Beach Front, Kazan, and the Rosenwald nexus — findings

This memorandum is reproduced as compiled, including its internal caveats. References to “the user” mean the archive's compiler; characterizations tagged [ASSERTED] are the compiler's, and are expressly not supported by any record cited.

Folder: JBR3_RECORDS_BINDER_20260617/06_BEACHFRONT/ Prepared: 2026-06-17 · primary records pulled via curl (SEC EDGAR) + WebFetch (Wikipedia) Tagging: CONFIRMED = stated in a primary record cited here · PARTIAL = supported but record incomplete / one element unverified · UNCONFIRMED = could not retrieve a record this session · [ASSERTED] = the user's characterization, not (yet) in any record.

Controlling caveat (carry with every use): No record located in this binder shows any familial relationship between Kyle Kazan and any Rosenwald. Every record describes them as business co-founders / related parties. The "basically family" premise is tagged [ASSERTED] throughout.

Q1 — Does RCM / the Rosenwald Family Trust / James or Jocelyn Rosenwald hold an EQUITY/ownership interest in Beach Front (beyond a management role)?

Answer: PARTIAL — YES as to the Rosenwald individuals/founders (they are named co-owners/founders of the Beach Front entities and hold the GH preferred into which Beach Front's note converted); UNCONFIRMED as to the precise RCM-entity equity percentage and the family-trust line, which the available public records describe in relationship terms, not percentages.

What the records actually show:

• RCM discloses Beach Front Properties, LLC as a "Related Person." RCM's Form ADV Part 1A, Schedule D Section 7.A (Financial Industry Affiliations) lists "BEACH FRONT PROPERTIES, LLC" as a related person of Rosenwald Capital Management. → CONFIRMED the affiliation is disclosed. PARTIAL on its nature: pdftotext does not render the Form ADV checkboxes, so Q6 ("Do you control / are you controlled by the related person?") and Q7 ("under common control?") box-states could not be read from the saved PDF — the live IAPD page (adviserinfo.sec.gov, CRD 290118) must be consulted to confirm which boxes are checked.

• Saved: RCM_ADV_ScheduleD_7A_BeachFront_excerpt.txt (excerpt) · original ../01_SEC_ADV/290118_RCM_ADV.pdf.

• Beach Front Properties, LLC is a Rosenwald-co-founded entity. Glass House Brands' own SEC AIF lists the Rosenwalds among the company "Founders," and Wikipedia (corroborative) states Kazan and James B. Rosenwald co-founded Beach Front Properties, LLC in 1997. The James B. Rosenwald Wikipedia entry lists "Beach Front Property Management, Inc." among his private directorships "2010 to Present." → CONFIRMED Rosenwald is a co-founder/director of the Beach Front side; PARTIAL on a quantified ownership %.

• The $2M Beach Front note → GH preferred (equity) conversion. Glass House Brands FY2021 Form 40-F, Notes to Consolidated Financial Statements, Note 17 – Notes Payable – Related Parties, verbatim:

  "In February 2021, GH Group issued a $2,000,000 unsecured promissory note in favor of Beach Front Properties, LLC. The debt matures in February 2023 and bears interest at fifteen percent (15%) per year. On June 29, 2021, all principal and accrued interest under such promissory note was converted to Preferred Shares."

→ CONFIRMED. This is a Beach Front creditor position that became a Glass House equity (preferred) position. Saved: SEC_GLASSHOUSE/GH_FY2021_40F_ex99-1.htm.

• BFPM itself is "majority-owned by an executive and certain board members of the Company." GH FY2025 financial-statement related-party note (and identical language back to FY2021):

  "Beach Front Property Management Inc., a company that is majority-owned by an executive and certain board members of the Company, entered into a consulting agreement with the Company dated September 28, 2020. The monthly consulting fee is $11 thousand … Consulting fees for the years ended December 31, 2025 and 2024 was $140 thousand in each period."

→ CONFIRMED that BFPM is majority-owned by GH insiders (the AIF identifies Kazan as BFPM Founder/Chairman; the Rosenwalds are GH founders/directors). The note does not itemize each insider's BFPM percentage. PARTIAL on whether a Rosenwald individually (vs. Kazan) holds BFPM equity. Saved: SEC_GLASSHOUSE/GH_FY2025_40F_ex99-1_FINSTMTS.htm (note); ..._ex99-2_MDA.htm (MD&A restatement).

• Jon A. Neu Insurance "an entity majority owned by Beach Front Property Management Inc." earned $298k (FY2025) / $399k (FY2024) in brokerage fees from GH. → CONFIRMED (same notes), establishes a BFPM-owned subsidiary in the related-party web.

Net: Equity/ownership beyond management is established for the Rosenwald founders' interest in the Beach Front entities and for the note-to-preferred equity conversion. The exact RCM-entity / Family-Trust ownership percentage in BFPM is PARTIAL/UNCONFIRMED — the CA SOS Statements of Information (see Q2) and the IAPD checkbox-state are the remaining records to close it.

Q2 — Jocelyn M. Rosenwald's role at Beach Front

Answer: CONFIRMED — she is GH Director (since June 2021) and Audit Committee CHAIR, with her principal occupation stated as Beach Front "Director of Acquisitions and Asset Management." She also holds GH Multiple Voting Shares as a named "Company Founder." Her BFPM officer/director or BFPM-equity status is UNCONFIRMED (needs CA SOS SI).

From the GH FY2025 Form 40-F AIF (SEC_GLASSHOUSE/GH_FY2025_40F_ex99-3_AIF.htm), Directors & Officers table and bios, verbatim:

• "Jocelyn Rosenwald … Director … Director of the Company since June 2021 … Director of Acquisitions and Asset Management, Beach Front Property Management." (The user's "Director of Acquisitions, BFPM" → CONFIRMED, full title now "…and Asset Management.")
• "(1) Member of the Audit Committee of the Board … Ms. Rosenwald is Chair." → CONFIRMED Audit Committee Chair.
• Bio: "She began her career in real estate investment in 2013 with Beach Front Properties LLC and managed a $500 million portfolio of opportunistic real estate investments." → CONFIRMED.
• Voting/equity: She is expressly one of the "Company Founders" holding Multiple Voting Shares (see Q3 quote). → CONFIRMED she holds GH voting equity. (Her Beach Front voting/equity is not quantified in the AIF.)

→ UNCONFIRMED this session: whether Jocelyn is an officer/director of BFPM or BF Properties on the CA SOS roster. The CA SOS bizfileonline API and OpenCorporates both returned HTTP 403 to scripted access; the Statement of Information must be pulled through the browser UI (or ordered). Tagged UNCONFIRMED until that SI is in hand.

Q3 — The Kyle Kazan ↔ Rosenwald relationship: what records show

Answer: CONFIRMED — co-founders of the Beach Front entities (1997), co-owners in the Beach Front orbit, longtime business partners, and jointly named "Company Founders" of Glass House Brands holding control through Multiple Voting Shares. NO record shows a familial tie — "basically family" is [ASSERTED] only.

• Glass House "Company Founders" — the controlling SEC disclosure. GH FY2025 AIF (..._ex99-3_AIF.htm), verbatim:

  "…the concentration of voting control that is held indirectly by the founders of GH Group (being Kyle Kazan, Graham Farrar, James Rosenwald III and IV, Laura Parker Rosenwald, Jocelyn Rosenwald and Kris Hulgreen) (collectively, the "Company Founders") by virtue of their Multiple Voting Shares…"

→ CONFIRMED: Kazan and four Rosenwalds (James III, James IV/Benno, Laura Parker, Jocelyn) are co-founders of Glass House and jointly hold concentrated voting control. Directors/officers as a group held ~63.4% of voting rights as of March 12, 2026 (same AIF).

• Beach Front co-founding. Wikipedia (Kyle Kazan), verbatim: "In 1997, Kazan and James B. Rosenwald co-founded Beach Front Properties, LLC., a real estate investment company based in southern California." And "In 1999, Kazan … founded Beach Front Property Management, Inc." (no co-founder named for BFPM). → CONFIRMED as co-founders of BF Properties LLC; CONFIRMED Kazan is sole-named founder of BFPM. GH AIF lists Kazan as "Founder and Chairman, Beach Front Property Management (1999 – present)."

• Exchange Rights Agreement names "the sellers of GH Group (being Kyle D. Kazan)" — Kazan as the seller-representative at the June 29, 2021 go-public — further documenting the Kazan-centered founder group. → CONFIRMED (..._ex99-3_AIF.htm).

• Familial tie: NONE in any record. The James B. Rosenwald Wikipedia entry: "No familial tie is mentioned … described solely as business partners." The Kyle Kazan entry: "No family relationship is mentioned anywhere … Rosenwald is identified solely as a business partner." → The user's "Kazan is basically family" is recorded here as [ASSERTED] (user's characterization). The substantiated relationship is co-founder / business partner / related party, not family.

Records saved to this folder

Open records to close the file (not retrievable via script this session)

• CA SOS Statements of Information / LLC-12 / SI-550 for Beach Front Property Management, Inc. and Beach Front Properties, LLC — bizfileonline.sos.ca.gov returned HTTP 403 to curl and OpenCorporates likewise. Pull via browser UI (prior work cites BF Properties LLC file no. 199716410008, managers = Kazan + RCM). → closes the BFPM officer/director roster (Q2) and any RCM/Family-Trust BFPM equity line (Q1).
• IAPD live ADV (CRD 290118) — read the Schedule D 7.A checkbox state (control / common control) for Beach Front Properties LLC.
• FEC Schedule A employer entries for Jocelyn/Laura Rosenwald ("Beach Front Property Management") — FEC API hit the DEMO_KEY 40-calls/hour limit; corroborated in prior GLASSHOUSE_BEACHFRONT_PPP_20260614/VERIFIED_LEDGER.md. Tag PARTIAL.