BrightSpire Capital Inc

During the three months ended June 30, 2024, no director or officer of the Company adopted or terminated a “Rule 10b5-1 trading arrangement” or “non-Rule 10b5-1 trading arrangement,” as each term is defined in Item 408(a) of Regulation S-K.

On July 29, 2024, in an effort to preserve cash in the current operating environment and to further align the interests of the Company’s named executive officers and shareholders, each of the Company’s named executive officers entered into a voluntary waiver (the “Waiver”) of a percentage of their cash incentive compensation opportunity which may be earned pursuant to the 2024 BrightSpire Annual Incentive Plan (the “2024 AIP”).

Pursuant to the terms of the Waivers, each named executive officer agreed to receive the portion of their cash incentive compensation earned under the 2024 AIP that exceeds 70%, or in the case of the Chief Executive Officer, 60%, of their respective 2024 annual cash incentive award targets, in fully vested shares of the Company’s class A common stock (the “2024 AIP Grant Shares”). The number of 2024 AIP Grant Shares to be issued will be based on the closing price of the Company’s class A common stock on the trading date immediately preceding the payment date for the cash incentive compensation earned pursuant to the 2024 AIP.

The foregoing summary of the Waivers does not purport to be complete and is qualified in its entirety by reference to the complete text of the Waivers, a form of which is included as Exhibit 10.1 to this Quarterly Report on Form 10-Q and is incorporated by reference herein.