SPOHLER BRUCE J 4

What Happened

• Bruce J. Spohler (Co‑Chief Executive Officer, Chief Operating Officer and Director) was involved in RSU transactions for SLR Investment Corp. on March 13, 2026. The SCP Plan administrators (Messrs. Spohler and Gross) elected to cash‑settle 354,511.3826 restricted stock units (RSUs) previously granted to employees (the filing shows $0.00 per share for the derivative entries; the cash value was paid to employees but the Form 4 reports the settlement as a deemed acquisition/disposition). Separately, 466,378.4286 new RSUs were granted to certain employees (vesting 50% on the later of March 1, 2028 or the next trading window, and 50% on the later of March 1, 2029 or the next trading window). Additionally, 10,986.5968 RSUs held by the SCP Plan expired without value. The filing notes no new shares were actually issued as a result of the cash settlement and the total reported beneficial ownership remains 3,827,977 shares.

Key Details

• Transaction date: March 13, 2026; Form 4 filed March 17, 2026 (filed within the 2 business‑day window).
• Cash‑settled RSUs: 354,511.3826 RSUs (settled in cash to employees; may be treated as a deemed acquisition for Section 16 purposes).
• New RSU grant: 466,378.4286 RSUs granted to SCP Plan participants; vesting 50% in 2028 and 50% in 2029 (or upon open trading windows).
• Expired RSUs: 10,986.5968 RSUs terminated without value.
• Shares reported after transaction: 3,827,977 beneficially owned (per filing/footnote — reflects no net new shares issued from the cash settlement).
• Notable footnotes: SCP Plan is controlled by SLR Capital Partners; Messrs. Spohler and Gross may be deemed to beneficially own shares held by the Plan by virtue of that control but disclaims beneficial ownership except for pecuniary interest (see footnotes F1–F9).
• Filing timeliness: Timely (transaction Mar 13; Form 4 filed Mar 17).

Context:

• These were plan RSU actions (administrative settlements and grants), not an open‑market personal buy or sale by Mr. Spohler. Cash settlement of RSUs means employees received cash instead of shares; the administrators’ election can create bookkeeping entries that are treated as deemed acquisitions/dispositions for Section 16 reporting even though no new shares were issued. Such administrative or plan‑level transactions do not necessarily signal the insider’s personal trading intent.