X0306 4 2020-03-27 0 0001452936 Pacific Oak Strategic Opportunity REIT, Inc. NONE 0001397375 Hall Keith D 11150 SANTA MONICA BLVD., SUITE 400 LOS ANGELES CA 90025 1 1 0 0 Chief Executive Officer Common Stock 2020-03-27 4 A 0 3411737 0.00 A 3442483 I By KBS Capital Advisors LLC Common Stock 511927 I By Willowbrook Capital Group LLC On March 27, 2020, the Issuer issued 3,411,737 restricted shares of its common stock (the "Restricted Shares") to its former external advisor, KBS Capital Advisors LLC ("KBS") pursuant to a Restricted Stock Agreement, dated as of March 27, 2020 (the "Agreement"). Under the Agreement, the Restricted Shares are nonvested and forfeitable until the earliest of: (i) November 1, 2021 or (ii) immediately before and contingent upon the occurrence of a Change in Control (as defined in the Agreement) of the Issuer. The Restricted Shares will be forfeited prior to vesting if KBS fails to honor certain non-compete, voting, and other requirements set forth in the Agreement. 3,411,737 of the shares reported in this box are shares of Restricted Shares. The Reporting Person shares ownership and control of the limited liability company that acquired the reported securities. The Reporting Person shares ownership and control of the limited liability company that acquired the reported securities. /s/ Michael A. Bender, Attorney-in-Fact 2020-03-31