, has the right to nominate a director for election to a portfolio company's board of directors, the right to appoint a board observer or any similar right to participate in the governance or management of a portfolio company, the Board of each Regulated Fund that does not hold this right must be given the opportunity to veto the selection of such person.¹³

2. Existing Investments in the Issuer. Prior to a Regulated Fund acquiring in a Co-Investment Transaction a security of an issuer in which an Affiliated Entity has an existing interest in such issuer, the "required majority," as defined in Section 57(o) of the 1940 Act,¹⁴ of the Regulated Fund ("Required Majority") will take the steps set forth in Section 57(f) of the 1940 Act,¹⁵ unless: (i) the Regulated Fund already holds the same security as each such Affiliated Entity; and (ii) the Regulated Fund and each other Affiliated Entity holding the security is participating in the acquisition in approximate proportion to its then-current holdings.

3. Related Expenses. Any expenses associated with acquiring, holding or disposing of any securities acquired in a Co-Investment Transaction, to the extent not borne by the Adviser(s), will be shared among the Participants in proportion to the relative amounts of the securities being acquired, held or disposed of, as the case may be.¹⁶

4. No Remuneration. Any transaction fee¹⁷ (including break-up, structuring, monitoring or commitment fees but excluding broker's fees contemplated by section 17(e) or 57(k) of the 1940 Act, as applicable), received by an Adviser and/or a Participant in connection with a Co-Investment Transaction will be distributed to the Participants on a pro rata basis based on the amounts they invested or committed,

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as the case may be, in such Co-Investment Transaction. If any transaction fee is to be held by an Adviser pending consummation of the transaction, the fee will be deposited into an account maintained by the Adviser at a bank or banks having the qualifications prescribed in section 26(a)(1) of the 1940 Act, and the account will earn a competitive rate of interest that will also be divided pro rata among the Participants based on the amount they invest in such Co-Investment Transaction. No Affiliated Entity, Regulated Fund, or any of their affiliated persons will accept any compensation, remuneration or financial benefit in connection with a Regulated Fund's participation in a Co-Investment Transaction, except: (i) to the extent permitted by Section 17(e) or 57(k) of the 1940 Act; (ii) as a result of either being a Participant in the Co-Investment Transaction or holding an interest in the securities issued by one of the Participants; or (iii) in the case of an Adviser, investment advisory compensation paid in accordance with investment advisory agreement(s) with the Regulated Fund(s) or Affiliated Entity(ies).

5. Co-Investment Policies. Each Adviser (and each Affiliated Entity that is not advised by an Adviser) will adopt and implement policies and procedures reasonably designed to ensure that: (i) opportunities to participate in Co-Investment Transactions are allocated in a manner that is fair and equitable to every Regulated Fund; and (ii) the Adviser negotiating the Co-Investment Transaction considers the interest in the Transaction of any participating Regulated Fund (the "Co-Investment Policies"). Each Adviser (and each Affiliated Entity that is not advised by an Adviser) will provide its Co-Investment Policies to the Regulated Funds and will notify the Regulated Funds of any material changes thereto.¹⁸

6. Dispositions:

(a) Prior to any Disposition¹⁹ by an Affiliated Entity of a security acquired in a Co-Investment Transaction, the Adviser to each Regulated Fund that participated in the Co-Investment Transaction will be notified and each such Regulated Fund given the opportunity to participate pro rata based on the proportion of its holdings relative to the other Affiliated Entities participating in such Disposition.

(b) Prior to any Disposition by a Regulated Fund of a security acquired in a Co-Investment Transaction, the Required Majority will take the steps set forth in Section 57(f) of the 1940 Act, unless: (i) each Affiliated Entity holding the security participates in the Disposition in approximate proportion to its then-current holding of the security; or (ii) the Disposition is a sale of a Tradable Security.²⁰

7.Board Oversight

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8. Recordkeeping. All information presented to the Board pursuant to the order will be kept for the life of the Regulated Fund and at least two years thereafter, and will be subject to examination by the Commission and its Staff. Each Regulated Fund will maintain the records required by Section 57(f)(3) as if it were a business development company and each of the Co-Investment Transactions were approved by the Required Majority under Section 57(f).²¹

9. In the event that the Commission adopts a rule under the 1940 Act allowing co-investments of the type described in this Application, any relief granted by the Order will expire on the effective date of that rule.

Applicants submit that allowing the Co-Investment Transactions described by this Application is justified on the basis of (i) the potential benefits to the Regulated Funds and their respective shareholders and (ii) the protections found in the terms and conditions set forth in this Application.

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Section 57(a)(4) and Rule 17d-1 (as applicable) limit the ability of the Regulated Funds to participate in attractive co-investment opportunities under certain circumstances. If the relief is granted, the Regulated Funds should: (i) be able to participate in a larger number and greater variety of investments, thereby diversifying their portfolios and providing related risk-limiting benefits; (ii) be able to participate in larger financing opportunities, including those involving issuers with better credit quality, which otherwise might not be available to investors of a Regulated Fund's size; (iii) have greater bargaining power (notably with regard to creditor protection terms and other similar investor rights), more control over the investment and less need to bring in other external investors or structure investments to satisfy the different needs of external investors; (iv) benefit from economies of scale by sharing fixed expenses associated with an investment with the other Participants; and (v) be able to obtain better deal flow from investment bankers and other sources of investments.

Each Co-Investment Transaction would be subject to the terms and conditions of this Application. The Conditions are designed to address the concerns underlying Sections 17(d) and 57(a)(4) and Rule 17d-l by ensuring that participation by a Regulated Fund in any Co-Investment Transaction would not be on a basis different from or less advantageous than that of other Participants. Under Condition 5, each Adviser (and each Affiliated Entity that is not advised by an Adviser) will adopt and implement Co-Investment Policies that are reasonably designed to ensure that (i) opportunities to participate in Co-Investment Transactions are allocated in a manner that is fair and equitable to every Regulated Fund; and (ii) the Adviser negotiating the Co Investment Transaction considers the interest in the Transaction of any participating Regulated Fund. The Co-Investment Policies will require an Adviser to make an independent determination of the appropriateness of a Co-Investment Transaction and the proposed allocation size based on each Participant's specific investment profile and other relevant characteristics.

The Commission has previously issued orders permitting certain investment companies subject to regulation under the 1940 Act and their affiliated persons to be able to participate in Co-Investment Transactions (the "Existing Orders").²² Similar to the Existing Orders, the Conditions described herein are designed to mitigate the possibility for overreaching and to promote fair and equitable treatment of the Regulated Funds. Accordingly, the Applicants submit that the scope of investor protections contemplated by the Conditions are consistent with those found in the Existing Orders.

Please address all communications concerning this Application, the Notice and the Order to:

Ted Goldthorpe

BC Partners Lending Corporation

650 Madison Avenue

New York, New York 10022

(212) 891-2880

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Please address any questions, and a copy of any communications, concerning this Application, the Notice, and the Order to:

The filing of this Application for the Order sought hereby and the taking of all acts reasonably necessary to obtain the relief requested herein was authorized by the Board of each Existing Regulated Fund pursuant to resolutions duly adopted by the Board. Copies of the resolutions are provided below.

Pursuant to Rule 0-2(c), Applicants hereby state that each Existing Regulated Fund and Existing Affiliated Fund have authorized to cause to be prepared and to execute and file with the Commission this Application and any amendment thereto for an order pursuant to Sections 17(d) and 57(i) and Rule 17d-1 permitting certain joint transactions otherwise prohibited by Sections 17(d) and 57(a)(4) and Rule 17d-1. The person executing the Application on behalf of the Applicants being duly sworn deposes and says that he has duly executed the Application for and on behalf of the applicable entity listed; that he is authorized to execute the Application pursuant to the terms of an operating agreement, management agreement or otherwise; and that all actions by members, directors or other bodies necessary to authorize each such deponent to execute and file the Application have been taken.

The Applicants have caused this Application to be duly signed on their behalf on the 12th day of September, 2025.

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VERIFICATION

The undersigned states that they have duly executed the attached Application for an Order under Sections 17(d) and 57(i) of the Investment Company Act of 1940, as amended, and Rule 17d-1 thereunder, dated September 12, 2025 for and on behalf of the Applicants, as the case may be, that they hold the office with each such entity as indicated below, and that all actions by stockholders, officers, directors, and other bodies necessary to authorize the undersigned to execute and file such Application have been taken. The undersigned further states that they are familiar with the instrument and the contents thereof, and that the facts set forth therein are true to the best of their knowledge, information, and belief.

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SCHEDULE A

Existing Wholly-Owned Subsidiaries of BC Partners Lending Corporation:

Great Lakes BCPL Funding Ltd.

BCPL Sub Holdings LLC

Existing Wholly-Owned Subsidiaries of BCP Investment Corporation:

PTMN Sub Holdings LLC

Garrison Capital Equity Holdings II LLC

Garrison Capital Equity Holdings VIII LLC

Garrison Capital Equity Holdings XI LLC

GIG Rooster Holdings I LLC

Great Lakes Portman Ridge Funding I, LLC

HCAP Equity Holdings, LLC

Capitala Business Lending, LLC

CPTA Master Blocker, Inc.

Existing Wholly-Owned Subsidiaries of Alternative Credit Income Fund:

ACIF Master Blocker, LLC

CIF Investments LLC

Existing Wholly-Owned Subsidiaries of Opportunistic Credit Interval Fund:

SOFIX Master Blocker, LLC

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SCHEDULE B

Existing Proprietary Accounts:

Mount Logan Capital, Inc.

Great Lakes Senior MLC I LLC

Ability Insurance Company

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SCHEDULE C

Existing Advisers to Existing Affiliated Entities:

BC Partners Advisors L.P.

Mount Logan Management, LLC

Runway Growth Capital LLC

Sierra Crest Investment Management LLC

Existing Affiliated Entities (except for Existing Proprietary Accounts and Existing Wholly-Owned Subsidiaries):

BCP Special Opportunities Fund II EUR Holdings LP

BCP Special Opportunities Fund II Holdings LP

BCP Special Opportunities Fund II LP

BCP Special Opportunities Fund II Originations LP

BCP Special Opportunities Fund III Holdings LP

Blue Sky Credit Fund LP

Cornhusker Funding 1A LLC

Cornhusker Funding 1B LLC

Cornhusker Funding 1C LLC

Garrison MML CLO 2019-1 LLC

Great Lakes Funding II LLC

Great Lakes KCAP Funding I, LLC

KCAP Freedom 3 LLC

Kohlberg Capital Funding LLC I

Mount Logan Funding 2018-1 LP

Mount Logan MML CLO 2019-1 LP

Runway Growth Finance L.P.

Runway Growth Finance Opportunities Fund I LP

Sparrowhawk RE SPC

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EXHIBIT A

Resolutions of the Board of Directors of BC Partners Lending Corporation (the "Company")

WHEREAS, the Board of Directors deems it advisable and in the best interest of the Company to file with the Securities and Exchange Commission (the "Commission") an application for an Order of Exemption pursuant to Sections 17(d) and 57(i) of the Investment Company Act, as amended (the "1940 Act"), and Rule 17d-1 promulgated thereunder (an "Application"), to authorize the entering into of certain joint transactions and co-investments by the Company with certain entities which may be deemed to be "affiliates" of the Company pursuant to the provisions of the 1940 Act, which such joint transactions and co-investments may otherwise be prohibited by Sections 17(d) and 57(a)(4) of the 1940 Act;

NOW, THEREFORE, BE IT RESOLVED, that the officers of the Company be, and each of them hereby is, authorized and directed on behalf of the Company and in its name to prepare, execute, and cause to be filed with the Commission the Application, and any amendments thereto; and

FURTHER RESOLVED, that the officers of the Company be, and each of them hereby is, authorized and directed to take such further action and execute such other documents as such officer or officers shall deem necessary or advisable in order to effectuate the intent of the foregoing resolution.

Resolutions of the Board of Directors of BCP Investment Corporation (the "Company")

WHEREAS, the Board of Directors deems it advisable and in the best interest of the Company to file with the Securities and Exchange Commission (the "Commission") an application for an Order of Exemption pursuant to Sections 17(d) and 57(i) of the Investment Company Act, as amended (the "1940 Act"), and Rule 17d-1 promulgated thereunder (an "Application"), to authorize the entering into of certain joint transactions and co-investments by the Company with certain entities which may be deemed to be "affiliates" of the Company pursuant to the provisions of the 1940 Act, which such joint transactions and co-investments may otherwise be prohibited by Sections 17(d) and 57(a)(4) of the 1940 Act;

NOW, THEREFORE, BE IT RESOLVED, that the officers of the Company be, and each of them hereby is, authorized and directed on behalf of the Company and in its name to prepare, execute, and cause to be filed with the Commission the Application, and any amendments thereto; and

FURTHER RESOLVED, that the officers of the Company be, and each of them hereby is, authorized and directed to take such further action and execute such other documents as such officer or officers shall deem necessary or advisable in order to effectuate the intent of the foregoing resolution.

Resolutions of the Board of Trustees of Alternative Credit Income Fund (the "Fund")

WHEREAS, the Board of Trustees deems it advisable and in the best interest of the Fund to file with the Securities and Exchange Commission (the "Commission") an application for an Order of Exemption pursuant to Sections 17(d) and 57(i) of the Investment Company Act, as amended (the "1940 Act"), and Rule 17d-1 promulgated thereunder (an "Application"), to authorize the entering into of certain joint transactions and co-investments by the Fund with certain entities which may be deemed to be "affiliates" of the Fund pursuant to the provisions of the 1940 Act, which such joint transactions and co-investments may otherwise be prohibited by Sections 17(d) and 57(a)(4) of the 1940 Act;

NOW, THEREFORE, BE IT RESOLVED, that the officers of the Fund be, and each of them hereby is, authorized and directed on behalf of the Fund and in its name to prepare, execute, and cause to be filed with the Commission the Application, and any amendments thereto; and

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FURTHER RESOLVED, that the officers of the Fund be, and each of them hereby is, authorized and directed to take such further action and execute such other documents as such officer or officers shall deem necessary or advisable in order to effectuate the intent of the foregoing resolution.

Resolutions of the Board of Trustees of Opportunistic Credit Interval Fund (the "Fund")

WHEREAS, the Board of Trustees deems it advisable and in the best interest of the Fund to file with the Securities and Exchange Commission (the "Commission") an application for an Order of Exemption pursuant to Sections 17(d) and 57(i) of the Investment Company Act, as amended (the "1940 Act"), and Rule 17d-1 promulgated thereunder (an "Application"), to authorize the entering into of certain joint transactions and co-investments by the Fund with certain entities which may be deemed to be "affiliates" of the Fund pursuant to the provisions of the 1940 Act, which such joint transactions and co-investments may otherwise be prohibited by Sections 17(d) and 57(a)(4) of the 1940 Act;

NOW, THEREFORE, BE IT RESOLVED, that the officers of the Fund be, and each of them hereby is, authorized and directed on behalf of the Fund and in its name to prepare, execute, and cause to be filed with the Commission the Application, and any amendments thereto; and

FURTHER RESOLVED, that the officers of the Fund be, and each of them hereby is, authorized and directed to take such further action and execute such other documents as such officer or officers shall deem necessary or advisable in order to effectuate the intent of the foregoing resolution.

Resolutions of the Board of Directors of Runway Growth Finance Corp. (the "Company")

WHEREAS, the Board of Directors deems it advisable and in the best interest of the Company to file with the Securities and Exchange Commission (the "Commission") an application for an Order of Exemption pursuant to Sections 17(d) and 57(i) of the Investment Company Act, as amended (the "1940 Act"), and Rule 17d-1 promulgated thereunder (an "Application"), to authorize the entering into of certain joint transactions and co-investments by the Company with certain entities which may be deemed to be "affiliates" of the Company pursuant to the provisions of the 1940 Act, which such joint transactions and co-investments may otherwise be prohibited by Sections 17(d) and 57(a)(4) of the 1940 Act;

NOW, THEREFORE, BE IT RESOLVED, that the officers of the Company be, and each of them hereby is, authorized and directed on behalf of the Company and in its name to prepare, execute, and cause to be filed with the Commission the Application, and any amendments thereto; and

FURTHER RESOLVED, that the officers of the Company be, and each of them hereby is, authorized and directed to take such further action and execute such other documents as such officer or officers shall deem necessary or advisable in order to effectuate the intent of the foregoing resolution.

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