Pacific Oak Strategic Opportunity REIT (PCOK) leader details large share rescission and $1 sale

Rhea-AI Filing Summary

Pacific Oak Strategic Opportunity REIT, Inc. insider activity shows significant changes in indirect holdings. A Form 4 reports that on 12/30/2025, restricted common shares totaling 2,503,452.65 were rescinded at a stated price of $0 by GKP Holding LLC, a limited liability company owned and controlled by the reporting person. Following this, 901,509.91 common shares were indirectly held through GKP Holding LLC.

On 12/31/2025, 901,509.91 common shares were disposed of at a stated price of $0 through Willowbrook Capital Group LLC, another limited liability company owned and controlled by the reporting person, for total consideration of $1. The reporting person, who serves as Chairman of the Board, President, and Director, no longer held shares through Willowbrook after this transaction while maintaining indirect ownership through GKP Holding LLC.

Insider Trade Summary

2 transactions reported

Net Sell 2 txns

Insider McMillan Peter

Role See Remarks

Sold 901,509.91 shs ($0.00)

Type	Security	Shares	Price	Value
Sale	Common Stock	901,509.91	$0.00	--
Other	Common Stock	2,503,452.65	$0.00	--

Holdings After Transaction: Common Stock — 0 shares (Indirect, By Willowbrook Capital Group LLC)

Footnotes (1)

1. These shares were restricted shares rescinded by the reporting person prior to vesting. The reporting person owns and controls the limited liability company that rescinded the reported securities. The reporting person owns and controls the limited liability company that sold the reported securities for a total consideration of $1.

Form 4 Insider Transactions: What Each Field Means →

SEC Form 4

FORM 4

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940

OMB APPROVAL

OMB Number:			3235-0287
Estimated average burden
hours per response:			0.5

Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).

Check this box to indicate that a transaction was made pursuant to a contract, instruction or written plan for the purchase or sale of equity securities of the issuer that is intended to satisfy the affirmative defense conditions of Rule 10b5-1(c). See Instruction 10.

1. Name and Address of Reporting Person^*

McMillan Peter

(Last) (First) (Middle)

3200 PARK CENTER DR.

SUITE 800

(Street)

COSTA MESA CA 92626

(City) (State) (Zip)

2. Issuer Name and Ticker or Trading Symbol
Pacific Oak Strategic Opportunity REIT, Inc. [ NONE ]

5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)

X	Director		10% Owner
X	Officer (give title below)		Other (specify below)
	See Remarks

3. Date of Earliest Transaction (Month/Day/Year)
12/30/2025

4. If Amendment, Date of Original Filed (Month/Day/Year)

6. Individual or Joint/Group Filing (Check Applicable Line)

X	Form filed by One Reporting Person
	Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1. Title of Security (Instr. 3)	2. Transaction Date (Month/Day/Year)	2A. Deemed Execution Date, if any (Month/Day/Year)	3. Transaction Code (Instr. 8)		4. Securities Acquired (A) or Disposed Of (D) (Instr. 3, 4 and 5)			5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4)	6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	7. Nature of Indirect Beneficial Ownership (Instr. 4)
			Code	V	Amount	(A) or (D)	Price
Common Stock	12/30/2025		J		2,503,452.65	D	$0	901,509.91	I	By GKP Holding LLC(1)
Common Stock	12/31/2025		S		901,509.91	D	$0	0	I	By Willowbrook Capital Group LLC(2)

Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 3)	2. Conversion or Exercise Price of Derivative Security	3. Transaction Date (Month/Day/Year)	3A. Deemed Execution Date, if any (Month/Day/Year)	4. Transaction Code (Instr. 8)		5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5)		6. Date Exercisable and Expiration Date (Month/Day/Year)		7. Title and Amount of Securities Underlying Derivative Security (Instr. 3 and 4)		8. Price of Derivative Security (Instr. 5)	9. Number of derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4)	10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	11. Nature of Indirect Beneficial Ownership (Instr. 4)
				Code	V	(A)	(D)	Date Exercisable	Expiration Date	Title	Amount or Number of Shares

Explanation of Responses:

1. These shares were restricted shares rescinded by the reporting person prior to vesting. The reporting person owns and controls the limited liability company that rescinded the reported securities.

2. The reporting person owns and controls the limited liability company that sold the reported securities for a total consideration of $1.

Remarks:

Chairman of the Board and President

	/s/ Peter McMillan	01/02/2026
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 4 (b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.

FAQ

What insider transaction was reported for PCOK in this Form 4?

The Form 4 reports that the Chairman, President, and Director of Pacific Oak Strategic Opportunity REIT, Inc. rescinded restricted common shares and disposed of additional common shares through entities he owns and controls.

How many Pacific Oak (PCOK) shares were rescinded in the reported transaction?

On 12/30/2025, restricted common shares totaling 2,503,452.65 were rescinded at a stated price of $0 by GKP Holding LLC, an entity owned and controlled by the reporting person.

How many Pacific Oak (PCOK) shares were sold and for what consideration?

On 12/31/2025, 901,509.91 common shares of Pacific Oak Strategic Opportunity REIT, Inc. were disposed of through Willowbrook Capital Group LLC for a total consideration of $1.

What is the role of the reporting person at Pacific Oak Strategic Opportunity REIT, Inc. (PCOK)?

The reporting person is a Director and serves as Chairman of the Board and President of Pacific Oak Strategic Opportunity REIT, Inc.

How were the Pacific Oak (PCOK) transactions structured through related entities?

The rescinded restricted shares were held by GKP Holding LLC, and the sold shares were held by Willowbrook Capital Group LLC. The reporting person owns and controls both limited liability companies.

What were the transaction codes used for the Pacific Oak (PCOK) insider trades?

The rescission of restricted shares on 12/30/2025 is coded as "J", and the disposal of common shares on 12/31/2025 is coded as "S" in Table I of the Form 4.