What changed in this filing

/stocks — the workspaceLOADING

Item 1B. Unresolved Staff Comments

2026-05-05 compared with 2025-05-07 · 30 added, 29 removed, 17 unchanged (78% of the section changed)

1 unchanged sentence

CYBERSECURITY

The Company’s cybersecurity program is designed

to identify, assess, and manage material risks from cybersecurity threats.

The Company relies on Saratoga Investment Advisors to implement

the cybersecurity program.

The cyber risk management program involves risk assessments relating to the information systems of Saratoga

Investment Advisors, incident response training and testing, implementation of security measures, identification of sensitive information

assets (“Critical Information”) and ongoing monitoring of systems and networks and assessment of the associated risks on an

annual basis, including networks on which the Company relies on.

The Chief Compliance Officer, along with the Company’s external

information technology consultant (the “IT Consultant”), actively monitors the current threat landscape in an effort to identify

material risks arising from new and evolving cybersecurity threats.

The Company and Saratoga Investment Advisors have engaged external

experts, including consultants, such as the IT Consultant, to evaluate cybersecurity measures and risk management processes, and depends

on and engages various third parties, including suppliers, vendors, and service providers.

The compliance team of the Company and Saratoga

Investment Advisors will conduct ongoing due diligence of its significant service providers to determine whether the cybersecurity programs

of service providers include, among other things, procedures and safeguards designed to ensure the protection of Critical Information

The Company’s cybersecurity program is

designed to identify, assess, and manage material risks from cybersecurity threats.

The Company relies on Saratoga Investment Advisors

to implement the cybersecurity program.

The cyber risk management program involves risk assessments relating to the information systems

of Saratoga Investment Advisors, incident response training and testing, implementation of security measures, identification of sensitive

information assets (“Critical Information”) and ongoing monitoring of systems and networks and assessment of the associated

risks on an annual basis, including networks on which the Company relies on.

The Chief Compliance Officer, along with the Company’s

external information technology consultant (the “IT Consultant”), actively monitors the current threat landscape in an effort

to identify material risks arising from new and evolving cybersecurity threats.

The Company and Saratoga Investment Advisors have engaged

external experts, including consultants, such as the IT Consultant, to evaluate cybersecurity measures and risk management processes,

and depends on and engages various third parties, including suppliers, vendors, and service providers.

The compliance team of the Company

and Saratoga Investment Advisors will conduct ongoing due diligence of its significant service providers to determine whether the cybersecurity

programs of service providers include, among other things, procedures and safeguards designed to ensure the protection of Critical Information

and the information of the Company’s stockholders and portfolio companies, as well as adequate responses in the case of a cybersecurity

Board Oversight

of Cybersecurity Risks

The Board has the primary responsibility for overseeing

and reviewing the guidelines and policies with respect to the Company’s risk management, including risks associated with cybersecurity

The Chief Compliance Officer will periodically report to the Board on cybersecurity matters, such as the overall state of the

Company’s cybersecurity program, information on the current threat landscape, and risks from cybersecurity threats and material

cybersecurity incidents.

Management’s Role

in Cybersecurity Risk Management

Board Oversight of

Cybersecurity Risks

The Board has the primary responsibility for

overseeing and reviewing the guidelines and policies with respect to the Company’s risk management, including risks associated

with cybersecurity threats.

The Chief Compliance Officer will periodically report to the Board on cybersecurity matters, such as the

overall state of the Company’s cybersecurity program, information on the current threat landscape, and risks from cybersecurity

threats and material cybersecurity incidents.

Role in Cybersecurity Risk Management

The Company’s management is responsible

9 unchanged sentences

results, and financial condition are regularly evaluated.

During the reporting period, the Company has not identified any risks from cybersecurity

threats, including as a result of previous cybersecurity incidents, that the Company believes has materially affected, or are reasonably

likely to materially affect, the Company, including the Company’s business strategy, operational results, and financial condition.

During the reporting period, the Company has not identified any risks from

cybersecurity threats, including as a result of previous cybersecurity incidents, that the Company believes has materially affected,

or are reasonably likely to materially affect, the Company, including the Company’s business strategy, operational results, and

financial condition.

We do not own any real estate or other physical

2 unchanged sentences

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1B. Unresolved Staff Comments