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David Wachter

Director at SLR Investment
Board

About David S. Wachter

Independent director of SLR Investment Corp. (SLRC); age 61; Class I director since 2007, with term expiring in 2025 and nominated for re‑election to a three‑year term expiring in 2028 . CEO and founder of W Capital Partners (private equity GP solutions secondary investor) since 2001; prior 15 years as an investment banker; as of 2024 W Capital is a division of AXA IM; Wachter is not an “interested person” under the 1940 Act . Oversees four portfolios across the SLRC fund complex; recognized for extensive private equity and investment banking expertise valuable to SLRC’s board .

Past Roles

OrganizationRoleTenureCommittees/Impact
W Capital PartnersCEO & Founder2001–present Specialist GP solutions secondary investor; firm became a division of AXA IM in 2024
Investment Banking (prior career)Banker~15 years prior to 2001 Capital markets and advisory experience
SLR Senior Investment Corp.Director (prior)2011–Apr 2022 Prior BDC board service within SLR fund complex

External Roles

OrganizationRoleTenureNotes
SCP Private Credit Income BDC LLC (Fund Complex)DirectorSince 2018 Unlisted BDC advised by SLR Capital Partners
SLR HC BDC LLC (Fund Complex)DirectorSince 2020 Unlisted BDC focused on healthcare credit
SLR Private Credit BDC II LLC (Fund Complex)DirectorSince 2022 Unlisted BDC focused on first‑lien senior loans
Other public company boards (non‑Fund Complex)None disclosedWachter’s disclosed directorships are within the SLR fund complex; no external public boards listed

Board Governance

  • Committees: Member of Audit, Compensation, and Nominating & Corporate Governance Committees; Chairman of the Nominating & Corporate Governance Committee .
  • Independence: Board annually reviews independence; Wachter is independent and not an “interested person” under NASDAQ rules and Section 2(a)(19) of the 1940 Act .
  • Attendance & Engagement: In 2024, SLRC held 5 board meetings, 5 Audit Committee meetings, 1 Nominating & Corporate Governance meeting, and 1 Compensation Committee meeting; all directors attended at least 75% of the aggregate meetings of the board and their committees; two directors attended the 2024 annual meeting virtually .
  • Risk Oversight: Board conducts risk oversight via the three independent director‑only committees and compliance oversight by the Chief Compliance Officer, including an annual CCO report and executive sessions with independent directors; oversight includes cybersecurity and third‑party IT provider monitoring .
  • Leadership Structure: Chairman is an interested director (Michael S. Gross); the board does not have a designated lead independent director but mitigates conflicts via executive sessions and independent committees .

Fixed Compensation

ComponentAmount (USD)Basis
Base annual fee$100,000 Independent director base fee
Board meeting fees$12,5005 board meetings × $2,500 per meeting in 2024
Committee meeting fees$7,0007 committee meetings × $1,000 per meeting in 2024 (5 Audit, 1 Nominating, 1 Compensation)
Committee chair fee$2,500Nominating & Corporate Governance Committee chair stipend
Total compensation from SLRC (2024)$122,000 Reported total aligns with fee schedule and 2024 meeting count
Total compensation from Fund Complex (2024)$197,000 Includes other BDCs in fund complex

Notes: Independent directors may elect to receive fees in SLRC common stock at the greater of NAV or market price; no shares were issued in lieu of cash to independent directors in 2024 . SLRC does not maintain director stock/option plans, non‑equity incentive plans, or pensions for directors .

Performance Compensation

Performance‑linked elementStatus
Equity awards (RSUs/PSUs/options)Not granted to directors; no stock/option plans for directors
Bonus/short‑term incentivesNot applicable to directors
Performance metrics (TSR, EBITDA, ESG)Not applicable to directors
Clawbacks/COC/severance for directorsNot disclosed; director compensation is fee‑based

Other Directorships & Interlocks

CompanyTypeRolePotential Interlock/Conflict Considerations
SLR Senior Investment Corp.Public BDC (prior)Director (2011–Apr 2022) Within SLR fund complex; adviser/administrator relationships centralize governance; co‑investment exemptive order governs allocations
SCP Private Credit Income BDC LLCUnlisted BDCDirector Same adviser (SLR Capital Partners); overlapping governance/fees
SLR HC BDC LLCUnlisted BDCDirector Same adviser (SLR Capital Partners); healthcare focus
SLR Private Credit BDC II LLCUnlisted BDCDirector Same adviser (SLR Capital Partners); upper middle market focus

Expertise & Qualifications

  • Extensive private equity secondary/GP solutions expertise and 15 years of investment banking experience; provides seasoned financial management insight to SLRC’s board .
  • Active participation on Audit, Compensation, and Nominating committees; chairs the Nominating & Corporate Governance Committee, contributing to board composition and governance principles .
  • Oversees four portfolios in the fund complex, supporting cross‑BDC governance continuity .

Equity Ownership

MetricValue
Shares beneficially owned53,494 shares
Shares outstanding (Record Date)54,554,634 shares
Ownership % of shares outstanding~0.098% (53,494 ÷ 54,554,634)
Dollar range of SLRC equity ownedOver $100,000
Dollar range of equity in Fund ComplexOver $100,000 (no beneficial ownership in unlisted BDCs)

Section 16 compliance: All Section 16(a) filings were timely for 2024 except one late Form 4 for Andrea C. Roberts; no late filings disclosed for Wachter .

Governance Assessment

  • Strengths:

    • Independent director with deep private equity and banking expertise; chairs Nominating & Corporate Governance Committee, supporting board refreshment and governance standards .
    • Active committee engagement across Audit and Compensation; independent committees perform core risk oversight functions, including valuation, governance principles, and advisory/administration agreements .
    • Clear disclosure of director fee schedule and meeting activity; Wachter’s 2024 compensation reconciles to base, meeting fees, and chair stipend, suggesting consistent engagement .
  • Potential conflicts and mitigants:

    • SLRC is externally managed by SLR Capital Partners; co‑investment and allocation decisions across affiliated vehicles can create conflicts, mitigated by an SEC exemptive order and allocation policies, but decisions remain at the adviser’s discretion .
    • Advisory and administration fee relationships with SLR Capital Partners/SLR Capital Management create inherent conflicts; board re‑approves the Advisory Agreement annually with independent director majority and considers fees, performance, and alternatives .
  • Risk indicators and red flags:

    • No designated lead independent director while the chair is an “interested person”; this structure may dilute independent oversight despite mitigations via executive sessions and committee independence (RED FLAG) .
    • Joint Code does not expressly prohibit hedging transactions; independent directors are exempt from pre‑clearance, potentially weakening alignment (RED FLAG) .
    • Broad adviser‑affiliated ecosystem (multiple BDCs) raises persistent related‑party exposure; reliance on exemptive order and policies is necessary but not foolproof (RED FLAG) .
  • Ownership alignment:

    • Wachter holds 53,494 shares (~0.098% of outstanding), dollar range “Over $100,000,” providing some alignment, though director equity is not structurally emphasized via grants/elective stock fees in 2024 .

Implications: Governance quality for Wachter reflects strong committee leadership and independence; key investor watch‑items remain SLRC’s leadership structure (no lead independent), the permissive hedging policy, and adviser‑related conflicts requiring ongoing scrutiny of committee rigor and annual advisory agreement review outcomes .