Ares Commercial Real Estate Corp

As required by Section 953(a) of the Dodd-Frank Wall Street Reform and Consumer Protection Act and Item 402(v) of Regulation S-K, we are providing the following information about the relationship between executive compensation actually paid (as defined by SEC Rules) and certain financial performance of the Company. We do not use any financial performance measures to link compensation actually paid to our named executive officers to the Company’s performance. Accordingly, pursuant to SEC rules, we have not included a “Company-Selected Measure” or a tabular list of performance measures. For more information about our executive compensation program, please refer to the “Executive Compensation—Compensation Discussion and Analysis” above.

(1)The dollar amounts reported in this column are the amounts of total compensation reported for our Chief Executive Officer (the “PEO”) for each corresponding year, as reported in the “Total” column of the Summary Compensation Table. The name of the PEO of the Company reflected in these columns for each of the applicable fiscal years is Bryan P. Donohoe.

(2)“Compensation Actually Paid” has been calculated in accordance with the requirements of Item 402(v)(2)(iii) of Regulation S-K and does not reflect compensation actually earned, realized or received. The following adjustments in the table below were made to the amounts reported for Mr. Donohoe in the Summary Compensation Table. In calculating “Compensation Actually Paid”, the fair value or change in fair value, as applicable, of the equity award adjustments included in each calculation was computed in accordance with FASB ASC Topic 718. Importantly, the dollar amounts do not reflect the actual amount of compensation earned by or paid to Mr. Donohoe during the applicable year.

(a) The Company has no pension plans.

(b) Total grant date fair value of equity awards reported in the “Stock Awards” column in the Summary Compensation Table for the applicable year. Mr. Donohoe did not receive option awards in the years shown.

(c) For each covered year, the amounts added or deducted in calculated equity award adjustments include:

(3)The dollar amounts reported in this column represent the average of the total amounts reported for our non-PEO named executive officers (the “Other NEOs”) for each corresponding year in the “Total” column of the Summary Compensation Table. For each of the applicable fiscal years, our Other NEOs were Tae-Sik Yoon and Anton S. Feingold.

(4)“Compensation Actually Paid” has been calculated in accordance with the requirements of Item 402(v)(2)(iii) of Regulation S-K and does not reflect compensation actually earned, realized or received. When calculating the “average compensation actually paid for the Other NEOs, the following adjustments in the table below were made to the amounts reported in the Summary Compensation Table. In calculating “Compensation Actually Paid”, the fair value or change in fair value, as applicable, of the equity award adjustments included in such calculations was computed in accordance with FASB ASC Topic 718. Importantly, the dollar amounts do not reflect the actual amount of compensation earned by or paid to our Other NEOs as a group during the applicable year.

(a) The Company has no pension plans.

(b) Average total grant date fair value of equity awards reported in the “Stock Awards” column in the Summary Compensation Table for the applicable year. The Other NEOs did not receive option awards in the years shown.

(c) For each covered year, the amounts added or deducted in calculated equity award adjustments include:

(5)The total shareholder return as calculated based on a fixed investment of one hundred ($100) dollars measured from the market close on December 31, 2019 (the last trading day of 2019) through and including the end of the fiscal year for each year reported in the table.

(6)Total shareholder return for our peer group is the FTSE NAREIT All Mortgage Capped Index (the “Peer Group”), which we also use for purposes of the stock performance graph required by Item 201(e) of Regulation S-K included in our Annual Report on Form 10-K for the year ended December 31, 2024. We replaced the Bloomberg Mortgage REIT Index (old peer group) for 2024, following its discontinuation, with the FTSE NAREIT All Mortgage Capped Index, which we believe is representative of companies similar to ours. The information disclosed for the years 2024, 2023, 2022, 2021 and 2020 reflects the total shareholder return for our new Peer Group. Under Item 402 of Regulation S-K, we are also required to disclose the total shareholder return of our old peer group as filed in our definitive proxy statement filed with the SEC on April 4, 2024.