REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933
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[ X ]
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Pre-Effective Amendment No.
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Post-Effective Amendment No.
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71
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[ X ]
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and/or
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REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940
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[ X ]
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Amendment No.
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73
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[ X ]
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immediately upon filing pursuant to paragraph (b)
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X
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on February 28, 2020 pursuant to paragraph (b)
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60 days after filing pursuant to paragraph (a)(1)
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on ____________ pursuant to paragraph (a)(1)
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75 days after filing pursuant to paragraph (a)(2)
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on ____________ pursuant to paragraph (a)(2)
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this post-effective amendment designates a new effective date for a previously filed post-effective amendment.
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Class A | Class C |
Institutional
Class |
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Neuberger Berman Absolute Return Multi-Manager Fund | NABAX | NABCX | NABIX |
Fund Summary
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Neuberger Berman Absolute Return Multi-Manager Fund
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2
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Descriptions of Certain Practices and Security Types
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19
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Additional Information about Principal Investment Risks
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20
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Information about Additional Potential Principal Investment Strategies
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35
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Information about Additional Risks and Other Practices
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35
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Descriptions of Indices
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35
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Management of the Fund
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36
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Financial Highlights
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39
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YOUR INVESTMENT
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Choosing a Share Class
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42
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Maintaining Your Account
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43
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Share Prices
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48
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Privileges and Services
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49
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Sales Charges
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49
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Sales Charge Reductions and Waivers
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50
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Distributions and Taxes
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54
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Grandfathered Investors
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55
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Buying Shares—Grandfathered Investors
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57
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Selling Shares—Grandfathered Investors
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58
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Market Timing Policy
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59
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Portfolio Holdings Policy
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59
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Fund Structure
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59
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Appendix A
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A-1
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Class A | Class C | Institutional Class | |
Shareholder Fees (fees paid directly from your investment) | |||
Maximum initial sales charge on purchases (as a % of offering price) | 5.75 | None | None |
Maximum contingent deferred sales charge (as a % of the lower of original purchase price or current market value)1 | None | 1.00 | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |||
Management fees | 1.96 | 1.96 | 1.85 |
Distribution and/or shareholder service (12b-1) fees | 0.25 | 1.00 | None |
Total other expenses | 0.77 | 0.76 | 0.75 |
Other expenses | 0.44 | 0.44 | 0.43 |
Dividend and interest expenses relating to short sales | 0.33 | 0.32 | 0.32 |
Acquired fund fees and expenses | 0.07 | 0.07 | 0.07 |
Total annual operating expenses | 3.05 | 3.79 | 2.67 |
Fee waivers and/or expense reimbursement | 0.31 | 0.31 | 0.30 |
Total annual operating expenses after fee waiver and/or expense reimbursement2 | 2.74 | 3.48 | 2.37 |
1 | For Class A shares, a contingent deferred sales charge (“CDSC”) of 1.00% applies on certain redemptions made within 18 months following purchases of $1 million or more made without an initial sales charge. For Class C shares, the CDSC is eliminated one year after purchase. |
2 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class A, Class C and Institutional Class so that the total annual operating expenses (excluding interest, taxes, brokerage commissions, acquired fund fees and expenses, dividend and interest expenses relating to short sales, and extraordinary expenses, if any) (“annual operating expenses”) of each class are limited to 2.33%, 3.08% and 1.97% of average net assets, respectively. Each of these undertakings lasts until 10/31/2023 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that each of Class A, Class C and Institutional Class will repay the Manager for fees and expenses waived or reimbursed for the class provided that repayment does not cause annual operating expenses to exceed 2.33%, 3.08% and 1.97% of the class’ average net assets, respectively. Any such repayment must be made within three years after the year in which the Manager incurred the expense. |
1 Year | 3 Years | 5 Years | 10 Years | |
Class A | $836 | $1,376 | $2,003 | $3,680 |
Class C (assuming redemption) | $451 | $1,068 | $1,871 | $3,964 |
Class C (assuming no redemption) | $351 | $1,068 | $1,871 | $3,964 |
Institutional Class | $240 | $739 | $1,330 | $2,932 |
Absolute Return Multi-Manager Fund | 1 Year | 5 Years |
Since Inception
(5/15/2012) |
Institutional Class Return Before Taxes | 6.67 | 0.76 | 2.02 |
Institutional Class Return After Taxes on Distributions | 5.23 | 0.40 | 1.58 |
Institutional Class Return After Taxes on Distributions and Sale of Fund Shares | 4.05 | 0.45 | 1.39 |
Class A Return Before Taxes | 0.25 | -0.79 | 0.87 |
Class C Return Before Taxes | 4.52 | -0.36 | 0.89 |
HFRX Global Hedge Fund Index (reflects deductions for fees and expenses, but not taxes) | 8.62 | 1.19 | 1.74 |
S&P 500® Index (reflects no deduction for fees, expenses or taxes) | 31.49 | 11.70 | 14.60 |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deduction for fees, expenses or taxes) | 8.72 | 3.05 | 2.79 |
After-tax returns are shown for Institutional Class shares only and after-tax returns for other classes may vary. After-tax returns are calculated using the historical highest individual federal marginal income tax rates and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ from those shown. After-tax returns are not relevant to investors who hold their Fund shares through tax-deferred arrangements, such as 401(k) plans or individual retirement accounts. Return After Taxes on Distributions and Sale of Fund Shares may be higher than other returns for the same period due to a tax benefit of realizing a capital loss upon the sale of Fund shares. |
Manager/Subadviser | Investment Strategy |
P/E Global, LLC | Global Macro |
Portland Hill Asset Management Limited | European Event Driven and Equity Long/Short |
(1) | Shows what this ratio would have been if there had been no expense reimbursement/repayment and/or waiver of a portion of the management fee. |
(2) | Would have been lower/higher if the Manager had not reimbursed/recouped certain expenses. |
(3) | Calculated based on the average number of shares outstanding during each fiscal period. |
(4) | Does not include the effect of sales charges. |
YEAR ENDED OCTOBER 31, | 2015 | 2016 | 2017 | 2018 | 2019 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 10.72 | 10.15 | 9.78 | 10.24 | 10.06 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | (0.16) | (0.09) | (0.05) | (0.03) | (0.03) |
Net gains (losses) — realized and unrealized | (0.18) | (0.18) | 0.51 | (0.15) | 0.17 |
Subtotal: income (loss) from investment operations | (0.34) | (0.27) | 0.46 | (0.18) | 0.14 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | — | — | — | — |
Net capital gain distributions | 0.23 | 0.10 | — | — | — |
Subtotal: distributions to shareholders | 0.23 | 0.10 | — | — | — |
Equals: | |||||
Share price (NAV) at end of year | 10.15 | 9.78 | 10.24 | 10.06 | 10.20 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund’s expenses and net investment income (loss) — as they actually are as well as how they would have been if certain expense reimbursement/repayment and/or waiver arrangements had not been in effect. | |||||
Net expenses — actual | 3.81 | 3.89 | 3.69 | 3.45 | 3.40 |
Net expenses (excluding expenses on securities sold short) — actual | 3.08 | 3.08 | 3.08 | 3.08 | 3.09 |
Gross expenses(1) | 3.81 | 3.96 | 3.82 | 3.65 | 3.71 |
Gross expenses (excluding expenses on securities sold short)(1) | 3.08 | 3.15 | 3.21 | 3.28 | 3.39 |
Net investment income (loss) — actual | (1.48) | (0.96) | (0.53) | (0.24) | (0.33) |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(2)(4) | (3.21) | (2.66) | 4.70 | (1.76) | 1.39 |
Net assets at end of year (in millions of dollars) | 87.1 | 40.9 | 17.9 | 11.6 | 7.7 |
Portfolio turnover rate (including securities sold short)(%) | 433 | 485 | 382 | 194 | 248 |
Portfolio turnover rate (excluding securities sold short)(%) | 452 | 474 | 357 | 179 | 246 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement/repayment and/or waiver of a portion of the management fee. |
(2) | Would have been lower/higher if the Manager had not reimbursed/recouped certain expenses. |
(3) | Calculated based on the average number of shares outstanding during each fiscal period. |
(4) | Does not include the effect of sales charges. |
(1) | Shows what this ratio would have been if there had been no expense reimbursement/repayment and/or waiver of a portion of the management fee. |
(2) | Would have been lower/higher if the Manager had not reimbursed/recouped certain expenses. |
(3) | Calculated based on the average number of shares outstanding during each fiscal period. |
■ | how long you expect to own the shares |
■ | how much you intend to invest |
■ | total expenses associated with owning shares of each class |
■ | whether you qualify for any reduction or waiver of sales charges (for example, Class A shares may be a less expensive option than Class C shares over time, particularly if you qualify for a sales charge reduction or waiver) |
■ | whether you plan to take any distributions in the near future |
■ | availability of (and eligibility for) share classes. |
Class A Shares | |
Initial sales charge |
Up to 5.75% (reduced for purchases of $50,000 or more and eliminated for purchases of $1 million or more)
|
Contingent deferred sales charge | None (except that a charge of 1.00% applies to certain redemptions made within 18 months following purchases of $1 million or more without an initial sales charge) |
12b-1 fees | 0.25% annually |
Dividends | Generally higher than Class C due to lower annual expenses and lower than Institutional Class due to higher annual expenses |
Purchase maximum | None |
Conversion | None |
Class C Shares | |
Initial sales charge | None |
Contingent deferred sales charge | 1.00% if shares are sold within one year after purchase |
12b-1 fees | 1.00% annually |
Dividends | Generally lower than Class A and Institutional Class due to higher annual expenses |
Purchase maximum | See the discussion regarding purchase minimums and maximums in “Maintaining Your Account” |
Conversion | Automatic conversion into Class A shares of the same Fund at the end of the month following the tenth anniversary of the purchase date of Class C shares. Class C shares held through a financial intermediary may be converted pursuant to the conversion schedule or eligibility requirements of such financial intermediary. It is the financial intermediary’s (and not the Fund’s) responsibility to keep records and to ensure that the shareholder is credited with the proper holding period as the Fund and its agents may not have transparency into how long a shareholder has held Class C shares for purposes of determining whether such Class C shares are eligible to automatically convert pursuant to the conversion feature. Please see the Statement of Additional Information for more information regarding the conversion privileges of Class C shares. |
Institutional Class Shares | |
Initial sales charge | None |
Contingent deferred sales charge | None |
12b-1 fees | None |
Dividends | Generally higher than Class A and Class C due to lower annual expenses |
Purchase maximum | None |
Conversion | None |
■ | both accounts must have the same registration |
■ | you will need to observe any eligibility requirements, including minimum investment and minimum account balance requirements for the fund accounts involved |
■ | because an exchange is treated as a sale (redemption) of the exchanged shares for federal income tax purposes, consider any tax consequences before placing your order. |
■ | in unusual circumstances where the law allows additional time if needed |
■ | if a check you wrote to buy shares has not cleared by the time you sell those shares; clearance may take up to 15 calendar days from the date of purchase. |
■ | suspend the offering of shares |
■ | reject any exchange or purchase order |
■ | suspend or reject future purchase orders from any investor who has not provided timely payment to settle a purchase order |
■ | change, suspend, or revoke the exchange privilege |
■ | suspend the telephone order privilege |
■ | satisfy an order to sell Fund shares with securities rather than cash |
■ | suspend or postpone investors’ ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when trading on the New York Stock Exchange (“Exchange”) is restricted, or as otherwise permitted by the Securities and Exchange Commission (“SEC”) |
■ | suspend or postpone investors' ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when the Exchange or the bond market is closed |
■ | suspend or postpone investors' ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when the Exchange, the Federal Reserve or the bond market closes early (e.g., on the eve of a major holiday or because of a local emergency, such as a blizzard) |
■ | change investment minimums or other requirements for buying and selling, or waive any minimums or requirements for certain investors |
■ | remain open and process orders to purchase or sell Fund shares when the Exchange is closed. |
Sales charges as a percentage of: | |||
Investment | Offering Price |
Net amount
invested |
Dealer commission
as a percentage of offering price |
Less than $50,000 | 5.75% | 6.10% | 5.00% |
$50,000 or more but less than $100,000 | 4.75% | 4.99% | 4.00% |
$100,000 or more but less than $250,000 | 3.75% | 3.90% | 3.00% |
$250,000 or more but less than $500,000 | 2.75% | 2.83% | 2.25% |
$500,000 or more but less than $1 million | 2.00% | 2.04% | 1.75% |
$1 million or more and certain other investments described below | None | None | See below |
1. | current or retired directors, trustees, and officers of the Neuberger Berman Funds, current or retired employees and partners of NB Group and any affiliates, or of any entity controlling, controlled by or under common control with a Neuberger Berman Fund, NB Group and any affiliates; |
2. | current employees of firms, including wholesalers, that have entered into selling agreements to distribute shares of the Neuberger Berman Funds; |
3. | current employees of registered investment advisers that invest in the Neuberger Berman Funds either for proprietary accounts or on behalf of clients; |
4. | immediate family members of persons listed in (1) through (3) above (as “immediate family” is defined below); |
5. | companies exchanging securities with the Fund through a merger, acquisition or exchange offer; |
6. | insurance company separate accounts; |
7. | NB Group and its affiliated companies; |
8. | an individual or entity with a substantial client relationship with NB Group and its affiliated companies, or an individual or entity related or relating to such individual or entity that holds its shares directly with the Fund; |
9. | financial intermediaries (including but not limited to registered investment advisors and financial planners) that have entered into an agreement with the Distributor or one of its affiliates, purchasing shares on behalf of clients participating in a fund supermarket or in a wrap program, asset allocation program or other program in which the clients pay an asset-based fee; |
10. | Employer-sponsored qualified retirement plans, including 401(k) plans, 457 plans, group 403(b) plans and individual 403(b) accounts, maintained at a financial intermediary that has an agreement with the Distributor, the Manager or the Administrator, profit-sharing and money purchase pension plans, defined benefit plans and non-qualified deferred compensation plans; and individual retirement account (“IRA”) rollovers involving retirement plan assets invested in the Fund and transferred in-kind to an IRA held at a financial intermediary that has an agreement with the Distributor, the Manager or the Administrator to service such accounts; |
11. | Employee benefit and retirement plans sponsored by NB Group and any affiliates and any entity controlling, controlled by or under common control with NB Group and any affiliates; |
12. | Certain IRAs that are part of an IRA platform sponsored by or maintained at a financial intermediary that has an agreement with the Distributor, the Manager or the Administrator which specifically provides that the Fund's shares are offered at NAV on such IRA platform; and |
13. | Qualified Tuition Programs under Section 529 of the Code. |
■ | trust accounts established by you or your immediate family (for trusts with only one primary beneficiary, upon the trustor’s death the trust account may be aggregated with such beneficiary’s own accounts; for trusts with multiple primary beneficiaries, upon the trustor’s death the trustees of the trust may instruct the Fund’s transfer agent to establish separate trust accounts for each primary beneficiary; each primary beneficiary’s separate trust account may then be aggregated with such beneficiary’s own accounts); |
■ | business accounts solely controlled by you or your immediate family (for example, you own the entire business); |
■ | individual retirement plans, such as an IRA, individual 403(b) plan (see exception in “Purchases by certain 403(b) plans” under “Sales Charges”) or single-participant Keogh-type plan ; |
■ | endowments or foundations established and controlled by you or your immediate family; or |
■ | 529 accounts, which will be aggregated at the account owner level. |
■ | for a single trust estate or fiduciary account, including employee benefit plans other than the individual-type employee benefit plans described above; |
■ | made for two or more employee benefit plans of a single employer or of affiliated employers as defined in the 1940 Act, excluding the individual-type employee benefit plans described above; |
■ | for a diversified common trust fund or other diversified pooled account not specifically formed for the purpose of accumulating Fund shares; |
■ | for nonprofit, charitable or educational organizations, or any endowments or foundations established and controlled by such organizations, or any employer-sponsored retirement plans established for the benefit of the employees of such organizations, their endowments, or their foundations; or |
■ | for individually established participant accounts of a 403(b) plan that is treated similarly to an employer-sponsored plan for sales charge purposes (see “Purchases by certain 403(b) plans” under “Sales Charges” above), or made for two or more such 403(b) plans that are treated similarly to employer-sponsored plans for sales charge purposes, in each case of a single employer or affiliated employers as defined in the 1940 Act. |
■ | permitted exchanges of shares, except if shares acquired by exchange are then redeemed within the period during which contingent deferred sales charge would apply to the initial shares purchased |
■ | tax-free returns of excess contributions to IRAs |
■ | redemptions due to death or post-purchase disability of the shareholder (this generally excludes accounts registered in the names of trusts and other entities). In the case of joint tenant accounts, if one joint tenant dies, a surviving joint tenant, at the time he or she notifies the Fund’s transfer agent of the other joint tenant’s death and removes the decedent’s name from the account, may redeem shares from the account without incurring a CDSC. Redemptions made after the date of such notification will be subject to a CDSC. |
■ | distributions from an IRA upon the shareholder’s attainment of age 59½ |
■ | the following types of transactions, if together they do not exceed 12% of the value of an “account” (defined below) annually (the 12% limit): |
■ | purchases where no commission or transaction fee is paid by the Distributor to authorized dealers at the time of purchase. |
■ | Employer-sponsored retirement plans (e.g., 401(k) plans, 457 plans, employer-sponsored 403(b) plans, profit sharing and money purchase pension plans and defined benefit plans). For purposes of this provision, employer-sponsored retirement plans do not include SEP IRAs, Simple IRAs or SAR-SEPs. |
■ | Shares purchased through an Ameriprise Financial investment advisory program (if an Advisory or similar share class for such investment advisory program is not available). |
■ | Shares purchased by third party investment advisors on behalf of their advisory clients through Ameriprise Financial’s platform (if an Advisory or similar share class for such investment advisory program is not available). |
■ | Shares purchased through reinvestment of capital gains distributions and dividend reinvestment when purchasing shares of the same Fund (but not any other fund within the same fund family). |
■ | Shares exchanged from Class C shares of the same fund in the month of or following the 10-year anniversary of the purchase date. To the extent that this prospectus elsewhere provides for a waiver with respect to such shares following a shorter holding period, that waiver will apply to exchanges following such shorter period. To the extent that this prospectus elsewhere provides for a waiver with respect to exchanges of Class C shares for load waived shares, that waiver will also apply to such exchanges. |
■ | Employees and registered representatives of Ameriprise Financial or its affiliates and their immediate family members. |
■ | Shares purchased by or through qualified accounts (including IRAs, Coverdell Education Savings Accounts, 401(k)s, 403(b) TSCAs subject to ERISA and defined benefit plans) that are held by a covered family member, defined as an Ameriprise financial advisor and/or the advisor’s spouse, advisor’s lineal ascendant (mother, father, grandmother, grandfather, great grandmother, great grandfather), advisor’s lineal descendant (son, step-son, daughter, step-daughter, grandson, granddaughter, great grandson, great granddaughter) or any spouse of a covered family member who is a lineal descendant. |
■ | Shares purchased from the proceeds of redemptions within the same fund family, provided (1) the repurchase occurs within 90 days following the redemption, (2) the redemption and purchase occur in the same account, and (3) redeemed shares were subject to a front-end or deferred sales load (i.e. Rights of Reinstatement). |
■ | The applicable sales charge on a purchase of Class A shares is determined by taking into account all share classes (except any money market funds and retirement plan share classes) of the fund family held by the shareholder or in an account grouped by Edward Jones with other accounts for the purpose of providing certain pricing considerations (“pricing groups”). This includes all share classes held on the Edward Jones platform and/or held on another platform. The inclusion of eligible fund family assets in the rights of accumulation calculation is dependent on the shareholder notifying his or her financial advisor of such assets at the time of calculation. |
■ | ROA is determined by calculating the higher of cost or market value (current shares x NAV). |
■ | Through a LOI, shareholders can receive the sales charge and breakpoint discounts for purchases shareholders intend to make over a 13-month period from the date Edward Jones receives the LOI. The LOI is determined by calculating the higher of cost or market value of qualifying holdings at LOI initiation in combination with the value that the shareholder intends to buy over a 13-month period to calculate the front-end sales charge and any breakpoint discounts. Each purchase the shareholder makes during that 13-month period will receive the sales charge and breakpoint discount that applies to the total amount. The inclusion of eligible fund family assets in the LOI calculation is dependent on the shareholder notifying his or her financial advisor of such assets at the time of calculation. Purchases made before the LOI is received by Edward Jones are not covered under the LOI and will not reduce the sales charge previously paid. Sales charges will be adjusted if LOI is not met. |
■ | Associates of Edward Jones and its affiliates and their family members who are in the same pricing group (as determined by Edward Jones under its policies and procedures) as the associate. This waiver will continue for the remainder of the associate's life if the associate retires from Edward Jones in good-standing. |
■ | Shares purchased in an Edward Jones fee-based program. |
■ | Shares purchased through reinvestment of capital gains distributions and dividend reinvestment. |
■ | Shares purchased from the proceeds of redeemed shares of the same fund family so long as the following conditions are met: 1) the proceeds are from the sale of shares within 60 days of the purchase, and 2) the sale and purchase are made in the same share class and the same account or the purchase is made in an individual retirement account with proceeds from liquidations in a non-retirement account. |
■ | Shares exchanged into class A shares from another share class so long as the exchange is into the same fund and was initiated at the discretion of Edward Jones. Edward Jones is responsible for any remaining CDSC due to the fund company, if applicable. Any future purchases are subject to the applicable sales charge as disclosed in the prospectus. |
■ | Exchanges from class C shares to class A shares of the same fund, generally, in the 84th month following the anniversary of the purchase date or earlier at the discretion of Edward Jones. |
■ | The death or disability of the shareholder |
■ | Systematic withdrawals with up to 10% per year of the account value |
■ | Return of excess contributions from an Individual Retirement Account (IRA) |
■ | Shares sold as part of a required minimum distribution for IRA and retirement accounts if the redemption is taken in or after the year the shareholder reaches qualified age based on applicable IRS regulations |
■ | Shares sold to pay Edward Jones fees or costs in such cases where the transaction is initiated by Edward Jones |
■ | Shares exchanged in an Edward Jones fee-based program |
■ | Shares acquired through NAV reinstatement |
1.1 | Minimum Purchase Amounts |
■ | $250 initial purchase minimum |
■ | $50 subsequent purchase minimum |
1.2 | Minimum Balances |
■ | Edward Jones has the right to redeem at its discretion fund holdings with a balance of $250 or less. The following are examples of accounts that are not included in this policy: |
■ | A fee-based account held on an Edward Jones platform |
■ | A 529 account held on an Edward Jones platform |
■ | An account with an active systematic investment plan or letter of intent (LOI) |
1.3 | Changing Share Classes |
■ | At any time it deems necessary, Edward Jones has the authority to exchange at NAV a shareholder's holdings in a fund to Class A shares. |
■ | Shares purchased through reinvestment of capital gains distributions and dividend reinvestment when purchasing shares of the same fund (but not any other fund within the fund family). |
■ | Shares purchased by employees and registered representatives of Janney or its affiliates and their family members as designated by Janney. |
■ | Shares purchased from the proceeds of redemptions within the same fund family, provided (1) the repurchase occurs within ninety (90) days following the redemption, (2) the redemption and purchase occur in the same account, and (3) redeemed shares were subject to a front-end or deferred sales load (i.e., right of reinstatement). |
■ | Employer-sponsored retirement plans (e.g., 401(k) plans, 457 plans, employer-sponsored 403(b) plans, profit sharing and money purchase pension plans and defined benefit plans). For purposes of this provision, employer-sponsored retirement plans do not include SEP IRAs, Simple IRAs, SAR-SEPs or Keogh plans. |
■ | Shares acquired through a right of reinstatement. |
■ | Class C shares that are no longer subject to a contingent deferred sales charge and are converted to Class A shares of the same fund pursuant to Janney’s policies and procedures. |
■ | Shares sold upon the death or disability of the shareholder. |
■ | Shares sold as part of a systematic withdrawal plan as described in the Fund’s Prospectus. |
■ | Shares purchased in connection with a return of excess contributions from an IRA account. |
■ | Shares sold as part of a required minimum distribution for IRA and other retirement accounts due to the shareholder reaching age 70½ as described in the Fund’s Prospectus. |
■ | Shares sold to pay Janney fees but only if the transaction is initiated by Janney. |
■ | Shares acquired through a right of reinstatement. |
■ | Shares exchanged into the same share class of a different fund. |
■ | Breakpoints as described in the Fund’s Prospectus. |
■ | Rights of accumulation (“ROA”), which entitle shareholders to breakpoint discounts, will be automatically calculated based on the aggregated holding of fund family assets held by accounts within the purchaser’s household at Janney. Eligible fund family assets not held at Janney may be included in the ROA calculation only if the shareholder notifies his or her financial advisor about such assets. |
■ | Letters of intent which allow for breakpoint discounts based on anticipated purchases within a fund family, over a 13-month time period. Eligible fund family assets not held at Janney may be included in the calculation of letters of intent only if the shareholder notifies his or her financial advisor about such assets. |
■ | Employer-sponsored retirement, deferred compensation and employee benefit plans (including health savings accounts) and trusts used to fund those plans, provided that the shares are not held in a commission-based brokerage account and shares are held for the benefit of the plan |
■ | Shares purchased by a 529 Plan (does not include 529 Plan units or 529-specific share classes or equivalents) |
■ | Shares purchased through a Merrill Lynch affiliated investment advisory program |
■ | Shares exchanged due to the holdings moving from a Merrill Lynch affiliated investment advisory program to a Merrill Lynch brokerage (non-advisory) account pursuant to Merrill Lynch’s policies relating to sales load discounts and waivers |
■ | Shares purchased by third party investment advisors on behalf of their advisory clients through Merrill Lynch’s platform |
■ | Shares of funds purchased through the Merrill Edge Self-Directed platform (if applicable) |
■ | Shares purchased through reinvestment of capital gains distributions and dividend reinvestment when purchasing shares of the same fund (but not any other fund within the fund family) |
■ | Shares exchanged from Class C (i.e. level-load) shares of the same fund pursuant to Merrill Lynch’s policies relating to sales load discounts and waivers |
■ | Employees and registered representatives of Merrill Lynch or its affiliates and their family members |
■ | Directors or Trustees of the Fund, and employees of the Fund’s investment adviser or any of its affiliates, as described in this prospectus |
■ | Eligible shares purchased from the proceeds of redemptions within the same fund family, provided (1) the repurchase occurs within 90 days following the redemption, (2) the redemption and purchase occur in the same account, and (3) redeemed shares were subject to a front-end or deferred sales load (known as Rights of Reinstatement). Automated transactions (i.e. systematic purchases and withdrawals) and purchases made after shares are automatically sold to pay Merrill Lynch’s account maintenance fees are not eligible for reinstatement |
■ | Death or disability of the shareholder |
■ | Shares sold as part of a systematic withdrawal plan as described in the Fund’s prospectus |
■ | Return of excess contributions from an IRA Account |
■ | Shares sold as part of a required minimum distribution for IRA and retirement accounts pursuant to the Internal Revenue Code |
■ | Shares sold to pay Merrill Lynch fees but only if the transaction is initiated by Merrill Lynch |
■ | Shares acquired through a right of reinstatement |
■ | Shares held in retirement brokerage accounts, that are exchanged for a lower cost share class due to transfer to a fee based account or platform (applicable to A and C shares only) |
■ | Shares received through an exchange due to the holdings moving from a Merrill Lynch affiliated investment advisory program to a Merrill Lynch brokerage (non-advisory) account pursuant to Merrill Lynch’s policies relating to sales load discounts and waivers |
■ | Breakpoints as described in this prospectus. |
■ | Rights of Accumulation (ROA) which entitle shareholders to breakpoint discounts as described in the Fund’s prospectus will be automatically calculated based on the aggregated holding of fund family assets held by accounts (including 529 program holdings, where applicable) within the purchaser’s household at Merrill Lynch. Eligible fund family assets not held at Merrill Lynch may be included in the ROA calculation only if the shareholder notifies his or her financial advisor about such assets |
■ | Letters of Intent (LOI) which allow for breakpoint discounts based on anticipated purchases within a fund family, through Merrill Lynch, over a 13-month period of time (if applicable) |
■ | Employer-sponsored retirement plans (e.g., 401(k) plans, 457 plans, employer-sponsored 403(b) plans, profit sharing and money purchase pension plans and defined benefit plans). For purposes of this provision, employer-sponsored retirement plans do not include SEP IRAs, Simple IRAs, SAR-SEPs or Keogh plans |
■ | Morgan Stanley employee and employee-related accounts according to Morgan Stanley’s account linking rules |
■ | Shares purchased through reinvestment of dividends and capital gains distributions when purchasing shares of the same fund |
■ | Shares purchased through a Morgan Stanley self-directed brokerage account |
■ | Class C (i.e., level-load) shares that are no longer subject to a contingent deferred sales charge and are converted to Class A shares of the same fund pursuant to Morgan Stanley Wealth Management’s share class conversion program |
■ | Shares purchased from the proceeds of redemptions within the same fund family, provided (i) the repurchase occurs within 90 days following the redemption, (ii) the redemption and purchase occur in the same account, and (iii) redeemed shares were subject to a front-end or deferred sales charge. |
■ | Shares purchased in an investment advisory program. |
■ | Shares purchased within the same fund family through a systematic reinvestment of capital gains and dividend distributions. |
■ | Employees and registered representatives of Raymond James or its affiliates and their family members as designated by Raymond James. |
■ | Shares purchased from the proceeds of redemptions within the same fund family, provided (1) the repurchase occurs within 90 days following the redemption, (2) the redemption and purchase occur in the same account, and (3) redeemed shares were subject to a front-end or deferred sales load (known as Rights of Reinstatement). |
■ | A shareholder in the Fund’s Class C shares will have their shares converted at net asset value to Class A shares (or the appropriate share class) of the Fund if the shares are no longer subject to a CDSC and the conversion is in line with the policies and procedures of Raymond James. |
■ | Death or disability of the shareholder. |
■ | Shares sold as part of a systematic withdrawal plan as described in the Fund’s Prospectus. |
■ | Return of excess contributions from an IRA Account. |
■ | Shares sold as part of a required minimum distribution for IRA and retirement accounts due to the shareholder reaching the qualified age based on applicable IRS regulations as described in the Fund’s prospectus. |
■ | Shares sold as part of a required minimum distribution for IRA and retirement accounts due to the shareholder reaching age 70½ as described in the Fund’s Prospectus. |
■ | Shares sold to pay Raymond James fees but only if the transaction is initiated by Raymond James. |
■ | Shares acquired through a right of reinstatement. |
■ | Breakpoints as described in this Prospectus. |
■ | Rights of accumulation which entitle shareholders to breakpoint discounts will be automatically calculated based on the aggregated holding of fund family assets held by accounts within the purchaser’s household at Raymond James. Eligible fund family assets not held at Raymond James may be included in the calculation of rights of accumulation only if the shareholder notifies his or her financial advisor about such assets. |
■ | Letters of intent which allow for breakpoint discounts based on anticipated purchases within a fund family, over a 13-month time period. Eligible fund family assets not held at Raymond James may be included in the calculation of letters of intent only if the shareholder notifies his or her financial advisor about such assets. |
■ | a discussion by the Portfolio Managers about strategies and market conditions that significantly affected the Fund’s performance during the last fiscal year |
■ | Fund performance data and financial statements |
■ | portfolio holdings. |
■ | various types of securities and practices, and their risks |
■ | investment limitations and additional policies |
■ | information about the Fund’s management and business structure. |
Fund Summary | |
Neuberger Berman Absolute Return Multi-Manager Fund
|
2 |
Descriptions of Certain Practices and Security Types
|
18 |
Additional Information about Principal Investment Risks
|
19 |
Information about Additional Potential Principal Investment Strategies
|
34 |
Information about Additional Risks and Other Practices
|
34 |
Descriptions of Indices
|
34 |
Management of the Fund
|
35 |
Financial Highlights
|
38 |
Your Investment | |
Maintaining Your Account
|
39 |
Share Prices
|
42 |
Distributions and Taxes
|
43 |
Market Timing Policy
|
44 |
Portfolio Holdings Policy
|
45 |
Fund Structure
|
45 |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees1 | 1.75 |
Distribution and/or shareholder service (12b-1) fees | None |
Total other expenses | 0.80 |
Other expenses | 0.46 |
Dividend and interest expenses relating to short sales | 0.34 |
Acquired fund fees and expenses | 0.07 |
Total annual operating expenses | 2.62 |
Fee waivers and/or expense reimbursement | 0.33 |
Total annual operating expenses after fee waiver and/or expense reimbursement2 | 2.29 |
1 | “Management fees” have been restated to reflect current administration fees. |
2 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class R6 so that the total annual operating expenses (excluding interest, taxes, brokerage commissions, acquired fund fees and expenses, dividend and interest expenses relating to short sales, and extraordinary expenses, if any) (“annual operating expenses”) are limited to 1.87% of average net assets. This undertaking lasts until 10/31/2023 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that Class R6 will repay the Manager for fees and expenses waived or reimbursed for the class provided that repayment does not cause annual operating expenses to exceed 1.87% of the average net assets. Any such repayment must be made within three years after the year in which the Manager incurred the expense. |
1 Year | 3 Years | 5 Years | 10 Years | |
Class R6 | $232 | $715 | $1,297 | $2,876 |
Absolute Return Multi-Manager Fund | 1 Year | 5 Years |
Since Inception
(5/15/2012) |
Return Before Taxes | 6.83 | 0.81 | 2.05 |
Return After Taxes on Distributions | 5.33 | 0.43 | 1.61 |
Return After Taxes on Distributions and Sale of Fund Shares | 4.15 | 0.48 | 1.42 |
HFRX Global Hedge Fund Index (reflects deductions for fees and expenses, but not taxes) | 8.62 | 1.19 | 1.74 |
S&P 500® Index (reflects no deduction for fees, expenses or taxes) | 31.49 | 11.70 | 14.60 |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deduction for fees, expenses or taxes) | 8.72 | 3.05 | 2.79 |
After-tax returns are calculated using the historical highest individual federal marginal income tax rates and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ from those shown. After-tax returns are not relevant to investors who hold their Fund shares through tax-deferred arrangements, such as 401(k) plans or individual retirement accounts. Return After Taxes on Distributions and Sale of Fund Shares may be higher than other returns for the same period due to a tax benefit of realizing a capital loss upon the sale of Fund shares. |
(1) | Shows what this ratio would have been if there had been no expense reimbursement/repayment and/or waiver of a portion of the management fee. |
(2) | Would have been lower/higher if the Manager had not reimbursed/recouped certain expenses. |
(3) | Calculated based on the average number of shares outstanding during each fiscal period. |
■ | both accounts must have the same registration |
■ | you will need to observe any eligibility requirements, including minimum investment and minimum account balance requirements for the fund accounts involved |
■ | because an exchange is treated as a sale (redemption) of the exchanged shares for federal income tax purposes, consider any tax consequences before placing your order. |
■ | suspend the offering of shares |
■ | reject any exchange or purchase order |
■ | suspend or reject future purchase orders from any investor who has not provided timely payment to settle a purchase order |
■ | change, suspend, or revoke the exchange privilege |
■ | satisfy an order to sell Fund shares with securities rather than cash |
■ | suspend or postpone investors’ ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when trading on the New York Stock Exchange (“Exchange”) is restricted, or as otherwise permitted by the Securities and Exchange Commission (“SEC”) |
■ | suspend or postpone investors' ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when the Exchange or the bond market is closed |
■ | suspend or postpone investors' ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when the Exchange, the Federal Reserve or the bond market closes early (e.g., on the eve of a major holiday or because of a local emergency, such as a blizzard) |
■ | remain open and process orders to purchase or sell Fund shares when the Exchange is closed. |
■ | in unusual circumstances where the law allows additional time if needed |
■ | if a check you wrote to buy shares has not cleared by the time you sell those shares; clearance may take up to 15 calendar days from the date of purchase. |
■ | a discussion by the Portfolio Managers about strategies and market conditions that significantly affected the Fund’s performance during the last fiscal year |
■ | Fund performance data and financial statements |
■ | portfolio holdings. |
■ | various types of securities and practices, and their risks |
■ | investment limitations and additional policies |
■ | information about the Fund’s management and business structure. |
Class A | Class C |
Institutional
Class |
|||
Neuberger Berman Commodity Strategy Fund | NRBAX | NRBCX | NRBIX | ||
Neuberger Berman Global Allocation Fund | NGLAX | NGLCX | NGLIX | ||
Neuberger Berman Long Short Fund | NLSAX | NLSCX | NLSIX | ||
Neuberger Berman Multi-Asset Income Fund | NANAX | NANCX | NANIX | ||
Neuberger Berman Multi-Style Premia Fund | NMLAX | NMLCX | NMLIX | ||
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund | NUPAX | NUPCX | NUPIX |
Fund Summaries
|
|
Neuberger Berman Commodity Strategy Fund
|
2
|
Neuberger Berman Global Allocation Fund
|
12
|
Neuberger Berman Long Short Fund
|
28
|
Neuberger Berman Multi-Asset Income Fund
|
39
|
Neuberger Berman Multi-Style Premia Fund
|
53
|
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund
|
66
|
Descriptions of Certain Practices and Security Types
|
75
|
Additional Information about Principal Investment Risks
|
76
|
Information about Additional Risks and Other Practices
|
94
|
Descriptions of Indices
|
94
|
Management of the Funds
|
96
|
Financial Highlights
|
100
|
YOUR INVESTMENT
|
|
Choosing a Share Class
|
118
|
Maintaining Your Account
|
119
|
Share Prices
|
124
|
Privileges and Services
|
125
|
Sales Charges
|
125
|
Sales Charge Reductions and Waivers
|
127
|
Distributions and Taxes
|
130
|
Grandfathered Investors
|
132
|
Buying Shares—Grandfathered Investors
|
134
|
Selling Shares—Grandfathered Investors
|
135
|
Market Timing Policy
|
136
|
Portfolio Holdings Policy
|
136
|
Fund Structure
|
136
|
Appendix A
|
A-1
|
Class A | Class C | Institutional Class | |
Shareholder Fees (fees paid directly from your investment) | |||
Maximum initial sales charge on purchases (as a % of offering price) | 5.75 | None | None |
Maximum contingent deferred sales charge (as a % of the lower of original purchase price or current market value)1 | None | 1.00 | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |||
Management fees of Fund and Subsidiary (as defined below) | 0.76 | 0.76 | 0.65 |
Distribution and/or shareholder service (12b-1) fees | 0.25 | 1.00 | None |
Total other expenses | 0.36 | 0.56 | 0.32 |
Other expenses of Fund | 0.28 | 0.48 | 0.24 |
Other expenses of Subsidiary | 0.08 | 0.08 | 0.08 |
Total annual operating expenses | 1.37 | 2.32 | 0.97 |
Fee waiver and/or expense reimbursement | 0.27 | 0.47 | 0.23 |
Total annual operating expenses after fee waiver and/or expense reimbursement2 | 1.10 | 1.85 | 0.74 |
1 | For Class A shares, a contingent deferred sales charge (“CDSC”) of 1.00% applies on certain redemptions made within 18 months following purchases of $1 million or more made without an initial sales charge. For Class C shares, the CDSC is eliminated one year after purchase. |
2 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class A, Class C and Institutional Class so that the total annual operating expenses (excluding interest, taxes, brokerage commissions, acquired fund fees and expenses, dividend and interest expenses relating to short sales, and extraordinary expenses, if any) (“Operating Expenses”) of each class are limited to 1.09%, 1.84% and 0.73% of average net assets, respectively. Each of these undertakings lasts until 10/31/2023 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that each of Class A, Class C and Institutional Class will repay the Manager for fees and expenses waived or reimbursed for the class provided that repayment does not cause annual Operating Expenses to exceed 1.09%, 1.84% and 0.73% of the class’ average net assets, respectively. Any such repayment must be made within three years after the year in which the Manager incurred the expense. |
For purposes of the contractual expense limitations, Operating Expenses shall be deemed to include the Operating Expenses of the Fund's wholly owned Cayman Islands subsidiary (see the “Principal Investment Strategies” section). |
1 Year | 3 Years | 5 Years | 10 Years | |
Class A | $681 | $905 | $1,205 | $2,056 |
Class C (assuming redemption) | $288 | $582 | $1,105 | $2,540 |
Class C (assuming no redemption) | $188 | $582 | $1,105 | $2,540 |
Institutional Class | $76 | $237 | $465 | $1,123 |
Commodity Strategy Fund | 1 Year | 5 Years |
Since Inception
(8/27/2012) |
Institutional Class Return Before Taxes | 12.16 | -2.26 | -5.56 |
Institutional Class Return After Taxes on Distributions | 11.44 | -2.92 | -6.00 |
Institutional Class Return After Taxes on Distributions and Sale of Fund Shares | 7.20 | -1.99 | -4.22 |
Class A Return Before Taxes | 5.42 | -3.71 | -6.65 |
Class C Return Before Taxes | 9.81 | -3.48 | -6.72 |
Bloomberg Commodity Index (reflects no deduction for fees, expenses or taxes) | 7.69 | -3.92 | -6.96 |
After-tax returns are shown for Institutional Class shares only and after-tax returns for other classes may vary. After-tax returns are calculated using the historical highest individual federal marginal income tax rates and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ from those shown. After-tax returns are not relevant to investors who hold their Fund shares through tax-deferred arrangements, such as 401(k) plans or individual retirement accounts. Return After Taxes on Distributions and Sale of Fund Shares may be higher than other returns for the same period due to a tax benefit of realizing a capital loss upon the sale of Fund shares. |
Class A | Class C | Institutional Class | |
Shareholder Fees (fees paid directly from your investment) | |||
Maximum initial sales charge on purchases (as a % of offering price) | 5.75 | None | None |
Maximum contingent deferred sales charge (as a % of the lower of original purchase price or current market value)1 | None | 1.00 | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |||
Management fees | 0.81 | 0.81 | 0.70 |
Distribution and/or shareholder service (12b-1) fees | 0.25 | 1.00 | None |
Total other expenses | 2.68 | 2.66 | 2.65 |
Acquired fund fees and expenses | 0.36 | 0.36 | 0.36 |
Total annual operating expenses | 4.10 | 4.83 | 3.71 |
Fee waiver and/or expense reimbursement | 2.90 | 2.88 | 2.86 |
Total annual operating expenses after fee waiver and/or expense reimbursement2 | 1.20 | 1.95 | 0.85 |
1 | For Class A shares, a contingent deferred sales charge (“CDSC”) of 1.00% applies on certain redemptions made within 18 months following purchases of $1 million or more made without an initial sales charge. For Class C shares, the CDSC is eliminated one year after purchase. |
2 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class A, Class C and Institutional Class so that the total annual operating expenses (excluding interest, taxes, brokerage commissions, acquired fund fees and expenses, dividend and interest expenses relating to short sales, and extraordinary expenses, if any) (“annual operating expenses”) of each class are limited to 1.11%, 1.86% and 0.75% of average net assets, respectively. Each of these undertakings lasts until 10/31/2023 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that each of Class A, Class C and Institutional Class will repay the Manager for fees and expenses waived or reimbursed for the class provided that repayment does not cause annual operating expenses to exceed 1.11%, 1.86% and 0.75% of the class’ average net assets, respectively. Any such repayment must be made within three years after the year in which the Manager incurred the expense. In addition, for so long as the Fund invests any assets in an affiliated Underlying Fund (as defined below), the Manager undertakes to waive a portion of the Fund's advisory fee equal to the advisory fee it receives from such affiliated Underlying Fund on those assets. This undertaking may not be terminated without the consent of the Board of Trustees. |
1 Year | 3 Years | 5 Years | 10 Years | |
Class A | $690 | $934 | $1,806 | $4,056 |
Class C (assuming redemption) | $298 | $612 | $1,671 | $4,334 |
Class C (assuming no redemption) | $198 | $612 | $1,671 | $4,334 |
Institutional Class | $87 | $271 | $1,120 | $3,341 |
Global Allocation Fund | 1 Year | 5 Years |
Since Inception
(12/29/2010) |
Institutional Class Return Before Taxes | 18.54 | 4.80 | 5.96 |
Institutional Class Return After Taxes on Distributions | 17.43 | 3.87 | 4.50 |
Institutional Class Return After Taxes on Distributions and Sale of Fund Shares | 11.36 | 3.45 | 4.11 |
Class A Return Before Taxes | 11.37 | 3.20 | 4.89 |
Class C Return Before Taxes | 16.27 | 3.66 | 4.79 |
60% MSCI All Country World Index (Net) (reflects reinvested dividends net of withholding taxes, but reflects no deduction for fees, expenses or taxes) and 40% Bloomberg Barclays Global Aggregate Index (reflects no deduction for fees, expenses or taxes) | 18.55 | 6.11 | 6.11 |
MSCI All Country World Index (Net) (reflects reinvested dividends net of withholding taxes, but reflects no deduction for fees, expenses or taxes) | 26.60 | 8.41 | 8.43 |
After-tax returns are shown for Institutional Class shares only and after-tax returns for other classes may vary. After-tax returns are calculated using the historical highest individual federal marginal income tax rates and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ from those shown. After-tax returns are not relevant to investors who hold their Fund shares through tax-deferred arrangements, such as 401(k) plans or individual retirement accounts. |
Class A | Class C | Institutional Class | |
Shareholder Fees (fees paid directly from your investment) | |||
Maximum initial sales charge on purchases (as a % of offering price) | 5.75 | None | None |
Maximum contingent deferred sales charge (as a % of the lower of original purchase price or current market value)1 | None | 1.00 | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |||
Management fees | 1.37 | 1.37 | 1.26 |
Distribution and/or shareholder service (12b-1) fees | 0.25 | 1.00 | None |
Total other expenses | 0.52 | 0.52 | 0.52 |
Other expenses | 0.08 | 0.08 | 0.08 |
Dividend and interest expenses relating to short sales | 0.44 | 0.44 | 0.44 |
Total annual operating expenses | 2.14 | 2.89 | 1.78 |
1 | For Class A shares, a contingent deferred sales charge (“CDSC”) of 1.00% applies on certain redemptions made within 18 months following purchases of $1 million or more made without an initial sales charge. For Class C shares, the CDSC is eliminated one year after purchase. |
1 Year | 3 Years | 5 Years | 10 Years | |
Class A | $780 | $1,206 | $1,658 | $2,905 |
Class C (assuming redemption) | $392 | $895 | $1,523 | $3,214 |
Class C (assuming no redemption) | $292 | $895 | $1,523 | $3,214 |
Institutional Class | $181 | $560 | $964 | $2,095 |
Long Short Fund | 1 Year | 5 Years |
Since Inception
(12/29/2011) |
Institutional Class Return Before Taxes | 17.12 | 4.27 | 6.28 |
Institutional Class Return After Taxes on Distributions | 16.46 | 3.87 | 5.95 |
Institutional Class Return After Taxes on Distributions and Sale of Fund Shares | 10.60 | 3.28 | 4.96 |
Class A Return Before Taxes | 10.06 | 2.66 | 5.12 |
Class C Return Before Taxes | 14.84 | 3.12 | 5.11 |
HFRX Equity Hedge Index (reflects deductions for fees and expenses, but reflects no deduction for taxes) | 10.71 | 1.52 | 3.10 |
S&P 500® Index (reflects no deduction for fees, expenses or taxes) | 31.49 | 11.70 | 14.95 |
After-tax returns are shown for Institutional Class shares only and after-tax returns for other classes may vary. After-tax returns are calculated using the historical highest individual federal marginal income tax rates and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ from those shown. After-tax returns are not relevant to investors who hold their Fund shares through tax-deferred arrangements, such as 401(k) plans or individual retirement accounts. |
Class A | Class C | Institutional Class | |
Shareholder Fees (fees paid directly from your investment) | |||
Maximum initial sales charge on purchases (as a % of offering price) | 4.25 | None | None |
Maximum contingent deferred sales charge (as a % of the lower of original purchase price or current market value)1 | None | 1.00 | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |||
Management fees | 0.72 | 0.72 | 0.60 |
Distribution and/or shareholder service (12b-1) fees | 0.25 | 1.00 | None |
Other expenses | 2.02 | 1.97 | 1.96 |
Acquired fund fees and expenses | 0.13 | 0.13 | 0.13 |
Total annual operating expenses | 3.12 | 3.82 | 2.69 |
Fee waiver and/or expense reimbursement | 2.05 | 2.00 | 1.99 |
Total annual operating expenses after fee waiver and/or expense reimbursement2 | 1.07 | 1.82 | 0.70 |
1 | For Class A shares, a contingent deferred sales charge (“CDSC”) of 1.00% applies on certain redemptions made within 18 months following purchases of $1 million or more made without an initial sales charge. For Class C shares, the CDSC is eliminated one year after purchase. |
2 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class A, Class C and Institutional Class so that the total annual operating expenses (excluding interest, taxes, brokerage commissions, acquired fund fees and expenses, dividend and interest expenses relating to short sales, and extraordinary expenses, if any) (“annual operating expenses”) of each class are limited to 1.02%, 1.77% and 0.65% of average net assets, respectively. Each of these undertakings lasts until 10/31/2023 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that each of Class A, Class C and Institutional Class will repay the Manager for fees and expenses waived or reimbursed for the class provided that repayment does not cause annual operating expenses to exceed 1.02%, 1.77% and 0.65% of the class’ average net assets, respectively. Any such repayment must be made within three years after the year in which the Manager incurred the expense. In addition, for so long as the Fund invests any assets in an affiliated Underlying Fund (as defined below), the Manager undertakes to waive a portion of the Fund’s advisory fee equal to the advisory fee it receives from such affiliated Underlying Fund on those assets. This undertaking may not be terminated without the consent of the Board of Trustees. |
1 Year | 3 Years | 5 Years | 10 Years | |
Class A | $529 | $751 | $1,434 | $3,258 |
Class C (assuming redemption) | $285 | $573 | $1,025 | $2,281 |
Class C (assuming no redemption) | $185 | $573 | $1,025 | $2,281 |
Institutional Class | $72 | $224 | $848 | $2,541 |
Multi-Asset Income Fund | 1 Year |
Since Inception
(3/27/2015) |
Institutional Class Return Before Taxes | 13.20 | 4.13 |
Institutional Class Return After Taxes on Distributions | 12.08 | 2.85 |
Institutional Class Return After Taxes on Distributions and Sale of Fund Shares | 8.43 | 2.82 |
Class A Return Before Taxes | 7.98 | 2.82 |
Class C Return Before Taxes | 10.95 | 2.98 |
60% Bloomberg Barclays U.S. Aggregate Bond Index and 40% S&P 500® Index (reflects no deduction for fees, expenses or taxes) | 17.62 | 6.76 |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deduction for fees, expenses or taxes) | 8.72 | 2.95 |
After-tax returns are shown for Institutional Class shares only and after-tax returns for other classes may vary. After-tax returns are calculated using the historical highest individual federal marginal income tax rates and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ from those shown. After-tax returns are not relevant to investors who hold their Fund shares through tax-deferred arrangements, such as 401(k) plans or individual retirement accounts. |
Class A | Class C | Institutional Class | |
Shareholder Fees (fees paid directly from your investment) | |||
Maximum initial sales charge on purchases (as a % of offering price) | 5.75 | None | None |
Maximum contingent deferred sales charge (as a % of the lower of original purchase price or current market value)1 | None | 1.00 | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |||
Management fees of Fund and Subsidiary (as defined below) | 0.91 | 0.91 | 0.80 |
Distribution and/or shareholder service (12b-1) fees | 0.25 | 1.00 | None |
Total other expenses2 | 4.08 | 3.59 | 3.65 |
Other expenses of Fund | 3.51 | 3.02 | 3.08 |
Other expenses of Subsidiary | 0.57 | 0.57 | 0.57 |
Acquired fund fees and expenses | 0.04 | 0.04 | 0.04 |
Total annual operating expenses | 5.28 | 5.54 | 4.49 |
Fee waiver and/or expense reimbursement | 3.93 | 3.44 | 3.50 |
Total annual operating expenses after fee waiver and/or expense reimbursement2 | 1.35 | 2.10 | 0.99 |
1 | For Class A shares, a contingent deferred sales charge (“CDSC”) of 1.00% applies on certain redemptions made within 18 months following purchases of $1 million or more made without an initial sales charge. For Class C shares, the CDSC is eliminated one year after purchase. |
2 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class A, Class C and Institutional Class so that the total annual operating expenses (excluding interest, taxes, brokerage commissions, acquired fund fees and expenses, dividend and interest expenses relating to short sales, and extraordinary expenses, if any) of each class are limited to 1.31%, 2.06% and 0.95% of average net assets, respectively. Each of these undertakings lasts until 10/31/2023 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that each of Class A, Class C and Institutional Class will repay the Manager for fees and expenses waived or reimbursed for the class provided that repayment does not cause annual operating expenses to exceed 1.31%, 2.06% and 0.95% of the class’ average net assets, respectively. Any such repayment must be made within three years after the year in which the Manager incurred the expense. |
For purposes of the contractual expense limitations, Operating Expenses shall be deemed to include the Operating Expenses of the Fund’s wholly owned Cayman Islands subsidiary (see the “Principal Investment Strategies” section). |
1 Year | 3 Years | 5 Years | 10 Years | |
Class A | $705 | $978 | $2,083 | $4,819 |
Class C (assuming redemption) | $313 | $658 | $1,859 | $4,804 |
Class C (assuming no redemption) | $213 | $658 | $1,859 | $4,804 |
Institutional Class | $101 | $315 | $1,331 | $3,915 |
Multi-Style Premia Fund | 1 Year |
Since Inception
(5/18/2018) |
Institutional Class Return Before Taxes | 6.32 | 1.69 |
Institutional Class Return After Taxes on Distributions | 3.85 | -1.08 |
Institutional Class Return After Taxes on Distributions and Sale of Fund Shares | 3.96 | 0.22 |
Class A Return Before Taxes | -0.13 | -2.30 |
Class C Return Before Taxes | 4.18 | 0.59 |
ICE BofA 3-Month U.S. Treasury Bill Index* (reflects no deduction for fees, expenses or taxes) | 2.28 | 2.21 |
After-tax returns are shown for Institutional Class shares only and after-tax returns for other classes may vary. After-tax returns are calculated using the historical highest individual federal marginal income tax rates and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ from those shown. After-tax returns are not relevant to investors who hold their Fund shares through tax-deferred arrangements, such as 401(k) plans or individual retirement accounts. Return After Taxes on Distributions and Sale of Fund Shares may be higher than other returns for the same period due to a tax benefit of realizing a capital loss upon the sale of Fund shares. |
Class A | Class C | Institutional Class | |
Shareholder Fees (fees paid directly from your investment) | |||
Maximum initial sales charge on purchases (as a % of offering price) | 5.75 | None | None |
Maximum contingent deferred sales charge (as a % of the lower of original purchase price or current market value)1 | None | 1.00 | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |||
Management fees | 0.71 | 0.71 | 0.60 |
Distribution and/or shareholder service (12b-1) fees | 0.25 | 1.00 | None |
Other expenses | 0.17 | 0.21 | 0.17 |
Total annual operating expenses | 1.13 | 1.92 | 0.77 |
Fee waiver and/or expense reimbursement | 0.11 | 0.15 | 0.11 |
Total annual operating expenses after fee waiver and/or expense reimbursement2 | 1.02 | 1.77 | 0.66 |
1 | For Class A shares, a contingent deferred sales charge (“CDSC”) of 1.00% applies on certain redemptions made within 18 months following purchases of $1 million or more made without an initial sales charge. For Class C shares, the CDSC is eliminated one year after purchase. |
2 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class A, Class C and Institutional Class so that the total annual operating expenses (excluding interest, taxes, brokerage commissions, acquired fund fees and expenses, dividend and interest expenses relating to short sales, and extraordinary expenses, if any) (“annual operating expenses”) of each class are limited to 1.01%, 1.76% and 0.65% of average net assets, respectively. Each of these undertakings lasts until 10/31/2023 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that each of Class A, Class C and Institutional Class will repay the Manager for fees and expenses waived or reimbursed for the class provided that repayment does not cause annual operating expenses to exceed 1.01%, 1.76% and 0.65% of the class’ average net assets, respectively. Any such repayment must be made within three years after the year in which the Manager incurred the expense. |
1 Year | 3 Years | 5 Years | 10 Years | |
Class A | $673 | $881 | $1,130 | $1,841 |
Class C (assuming redemption) | $280 | $557 | $993 | $2,205 |
Class C (assuming no redemption) | $180 | $557 | $993 | $2,205 |
Institutional Class | $67 | $211 | $394 | $922 |
U.S. Equity Index PutWrite Strategy Fund | 1 Year |
Since Inception
(9/16/2016) |
Institutional Class Return Before Taxes | 16.13 | 7.41 |
Institutional Class Return After Taxes on Distributions | 14.00 | 6.00 |
Institutional Class Return After Taxes on Distributions and Sale of Fund Shares | 9.92 | 5.27 |
Class A Return Before Taxes | 9.06 | 5.14 |
Class C Return Before Taxes | 13.82 | 6.24 |
42.5% CBOE S&P 500 One-Week PutWrite Index/42.5% CBOE S&P 500 PutWrite Index/7.5% CBOE Russell 2000 One-Week PutWrite Index/7.5% CBOE Russell 2000 PutWrite Index (reflects no deduction for fees, expenses or taxes) | 14.01 | 4.72 |
85% S&P 500® Index and 15% Russell 2000® Index (reflects no deduction for fees, expenses or taxes) | 30.61 | 14.90 |
After-tax returns are shown for Institutional Class shares only and after-tax returns for other classes may vary. After-tax returns are calculated using the historical highest individual federal marginal income tax rates and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ from those shown. After-tax returns are not relevant to investors who hold their Fund shares through tax-deferred arrangements, such as 401(k) plans or individual retirement accounts. |
YEAR ENDED OCTOBER 31, | 2015 | 2016 | 2017 | 2018 | 2019 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 8.32 | 6.12 | 5.90 | 6.24 | 6.07 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | (0.07) | (0.05) | — | 0.06 | 0.09 |
Net gains (losses)—realized and unrealized | (2.13) | (0.17) | 0.34 | (0.01) | (0.14) |
Subtotal: income (loss) from investment operations | (2.20) | (0.22) | 0.34 | 0.05 | (0.05) |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | — | — | 0.22 | 0.13 |
Subtotal: distributions to shareholders | 0.00 | — | — | 0.22 | 0.13 |
Equals: | |||||
Share price (NAV) at end of year | 6.12 | 5.90 | 6.24 | 6.07 | 5.89 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund’s expenses and net investment income (loss)—as they actually are as well as how they would have been if certain expense reimbursement arrangements had not been in effect. | |||||
Net expenses—actual | 1.46 | 1.46 | 1.21 | 1.10 | 1.09 |
Gross expenses(1) | 1.84 | 2.04 | 1.56 | 1.35 | 1.37 |
Net investment income (loss)—actual | (1.05) | (0.82) | (0.02) | 0.95 | 1.65 |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(2)(4) | (26.43) | (3.59) | 5.76 | 0.81 | (0.64) |
Net assets at end of year (in millions of dollars) | 35.5 | 33.3 | 42.4 | 47.9 | 22.5 |
Portfolio turnover rate (%) | 35 | 58 | 105 | 107 | 88 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement. |
(2) | Would have been lower if the Manager had not reimbursed certain expenses. |
(3) | The per share amounts have been calculated based on the average number of shares outstanding during each fiscal period. |
(4) | Does not include the effect of sales charges. |
YEAR ENDED OCTOBER 31, | 2015 | 2016 | 2017 | 2018 | 2019 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 8.19 | 5.98 | 5.71 | 5.95 | 5.83 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | (0.12) | (0.09) | (0.05) | 0.01 | 0.05 |
Net gains (losses)—realized and unrealized | (2.09) | (0.18) | 0.29 | — | (0.14) |
Subtotal: income (loss) from investment operations | (2.21) | (0.27) | 0.24 | 0.01 | (0.09) |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | — | — | 0.13 | 0.08 |
Subtotal: distributions to shareholders | 0.00 | — | — | 0.13 | 0.08 |
Equals: | |||||
Share price (NAV) at end of year | 5.98 | 5.71 | 5.95 | 5.83 | 5.66 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund’s expenses and net investment income (loss)—as they actually are as well as how they would have been if certain expense reimbursement arrangements had not been in effect. | |||||
Net expenses—actual | 2.21 | 2.21 | 2.03 | 1.85 | 1.84 |
Gross expenses(1) | 2.70 | 3.06 | 3.20 | 2.34 | 2.32 |
Net investment income (loss)—actual | (1.79) | (1.65) | (0.92) | 0.19 | 0.88 |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(2)(4) | (26.98) | (4.52) | 4.20 | 0.15 | (1.51) |
Net assets at end of year (in millions of dollars) | 3.1 | 0.1 | 0.0 | 0.0 | 0.0 |
Portfolio turnover rate (%) | 35 | 58 | 105 | 107 | 88 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement. |
(2) | Would have been lower if the Manager had not reimbursed certain expenses. |
(3) | The per share amounts have been calculated based on the average number of shares outstanding during each fiscal period. |
(4) | Does not include the effect of sales charges. |
(1) | Shows what this ratio would have been if there had been no expense reimbursement. |
(2) | Would have been lower if the Manager had not reimbursed certain expenses. |
(3) | The per share amounts have been calculated based on the average number of shares outstanding during each fiscal period. |
YEAR ENDED OCTOBER 31, | 2015 | 2016 | 2017 | 2018 | 2019 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 10.76 | 10.36 | 10.40 | 12.04 | 11.05 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | 0.02 | 0.06 | 0.14 | 0.20 | 0.20 |
Net gains (losses)—realized and unrealized | (0.18) | — | 1.50 | (0.59) | 0.79 |
Subtotal: income (loss) from investment operations | (0.16) | 0.06 | 1.64 | (0.39) | 0.99 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | 0.24 | — | — | 0.18 | 0.20 |
Net capital gains | — | 0.02 | — | 0.42 | 0.29 |
Subtotal: distributions to shareholders | 0.24 | 0.02 | — | 0.60 | 0.49 |
Equals: | |||||
Share price (NAV) at end of year | 10.36 | 10.40 | 12.04 | 11.05 | 11.55 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund’s expenses and net investment income (loss)—as they actually are as well as how they would have been if certain expense reimbursement and/or waiver arrangements had not been in effect. | |||||
Net expenses—actual | 1.39 | 1.49 | 0.89 | 0.82 | 0.84 |
Net expenses (excluding expenses on securities sold short)—actual | 1.04 | 0.96 | 0.84 | 0.82 | 0.84 |
Gross expenses(1) | 3.69 | 4.53 | 4.10 | 3.46 | 3.74 |
Gross expenses (excluding expenses on securities sold short)(1) | 3.34 | 4.01 | 4.05 | 3.46 | 3.74 |
Net investment income (loss)—actual | 0.16 | 0.64 | 1.27 | 1.70 | 1.79 |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(2)(4) | (1.52) | 0.59 | 15.77 | (3.49) | 9.70 |
Net assets at end of year (in millions of dollars) | 8.1 | 5.9 | 3.9 | 2.8 | 2.1 |
Portfolio turnover rate (including securities sold short)(%)(5) | 195 | 176 | 113 | 59 | 74 |
Portfolio turnover rate (excluding securities sold short)(%)(5) | 185 | 174 | 101 | 59 | 74 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement and/or waiver of a portion of the investment management fee. |
(2) | Would have been lower if the Manager had not reimbursed certain expenses and/or waived a portion of the investment management fee. |
(3) | The per share amounts have been calculated based on the average number of shares outstanding during each fiscal period. |
(4) | Does not include the effect of sales charges. |
(5) | The portfolio turnover rates including mortgage dollar roll transactions, including and excluding securities sold short, were 159%, and 159%, respectively, for the year ended October 31, 2019, 129% and 129%, respectively, for the year ended October 31, 2018, 165% and 154%, respectively, for the year ended October 31, 2017, 182% and 183%, respectively, for the year ended October 31, 2016 and 198% and 189%, respectively, for the year ended October 31, 2015. |
YEAR ENDED OCTOBER 31, | 2015 | 2016 | 2017 | 2018 | 2019 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 10.60 | 10.18 | 10.14 | 11.66 | 10.70 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | (0.06) | (0.01) | 0.05 | 0.11 | 0.11 |
Net gains (losses)—realized and unrealized | (0.18) | (0.01) | 1.47 | (0.58) | 0.79 |
Subtotal: income (loss) from investment operations | (0.24) | (0.02) | 1.52 | (0.47) | 0.90 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | 0.18 | — | — | 0.07 | 0.11 |
Net capital gains | — | 0.02 | — | 0.42 | 0.29 |
Subtotal: distributions to shareholders | 0.18 | 0.02 | — | 0.49 | 0.40 |
Equals: | |||||
Share price (NAV) at end of year | 10.18 | 10.14 | 11.66 | 10.70 | 11.20 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund’s expenses and net investment income (loss)—as they actually are as well as how they would have been if certain expense reimbursement and/or waiver arrangements had not been in effect. | |||||
Net expenses—actual | 2.14 | 2.24 | 1.63 | 1.57 | 1.59 |
Net expenses (excluding expenses on securities sold short)—actual | 1.79 | 1.71 | 1.59 | 1.57 | 1.59 |
Gross expenses(1) | 4.45 | 5.26 | 4.84 | 4.18 | 4.47 |
Gross expenses (excluding expenses on securities sold short)(1) | 4.10 | 4.74 | 4.79 | 4.18 | 4.47 |
Net investment income (loss)—actual | (0.57) | (0.10) | 0.50 | 0.92 | 1.01 |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(2)(4) | (2.29) | (0.19) | 14.99 | (4.25) | 8.97 |
Net assets at end of year (in millions of dollars) | 6.6 | 4.7 | 3.2 | 2.3 | 1.8 |
Portfolio turnover rate (including securities sold short)(%)(5) | 195 | 176 | 113 | 59 | 74 |
Portfolio turnover rate (excluding securities sold short)(%)(5) | 185 | 174 | 101 | 59 | 74 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement and/or waiver of a portion of the investment management fee. |
(2) | Would have been lower if the Manager had not reimbursed certain expenses and/or waived a portion of the investment management fee. |
(3) | The per share amounts have been calculated based on the average number of shares outstanding during each fiscal period. |
(4) | Does not include the effect of sales charges. |
(5) | The portfolio turnover rates including mortgage dollar roll transactions, including and excluding securities sold short, were 159%, and 159%, respectively, for the year ended October 31, 2019, 129% and 129%, respectively, for the year ended October 31, 2018, 165% and 154%, respectively, for the year ended October 31, 2017, 182% and 183%, respectively, for the year ended October 31, 2016 and 198% and 189%, respectively, for the year ended October 31, 2015. |
(1) | Shows what this ratio would have been if there had been no expense reimbursement and/or waiver of a portion of the investment management fee. |
(2) | Would have been lower if the Manager had not reimbursed certain expenses and/or waived a portion of the investment management fee. |
(3) | The per share amounts have been calculated based on the average number of shares outstanding during each fiscal period. |
(4) | The portfolio turnover rates including mortgage dollar roll transactions, including and excluding securities sold short, were 159%, and 159%, respectively, for the year ended October 31, 2019, 129% and 129%, respectively, for the year ended October 31, 2018, 165% and 154%, respectively, for the year ended October 31, 2017, 182% and 183%, respectively, for the year ended October 31, 2016 and 198% and 189%, respectively, for the year ended October 31, 2015. |
YEAR ENDED OCTOBER 31, | 2015 | 2016 | 2017 | 2018 | 2019 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 13.18 | 12.89 | 12.83 | 14.26 | 14.54 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | (0.03) | (0.07) | (0.02) | (0.02) | (0.01) |
Net gains (losses)—realized and unrealized | (0.21) | 0.01 | 1.45 | 0.30 | 0.84 |
Subtotal: income (loss) from investment operations | (0.24) | (0.06) | 1.43 | 0.28 | 0.83 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | — | — | — | — |
Capital gain distributions | 0.05 | — | — | — | 0.76 |
Subtotal: distributions to shareholders | 0.05 | — | — | — | 0.76 |
Equals: | |||||
Share price (NAV) at end of year | 12.89 | 12.83 | 14.26 | 14.54 | 14.61 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund’s expenses and net investment income (loss)—as they actually are as well as how they would have been if certain expense reimbursement/repayment and offset arrangements had not been in effect. | |||||
Net expenses—actual | 2.03 | 2.28 | 2.16 | 1.96 | 2.13 |
Net expenses (excluding expenses on securities sold short)—actual | 1.68 | 1.69 | 1.68 | 1.67 | 1.69 |
Gross expenses | 2.03 | 2.28 | 2.16(1) | 1.96 | 2.13 |
Gross expenses (excluding expenses on securities sold short) | 1.68 | 1.69 | 1.68(1) | 1.67 | 1.69 |
Net investment income (loss)—actual | (0.20) | (0.59) | (0.18) | (0.13) | (0.08) |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(2)(4) | (1.89) | (0.48) | 11.15 | 2.01 | 6.54 |
Net assets at end of year (in millions of dollars) | 361.7 | 206.4 | 145.6 | 105.9 | 63.6 |
Portfolio turnover rate (including securities sold short)(%) | 91 | 86 | 80 | 83 | 66 |
Portfolio turnover rate (excluding securities sold short)(%) | 69 | 72 | 64 | 69 | 47 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement/repayment of a portion of the investment management fee. |
(2) | Would have been lower/higher if the Manager had not reimbursed/recouped certain expenses. |
(3) | The per share amounts have been calculated based on the average number of shares outstanding during each fiscal period. |
(4) | Does not include the effect of sales charges. |
YEAR ENDED OCTOBER 31, | 2015 | 2016 | 2017 | 2018 | 2019 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 13.57 | 13.18 | 13.00 | 14.34 | 14.53 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | (0.13) | (0.18) | (0.13) | (0.13) | (0.12) |
Net gains (losses)—realized and unrealized | (0.21) | — | 1.47 | 0.32 | 0.84 |
Subtotal: income (loss) from investment operations | (0.34) | (0.18) | 1.34 | 0.19 | 0.72 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | — | — | — | — |
Capital gain distributions | 0.05 | — | — | — | (0.76) |
Subtotal: distributions to shareholders | 0.05 | — | — | — | (0.76) |
Equals: | |||||
Share price (NAV) at end of year | 13.18 | 13.00 | 14.34 | 14.53 | 14.49 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund’s expenses and net investment income (loss)—as they actually are as well as how they would have been if certain expense reimbursement/repayment and offset arrangements had not been in effect. | |||||
Net expenses—actual | 2.77 | 3.02 | 2.90 | 2.71 | 2.88 |
Net expenses (excluding expenses on securities sold short)—actual | 2.42 | 2.44 | 2.43 | 2.42 | 2.44 |
Gross expenses | 2.77 | 3.02 | 2.90(1) | 2.71 | 2.88 |
Gross expenses (excluding expenses on securities sold short)—actual | 2.42 | 2.44 | 2.43(1) | 2.42 | 2.44 |
Net investment income (loss)—actual | (0.94) | (1.33) | (0.94) | (0.88) | (0.82) |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(2)(4) | (2.56) | (1.30) | 10.31 | 1.27 | 5.79 |
Net assets at end of year (in millions of dollars) | 190.6 | 117.3 | 92.7 | 77.6 | 61.4 |
Portfolio turnover rate (including securities sold short)(%) | 91 | 86 | 80 | 83 | 66 |
Portfolio turnover rate (excluding securities sold short)(%) | 69 | 72 | 64 | 69 | 47 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement/repayment of a portion of the investment management fee. |
(2) | Would have been lower/higher if the Manager had not reimbursed/recouped certain expenses. |
(3) | The per share amounts have been calculated based on the average number of shares outstanding during each fiscal period. |
(4) | Does not include the effect of sales charges. |
YEAR ENDED OCTOBER 31, | 2015 | 2016 | 2017 | 2018 | 2019 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 13.02 | 12.76 | 12.74 | 14.21 | 14.54 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | 0.02 | (0.03) | 0.02 | 0.03 | 0.04 |
Net gains (losses)—realized and unrealized | (0.21) | 0.01 | 1.45 | 0.30 | 0.85 |
Subtotal: income (loss) from investment operations | (0.19) | (0.02) | 1.47 | 0.33 | 0.89 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | 0.02 | (0.00) | — | — | — |
Capital gain distributions | 0.05 | — | — | — | 0.76 |
Subtotal: distributions to shareholders | 0.07 | (0.00) | — | — | 0.76 |
Equals: | |||||
Share price (NAV) at end of year | 12.76 | 12.74 | 14.21 | 14.54 | 14.67 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund’s expenses and net investment income (loss)—as they actually are as well as how they would have been if certain expense reimbursement/repayment and offset arrangements had not been in effect. | |||||
Net expenses—actual | 1.66 | 1.91 | 1.80 | 1.60 | 1.78 |
Net expenses (excluding expenses on securities sold short)—actual | 1.31 | 1.33 | 1.32 | 1.31 | 1.33 |
Gross expenses | 1.66 | 1.91 | 1.80(1) | 1.60 | 1.78 |
Gross expenses (excluding expenses on securities sold short)—actual | 1.31 | 1.33 | 1.33(1) | 1.31 | 1.33 |
Net investment income (loss)—actual | 0.16 | (0.22) | 0.12 | 0.23 | 0.28 |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(2) | (1.45) | (0.14) | 11.54 | 2.32 | 6.98 |
Net assets at end of year (in millions of dollars) | 2,719.8 | 2,074.7 | 2,853.0 | 2,847.3 | 2,098.0 |
Portfolio turnover rate (including securities sold short)(%) | 91 | 86 | 80 | 83 | 66 |
Portfolio turnover rate (excluding securities sold short)(%) | 69 | 72 | 64 | 69 | 47 |
(1) | Shows what this ratio would have been if there had been no expense reimbursement/repayment of a portion of the investment management fee. |
(2) | Would have been lower/higher if the Manager had not reimbursed/recouped certain expenses. |
(3) | The per share amounts have been calculated based on the average number of shares outstanding during each fiscal period. |
YEAR ENDED OCTOBER 31, | 2015(1) | 2016 | 2017 | 2018 | 2019 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 10.00 | 9.43 | 9.60 | 10.18 | 9.58 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(6) | 0.20 | 0.28 | 0.29 | 0.29 | 0.31 |
Net gains (losses)—realized and unrealized | (0.56) | 0.24 | 0.61 | (0.51) | 0.36 |
Subtotal: income (loss) from investment operations | (0.36) | 0.52 | 0.90 | (0.22) | 0.67 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | 0.21 | 0.26 | 0.31 | 0.31 | 0.26 |
Capital gain distributions | — | — | — | — | — |
Tax return of capital | — | 0.09 | 0.01 | 0.07 | 0.09 |
Subtotal: distributions to shareholders | 0.21 | 0.35 | 0.32 | 0.38 | 0.35 |
Equals: | |||||
Share price (NAV) at end of year | 9.43 | 9.60 | 10.18 | 9.58 | 9.90 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund’s expenses and net investment income (loss)—as they actually are as well as how they would have been if certain expense reimbursement and/or waiver arrangements had not been in effect. | |||||
Net expenses—actual | 0.79(4)(7) | 0.81 | 0.86 | 0.92 | 0.94 |
Gross expenses(2) | 4.55(4)(7) | 4.27 | 3.47 | 2.97 | 2.99 |
Net investment income (loss)—actual | 3.50(4)(7) | 2.98 | 2.90 | 2.94 | 3.17 |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(3)(8) | (3.64)(5) | 5.70 | 9.53 | (2.28) | 7.14 |
Net assets at end of year (in millions of dollars) | 0.50 | 0.60 | 0.60 | 0.7 | 0.7 |
Portfolio turnover rate (%) | 33(5) | 94 | 84(9) | 74(9) | 74(9) |
(1) | Period from 3/27/2015 (beginning of operations) to 10/31/2015. |
(2) | Shows what this ratio would have been if there had been no expense reimbursement and/or waiver of a portion of the investment management fee. |
(3) | Would have been lower if the Manager had not reimbursed certain expenses and/or waived a portion of the investment management fee. |
(4) | Annualized. |
(5) | Not annualized. |
(6) | The per share amounts have been calculated based on the average number of shares outstanding during the fiscal period. |
(7) | Organization expenses, which are non-recurring expenses, are included in the ratio on a non-annualized basis. |
(8) | Does not include the effect of sales charges. |
(9) | The portfolio turnover rates including mortgage dollar roll transactions were 212%, 192% and 165% for the years ended October 31, 2019, 2018 and 2017, respectively. |
YEAR ENDED OCTOBER 31, | 2015(1) | 2016 | 2017 | 2018 | 2019 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 10.00 | 9.43 | 9.60 | 10.18 | 9.58 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(6) | 0.16 | 0.20 | 0.21 | 0.22 | 0.24 |
Net gains (losses)—realized and unrealized | (0.56) | 0.25 | 0.62 | (0.52) | 0.36 |
Subtotal: income (loss) from investment operations | (0.40) | 0.45 | 0.83 | (0.30) | 0.60 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | 0.17 | 0.19 | 0.24 | 0.23 | 0.19 |
Capital gain distributions | — | — | — | — | — |
Tax return of capital | — | 0.09 | 0.01 | 0.07 | 0.09 |
Subtotal: distributions to shareholders | 0.17 | 0.28 | 0.25 | 0.30 | 0.28 |
Equals: | |||||
Share price (NAV) at end of year | 9.43 | 9.60 | 10.18 | 9.58 | 9.90 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund’s expenses and net investment income (loss)—as they actually are as well as how they would have been if certain expense reimbursement and/or waiver arrangements had not been in effect. | |||||
Net expenses—actual | 1.53(4)(7) | 1.56 | 1.62 | 1.67 | 1.69 |
Gross expenses(2) | 5.29(4)(7) | 4.99 | 4.16 | 3.69 | 3.69 |
Net investment income (loss)—actual | 2.76(4)(7) | 2.20 | 2.15 | 2.17 | 2.42 |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(3)(8) | (4.07)(5) | 4.91 | 8.71 | (3.02) | 6.35 |
Net assets at end of year (in millions of dollars) | 0.5 | 0.6 | 0.7 | 0.6 | 0.7 |
Portfolio turnover rate (%) | 33(5) | 94 | 84(9) | 74(9) | 74(9) |
(1) | Period from 3/27/2015 (beginning of operations) to 10/31/2015. |
(2) | Shows what this ratio would have been if there had been no expense reimbursement and/or waiver of a portion of the investment management fee. |
(3) | Would have been lower if the Manager had not reimbursed certain expenses and/or waived a portion of the investment management fee. |
(4) | Annualized. |
(5) | Not annualized. |
(6) | The per share amounts have been calculated based on the average number of shares outstanding during the fiscal period. |
(7) | Organization expenses, which are non-recurring expenses, are included in the ratio on a non-annualized basis. |
(8) | Does not include the effect of sales charges. |
(9) | The portfolio turnover rates including mortgage dollar roll transactions were 212%, 192% and 165% for the years ended October 31, 2019, 2018 and 2017, respectively. |
(1) | Period from 3/27/2015 (beginning of operations) to 10/31/2015. |
(2) | Shows what this ratio would have been if there had been no expense reimbursement and/or waiver of a portion of the investment management fee. |
(3) | Would have been lower if the Manager had not reimbursed certain expenses and/or waived a portion of the investment management fee. |
(4) | Annualized. |
(5) | Not annualized. |
(6) | The per share amounts have been calculated based on the average number of shares outstanding during the fiscal period. |
(7) | Organization expenses, which are non-recurring expenses, are included in the ratio on a non-annualized basis. |
(8) | The portfolio turnover rates including mortgage dollar roll transactions were 212%, 192% and 165% for the years ended October 31, 2019, 2018 and 2017, respectively. |
YEAR ENDED OCTOBER 31, | 2018(1) | 2019 |
PER-SHARE DATA ($) | ||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | ||
Share price (NAV) at beginning of year | 25.00 | 24.67 |
Plus: | ||
Income from investment operations | ||
Net investment income (loss)(6) | 0.06 | 0.16 |
Net gains (losses)—realized and unrealized | (0.39) | 0.64 |
Subtotal: income from investment operations | (0.33) | 0.80 |
Minus: | ||
Distributions to shareholders | ||
Income dividends | — | 1.30 |
Capital gain distributions | — | — |
Subtotal: distributions to shareholders | — | 1.30 |
Equals: | ||
Share price (NAV) at end of year | 24.67 | 24.17 |
RATIOS (% OF AVERAGE NET ASSETS) | ||
The ratios show the Fund's expenses and net investment income (loss)—as they actually are as well as how they would have been if certain expense reimbursement and/or waiver arrangements had not been in effect. | ||
Net expenses—actual | 1.31(4)(7) | 1.31 |
Gross expenses(2) | 5.87(4)(7) | 5.24 |
Net investment income (loss)—actual | 0.57(4)(7) | 0.68 |
OTHER DATA | ||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | ||
Total return (%)(3)(8) | (1.32)(5) | 3.59 |
Net assets at end of year (in millions of dollars) | 0.0 | 0.3 |
Portfolio turnover rate (%) | 31)(5) | 103 |
(1) | Period from 5/18/2018 (beginning of operations) to 10/31/2018. |
(2) | Shows what this ratio would have been if there had been no expense reimbursement and/or waiver of a portion of the investment management fee. |
(3) | Would have been lower if the Manager had not reimbursed certain expenses and/or waived a portion of the investment management fee. |
(4) | Annualized. |
(5) | Not annualized. |
(6) | The per share amounts have been calculated based on the average number of shares outstanding during the fiscal period. |
(7) | Organization expenses, which are non-recurring expenses, are included in the ration on a non-annualized basis. |
(8) | Does not include the effect of sales charges. |
YEAR ENDED OCTOBER 31, | 2018(1) | 2019 |
PER-SHARE DATA ($) | ||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | ||
Share price (NAV) at beginning of year | 25.00 | 24.59 |
Plus: | ||
Income from investment operations | ||
Net investment income (loss)(6) | (0.02) | (0.00) |
Net gains (losses)—realized and unrealized | (0.39) | 0.62 |
Subtotal: income from investment operations | (0.41) | 0.62 |
Minus: | ||
Distributions to shareholders | ||
Income dividends | — | 1.17 |
Capital gain distributions | — | — |
Subtotal: distributions to shareholders | — | 1.17 |
Equals: | ||
Share price (NAV) at end of year | 24.59 | 24.04 |
RATIOS (% OF AVERAGE NET ASSETS) | ||
The ratios show the Fund's expenses and net investment income (loss)—as they actually are as well as how they would have been if certain expense reimbursement and/or waiver arrangements had not been in effect. | ||
Net expenses—actual | 2.06(4)(7) | 2.07 |
Gross expenses(2) | 6.62(4)(7) | 5.51 |
Net investment income (loss)—actual | (0.18)(4)(7) | (0.01) |
OTHER DATA | ||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | ||
Total return (%)(3)(8) | (1.64)(5) | 2.80 |
Net assets at end of year (in millions of dollars) | 0.0 | 0.0 |
Portfolio turnover rate (%) | 31(5) | 103 |
(1) | Period from 5/18/2018 (beginning of operations) to 10/31/2018. |
(2) | Shows what this ratio would have been if there had been no expense reimbursement and/or waiver of a portion of the investment management fee. |
(3) | Would have been lower if the Manager had not reimbursed certain expenses and/or waived a portion of the investment management fee. |
(4) | Annualized. |
(5) | Not annualized. |
(6) | The per share amounts have been calculated based on the average number of shares outstanding during the fiscal period. |
(7) | Organization expenses, which are non-recurring expenses, are included in the ration on a non-annualized basis. |
(8) | Does not include the effect of sales charges. |
(1) | Period from 5/18/2018 (beginning of operations) to 10/31/2018. |
(2) | Shows what this ratio would have been if there had been no expense reimbursement and/or waiver of a portion of the investment management fee. |
(3) | Would have been lower if the Manager had not reimbursed certain expenses and/or waived a portion of the investment management fee. |
(4) | Annualized. |
(5) | Not annualized. |
(6) | The per share amounts have been calculated based on the average number of shares outstanding during the fiscal period. |
(7) | Organization expenses, which are non-recurring expenses, are included in the ration on a non-annualized basis. |
(1) | Period from 9/16/2016 (beginning of operations) to 10/31/2016. |
(2) | Shows what this ratio would have been if there had been no expense reimbursement. |
(3) | Would have been lower if the Manager had not reimbursed certain expenses. |
(4) | Annualized. |
(5) | Not annualized. |
(6) | The per share amounts have been calculated based on the average number of shares outstanding during the fiscal period. |
(7) | Organization expenses, which are non-recurring expenses, are included in the ration on a non-annualized basis. |
(8) | Does not include the effect of sales charges. |
(1) | Period from 9/16/2016 (beginning of operations) to 10/31/2016. |
(2) | Shows what this ratio would have been if there had been no expense reimbursement. |
(3) | Would have been lower if the Manager had not reimbursed certain expenses. |
(4) | Annualized. |
(5) | Not annualized. |
(6) | The per share amounts have been calculated based on the average number of shares outstanding during the fiscal period. |
(7) | Organization expenses, which are non-recurring expenses, are included in the ration on a non-annualized basis. |
(8) | Does not include the effect of sales charges. |
(1) | Period from 9/16/2016 (beginning of operations) to 10/31/2016. |
(2) | Shows what this ratio would have been if there had been no expense reimbursement. |
(3) | Would have been lower if the Manager had not reimbursed certain expenses. |
(4) | Annualized. |
(5) | Not annualized. |
(6) | The per share amounts have been calculated based on the average number of shares outstanding during the fiscal period. |
(7) | Organization expenses, which are non-recurring expenses, are included in the ration on a non-annualized basis. |
■ | how long you expect to own the shares |
■ | how much you intend to invest |
■ | total expenses associated with owning shares of each class |
■ | whether you qualify for any reduction or waiver of sales charges (for example, Class A shares may be a less expensive option than Class C shares over time, particularly if you qualify for a sales charge reduction or waiver) |
■ | whether you plan to take any distributions in the near future |
■ | availability of (and eligibility for) share classes. |
Class A Shares | |
Initial sales charge |
Up to 5.75% for all Funds except Neuberger Berman Multi-Asset Income Fund. Up to 4.25% for Neuberger Berman Multi-Asset Income Fund. (reduced for purchases of $50,000 or more and
eliminated for purchases of $1 million or more)
|
Contingent deferred sales charge | None (except that a charge of 1.00% applies to certain redemptions made within 18 months following purchases of $1 million or more without an initial sales charge) |
12b-1 fees | 0.25% annually |
Dividends | Generally higher than Class C due to lower annual expenses and lower than Institutional Class due to higher annual expenses |
Purchase maximum | None |
Conversion | None |
Class C Shares | |
Initial sales charge | None |
Contingent deferred sales charge | 1.00% if shares are sold within one year after purchase |
12b-1 fees | 1.00% annually |
Dividends | Generally lower than Class A and Institutional Class due to higher annual expenses |
Purchase maximum | See the discussion regarding purchase minimums and maximums in “Maintaining Your Account” |
Conversion | Automatic conversion into Class A shares of the same Fund at the end of the month following the tenth anniversary of the purchase date of Class C shares. Class C shares held through a financial intermediary may be converted pursuant to the conversion schedule or eligibility requirements of such financial intermediary. It is the financial intermediary’s (and not the Fund’s) responsibility to keep records and to ensure that the shareholder is credited with the proper holding period as the Fund and its agents may not have transparency into how long a shareholder has held Class C shares for purposes of determining whether such Class C shares are eligible to automatically convert pursuant to the conversion feature. Please see the Statement of Additional Information for more information regarding the conversion privileges of Class C shares. |
Institutional Class Shares | |
Initial sales charge | None |
Contingent deferred sales charge | None |
12b-1 fees | None |
Dividends | Generally higher than Class A and Class C due to lower annual expenses |
Purchase maximum | None |
Conversion | None |
■ | both accounts must have the same registration |
■ | you will need to observe any eligibility requirements, including minimum investment and minimum account balance requirements for the fund accounts involved |
■ | because an exchange is treated as a sale (redemption) of the exchanged shares for federal income tax purposes, consider any tax consequences before placing your order. |
■ | in unusual circumstances where the law allows additional time if needed |
■ | if a check you wrote to buy shares has not cleared by the time you sell those shares; clearance may take up to 15 calendar days from the date of purchase. |
■ | suspend the offering of shares |
■ | reject any exchange or purchase order |
■ | suspend or reject future purchase orders from any investor who has not provided timely payment to settle a purchase order |
■ | change, suspend, or revoke the exchange privilege |
■ | suspend the telephone order privilege |
■ | satisfy an order to sell Fund shares with securities rather than cash |
■ | suspend or postpone investors’ ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when trading on the New York Stock Exchange (“Exchange”) is restricted, or as otherwise permitted by the Securities and Exchange Commission (“SEC”) |
■ | suspend or postpone investors' ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when the Exchange or the bond market is closed |
■ | suspend or postpone investors' ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when the Exchange, the Federal Reserve or the bond market closes early (e.g., on the eve of a major holiday or because of a local emergency, such as a blizzard) |
■ | change investment minimums or other requirements for buying and selling, or waive any minimums or requirements for certain investors |
■ | remain open and process orders to purchase or sell Fund shares when the Exchange is closed. |
Sales charges as a percentage of: | |||
Investment | Offering Price |
Net amount
invested |
Dealer commission
as a percentage of offering price |
Less than $50,000 | 4.25% | 4.44% | 4.00% |
$50,000 or more but less than $100,000 | 3.75% | 3.90% | 3.50% |
$100,000 or more but less than $250,000 | 3.25% | 3.36% | 3.00% |
$250,000 or more but less than $500,000 | 2.50% | 2.56% | 2.25% |
$500,000 or more but less than $1 million | 2.00% | 2.04% | 1.75% |
$1 million or more and certain other investments described below | None | None | See below |
Sales charges as a percentage of: | |||
Investment | Offering Price |
Net amount
invested |
Dealer commission
as a percentage of offering price |
Less than $50,000 | 5.75% | 6.10% | 5.00% |
$50,000 or more but less than $100,000 | 4.75% | 4.99% | 4.00% |
$100,000 or more but less than $250,000 | 3.75% | 3.90% | 3.00% |
$250,000 or more but less than $500,000 | 2.75% | 2.83% | 2.25% |
$500,000 or more but less than $1 million | 2.00% | 2.04% | 1.75% |
$1 million or more and certain other investments described below | None | None | See below |
1. | current or retired directors, trustees, and officers of the Neuberger Berman Funds, current or retired employees and partners of NB Group and any affiliates, or of any entity controlling, controlled by or under common control with a Neuberger Berman Fund, NB Group and any affiliates; |
2. | current employees of firms, including wholesalers, that have entered into selling agreements to distribute shares of the Neuberger Berman Funds; |
3. | current employees of registered investment advisers that invest in the Neuberger Berman Funds either for proprietary accounts or on behalf of clients; |
4. | immediate family members of persons listed in (1) through (3) above (as “immediate family” is defined below); |
5. | companies exchanging securities with a Fund through a merger, acquisition or exchange offer; |
6. | insurance company separate accounts; |
7. | NB Group and its affiliated companies; |
8. | an individual or entity with a substantial client relationship with NB Group and its affiliated companies, or an individual or entity related or relating to such individual or entity that holds its shares directly with a Fund; |
9. | financial intermediaries (including but not limited to registered investment advisors and financial planners) that have entered into an agreement with the Distributor or one of its affiliates, purchasing shares on behalf of clients |
participating in a fund supermarket or in a wrap program, asset allocation program or other program in which the clients pay an asset-based fee; | |
10. | Employer-sponsored qualified retirement plans, including 401(k) plans, 457 plans, group 403(b) plans and individual 403(b) accounts, maintained at a financial intermediary that has an agreement with the Distributor, the Manager or the Administrator, profit-sharing and money purchase pension plans, defined benefit plans and non-qualified deferred compensation plans; and individual retirement account (“IRA”) rollovers involving retirement plan assets invested in the Funds and transferred in-kind to an IRA held at a financial intermediary that has an agreement with the Distributor, the Manager or the Administrator to service such accounts; |
11. | Employee benefit and retirement plans sponsored by NB Group and any affiliates and any entity controlling, controlled by or under common control with NB Group and any affiliates; |
12. | Certain IRAs that are part of an IRA platform sponsored by or maintained at a financial intermediary that has an agreement with the Distributor, the Manager or the Administrator which specifically provides that the Funds' shares are offered at NAV on such IRA platform; and |
13. | Qualified Tuition Programs under Section 529 of the Code. |
■ | trust accounts established by you or your immediate family (for trusts with only one primary beneficiary, upon the trustor’s death the trust account may be aggregated with such beneficiary’s own accounts; for trusts with multiple primary beneficiaries, upon the trustor’s death the trustees of the trust may instruct the Fund’s transfer agent to establish separate trust accounts for each primary beneficiary; each primary beneficiary’s separate trust account may then be aggregated with such beneficiary’s own accounts); |
■ | business accounts solely controlled by you or your immediate family (for example, you own the entire business); |
■ | individual retirement plans, such as an IRA, individual 403(b) plan (see exception in “Purchases by certain 403(b) plans” under “Sales Charges”) or single-participant Keogh-type plan ; |
■ | endowments or foundations established and controlled by you or your immediate family; or |
■ | 529 accounts, which will be aggregated at the account owner level. |
■ | for a single trust estate or fiduciary account, including employee benefit plans other than the individual-type employee benefit plans described above; |
■ | made for two or more employee benefit plans of a single employer or of affiliated employers as defined in the 1940 Act, excluding the individual-type employee benefit plans described above; |
■ | for a diversified common trust fund or other diversified pooled account not specifically formed for the purpose of accumulating Fund shares; |
■ | for nonprofit, charitable or educational organizations, or any endowments or foundations established and controlled by such organizations, or any employer-sponsored retirement plans established for the benefit of the employees of such organizations, their endowments, or their foundations; or |
■ | for individually established participant accounts of a 403(b) plan that is treated similarly to an employer-sponsored plan for sales charge purposes (see “Purchases by certain 403(b) plans” under “Sales Charges” above), or made for two or more such 403(b) plans that are treated similarly to employer-sponsored plans for sales charge purposes, in each case of a single employer or affiliated employers as defined in the 1940 Act. |
■ | permitted exchanges of shares, except if shares acquired by exchange are then redeemed within the period during which contingent deferred sales charge would apply to the initial shares purchased |
■ | tax-free returns of excess contributions to IRAs |
■ | redemptions due to death or post-purchase disability of the shareholder (this generally excludes accounts registered in the names of trusts and other entities). In the case of joint tenant accounts, if one joint tenant dies, a surviving joint tenant, at the time he or she notifies the Fund’s transfer agent of the other joint tenant’s death and removes the decedent’s name from the account, may redeem shares from the account without incurring a CDSC. Redemptions made after the date of such notification will be subject to a CDSC. |
■ | distributions from an IRA upon the shareholder’s attainment of age 59½ |
■ | the following types of transactions, if together they do not exceed 12% of the value of an “account” (defined below) annually (the 12% limit): |
■ | purchases where no commission or transaction fee is paid by the Distributor to authorized dealers at the time of purchase. |
■ | Employer-sponsored retirement plans (e.g., 401(k) plans, 457 plans, employer-sponsored 403(b) plans, profit sharing and money purchase pension plans and defined benefit plans). For purposes of this provision, employer-sponsored retirement plans do not include SEP IRAs, Simple IRAs or SAR-SEPs. |
■ | Shares purchased through an Ameriprise Financial investment advisory program (if an Advisory or similar share class for such investment advisory program is not available). |
■ | Shares purchased by third party investment advisors on behalf of their advisory clients through Ameriprise Financial’s platform (if an Advisory or similar share class for such investment advisory program is not available). |
■ | Shares purchased through reinvestment of capital gains distributions and dividend reinvestment when purchasing shares of the same Fund (but not any other fund within the same fund family). |
■ | Shares exchanged from Class C shares of the same fund in the month of or following the 10-year anniversary of the purchase date. To the extent that this prospectus elsewhere provides for a waiver with respect to such shares following a shorter holding period, that waiver will apply to exchanges following such shorter period. To the extent that this prospectus elsewhere provides for a waiver with respect to exchanges of Class C shares for load waived shares, that waiver will also apply to such exchanges. |
■ | Employees and registered representatives of Ameriprise Financial or its affiliates and their immediate family members. |
■ | Shares purchased by or through qualified accounts (including IRAs, Coverdell Education Savings Accounts, 401(k)s, 403(b) TSCAs subject to ERISA and defined benefit plans) that are held by a covered family member, defined as an Ameriprise financial advisor and/or the advisor’s spouse, advisor’s lineal ascendant (mother, father, grandmother, grandfather, great grandmother, great grandfather), advisor’s lineal descendant (son, step-son, daughter, step-daughter, grandson, granddaughter, great grandson, great granddaughter) or any spouse of a covered family member who is a lineal descendant. |
■ | Shares purchased from the proceeds of redemptions within the same fund family, provided (1) the repurchase occurs within 90 days following the redemption, (2) the redemption and purchase occur in the same account, and (3) redeemed shares were subject to a front-end or deferred sales load (i.e. Rights of Reinstatement). |
■ | The applicable sales charge on a purchase of Class A shares is determined by taking into account all share classes (except any money market funds and retirement plan share classes) of the fund family held by the shareholder or in an account grouped by Edward Jones with other accounts for the purpose of providing certain pricing considerations (“pricing groups”). This includes all share classes held on the Edward Jones platform and/or held on another platform. The inclusion of eligible fund family assets in the rights of accumulation calculation is dependent on the shareholder notifying his or her financial advisor of such assets at the time of calculation. |
■ | ROA is determined by calculating the higher of cost or market value (current shares x NAV). |
■ | Through a LOI, shareholders can receive the sales charge and breakpoint discounts for purchases shareholders intend to make over a 13-month period from the date Edward Jones receives the LOI. The LOI is determined by calculating the higher of cost or market value of qualifying holdings at LOI initiation in combination with the value that the shareholder intends to buy over a 13-month period to calculate the front-end sales charge and any breakpoint discounts. Each purchase the shareholder makes during that 13-month period will receive the sales charge and breakpoint discount that applies to the total amount. The inclusion of eligible fund family assets in the LOI calculation is dependent on the shareholder notifying his or her financial advisor of such assets at the time of calculation. Purchases made before the LOI is received by Edward Jones are not covered under the LOI and will not reduce the sales charge previously paid. Sales charges will be adjusted if LOI is not met. |
■ | Associates of Edward Jones and its affiliates and their family members who are in the same pricing group (as determined by Edward Jones under its policies and procedures) as the associate. This waiver will continue for the remainder of the associate's life if the associate retires from Edward Jones in good-standing. |
■ | Shares purchased in an Edward Jones fee-based program. |
■ | Shares purchased through reinvestment of capital gains distributions and dividend reinvestment. |
■ | Shares purchased from the proceeds of redeemed shares of the same fund family so long as the following conditions are met: 1) the proceeds are from the sale of shares within 60 days of the purchase, and 2) the sale and purchase are made in the same share class and the same account or the purchase is made in an individual retirement account with proceeds from liquidations in a non-retirement account. |
■ | Shares exchanged into class A shares from another share class so long as the exchange is into the same fund and was initiated at the discretion of Edward Jones. Edward Jones is responsible for any remaining CDSC due to the fund company, if applicable. Any future purchases are subject to the applicable sales charge as disclosed in the prospectus. |
■ | Exchanges from class C shares to class A shares of the same fund, generally, in the 84th month following the anniversary of the purchase date or earlier at the discretion of Edward Jones. |
■ | The death or disability of the shareholder |
■ | Systematic withdrawals with up to 10% per year of the account value |
■ | Return of excess contributions from an Individual Retirement Account (IRA) |
■ | Shares sold as part of a required minimum distribution for IRA and retirement accounts if the redemption is taken in or after the year the shareholder reaches qualified age based on applicable IRS regulations |
■ | Shares sold to pay Edward Jones fees or costs in such cases where the transaction is initiated by Edward Jones |
■ | Shares exchanged in an Edward Jones fee-based program |
■ | Shares acquired through NAV reinstatement |
1.1 | Minimum Purchase Amounts |
■ | $250 initial purchase minimum |
■ | $50 subsequent purchase minimum |
1.2 | Minimum Balances |
■ | Edward Jones has the right to redeem at its discretion fund holdings with a balance of $250 or less. The following are examples of accounts that are not included in this policy: |
■ | A fee-based account held on an Edward Jones platform |
■ | A 529 account held on an Edward Jones platform |
■ | An account with an active systematic investment plan or letter of intent (LOI) |
1.3 | Changing Share Classes |
■ | At any time it deems necessary, Edward Jones has the authority to exchange at NAV a shareholder's holdings in a fund to Class A shares. |
■ | Shares purchased through reinvestment of capital gains distributions and dividend reinvestment when purchasing shares of the same fund (but not any other fund within the fund family). |
■ | Shares purchased by employees and registered representatives of Janney or its affiliates and their family members as designated by Janney. |
■ | Shares purchased from the proceeds of redemptions within the same fund family, provided (1) the repurchase occurs within ninety (90) days following the redemption, (2) the redemption and purchase occur in the same account, and (3) redeemed shares were subject to a front-end or deferred sales load (i.e., right of reinstatement). |
■ | Employer-sponsored retirement plans (e.g., 401(k) plans, 457 plans, employer-sponsored 403(b) plans, profit sharing and money purchase pension plans and defined benefit plans). For purposes of this provision, employer-sponsored retirement plans do not include SEP IRAs, Simple IRAs, SAR-SEPs or Keogh plans. |
■ | Shares acquired through a right of reinstatement. |
■ | Class C shares that are no longer subject to a contingent deferred sales charge and are converted to Class A shares of the same fund pursuant to Janney’s policies and procedures. |
■ | Shares sold upon the death or disability of the shareholder. |
■ | Shares sold as part of a systematic withdrawal plan as described in the Fund’s Prospectus. |
■ | Shares purchased in connection with a return of excess contributions from an IRA account. |
■ | Shares sold as part of a required minimum distribution for IRA and other retirement accounts due to the shareholder reaching age 70½ as described in the Fund’s Prospectus. |
■ | Shares sold to pay Janney fees but only if the transaction is initiated by Janney. |
■ | Shares acquired through a right of reinstatement. |
■ | Shares exchanged into the same share class of a different fund. |
■ | Breakpoints as described in the Fund’s Prospectus. |
■ | Rights of accumulation (“ROA”), which entitle shareholders to breakpoint discounts, will be automatically calculated based on the aggregated holding of fund family assets held by accounts within the purchaser’s household at Janney. Eligible fund family assets not held at Janney may be included in the ROA calculation only if the shareholder notifies his or her financial advisor about such assets. |
■ | Letters of intent which allow for breakpoint discounts based on anticipated purchases within a fund family, over a 13-month time period. Eligible fund family assets not held at Janney may be included in the calculation of letters of intent only if the shareholder notifies his or her financial advisor about such assets. |
■ | Employer-sponsored retirement, deferred compensation and employee benefit plans (including health savings accounts) and trusts used to fund those plans, provided that the shares are not held in a commission-based brokerage account and shares are held for the benefit of the plan |
■ | Shares purchased by a 529 Plan (does not include 529 Plan units or 529-specific share classes or equivalents) |
■ | Shares purchased through a Merrill Lynch affiliated investment advisory program |
■ | Shares exchanged due to the holdings moving from a Merrill Lynch affiliated investment advisory program to a Merrill Lynch brokerage (non-advisory) account pursuant to Merrill Lynch’s policies relating to sales load discounts and waivers |
■ | Shares purchased by third party investment advisors on behalf of their advisory clients through Merrill Lynch’s platform |
■ | Shares of funds purchased through the Merrill Edge Self-Directed platform (if applicable) |
■ | Shares purchased through reinvestment of capital gains distributions and dividend reinvestment when purchasing shares of the same fund (but not any other fund within the fund family) |
■ | Shares exchanged from Class C (i.e. level-load) shares of the same fund pursuant to Merrill Lynch’s policies relating to sales load discounts and waivers |
■ | Employees and registered representatives of Merrill Lynch or its affiliates and their family members |
■ | Directors or Trustees of the Fund, and employees of the Fund’s investment adviser or any of its affiliates, as described in this prospectus |
■ | Eligible shares purchased from the proceeds of redemptions within the same fund family, provided (1) the repurchase occurs within 90 days following the redemption, (2) the redemption and purchase occur in the same account, and (3) redeemed shares were subject to a front-end or deferred sales load (known as Rights of Reinstatement). Automated transactions (i.e. systematic purchases and withdrawals) and purchases made after shares are automatically sold to pay Merrill Lynch’s account maintenance fees are not eligible for reinstatement |
■ | Death or disability of the shareholder |
■ | Shares sold as part of a systematic withdrawal plan as described in the Fund’s prospectus |
■ | Return of excess contributions from an IRA Account |
■ | Shares sold as part of a required minimum distribution for IRA and retirement accounts pursuant to the Internal Revenue Code |
■ | Shares sold to pay Merrill Lynch fees but only if the transaction is initiated by Merrill Lynch |
■ | Shares acquired through a right of reinstatement |
■ | Shares held in retirement brokerage accounts, that are exchanged for a lower cost share class due to transfer to a fee based account or platform (applicable to A and C shares only) |
■ | Shares received through an exchange due to the holdings moving from a Merrill Lynch affiliated investment advisory program to a Merrill Lynch brokerage (non-advisory) account pursuant to Merrill Lynch’s policies relating to sales load discounts and waivers |
■ | Breakpoints as described in this prospectus. |
■ | Rights of Accumulation (ROA) which entitle shareholders to breakpoint discounts as described in the Fund’s prospectus will be automatically calculated based on the aggregated holding of fund family assets held by accounts (including 529 program holdings, where applicable) within the purchaser’s household at Merrill Lynch. Eligible fund family assets not held at Merrill Lynch may be included in the ROA calculation only if the shareholder notifies his or her financial advisor about such assets |
■ | Letters of Intent (LOI) which allow for breakpoint discounts based on anticipated purchases within a fund family, through Merrill Lynch, over a 13-month period of time (if applicable) |
■ | Employer-sponsored retirement plans (e.g., 401(k) plans, 457 plans, employer-sponsored 403(b) plans, profit sharing and money purchase pension plans and defined benefit plans). For purposes of this provision, employer-sponsored retirement plans do not include SEP IRAs, Simple IRAs, SAR-SEPs or Keogh plans |
■ | Morgan Stanley employee and employee-related accounts according to Morgan Stanley’s account linking rules |
■ | Shares purchased through reinvestment of dividends and capital gains distributions when purchasing shares of the same fund |
■ | Shares purchased through a Morgan Stanley self-directed brokerage account |
■ | Class C (i.e., level-load) shares that are no longer subject to a contingent deferred sales charge and are converted to Class A shares of the same fund pursuant to Morgan Stanley Wealth Management’s share class conversion program |
■ | Shares purchased from the proceeds of redemptions within the same fund family, provided (i) the repurchase occurs within 90 days following the redemption, (ii) the redemption and purchase occur in the same account, and (iii) redeemed shares were subject to a front-end or deferred sales charge. |
■ | Shares purchased in an investment advisory program. |
■ | Shares purchased within the same fund family through a systematic reinvestment of capital gains and dividend distributions. |
■ | Employees and registered representatives of Raymond James or its affiliates and their family members as designated by Raymond James. |
■ | Shares purchased from the proceeds of redemptions within the same fund family, provided (1) the repurchase occurs within 90 days following the redemption, (2) the redemption and purchase occur in the same account, and (3) redeemed shares were subject to a front-end or deferred sales load (known as Rights of Reinstatement). |
■ | A shareholder in the Fund’s Class C shares will have their shares converted at net asset value to Class A shares (or the appropriate share class) of the Fund if the shares are no longer subject to a CDSC and the conversion is in line with the policies and procedures of Raymond James. |
■ | Death or disability of the shareholder. |
■ | Shares sold as part of a systematic withdrawal plan as described in the Fund’s Prospectus. |
■ | Return of excess contributions from an IRA Account. |
■ | Shares sold as part of a required minimum distribution for IRA and retirement accounts due to the shareholder reaching the qualified age based on applicable IRS regulations as described in the Fund’s prospectus. |
■ | Shares sold as part of a required minimum distribution for IRA and retirement accounts due to the shareholder reaching age 70½ as described in the Fund’s Prospectus. |
■ | Shares sold to pay Raymond James fees but only if the transaction is initiated by Raymond James. |
■ | Shares acquired through a right of reinstatement. |
■ | Breakpoints as described in this Prospectus. |
■ | Rights of accumulation which entitle shareholders to breakpoint discounts will be automatically calculated based on the aggregated holding of fund family assets held by accounts within the purchaser’s household at Raymond James. Eligible fund family assets not held at Raymond James may be included in the calculation of rights of accumulation only if the shareholder notifies his or her financial advisor about such assets. |
■ | Letters of intent which allow for breakpoint discounts based on anticipated purchases within a fund family, over a 13-month time period. Eligible fund family assets not held at Raymond James may be included in the calculation of letters of intent only if the shareholder notifies his or her financial advisor about such assets. |
■ | a discussion by the Portfolio Managers about strategies and market conditions that significantly affected the Fund’s performance during the last fiscal year |
■ | Fund performance data and financial statements |
■ | portfolio holdings. |
■ | various types of securities and practices, and their risks |
■ | investment limitations and additional policies |
■ | information about the Fund’s management and business structure. |
Class R6 | |
Neuberger Berman Global Allocation Fund | NRGLX |
Neuberger Berman Multi-Asset Income Fund | NRANX |
Neuberger Berman Multi-Style Premia Fund | NMLRX |
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund | NUPRX |
Fund Summaries | |
Neuberger Berman Global Allocation Fund
|
2 |
Neuberger Berman Multi-Asset Income Fund
|
17 |
Neuberger Berman Multi-Style Premia Fund
|
30 |
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund
|
43 |
Descriptions of Certain Practices and Security Types
|
51 |
Additional Information about Principal Investment Risks
|
52 |
Information about Additional Risks and Other Practices
|
69 |
Descriptions of Indices
|
70 |
Management of the Funds
|
71 |
Financial Highlights
|
75 |
Your Investment | |
Maintaining Your Account
|
79 |
Share Prices
|
82 |
Distributions and Taxes
|
83 |
Market Timing Policy
|
84 |
Portfolio Holdings Policy
|
85 |
Fund Structure
|
85 |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees | 0.60 |
Distribution and/or shareholder service (12b-1) fees | None |
Other expenses | 2.95 |
Acquired fund fees and expenses | 0.36 |
Total annual operating expenses | 3.91 |
Fee waiver and/or expense reimbursement | 3.16 |
Total annual operating expenses after fee waiver and/or expense reimbursement1 | 0.75 |
1 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class R6 so that the total annual operating expenses (excluding interest, taxes, brokerage commissions, acquired fund fees and expenses, dividend and interest expenses relating to short sales, and extraordinary expenses, if any) (“annual operating expenses”) are limited to 0.65% of average net assets. This undertaking lasts until 10/31/2023 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that Class R6 will repay the Manager for fees and expenses waived or reimbursed for the class provided that repayment does not cause annual operating expenses to exceed 0.65% of its class’ average net assets. Any such repayment must be made within three years after the year in which the Manager incurred the expense. In addition, for so long as the Fund invests any assets in an affiliated Underlying Fund (as defined below), the Manager undertakes to waive a portion of the Fund's advisory fee equal to the advisory fee it receives from such affiliated Underlying Fund on those assets. This undertaking may not be terminated without the consent of the Board of Trustees. |
1 Year | 3 Years | 5 Years | 10 Years | |
Class R6 | $77 | $240 | $1,135 | $3,461 |
Global Allocation Fund | 1 Year | 5 Years |
Since Inception
(12/29/2010) |
Return Before Taxes | 18.54 | 4.80 | 5.96 |
Return After Taxes on Distributions | 17.40 | 3.87 | 4.49 |
Return After Taxes on Distributions and Sale of Fund Shares | 11.36 | 3.45 | 4.11 |
60% MSCI All Country World Index (Net) (reflects reinvested dividends net of withholding taxes, but reflects no deduction for fees, expenses or taxes) and 40% Bloomberg Barclays Global Aggregate Index (reflects no deduction for fees, expenses or taxes) | 18.55 | 6.11 | 6.11 |
MSCI All Country World Index (Net) (reflects reinvested dividends net of withholding taxes, but reflects no deduction for fees, expenses or taxes) | 26.60 | 8.41 | 8.43 |
After-tax returns are calculated using the historical highest individual federal marginal income tax rates and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ from those shown. After-tax returns are not relevant to investors who hold their Fund shares through tax-deferred arrangements, such as 401(k) plans or individual retirement accounts. |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees | 0.50 |
Distribution and/or shareholder service (12b-1) fees | None |
Other expenses | 1.96 |
Acquired fund fees and expenses | 0.13 |
Total annual operating expenses | 2.59 |
Fee waiver and/or expense reimbursement | 1.99 |
Total annual operating expenses after fee waiver and/or expense reimbursement1 | 0.60 |
1 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class R6 so that the total annual operating expenses (excluding interest, taxes, brokerage commissions, acquired fund fees and expenses, dividend and interest expenses relating to short sales, and extraordinary expenses, if any) (“annual operating expenses”) are limited to 0.55% of average net assets. This undertaking lasts until 10/31/2023 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that Class R6 will repay the Manager for fees and expenses waived or reimbursed for the class provided that repayment does not cause annual operating expenses to exceed 0.55% of its class’ average net assets. Any such repayment must be made within three years after the year in which the Manager incurred the expense. In addition, for so long as the Fund invests any assets in an affiliated Underlying Fund (as defined below), the Manager undertakes to waive a portion of the Fund’s advisory fee equal to the advisory fee it receives from such affiliated Underlying Fund on those assets. This undertaking may not be terminated without the consent of the Board of Trustees. |
1 Year | 3 Years | 5 Years | 10 Years | |
Class R6 | $61 | $192 | $796 | $2,437 |
Multi-Asset Income Fund | 1 Year |
Since Inception
(3/27/2015) |
Return Before Taxes | 13.31 | 4.21 |
Return After Taxes on Distributions | 12.17 | 2.91 |
Return After Taxes on Distributions and Sale of Fund Shares | 8.51 | 2.88 |
60% Bloomberg Barclays U.S. Aggregate Bond Index and 40% S&P 500® Index (reflects no deduction for fees, expenses or taxes) | 17.62 | 6.76 |
Bloomberg Barclays U.S. Aggregate Bond Index (reflects no deduction for fees, expenses or taxes) | 8.72 | 2.95 |
After-tax returns are calculated using the historical highest individual federal marginal income tax rates and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ from those shown. After-tax returns are not relevant to investors who hold their Fund shares through tax-deferred arrangements, such as 401(k) plans or individual retirement accounts. |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees | 0.70 |
Distribution and/or shareholder service (12b-1) fees | None |
Total other expenses | 16.77 |
Other expenses of Fund | 16.20 |
Other expenses of Subsidiary | 0.57 |
Acquired fund fees and expenses | 0.04 |
Total annual operating expenses | 17.51 |
Fee waiver and/or expense reimbursement | 16.62 |
Total annual operating expenses after fee waiver and/or expense reimbursement1 | 0.89 |
1 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class R6 so that the total annual operating expenses (excluding interest, taxes, brokerage commissions, acquired fund fees and expenses, dividend and interest expenses relating to short sales, and extraordinary expenses, if any) are limited to 0.85% of average net assets. This undertaking lasts until 10/31/2023 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that Class R6 will repay the Manager for fees and expenses waived or reimbursed for that class provided that repayment does not cause annual operating expenses to exceed 0.85% of its average net assets. Any such repayment must be made within three years after the year in which the Manager incurred the expense. |
For purposes of the contractual expense limitations, Operating Expenses shall be deemed to include the Operating Expenses of the Fund’s wholly owned Cayman Islands subsidiary (see the “Principal Investment Strategies” section). |
1 Year | 3 Years | 5 Years | 10 Years | |
Class R6 | $91 | $284 | $3,757 | $9,281 |
Multi-Style Premia Fund | 1 Year |
Since Inception
(5/18/2018) |
Return Before Taxes | 6.47 | 1.80 |
Return After Taxes on Distributions | 3.96 | -1.01 |
Return After Taxes on Distributions and Sale of Fund Shares | 4.06 | 0.29 |
ICE BofA 3-Month U.S. Treasury Bill Index* (reflects no deduction for fees, expenses or taxes) | 2.28 | 2.21 |
After-tax returns are calculated using the historical highest individual federal marginal income tax rates and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ from those shown. After-tax returns are not relevant to investors who hold their Fund shares through tax-deferred arrangements, such as 401(k) plans or individual retirement accounts. Return After Taxes on Distributions and Sale of Fund Shares may be higher than other returns for the same period due to a tax benefit of realizing a capital loss upon the sale of Fund shares. |
Shareholder Fees (fees paid directly from your investment) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a % of the value of your investment) | |
Management fees | 0.50 |
Distribution and/or shareholder service (12b-1) fees | None |
Other expenses | 0.17 |
Total annual operating expenses | 0.67 |
Fee waiver and/or expense reimbursement | 0.11 |
Total annual operating expenses after fee waiver and/or expense reimbursement1 | 0.56 |
1 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually undertaken to waive and/or reimburse certain fees and expenses of Class R6 so that the total annual operating expenses (excluding interest, taxes, brokerage commissions, acquired fund fees and expenses, dividend and interest expenses relating to short sales, and extraordinary expenses, if any) (“annual operating expenses”) are limited to 0.55% of average net assets. This undertaking lasts until 10/31/2023 and may not be terminated during its term without the consent of the Board of Trustees. The Fund has agreed that Class R6 will repay the Manager for fees and expenses waived or reimbursed for that class provided that repayment does not cause annual operating expenses to exceed 0.55% of its average net assets. Any such repayment must be made within three years after the year in which the Manager incurred the expense. |
1 Year | 3 Years | 5 Years | 10 Years | |
Class R6 | $57 | $179 | $339 | $802 |
U.S. Equity Index PutWrite Strategy Fund | 1 Year |
Since Inception
(9/16/2016) |
Return Before Taxes | 16.23 | 7.52 |
Return After Taxes on Distributions | 14.05 | 6.07 |
Return After Taxes on Distributions and Sale of Fund Shares | 9.97 | 5.33 |
42.5% CBOE S&P 500 One-Week PutWrite Index/42.5% CBOE S&P 500 PutWrite Index/7.5% CBOE Russell 2000 One-Week PutWrite Index/7.5% CBOE Russell 2000 PutWrite Index (reflects no deduction for fees, expenses or taxes) | 14.01 | 4.72 |
85% S&P 500® Index and 15% Russell 2000® Index (reflects no deduction for fees, expenses or taxes) | 30.61 | 14.90 |
After-tax returns are calculated using the historical highest individual federal marginal income tax rates and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ from those shown. After-tax returns are not relevant to investors who hold their Fund shares through tax-deferred arrangements, such as 401(k) plans or individual retirement accounts. |
YEAR ENDED OCTOBER 31, | 2019(1) |
PER-SHARE DATA ($) | |
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |
Share price (NAV) at beginning of year | 10.56 |
Plus: | |
Income from investment operations | |
Net investment income (loss)(6) | 0.16 |
Net gains (losses)—realized and unrealized | 0.93 |
Subtotal: income (loss) from investment operations | 1.09 |
Minus: | |
Distributions to shareholders | |
Income dividends | - |
Net capital gains | - |
Subtotal: distributions to shareholders | - |
Equals: | |
Share price (NAV) at end of year | 11.65 |
RATIOS (% OF AVERAGE NET ASSETS) | |
The ratios show the Fund’s expenses and net investment income (loss)—as they actually are as well as how they would have been if certain expense reimbursement and/or waiver arrangements had not been in effect. | |
Net expenses—actual(4) | 0.39 |
Net expenses (excluding expenses on securities sold short)—actual(4) | 0.39 |
Gross expenses(2)(4) | 3.55 |
Gross expenses (excluding expenses on securities sold short)(2)(4) | 3.55 |
Net investment income (loss)—actual(4) | 1.78 |
OTHER DATA | |
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |
Total return (%)(3)(5) | 10.32 |
Net assets at end of year (in millions of dollars) | 0.0 |
Portfolio turnover rate (including securities sold short)(%)(5)(7) | 74 |
Portfolio turnover rate (excluding securities sold short)(%)(5)(7) | 74 |
(1) | Period from 1/18/2019 (beginning of operations) to 10/31/2019. |
(2) | Shows what this ratio would have been if there had been no expense reimbursement and/or waiver of a portion of the investment management fee. |
(3) | Would have been lower if the Manager had not reimbursed certain expenses and/or waived a portion of the investment management fee. |
(4) | Annualized. |
(5) | Not Annualized. |
(6) | Calculated based on the average number of shares outstanding during the fiscal period. |
(7) | The portfolio turnover rates including mortgage dollar roll transactions, including and excluding securities sold short, were 159%, and 159%, respectively, for the year ended October 31, 2019. |
YEAR ENDED OCTOBER 31, | 2015(1) | 2016 | 2017 | 2018 | 2019 |
PER-SHARE DATA ($) | |||||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | |||||
Share price (NAV) at beginning of year | 10.00 | 9.43 | 9.60 | 10.18 | 9.58 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(6) | 0.23 | 0.32 | 0.33 | 0.34 | 0.35 |
Net gains (losses)—realized and unrealized | (0.57) | 0.24 | 0.61 | (0.52) | 0.37 |
Subtotal: income (loss) from investment operations | (0.34) | 0.56 | 0.94 | (0.18) | 0.72 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | 0.23 | 0.30 | 0.35 | 0.35 | 0.31 |
Capital gain distributions | — | — | — | — | — |
Tax return of capital | — | 0.09 | 0.01 | 0.07 | 0.09 |
Subtotal: distributions to shareholders | 0.23 | 0.39 | 0.36 | 0.42 | 0.40 |
Equals: | |||||
Share price (NAV) at end of year | 9.43 | 9.60 | 10.18 | 9.58 | 9.90 |
RATIOS (% OF AVERAGE NET ASSETS) | |||||
The ratios show the Fund’s expenses and net investment income (loss)—as they actually are as well as how they would have been if certain expense reimbursement and/or waiver arrangements had not been in effect. | |||||
Net expenses—actual | 0.36(4)(7) | 0.37 | 0.42 | 0.48 | 0.48 |
Gross expenses(2) | 3.63(4)(7) | 3.78 | 2.97 | 2.49 | 2.47 |
Net investment income (loss)—actual | 3.93(4)(7) | 3.42 | 3.34 | 3.36 | 3.63 |
OTHER DATA | |||||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | |||||
Total return (%)(3) | (3.39)(5) | 6.16 | 10.01 | (1.86) | 7.64 |
Net assets at end of year (in millions of dollars) | 3.8 | 3.9 | 4.1 | 3.9 | 4.0 |
Portfolio turnover rate (%) | 33(5) | 94 | 84(8) | 74(8) | 74(8) |
(1) | Period from 3/27/2015 (beginning of operations) to 10/31/2015. |
(2) | Shows what this ratio would have been if there had been no expense reimbursement and/or waiver of a portion of the investment management fee. |
(3) | Would have been lower if the Manager had not reimbursed certain expenses and/or waived a portion of the investment management fee. |
(4) | Annualized. |
(5) | Not annualized. |
(6) | The per share amounts have been calculated based on the average number of shares outstanding during the fiscal period. |
(7) | Organization expenses, which are non-recurring expenses, are included in the ratio on a non-annualized basis. |
(8) | The portfolio turnover rates including mortgage dollar roll transactions were 212%, 192% and 165% for the years ended October 31, 2019, 2018 and 2017, respectively. |
YEAR ENDED OCTOBER 31, | 2018(1) | 2019 |
PER-SHARE DATA ($) | ||
Data apply to a single share throughout each year indicated. You can see what the Fund earned (or lost), what it distributed to investors, and how its share price changed. | ||
Share price (NAV) at beginning of year | 25.00 | 24.72 |
Plus: | ||
Income from investment operations | ||
Net investment income (loss)(6) | 0.11 | 0.28 |
Net gains (losses)—realized and unrealized | (0.39) | 0.63 |
Subtotal: income (loss) from investment operations | (0.28) | 0.91 |
Minus: | ||
Distributions to shareholders | ||
Income dividends | — | 1.32 |
Subtotal: distributions to shareholders | — | 1.32 |
Equals: | ||
Share price (NAV) at end of year | 24.72 | 24.31 |
RATIOS (% OF AVERAGE NET ASSETS) | ||
The ratios show the Fund’s expenses and net investment income (loss)—as they actually are as well as how they would have been if certain expense reimbursement and/or waiver arrangements had not been in effect. | ||
Net expenses—actual | 0.88(4)(7) | 0.86 |
Gross expenses(2) | 5.44(4)(7) | 17.48 |
Net investment income (loss)—actual | 1.00(4)(7) | 1.20 |
OTHER DATA | ||
Total return shows how an investment in the Fund would have performed over each year, assuming all distributions were reinvested. The turnover rate reflects how actively the Fund bought and sold securities. | ||
Total return (%)(3) | (1.12)(5) | 4.07 |
Net assets at end of year (in millions of dollars) | 0.0 | 0.0 |
Portfolio turnover rate (%) | 31(5) | 103 |
(1) | Period from 5/18/2018 (beginning of operations) to 10/31/2018. |
(2) | Shows what this ratio would have been if there had been no expense reimbursement and/or waiver of a portion of the investment management fee. |
(3) | Would have been lower if the Manager had not reimbursed certain expenses and/or waived a portion of the investment management fee. |
(4) | Annualized. |
(5) | Not annualized. |
(6) | The per share amounts have been calculated based on the average number of shares outstanding during the fiscal period. |
(7) | Organization expenses, which are non-recurring expenses, are included in the ratio on a non-annualized basis. |
(1) | Period from 9/16/2016 (beginning of operations) to 10/31/2016. |
(2) | Shows what this ratio would have been if there had been no expense reimbursement. |
(3) | Would have been lower if the Manager had not reimbursed certain expenses. |
(4) | Annualized. |
(5) | Not annualized. |
(6) | The per share amounts have been calculated based on the average number of shares outstanding during the fiscal period. |
(7) | Organization expenses, which are non-recurring expenses, are included in the ration on a non-annualized basis. |
■ | both accounts must have the same registration |
■ | you will need to observe any eligibility requirements, including minimum investment and minimum account balance requirements for the fund accounts involved |
■ | because an exchange is treated as a sale (redemption) of the exchanged shares for federal income tax purposes, consider any tax consequences before placing your order. |
■ | suspend the offering of shares |
■ | reject any exchange or purchase order |
■ | suspend or reject future purchase orders from any investor who has not provided timely payment to settle a purchase order |
■ | change, suspend, or revoke the exchange privilege |
■ | satisfy an order to sell Fund shares with securities rather than cash |
■ | suspend or postpone investors’ ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when trading on the New York Stock Exchange (“Exchange”) is restricted, or as otherwise permitted by the Securities and Exchange Commission (“SEC”) |
■ | suspend or postpone investors' ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when the Exchange or the bond market is closed |
■ | suspend or postpone investors' ability to sell Fund shares or postpone payments on redemptions for more than seven days, on days when the Exchange, the Federal Reserve or the bond market closes early (e.g., on the eve of a major holiday or because of a local emergency, such as a blizzard) |
■ | remain open and process orders to purchase or sell Fund shares when the Exchange is closed. |
■ | in unusual circumstances where the law allows additional time if needed |
■ | if a check you wrote to buy shares has not cleared by the time you sell those shares; clearance may take up to 15 calendar days from the date of purchase. |
■ | a discussion by the Portfolio Managers about strategies and market conditions that significantly affected the Fund’s performance during the last fiscal year or fiscal period |
■ | Fund performance data and financial statements |
■ | portfolio holdings. |
■ | various types of securities and practices, and their risks |
■ | investment limitations and additional policies |
■ | information about the Fund’s management and business structure. |
Fund
|
Institutional Class
|
Class A
|
Class C
|
Class R6
|
Neuberger Berman Absolute Return Multi-Manager Fund
|
NABIX
|
NABCX
|
NABAX
|
NRABX
|
1290 Avenue of the Americas, New York, NY 10104
Shareholder Services
800.877.9700
Institutional Services
800.366.6264
www.nb.com
|
INVESTMENT INFORMATION |
1
|
Investment Policies and Limitations
|
1
|
Cash Management and Temporary Defensive Positions
|
4
|
Additional Investment Information
|
4
|
|
|
PERFORMANCE INFORMATION |
83
|
|
|
TRUSTEES AND OFFICERS |
83
|
Information about the Board of Trustees
|
84 |
Information about the Officers of the Trust
|
90 |
INVESTMENT MANAGEMENT AND ADMINISTRATION SERVICES
|
102
|
Investment Manager and Administrator
|
102
|
Management and Administration Fees
|
104 |
Fund Accounting Agent
|
106
|
Contractual Expense Limitations
|
106
|
Subadvisers
|
107
|
Portfolio Manager Information
|
108
|
Other Investment Companies or Accounts Managed
|
112 |
Codes of Ethics
|
113 |
Management and Control of NBIA
|
113
|
DISTRIBUTION ARRANGEMENTS |
113
|
Distributor
|
114
|
Additional Payments to Financial Intermediaries
|
115
|
Distribution Plan (Class A Only)
|
116
|
Distribution Plan (Class C Only)
|
117
|
Distribution Plan (Class A and Class C)
|
118
|
|
|
ADDITIONAL PURCHASE INFORMATION |
118
|
Share Prices and Net Asset Value
|
118
|
Subscriptions in Kind
|
121
|
Financial Intermediaries
|
121
|
Automatic Investing and Dollar Cost Averaging
|
121
|
Sales Charges
|
121
|
ADDITIONAL EXCHANGE INFORMATION |
122
|
ADDITIONAL REDEMPTION INFORMATION |
123
|
Suspension of Redemptions
|
123
|
Redemptions in Kind
|
123
|
|
|
CONVERSION INFORMATION |
123
|
DIVIDENDS AND OTHER DISTRIBUTIONS |
125
|
ADDITIONAL TAX INFORMATION |
126
|
Taxation of the Fund
|
126
|
Taxation of the Fund’s Shareholders
|
134
|
Special Tax Considerations Pertaining to Funds of Funds
|
|
|
|
FUND TRANSACTIONS |
137
|
Portfolio Turnover
|
141
|
Proxy Voting
|
141
|
PORTFOLIO HOLDINGS DISCLOSURE |
142
|
Portfolio Holdings Disclosure Policy
|
142
|
Portfolio Holdings Approved Recipients
|
143
|
REPORTS TO SHAREHOLDERS |
145
|
ORGANIZATION, CAPITALIZATION AND OTHER MATTERS |
145
|
CUSTODIAN AND TRANSFER AGENT |
146
|
INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM |
146
|
LEGAL COUNSEL |
146
|
CONTROL PERSONS AND PRINCIPAL HOLDERS OF SECURITIES
|
146
|
REGISTRATION STATEMENT
|
149
|
FINANCIAL STATEMENTS |
149
|
APPENDIX A – Long-Term and Short-Term Debt Securities Rating Descriptions |
A-1
|
APPENDIX B – SUBADVISER PROXY VOTING POLICIES |
B-1
|
APPENDIX C – PROXY VOTING POLICY FOR NEUBERGER BERMAN INVESTMENT ADVISERS LLC |
C-1
|
Name,
(Year of
Birth), and
Address (1)
|
Position(s)
and
Length of
Time
Served (2)
|
Principal Occupation(s) (3)
|
Number
of Funds
in Fund
Complex
Overseen
by Fund
Trustee
|
Other Directorships Held Outside Fund
Complex by Fund Trustee (3)
|
Independent Fund Trustees
|
||||
Michael J. Cosgrove (1949)
|
Trustee since 2015
|
President, Carragh Consulting USA, since 2014; formerly, Executive, General Electric Company, 1970 to 2014, including President, Mutual Funds and Global Investment Programs, GE Asset Management, 2011 to 2014, President and Chief
Executive Officer, Mutual Funds and Intermediary Business, GE Asset Management, 2007 to 2011, President, Institutional Sales and Marketing, GE Asset Management, 1998 to 2007, and Chief Financial Officer, GE Asset Management, and Deputy
Treasurer, GE Company, 1988 to 1993.
|
51
|
Director, America Press, Inc. (not-for-profit Jesuit publisher), since 2015; formerly, Director, Fordham University, 2001 to 2018; formerly, Director, The Gabelli Go Anywhere Trust, June 2015 to June 2016; formerly, Director, Skin
Cancer Foundation (not-for-profit), 2006 to 2015; formerly, Director, GE Investments Funds, Inc., 1997 to 2014; formerly, Trustee, GE Institutional Funds, 1997 to 2014; formerly, Director, GE Asset Management, 1988 to 2014; formerly,
Director, Elfun Trusts, 1988 to 2014; formerly, Trustee, GE Pension & Benefit Plans, 1988 to 2014; formerly, Member of Board of Governors, Investment Company Institute.
|
Marc Gary (1952)
|
Trustee since 2015
|
Executive Vice Chancellor and Chief Operating Officer, Jewish Theological Seminary, since 2012; formerly, Executive Vice President and General Counsel, Fidelity Investments, 2007 to 2012; formerly, Executive Vice President and
General Counsel, BellSouth Corporation, 2004 to 2007; formerly, Vice President and Associate General Counsel, BellSouth Corporation, 2000 to 2004; formerly, Associate, Partner, and National Litigation Practice Co-Chair, Mayer, Brown
LLP, 1981 to 2000; formerly, Associate Independent Counsel, Office of Independent Counsel, 1990 to 1992.
|
51
|
Trustee, Jewish Theological Seminary, since 2015; Director, Legility, Inc. (privately held for-profit company), since 2012; Director, Lawyers Committee for Civil Rights Under Law (not-for-profit), since 2005; formerly, Director,
Equal Justice Works (not-for-profit), 2005 to 2014; formerly, Director, Corporate Counsel Institute, Georgetown University Law Center, 2007 to 2012; formerly, Director, Greater Boston Legal Services (not-for-profit), 2007 to 2012.
|
Name,
(Year of
Birth), and
Address (1)
|
Position(s)
and
Length of
Time
Served (2)
|
Principal Occupation(s) (3)
|
Number
of Funds
in Fund
Complex
Overseen
by Fund
Trustee
|
Other Directorships Held Outside Fund
Complex by Fund Trustee (3)
|
Martha C. Goss (1949)
|
Trustee since 2007
|
President, Woodhill Enterprises Inc./Chase Hollow Associates LLC (personal investment vehicle), since 2006; formerly, Consultant, Resources Global Professionals (temporary staffing), 2002 to 2006; formerly, Chief Financial Officer,
Booz-Allen & Hamilton, Inc., 1995 to 1999; formerly, Enterprise Risk Officer, Prudential Insurance, 1994 to1995; formerly, President, Prudential Asset Management Company, 1992 to 1994; formerly, President, Prudential Power Funding
(investments in electric and gas utilities and alternative energy projects), 1989 to 1992; formerly, Treasurer, Prudential Insurance Company, 1983 to 1989.
|
51
|
Director, American Water (water utility), since 2003; Director, Allianz Life of New York (insurance), since 2005; Director, Berger Group Holdings, Inc. (engineering consulting firm), since 2013; Director, Financial Women’s
Association of New York (not-for-profit association), since 2003; Trustee Emerita, Brown University, since 1998; Director, Museum of American Finance (not-for-profit), since 2013; formerly, Non-Executive Chair and Director, Channel
Reinsurance (financial guaranty reinsurance), 2006 to 2010; formerly, Director, Ocwen Financial Corporation (mortgage servicing), 2005 to 2010; formerly, Director, Claire’s Stores, Inc. (retailer), 2005 to 2007; formerly, Director,
Parsons Brinckerhoff Inc. (engineering consulting firm), 2007 to 2010; formerly, Director, Bank Leumi (commercial bank), 2005 to 2007; formerly, Advisory Board Member, Attensity (software developer), 2005 to 2007.
|
Michael M. Knetter (1960)
|
Trustee since 2007
|
President and Chief Executive Officer, University of Wisconsin Foundation, since 2010; formerly, Dean, School of Business, University of Wisconsin - Madison; formerly, Professor of International Economics and Associate Dean, Amos
Tuck School of Business - Dartmouth College, 1998 to 2002.
|
51
|
Director, 1 William Street Credit Income Fund, since 2018; Board Member, American Family Insurance (a mutual company, not publicly traded), since March 2009; formerly, Trustee, Northwestern Mutual Series Fund, Inc., 2007 to 2011;
formerly, Director, Wausau Paper, 2005 to 2011; formerly, Director, Great Wolf Resorts, 2004 to 2009.
|
Name,
(Year of
Birth), and
Address (1)
|
Position(s)
and
Length of
Time
Served (2)
|
Principal Occupation(s) (3)
|
Number
of Funds
in Fund
Complex
Overseen
by Fund
Trustee
|
Other Directorships Held Outside Fund
Complex by Fund Trustee (3)
|
Deborah C. McLean (1954)
|
Trustee since 2015
|
Member, Circle Financial Group (private wealth management membership practice), since 2011; Managing Director, Golden Seeds LLC (an angel investing group), since 2009; Adjunct Professor, Columbia University School of International
and Public Affairs, since 2008; formerly, Visiting Assistant Professor, Fairfield University, Dolan School of Business, Fall 2007; formerly, Adjunct Associate Professor of Finance, Richmond, The American International University in
London, 1999 to 2007.
|
51
|
Board member, Norwalk Community College Foundation, since 2014; Dean’s Advisory Council, Radcliffe Institute for Advanced Study, since 2014; formerly, Director and Treasurer, At Home in Darien (not-for-profit), 2012 to 2014;
formerly, Director, National Executive Service Corps (not-for-profit), 2012 to 2013; formerly, Trustee, Richmond, The American International University in London, 1999 to 2013.
|
George W. Morriss (1947)
|
Trustee since 2007
|
Adjunct Professor, Columbia University School of International and Public Affairs, since 2012; formerly, Executive Vice President and Chief Financial Officer, People’s United Bank, Connecticut (a financial services company), 1991 to
2001.
|
51
|
Director, 1 William Street Credit Income Fund, since 2018; Director and Chair, Thrivent Church Loan and Income Fund, since 2018; formerly, Trustee, Steben Alternative Investment Funds, Steben Select Multi-Strategy Fund, and Steben
Select Multi-Strategy Master Fund, 2013 to 2017; formerly, Treasurer, National Association of Corporate Directors, Connecticut Chapter, 2011 to 2015; formerly, Manager, Larch Lane Multi-Strategy Fund complex (which consisted of three
funds), 2006 to 2011; formerly, Member, NASDAQ Issuers’ Affairs Committee, 1995 to 2003.
|
Tom D. Seip (1950)
|
Trustee since inception; Chairman of the Board since 2008; formerly Lead Independent Trustee from 2006 to 2008
|
Formerly, Managing Member, Ridgefield Farm LLC (a private investment vehicle), 2004 to 2016; formerly, President and CEO, Westaff, Inc. (temporary staffing), May 2001 to January 2002; formerly, Senior Executive, The Charles Schwab
Corporation, 1983 to 1998, including Chief Executive Officer, Charles Schwab Investment Management, Inc.; Trustee, Schwab Family of Funds and Schwab Investments, 1997 to 1998; and Executive Vice President-Retail Brokerage, Charles
Schwab & Co., Inc., 1994 to 1997.
|
51
|
Formerly, Director, H&R Block, Inc. (tax services company), 2001 to 2018; formerly, Director, Talbot Hospice Inc., 2013 to 2016; formerly, Chairman, Governance and Nominating Committee, H&R Block, Inc., 2011 to 2015;
formerly, Chairman, Compensation Committee, H&R Block, Inc., 2006 to 2010; formerly, Director, Forward Management, Inc. (asset management company), 1999 to 2006.
|
Name,
(Year of
Birth), and
Address (1)
|
Position(s)
and
Length of
Time
Served (2)
|
Principal Occupation(s) (3)
|
Number
of Funds
in Fund
Complex
Overseen
by Fund
Trustee
|
Other Directorships Held Outside Fund
Complex by Fund Trustee (3)
|
James G. Stavridis (1955)
|
Trustee since 2015
|
Operating Executive, The Carlyle Group, since 2018; Commentator, NBC News, since 2015; formerly, Dean, Fletcher School of Law and Diplomacy, Tufts University, 2013 to 2018; formerly, Admiral, United States Navy, 1976 to 2013,
including Supreme Allied Commander, NATO and Commander, European Command, 2009 to 2013, and Commander, United States Southern Command, 2006 to 2009.
|
51
|
Director, American Water (water utility), since 2018; Director, NFP Corp. (insurance broker and consultant), since 2017; Director, U.S. Naval Institute, since 2014; Director, Onassis Foundation, since 2014; Director, BMC Software
Federal, LLC, since 2014; Director, Vertical Knowledge, LLC, since 2013; formerly, Director, Navy Federal Credit Union, 2000-2002.
|
Candace L. Straight (1947)
|
Trustee since inception
|
Private investor and consultant specializing in the insurance industry; formerly, Advisory Director, Securitas Capital LLC (a global private equity investment firm dedicated to making investments in the insurance sector), 1998 to
2003.
|
51
|
Director, ERA Coalition (not-for-profit), since January 2019; Director, Re belle Media (a privately held TV and film production company), since 2018; formerly, Public Member, Board of Governors and Board of Trustees, Rutgers
University, 2011 to 2016; formerly, Director, Montpelier Re Holdings Ltd. (reinsurance company), 2006 to 2015; formerly, Director, National Atlantic Holdings Corporation (property and casualty insurance company), 2004 to 2008; formerly,
Director, The Proformance Insurance Company (property and casualty insurance company), 2004 to 2008; formerly, Director, Providence Washington Insurance Company (property and casualty insurance company), 1998 to 2006; formerly,
Director, Summit Global Partners (insurance brokerage firm), 2000 to 2005.
|
Peter P. Trapp (1944)
|
Trustee since inception
|
Retired; formerly, Regional Manager for Mid-Southern Region, Ford Motor Credit Company, September 1997 to 2007; formerly, President, Ford Life Insurance Company, April 1995 to August 1997.
|
51
|
None.
|
Name,
(Year of
Birth), and
Address (1)
|
Position(s)
and
Length of
Time
Served (2)
|
Principal Occupation(s) (3)
|
Number
of Funds
in Fund
Complex
Overseen
by Fund
Trustee
|
Other Directorships Held Outside Fund
Complex by Fund Trustee (3)
|
Fund Trustees who are “Interested Persons”
|
||||
Joseph V. Amato*
(1962)
|
Chief Executive Officer and President since 2018 and Trustee since 2009
|
President and Director, Neuberger Berman Group LLC, since 2009; President and Chief Executive Officer, Neuberger Berman BD LLC (“Neuberger Berman”) and Neuberger Berman Holdings LLC (including its predecessor, Neuberger Berman
Inc.), since 2007; Chief Investment Officer (Equities) and President (Equities), NBIA (formerly, Neuberger Berman Fixed Income LLC and including predecessor entities), since 2007, and Board Member of NBIA since 2006; formerly, Global
Head of Asset Management of Lehman Brothers Holdings Inc.’s (“LBHI”) Investment Management Division, 2006 to 2009; formerly, member of LBHI’s Investment Management Division’s Executive Management Committee, 2006 to 2009; formerly,
Managing Director, Lehman Brothers Inc. (“LBI”), 2006 to 2008; formerly, Chief Recruiting and Development Officer, LBI, 2005 to 2006; formerly, Global Head of LBI’s Equity Sales and a Member of its Equities Division Executive Committee,
2003 to 2005; President and Chief Executive Officer, ten registered investment companies for which NBIA acts as investment manager and/or administrator.
|
51
|
Member of Board of Advisors, McDonough School of Business, Georgetown University, since 2001; Member of New York City Board of Advisors, Teach for America, since 2005; Trustee, Montclair Kimberley Academy (private school), since
2007; Member of Board of Regents, Georgetown University, since 2013.
|
Robert Conti* (1956)
|
Trustee since
2008;
prior thereto,
Chief
Executive
Officer and
President from
2008 to 2018
|
Retired; formerly, Managing Director, Neuberger Berman, 2007 to 2018; formerly, President—Mutual Funds, NBIA, 2008 to 2018; formerly, Senior Vice President, Neuberger Berman, 2003 to 2006; formerly, Vice President, Neuberger Berman,
1999 to 2003.
|
51
|
Director, Staten Island Mental Health Society, since 1994; formerly, Chairman of the Board, Staten Island Mental Health Society, 2008 to 2011; formerly, Member of the Board of Governors, Investment Company Institute.
|
(1)
|
The business address of each listed person is 1290 Avenue of the Americas, New York, NY 10104.
|
|
|
(2)
|
Pursuant to the Trust’s Amended and Restated Trust Instrument (“Trust Instrument”), subject to any limitations on the term of service imposed by the By-Laws or any
retirement policy adopted by the Fund Trustees, each Fund Trustee shall hold office for life or until his or her successor is elected or the Trust terminates; except that (a) any Fund Trustee may resign by delivering a written
resignation; (b) any Fund Trustee may be removed with or without cause at any time by a written instrument signed by at least two-thirds of the other Fund Trustees; (c) any Fund Trustee who requests to be retired, or who has become
unable to serve, may be retired by a written instrument signed by a majority of the other Fund Trustees; and (d) any Fund Trustee may be removed at any shareholder meeting by a vote of at least two-thirds of the outstanding shares.
|
|
|
(3)
|
Except as otherwise indicated, each individual has held the positions shown during at least the last five years.
|
|
|
*
|
Indicates a Fund Trustee who is an “interested person” within the meaning of the 1940 Act. Mr. Amato is an interested person of the Trust by virtue
of the fact that he is an officer of NBIA and/or its affiliates. Mr. Conti is an interested person of the Trust by virtue of the fact that he was an officer of NBIA and/or its affiliates until June 2018.
|
Name, (Year of Birth), and
Address (1)
|
Position(s) and Length of
Time Served (2) |
Principal Occupation(s) (3) |
Corey A. Issing
(1978)
|
Chief Legal Officer since 2016 (only for purposes of sections 307 and 406 of the Sarbanes-Oxley Act of 2002)
|
General Counsel and Head of Compliance – Mutual Funds since 2016 and Managing Director, NBIA, since 2017; formerly, Associate General Counsel (2015 to 2016), Counsel (2007 to 2015), Senior Vice President (2013-2016), Vice President
(2009 – 2013); Chief Legal Officer (only for purposes of sections 307 and 406 of the Sarbanes-Oxley Act of 2002), twenty-nine registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Sheila R. James (1965)
|
Assistant Secretary since inception
|
Vice President, Neuberger Berman, since 2008 and Employee since 1999; Vice President, NBIA, since 2008; formerly, Assistant Vice President, Neuberger Berman, 2007; Employee, NBIA, 1991 to 1999; Assistant Secretary, twenty-nine
registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Brian Kerrane (1969)
|
Chief Operating Officer since 2015 and Vice President since 2008
|
Managing Director, Neuberger Berman, since 2013; Chief Operating Officer – Mutual Funds and Managing Director, NBIA, since 2015; formerly, Senior Vice President, Neuberger Berman, 2006 to 2014; Vice President, NBIA, 2008 to 2015 and
Employee since 1991; Chief Operating Officer, ten registered investment companies for which NBIA acts as investment manager and/or administrator; Vice President, twenty-nine registered investment companies for which NBIA acts as
investment manager and/or administrator.
|
Anthony Maltese (1959)
|
Vice President since 2015
|
Senior Vice President, Neuberger Berman, since 2014 and Employee since 2000; Senior Vice President, NBIA, since 2014; Vice President, ten registered investment companies for which NBIA acts as investment manager and/or
administrator.
|
Josephine Marone (1963)
|
Assistant Secretary since 2017
|
Senior Paralegal, Neuberger Berman, since 2007 and Employee since 2007; Assistant Secretary, twenty-nine registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Name, (Year of Birth), and
Address (1)
|
Position(s) and Length of
Time Served (2) |
Principal Occupation(s) (3) |
Owen F. McEntee, Jr. (1961)
|
Vice President since 2008
|
Vice President, Neuberger Berman, since 2006; Vice President, NBIA, since 2006 and Employee since 1992; Vice President, ten registered investment companies for which NBIA acts as investment manager and/or administrator.
|
John M. McGovern (1970)
|
Treasurer and Principal Financial and Accounting Officer since inception
|
Senior Vice President, Neuberger Berman, since 2007; Senior Vice President, NBIA, since 2007 and Employee since 1993; formerly, Vice President, Neuberger Berman, 2004 to 2006; formerly, Assistant Treasurer, 2002 to 2005; Treasurer
and Principal Financial and Accounting Officer, twenty-nine registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Frank Rosato (1971)
|
Assistant Treasurer since inception
|
Vice President, Neuberger Berman, since 2006; Vice President, NBIA, since 2006 and Employee since 1995; Assistant Treasurer, ten registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Niketh Velamoor (1979)
|
Anti-Money Laundering
Compliance Officer since 2018
|
Senior Vice President and Associate General
Counsel, Neuberger Berman, since July 2018;
Assistant United States Attorney, Southern
District of New York, 2009 to 2018; Anti-
Money Laundering Compliance Officer, four registered investment companies for which NBIA acts as investment manager and/or administrator.
|
(1)
|
The business address of each listed person is 1290 Avenue of the Americas, New York, NY 10104.
|
|
|
(2)
|
Pursuant to the By‑Laws of the Trust, each officer elected by the Fund Trustees shall hold office until his or her successor shall have been elected and qualified or until
his or her earlier death, inability to serve, or resignation. Officers serve at the pleasure of the Fund Trustees and may be removed at any time with or without cause.
|
(3)
|
Except as otherwise indicated, each individual has held the positions shown during at least the last five years.
|
|
Name and Position with the Trust
|
Aggregate Compensation
from the Trust |
Total Compensation from Investment Companies in the Neuberger Berman
Fund Complex Paid to Fund Trustees
|
Independent Fund Trustees
|
||
Michael J. Cosgrove
Trustee
|
$35,625
|
$230,000
|
Marc Gary
Trustee
|
$34,851
|
$225,000
|
Martha C. Goss
Trustee
|
$34,851
|
$225,000
|
Michael M. Knetter
Trustee
|
$34,851
|
$225,000
|
Deborah C. McLean
Trustee
|
$35,625
|
$230,000
|
George W. Morriss
Trustee
|
$34,851
|
$225,000
|
Tom D. Seip
Chairman of the Board and Trustee |
$40,272
|
$260,000
|
James G. Stavridis
Trustee
|
$32,527
|
$210,000
|
Candace L. Straight
Trustee |
$32,527
|
$210,000
|
Peter P. Trapp
Trustee |
$32,527
|
$210,000
|
Fund Trustees who are “Interested Persons”
|
||
Joseph V. Amato
President, Chief Executive Officer and Trustee
|
$0
|
$0
|
Robert Conti
Trustee |
$32,527
|
$210,000
|
Name of Fund Trustee
|
Absolute Return Multi-
Manager Fund
|
Independent Fund Trustees
|
|
Michael J. Cosgrove
|
A
|
Marc Gary
|
A
|
Martha C. Goss
|
A
|
Michael M. Knetter
|
A
|
Deborah C. McLean
|
A
|
George W. Morriss
|
A
|
Tom D. Seip
|
A
|
James G. Stavridis
|
C
|
Candace L. Straight
|
A
|
Peter P. Trapp
|
A
|
Fund Trustees who are “Interested Persons”
|
|
Joseph V. Amato
|
A
|
Robert Conti
|
A
|
Management and Administration Fees
Accrued for Fiscal Years Ended October 31, |
||||
Fund
|
Class
|
2019
|
2018
|
2017
|
Absolute Return Multi-Manager Fund
|
Class A
|
$194,419
|
$369,685
|
$677,199
|
Class C
|
$182,289
|
$281,414
|
$512,975
|
|
Institutional
|
$3,150,749
|
$4,580,143
|
$7,107,128
|
|
Class R6
|
$130,564
|
$262,922
|
$75,031
|
Fund
|
Class
|
Limitation Period
|
Expense Limitation
|
Absolute Return Multi-Manager Fund
|
Institutional
|
10/31/2023
|
1.97%
|
A
|
10/31/2023
|
2.33%
|
|
C
|
10/31/2023
|
3.08%
|
|
R6
|
10/31/2023
|
1.87%*
|
Expenses Repaid for Fiscal Years Ended October 31,
|
||||
Fund
|
Class
|
2019
|
2018
|
2017
|
Absolute Return Multi-Manager Fund
|
Class A
|
$0
|
$0
|
$0
|
Class C
|
$0
|
$0
|
$0
|
|
Class R6
|
$0
|
$0
|
$0
|
|
Institutional Class
|
$0
|
$0
|
$0
|
Type of Account
|
Number of Accounts Managed
|
Total Assets Managed
($ millions)
|
Number of Accounts Managed for which Advisory Fee is Performance-Based
|
Assets Managed for which Advisory Fee is Performance-Based ($ millions)
|
David Kupperman***
|
Registered Investment Companies*
|
1
|
175
|
-
|
-
|
Other Pooled Investment Vehicles
|
14
|
2,083
|
8
|
785
|
Other Accounts**
|
11
|
4,102
|
3
|
62
|
Jeffrey Majit***
|
||||
Registered Investment Companies*
|
1
|
175
|
-
|
-
|
Other Pooled Investment Vehicles
|
14
|
2,083
|
8
|
785
|
Other Accounts**
|
11
|
4,102
|
3
|
62
|
Fred Ingham***
|
||||
Registered Investment Companies*
|
1
|
175
|
-
|
-
|
Other Pooled Investment Vehicles
|
14
|
2,083
|
8
|
785
|
Other Accounts**
|
11
|
4,102
|
3
|
62
|
Portfolio Manager
|
Fund Managed
|
Dollar Range of Equity Securities Owned in the Fund
|
David Kupperman
|
Neuberger Berman Absolute Return Multi-Manager Fund
|
E
|
Jeffrey Majit
|
Neuberger Berman Absolute Return Multi-Manager Fund
|
E
|
Fred Ingham
|
Neuberger Berman Absolute Return Multi-Manager Fund
|
D
|
A = None
B = $1-$10,000 C = $10,001 - $50,000 D =$50,001-$100,000
|
E = $100,001-$500,000
F = $500,001-$1,000,000 G = Over $1,000,001 |
Sales Charge Revenue
|
Deferred Sales Charge Revenue
|
|||||
Fund
|
Fiscal
Year
Ended
Oct. 31,
|
Amount
Paid to
Distributor
|
Amount
Retained
by
Distributor
|
Amount
Paid to
Distributor
|
Amount
Retained
by
Distributor
|
|
Absolute Return Multi-Manager Fund– Class A
|
2019
|
$ 8,291
|
$ 1,089
|
-
|
-
|
|
2018
|
$3,973
|
$710
|
-
|
-
|
||
2017
|
$26,985
|
$3,683
|
-
|
-
|
||
Absolute Return Multi-Manager Fund – Class C
|
2019
|
-
|
-
|
$28
|
-
|
|
2018
|
-
|
-
|
$70
|
-
|
||
2017
|
-
|
-
|
$1,221
|
-
|
||
Fiscal Year Ended
October 31,
|
|||
Fund
|
2019
|
2018
|
2017
|
Absolute Return Multi-Manager Fund
|
$24,798
|
$47,242
|
$86,936
|
Fiscal Year Ended
October 31,
|
|||
Fund
|
2019
|
2018
|
2017
|
Absolute Return Multi-Manager Fund
|
$93,005
|
$143,868
|
$263,634
|
Fund and Class
|
Name and Address
|
Percentage of
Shares Held
|
Neuberger Berman Absolute Return Multi-Manager Fund – Class A
|
CHARLES SCHWAB & CO INC
ATTN MUTUAL FUNDS
211 MAIN ST
SAN FRANCISCO CA 94105-1905
|
18.70%
|
MORGAN STANLEY SMITH BARNEY LLC
FOR THE EXCLUSIVE BENE OF ITS CUST
1 NEW YORK PLZ FL 12
NEW YORK NY 10004-1901
|
15.06%
|
|
PERSHING LLC
1 PERSHING PLZ
JERSEY CITY NJ 07399-0002
|
11.31%
|
|
AMERICAN ENTERPRISE INVESTMENT SVC
FBO # 41999970
707 2ND AVE S
MINNEAPOLIS MN 55402-2405
|
5.72%
|
|
LPL FINANCIAL
OMNIBUS CUSTOMER ACCOUNT
ATTN MUTUAL FUND TRADING
4707 EXECUTIVE DR
SAN DIEGO CA 92121-3091
|
5.12%
|
|
Neuberger Berman Absolute Return Multi-Manager Fund – Class C
|
AMERICAN ENTERPRISE INVESTMENT SVC
FBO # 41999970
707 2ND AVE S
MINNEAPOLIS MN 55402-2405
|
22.29%
|
MERRILL LYNCH PIERCE FENNER &
SMITH INC FUND ADMINISTRATION
ATTN SERVICE TEAM
4800 DEER LAKE DR E FL 2
JACKSONVILLE FL 32246-6484
|
16.44%
|
|
RAYMOND JAMES OMNIBUS FOR
MUTUAL FUNDS HOUSE ACCOUNT
FIRM 92500015
ATTN COURTNEY WALLER
880 CARILLON PKWY
ST PETERSBURG FL 33716-1100
|
14.90%
|
Fund and Class | Name and Address |
Percentage of
Shares Held
|
UBS WM USA
0O0 11011 6100
OMNI ACCOUNT M/F
SPEC CDY A/C EBOC UBSFSI
1000 HARBOR BLVD
WEEHAWKEN NJ 07086-6761
|
14.45%
|
|
MORGAN STANLEY SMITH BARNEY LLC
FOR THE EXCLUSIVE BENE OF ITS CUST
1 NEW YORK PLZ FL 12
NEW YORK NY 10004-1901
|
7.54%
|
|
WELLS FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE
EXCLUSIVE BENEFIT OF CUSTOMER
2801 MARKET ST
SAINT LOUIS MO 63103-2523
|
5.87%
|
|
LPL FINANCIAL
A/C 1000-0005
4707 EXECUTIVE DR
SAN DIEGO CA 92121-3091
|
5.76%
|
|
Neuberger Berman Absolute Return Multi-Manager Fund – Institutional Class
|
NATIONAL FINANCIAL SERVICES LLC
FOR THE EXCLUSIVE BENEFIT OF
OUR CUSTOMERS
ATTN MUTUAL FUNDS DEPT
499 WASHINGTON BLVD FL 4
JERSEY CITY NJ 07310-1995
|
21.64%
|
LPL FINANCIAL
OMNIBUS CUSTOMER ACCOUNT
ATTN MUTUAL FUND TRADING
4707 EXECUTIVE DR
SAN DIEGO CA 92121-3091
|
19.15%
|
|
CHARLES SCHWAB & CO INC
ATTN MUTUAL FUNDS
211 MAIN ST
SAN FRANCISCO CA 94105-1905
|
17.84%
|
Fund and Class | Name and Address |
Percentage of
Shares Held
|
UBS WM USA
0O0 11011 6100
OMNI ACCOUNT M/F
SPEC CDY A/C EBOC UBSFSI
1000 HARBOR BLVD
WEEHAWKEN NJ 07086-6761
|
12.52%
|
|
WELLS FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE
EXCLUSIVE BENEFIT OF CUSTOMER
2801 MARKET ST
SAINT LOUIS MO 63103-2523
|
5.33%
|
|
Neuberger Berman Absolute Return Multi-Manager Fund – Class R6
|
NATIONAL FINANCIAL SERVICES LLC
499 WASHINGTON BLVD
JERSEY CITY NJ 07310-1995
|
93.19%
|
VERSION
|
REASON FOR UPDATE
|
DATE OF RELEASE
|
INITIALS
|
1.1
|
First publication of the Firm’s Proxy Voting Policy
|
29 June 2015
|
|
1.2
|
General updates (non-material)
|
June 2017
|
YS
|
1.3
|
Updates to align proxy voting procedure
|
April 2018
|
YS
|
1.4
|
General updates regarding ESG alignment
|
2019
|
GS
|
I.
|
STATEMENT OF POLICY
|
II.
|
PROXY VOTING PROCEDURES
|
•
|
Keep a record of each proxy received;
|
•
|
Forward the proxy to the Portfolio Manager and/or the Head of Research, who make the voting decision in the Firm (hereafter referred to as the “Firm Managers”);
|
•
|
Determine which accounts managed by the Firm hold the security to which the proxy relates; and
|
•
|
Provide the Firm Managers with a list of accounts that hold the security, together with the number of votes each account controls (reconciling any duplications), and the date by which the Firm must
vote the proxy in order to allow enough time for the completed proxy to be returned to the issuer prior to the vote taking place.
|
•
|
Absent material conflicts (see Section IV below), the Firm Managers will determine how the Firm should vote the proxy. The Firm Managers will send its decision on how the Firm will vote a proxy to the
responsible member(s) who is/are responsible for completing the proxy and mailing the proxy in a timely and appropriate manner.
|
•
|
The Firm may retain a third party to assist it in coordinating and voting proxies with respect to client securities. If so, the responsible member(s) will monitor the third
|
|
party to assure that all proxies are being properly voted and appropriate records are being retained.
|
•
|
Perform reconciliations to ensure that all proxies are voted (e.g., reconcile the list of clients for which the Firm has proxy voting obligations against a list of votes cast by the Firm or by
the Proxy Voting Service for clients) or that the Firm has determined that not voting for a particular client is appropriate.
|
I.
|
VOTING GUIDELINES
|
|
a. |
Generally, the Firm will vote in favor of routine corporate housekeeping proposals, including election of directors (where no corporate governance issues are implicated) and selection of independent, reputable auditors.
|
|
b. |
Generally, the Firm will vote against proposals that make it more difficult to replace members of the issuer’s board of directors, including proposals to stagger the board, cause management to be overrepresented on the
board, introduce cumulative voting, introduce unequal voting rights, and create supermajority voting.
|
|
c. |
For other proposals, the Firm shall determine whether a proposal is in the best interests of its clients and may take into account the following factors, among others:
|
|
1. |
whether the proposal was recommended by management and the Firm's opinion of management;
|
|
2. |
whether the proposal acts to entrench existing management;
|
|
3. |
whether the proposal fairly compensates management, by promoting alignment with past and future performance and protecting long-term shareholder value creation; and
|
|
4. |
whether the proposal reflects the investee company’s commitment and efforts towards ESG considerations.
|
V. |
DISCLOSURE
|
VI. |
RECORDKEEPING
|
|
a. |
Copies of this proxy voting policy and procedures, and any amendments thereto.
|
|
b. |
A copy of each proxy statement that the Firm receives, provided however that the Firm may rely on obtaining a copy of proxy statements from the SEC’s EDGAR system for those proxy statements that are so available.1
|
|
c. |
A record of each vote that the Firm casts.2
|
|
d. |
A copy of any document the Firm created that was material to making a decision how to vote proxies, or that memorializes that decision.
|
|
e. |
A copy of each written client request for information on how the Firm voted such client’s proxies, and a copy of any written response to any (written or oral) client request for information on how the Firm voted its proxies
|
|
I. |
INTRODUCTION AND GENERAL PRINCIPLES
|
|
A. |
Certain subsidiaries of Neuberger Berman Group LLC (“NB”) have been delegated the authority and responsibility to vote the proxies of their respective investment advisory clients.
|
|
B. |
NB understands that proxy voting is an integral aspect of investment management. Accordingly, proxy voting must be conducted with the same degree of prudence and loyalty accorded any fiduciary or other
obligation of an investment manager.
|
|
C. |
NB believes that the following policies and procedures are reasonably expected to ensure that proxy matters are conducted in the best interest of clients, in accordance with NB’s fiduciary duties,
applicable rules under the Investment Advisers Act of 1940, fiduciary standards and responsibilities for ERISA clients set out in Department of Labor interpretations, the UK Stewardship Code, the Japan Stewardship Code and other
applicable laws and regulations.
|
|
D. |
In instances where NB does not have authority to vote client proxies, it is the responsibility of the client to instruct the relevant custody bank or banks to mail proxy material directly to such client.
|
|
E. |
In all circumstances, NB will comply with specific client directions to vote proxies, whether or not such client directions specify voting proxies in a manner that is different from NB’s policies and
procedures.
|
|
F. |
NB will seek to vote all shares under its authority so long as that action is not in conflict with client instructions.
There may be circumstances under which NB may abstain from voting a client proxy, such as when NB believes voting would not be in clients’ best interests
(e.g., not voting in countries with share blocking or meetings in which voting would entail additional costs). NB understands that it must weigh the costs and benefits of voting proxy
proposals relating to foreign securities and make an informed decision with respect to whether voting a given proxy proposal is prudent and solely in the interests of the clients and, in the case of an ERISA client and other
accounts and clients subject to similar local laws, a plan’s participants and beneficiaries. NB’s decision in such circumstances will take into account
the effect that the proxy vote, either by itself or together with other votes,
is expected to have on the value of the client’s investment and whether this expected effect would outweigh the cost of voting.
|
|
A. |
NB has designated a Governance & Proxy Committee (“Proxy Committee”) with the responsibility for: (1) developing, authorizing, implementing and updating NB’s policies and procedures; (2)
administering and overseeing the governance and proxy voting processes; and (3) engaging and overseeing any third-party vendors as voting delegates to review, monitor and/or vote proxies. NB, at the recommendation of the Proxy
Committee, has retained Glass, Lewis & Co., LLC (“Glass Lewis”) as its voting delegate.
|
|
B. |
The Proxy Committee will meet as frequently and in such manner as necessary or appropriate to fulfill its responsibilities.
|
|
C. |
The members of the Proxy Committee will be appointed from time to time and will include the Chief Investment Officer (Equities), the Head of Global Equity Research, the Head of ESG Investing, and senior
portfolio managers. A senior member of the Legal and Compliance Department will advise the Proxy Committee and may be included for purposes of ensuring a quorum.
|
|
D. |
In the event that one or more members of the Proxy Committee are not independent with respect to a particular matter, the remaining members of the Proxy Committee shall constitute an ad hoc independent
subcommittee of the Proxy Committee, which will have full authority to act upon such matter.
|
|
III. |
PROXY VOTING GUIDELINES
|
|
A. |
The Proxy Committee developed the Governance and Proxy Voting Guidelines (“Voting Guidelines”) based on our Governance and Engagement Principles. These Guidelines are updated as appropriate and generally
on an annual basis. With input from certain of our investment professionals, the modifications are intended to reflect emerging corporate governance issues and themes. The Proxy Committee recognizes that in certain circumstances
it may be in the interests of our clients to deviate from our Voting Guidelines.
|
|
B. |
Our views regarding corporate governance and engagement, and the related stewardship actions, are led by our ESG Investing group, in consultation with professionals in the Legal & Compliance and
Global Equity Research groups, among others. These insightful, experienced and dedicated groups enable us to think strategically about engagement and stewardship priorities.
|
PROXY VOTING POLICIES AND PROCEDURES
|
|
C. |
We believe NB’s Voting Guidelines generally represent the voting positions most likely to support our clients’ best economic interests across a range of sectors and contexts. These guidelines are not
intended to constrain our consideration of the specific issues facing a particular company on a particular vote, and so there will be times when we deviate from the Voting Guidelines.
|
|
D. |
In the event that a senior investment professional at Neuberger Berman believes that it is in the best interest of a client or clients to vote proxies in a manner inconsistent with NB’s Voting
Guidelines, the investment professional will submit in writing the basis for his or her recommendation. The Proxy Committee will review this recommendation in the context of the specific
circumstances of the situation and with the intention of remaining consistent with our Engagement Principles.
|
|
IV. |
PROXY VOTING PROCEDURES
|
|
A. |
NB will vote client proxies in accordance with a client’s specific request even if it is in a manner inconsistent with NB’s policies and procedures. Such specific requests should be made in writing
by the individual client or by an authorized officer, representative or named fiduciary of a client.
|
|
B. |
NB has engaged Glass Lewis as its advisor and voting agent to: (1) provide research on proxy matters; (2) vote proxies in accordance with NB’s Voting Guidelines or as otherwise instructed
and submit such proxies in a timely manner; (3) handle other administrative functions of proxy voting; (4) maintain records of proxy statements received in connection with proxy votes
and provide copies of such proxy statements promptly upon request; and (5) maintain records of votes cast.
|
|
C. |
Except in instances where clients have retained voting authority, NB will instruct custodians of client accounts to forward all proxy statements and materials received in respect of client accounts
to Glass Lewis.
|
|
D. |
Notwithstanding the foregoing, NB retains final authority and fiduciary responsibility for proxy voting.
|
|
V. |
CONFLICTS OF INTEREST
|
|
A. |
Glass Lewis will vote proxies in accordance with the Voting Guidelines described in Section III or, in instances where
a material conflict has been determined to exist, as Glass Lewis recommends. NB believes that this process is reasonably designed to address material
conflicts of interest that may arise in conjunction with proxy voting decisions. Potential conflicts considered by the Proxy Committee when it is determining whether to deviate from NB’s Voting Guidelines include, among others: a material client relationship with the corporate issuer being considered; personal or business relationships
between the portfolio managers and an executive officer; director, or director nominee of the issuer; joint business ventures; or a direct
transactional relationship between the issuer and senior executives of NB.
|
|
B. |
In the event that an NB Investment Professional believes that it is in the best interest of a client or clients to vote proxies in a manner inconsistent with the Voting Guidelines described in
Section III, such NB Investment Professional will contact a member of the Legal & Compliance Department advising the Proxy Committee and complete and sign a questionnaire in the form adopted from time to time. Such
questionnaires will require specific information, including the reasons the NB Investment Professional believes a proxy vote in this manner is in the best interest of a client or clients and disclosure of specific ownership,
business or personal relationship, or other matters that may raise a potential material conflict of interest with respect to the voting of the proxy. The Proxy Committee will meet with the NB Investment Professional to
review the completed questionnaire and consider such other matters as it deems appropriate to determine that there is no material conflict of interest with respect to the voting of the proxy in the requested manner. The
Proxy Committee shall document its consideration of such other matters. In the event that the Proxy Committee determines that such vote will not present a material conflict, the Proxy Committee will make a determination
whether to vote such proxy as recommended by the NB Investment Professional. In the event of a determination to vote the proxy as recommended by the NB Investment Professional, an authorized member of the Legal &
Compliance Department advising the Proxy Committee will instruct Glass Lewis to vote in such manner with respect to the client or clients. In the event that the Proxy Committee determines that the voting of a proxy as
recommended by the NB Investment Professional would not be appropriate, the Proxy Committee will:
|
|
(i) |
take no further action, in which case Glass Lewis shall vote such proxy in accordance with the Voting Guidelines;
|
|
(ii) |
disclose such conflict to the client or clients and obtain written direction from the client with respect to voting the proxy;
|
|
(iii) |
suggest that the client or clients engage another party to determine how to vote the proxy; or
|
|
(iv) |
engage another independent third party to determine how to vote the proxy. A record of the Proxy Committee’s determinations shall be prepared and maintained in accordance with applicable policies.
|
|
C. |
In the event that the Voting Guidelines described in Section III do not address how a proxy should be voted and Glass Lewis refrains from making a recommendation as to how such proxy should be voted,
the Proxy Committee will make a determination as to how the proxy should be voted. The Proxy Committee will consider such matters as it deems appropriate to determine how such proxy should be voted including whether there is a
material conflict of interest with respect to the voting of the proxy in accordance with its decision. The Proxy Committee shall document its consideration of such matters, and an authorized member of the Legal &
Compliance Department advising the Proxy Committee will instruct Glass Lewis to vote in such manner with respect to such client or clients.
|
|
D. |
Material conflicts cannot be resolved by simply abstaining from voting.
|
PROXY VOTING POLICIES AND PROCEDURES
|
|
VI. |
RECORDKEEPING
|
VII. |
ENGAGEMENT AND MONITORING
|
VIII. |
SECURITIES LENDING
|
IX. |
DISCLOSURE
|
|
|
Fund
|
Institutional
Class
|
Class A
|
Class C
|
Class R6
|
Neuberger Berman Commodity Strategy Fund
|
NRBIX
|
NRBAX
|
NRBCX
|
--
|
Neuberger Berman Global Allocation Fund
|
NGLIX
|
NGLAX
|
NGLCX
|
NRGLX
|
Neuberger Berman Long Short Fund
|
NLSIX
|
NLSAX
|
NLSCX
|
--
|
Neuberger Berman Multi-Asset Income Fund
|
NANIX
|
NANAX
|
NANCX
|
NRANX
|
Neuberger Berman Multi-Style Premia Fund
|
NMLIX
|
NMLAX
|
NMLCX
|
NMLRX
|
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund
|
NUPIX
|
NUPAX
|
NUPCX
|
NUPRX
|
1290 Avenue of the Americas, New York, NY 10104
Shareholder Services
800.877.9700
Institutional Services
800.366.6264
www.nb.com
|
INVESTMENT INFORMATION
|
1
|
|
Investment Policies and Limitations
|
1
|
|
Cash Management and Temporary Defensive Positions
|
9
|
|
Additional Investment Information
|
9
|
|
PERFORMANCE INFORMATION
|
89
|
|
TRUSTEES AND OFFICERS
|
90
|
|
Information about the Board of Trustees
|
90
|
|
Information about the Officers of the Trust
|
95
|
|
INVESTMENT MANAGEMENT AND ADMINISTRATION SERVICES
|
108
|
|
Investment Manager and Administrator
|
108
|
|
Management and Administration Fees
|
110
|
|
Contractual Expense Limitations
|
113
|
|
Advisory Fee Waiver
|
115
|
|
Portfolio Manager Information
|
116
|
|
Other Investment Companies or Accounts Managed
|
123
|
|
Codes of Ethics
|
125
|
|
Management and Control of NBIA
|
125
|
|
DISTRIBUTION ARRANGEMENTS
|
125
|
|
Distributor
|
125
|
|
Additional Payments to Financial Intermediaries
|
129
|
|
Distribution Plan (Class A Only)
|
131
|
|
Distribution Plan (Class C Only)
|
132
|
|
Distribution Plan (Class A and Class C)
|
132
|
|
ADDITIONAL PURCHASE INFORMATION
|
133
|
|
Share Prices and Net Asset Value
|
133
|
|
Subscriptions in Kind
|
135
|
|
Financial Intermediaries
|
135
|
|
Automatic Investing and Dollar Cost Averaging
|
136
|
|
Sales Charges
|
136
|
|
ADDITIONAL EXCHANGE INFORMATION
|
136
|
|
ADDITIONAL REDEMPTION INFORMATION
|
137
|
|
Suspension of Redemptions
|
137
|
|
Redemptions in Kind
|
138
|
|
CONVERSION INFORMATION
|
138
|
DIVIDENDS AND OTHER DISTRIBUTIONS
|
139
|
|
ADDITIONAL TAX INFORMATION
|
140
|
|
Taxation of the Funds
|
140
|
|
Taxation of the Funds’ Shareholders
|
149
|
|
Special Tax Considerations Pertaining to Funds of Funds
|
152
|
|
FUND TRANSACTIONS
|
153
|
|
Portfolio Turnover
|
159
|
|
Proxy Voting
|
159
|
|
PORTFOLIO HOLDINGS DISCLOSURE
|
160
|
|
Portfolio Holdings Disclosure Policy
|
160
|
|
Selective Disclosure Procedures
|
161
|
|
Portfolio Holdings Approved Recipients
|
161
|
|
REPORTS TO SHAREHOLDERS
|
163
|
|
ORGANIZATION, CAPITALIZATION AND OTHER MATTERS
|
163
|
|
CUSTODIAN AND TRANSFER AGENT
|
164
|
|
INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRMS
|
164
|
|
LEGAL COUNSEL
|
164
|
|
CONTROL PERSONS AND PRINCIPAL HOLDERS OF SECURITIES
|
164
|
|
REGISTRATION STATEMENT
|
174
|
|
FINANCIAL STATEMENTS
|
174
|
|
APPENDIX A – LONG-TERM AND SHORT-TERM DEBT SECURITIES RATING DESCRIPTIONS
|
A-1
|
|
APPENDIX B – PROXY VOTING POLICY FOR NEUBERGER BERMAN INVESTMENT ADVISERS LLC
|
B-1
|
Long Short
Fund
|
|
Gross income from securities lending activities
|
$1,390,186
|
Fees and/or compensation paid by the Fund for securities lending activities and related services
|
|
Fees paid to securities lending agent from a revenue split
|
$79,528
|
Fees paid for any cash collateral management service (including fees deducted from a pooled cash collateral reinvestment vehicle) that are not included in the revenue split
|
$19,529
|
Administrative fees not included in revenue split
|
$0
|
Indemnification fees not included in revenue split
|
$0
|
Rebate (paid to borrower)
|
$575,365
|
Other fees relating to the securities lending program that are not included in the revenue split
|
$0
|
Aggregate fees/compensation for securities lending activities
|
$674,422
|
Net income from securities lending activities
|
$715,764
|
Name,
(Year of Birth), and Address (1) |
Position(s)
and Length of Time Served (2) |
Principal Occupation(s) (3) |
Number
of Funds in Fund Complex Overseen by Fund Trustee |
Other Directorships Held Outside Fund
Complex by Fund Trustee (3) |
Independent Fund Trustees
|
||||
Michael J. Cosgrove (1949)
|
Trustee since 2015
|
President, Carragh Consulting USA, since 2014; formerly, Executive, General Electric Company, 1970 to 2014, including President, Mutual Funds and Global Investment Programs, GE Asset Management, 2011 to 2014, President and Chief
Executive Officer, Mutual Funds and Intermediary Business, GE Asset Management, 2007 to 2011, President, Institutional Sales and Marketing, GE Asset Management, 1998 to 2007, and Chief Financial Officer, GE Asset Management, and Deputy
Treasurer, GE Company, 1988 to 1993.
|
51
|
Director, America Press, Inc. (not-for-profit Jesuit publisher), since 2015; formerly, Director, Fordham University, 2001 to 2018; formerly, Director, The Gabelli Go Anywhere Trust, June 2015 to June 2016; formerly, Director, Skin
Cancer Foundation (not-for-profit), 2006 to 2015; formerly, Director, GE Investments Funds, Inc., 1997 to 2014; formerly, Trustee, GE Institutional Funds, 1997 to 2014; formerly, Director, GE Asset Management, 1988 to 2014; formerly,
Director, Elfun Trusts, 1988 to 2014; formerly, Trustee, GE Pension & Benefit Plans, 1988 to 2014; formerly, Member of Board of Governors, Investment Company Institute.
|
Marc Gary (1952)
|
Trustee since 2015
|
Executive Vice Chancellor and Chief Operating Officer, Jewish Theological Seminary, since 2012; formerly, Executive Vice President and General Counsel, Fidelity Investments, 2007 to 2012; formerly, Executive Vice President and
General Counsel, BellSouth Corporation, 2004 to 2007; formerly, Vice President and Associate General Counsel, BellSouth Corporation, 2000 to 2004; formerly, Associate, Partner, and National Litigation Practice Co-Chair, Mayer, Brown
LLP, 1981 to 2000; formerly, Associate Independent Counsel, Office of Independent Counsel, 1990 to 1992.
|
51
|
Trustee, Jewish Theological Seminary, since 2015; Director, Legility, Inc. (privately held for-profit company), since 2012; Director, Lawyers Committee for Civil Rights Under Law (not-for-profit), since 2005; formerly, Director,
Equal Justice Works (not-for-profit), 2005 to 2014; formerly, Director, Corporate Counsel Institute, Georgetown University Law Center, 2007 to 2012; formerly, Director, Greater Boston Legal Services (not-for-profit), 2007 to 2012.
|
Name,
(Year of Birth), and Address (1) |
Position(s)
and Length of Time Served (2) |
Principal Occupation(s) (3) |
Number
of Funds in Fund Complex Overseen by Fund Trustee |
Other Directorships Held Outside Fund
Complex by Fund Trustee (3) |
Martha C. Goss (1949)
|
Trustee since 2007
|
President, Woodhill Enterprises Inc./Chase Hollow Associates LLC (personal investment vehicle), since 2006; formerly, Consultant, Resources Global Professionals (temporary staffing), 2002 to 2006; formerly, Chief Financial Officer,
Booz-Allen & Hamilton, Inc., 1995 to 1999; formerly, Enterprise Risk Officer, Prudential Insurance, 1994 to1995; formerly, President, Prudential Asset Management Company, 1992 to 1994; formerly, President, Prudential Power Funding
(investments in electric and gas utilities and alternative energy projects), 1989 to 1992; formerly, Treasurer, Prudential Insurance Company, 1983 to 1989.
|
51
|
Director, American Water (water utility), since 2003; Director, Allianz Life of New York (insurance), since 2005; Director, Berger Group Holdings, Inc. (engineering consulting firm), since 2013; Director, Financial Women’s
Association of New York (not-for-profit association), since 2003; Trustee Emerita, Brown University, since 1998; Director, Museum of American Finance (not-for-profit), since 2013; formerly, Non-Executive Chair and Director, Channel
Reinsurance (financial guaranty reinsurance), 2006 to 2010; formerly, Director, Ocwen Financial Corporation (mortgage servicing), 2005 to 2010; formerly, Director, Claire’s Stores, Inc. (retailer), 2005 to 2007; formerly, Director,
Parsons Brinckerhoff Inc. (engineering consulting firm), 2007 to 2010; formerly, Director, Bank Leumi (commercial bank), 2005 to 2007; formerly, Advisory Board Member, Attensity (software developer), 2005 to 2007.
|
Michael M. Knetter (1960)
|
Trustee since 2007
|
President and Chief Executive Officer, University of Wisconsin Foundation, since 2010; formerly, Dean, School of Business, University of Wisconsin - Madison; formerly, Professor of International Economics and Associate Dean, Amos
Tuck School of Business - Dartmouth College, 1998 to 2002.
|
51
|
Director, 1 William Street Credit Income Fund, since 2018; Board Member, American Family Insurance (a mutual company, not publicly traded), since March 2009; formerly, Trustee, Northwestern Mutual Series Fund, Inc., 2007 to 2011;
formerly, Director, Wausau Paper, 2005 to 2011; formerly, Director, Great Wolf Resorts, 2004 to 2009.
|
Name,
(Year of Birth), and Address (1) |
Position(s)
and Length of Time Served (2) |
Principal Occupation(s) (3) |
Number
of Funds in Fund Complex Overseen by Fund Trustee |
Other Directorships Held Outside Fund
Complex by Fund Trustee (3) |
Deborah C. McLean (1954)
|
Trustee since 2015
|
Member, Circle Financial Group (private wealth management membership practice), since 2011; Managing Director, Golden Seeds LLC (an angel investing group), since 2009; Adjunct Professor, Columbia University School of International
and Public Affairs, since 2008; formerly, Visiting Assistant Professor, Fairfield University, Dolan School of Business, Fall 2007; formerly, Adjunct Associate Professor of Finance, Richmond, The American International University in
London, 1999 to 2007.
|
51
|
Board member, Norwalk Community College Foundation, since 2014; Dean’s Advisory Council, Radcliffe Institute for Advanced Study, since 2014; formerly, Director and Treasurer, At Home in Darien (not-for-profit), 2012 to 2014;
formerly, Director, National Executive Service Corps (not-for-profit), 2012 to 2013; formerly, Trustee, Richmond, The American International University in London, 1999 to 2013.
|
George W. Morriss (1947)
|
Trustee since 2007
|
Adjunct Professor, Columbia University School of International and Public Affairs, since 2012; formerly, Executive Vice President and Chief Financial Officer, People’s United Bank, Connecticut (a financial services company), 1991 to
2001.
|
51
|
Director, 1 William Street Credit Income Fund, since 2018; Director and Chair, Thrivent Church Loan and Income Fund, since 2018; formerly, Trustee, Steben Alternative Investment Funds, Steben Select Multi-Strategy Fund, and Steben
Select Multi-Strategy Master Fund, 2013 to 2017; formerly, Treasurer, National Association of Corporate Directors, Connecticut Chapter, 2011 to 2015; formerly, Manager, Larch Lane Multi-Strategy Fund complex (which consisted of three
funds), 2006 to 2011; formerly, Member, NASDAQ Issuers’ Affairs Committee, 1995 to 2003.
|
Tom D. Seip (1950)
|
Trustee since inception; Chairman of the Board since 2008; formerly Lead Independent Trustee from 2006 to 2008
|
Formerly, Managing Member, Ridgefield Farm LLC (a private investment vehicle), 2004 to 2016; formerly, President and CEO, Westaff, Inc. (temporary staffing), May 2001 to January 2002; formerly, Senior Executive, The Charles Schwab
Corporation, 1983 to 1998, including Chief Executive Officer, Charles Schwab Investment Management, Inc.; Trustee, Schwab Family of Funds and Schwab Investments, 1997 to 1998; and Executive Vice President-Retail Brokerage, Charles
Schwab & Co., Inc., 1994 to 1997.
|
51
|
Formerly, Director, H&R Block, Inc. (tax services company), 2001 to 2018; formerly, Director, Talbot Hospice Inc., 2013 to 2016; formerly, Chairman, Governance and Nominating Committee, H&R Block, Inc., 2011 to 2015;
formerly, Chairman, Compensation Committee, H&R Block, Inc., 2006 to 2010; formerly, Director, Forward Management, Inc. (asset management company), 1999 to 2006.
|
Name,
(Year of Birth), and Address (1) |
Position(s)
and Length of Time Served (2) |
Principal Occupation(s) (3) |
Number
of Funds in Fund Complex Overseen by Fund Trustee |
Other Directorships Held Outside Fund
Complex by Fund Trustee (3) |
James G. Stavridis (1955)
|
Trustee since 2015
|
Operating Executive, The Carlyle Group, since 2018; Commentator, NBC News, since 2015; formerly, Dean, Fletcher School of Law and Diplomacy, Tufts University, 2013 to 2018; formerly, Admiral, United States Navy, 1976 to 2013,
including Supreme Allied Commander, NATO and Commander, European Command, 2009 to 2013, and Commander, United States Southern Command, 2006 to 2009.
|
51
|
Director, American Water (water utility), since 2018; Director, NFP Corp. (insurance broker and consultant), since 2017; Director, U.S. Naval Institute, since 2014; Director, Onassis Foundation, since 2014; Director, BMC Software
Federal, LLC, since 2014; Director, Vertical Knowledge, LLC, since 2013; formerly, Director, Navy Federal Credit Union, 2000-2002.
|
Candace L. Straight (1947)
|
Trustee since inception
|
Private investor and consultant specializing in the insurance industry; formerly, Advisory Director, Securitas Capital LLC (a global private equity investment firm dedicated to making investments in the insurance sector), 1998 to
2003.
|
51
|
Director, ERA Coalition (not-for-profit), since January 2019; Director, Re belle Media (a privately held TV and film production company), since 2018; formerly, Public Member, Board of Governors and Board of Trustees, Rutgers
University, 2011 to 2016; formerly, Director, Montpelier Re Holdings Ltd. (reinsurance company), 2006 to 2015; formerly, Director, National Atlantic Holdings Corporation (property and casualty insurance company), 2004 to 2008; formerly,
Director, The Proformance Insurance Company (property and casualty insurance company), 2004 to 2008; formerly, Director, Providence Washington Insurance Company (property and casualty insurance company), 1998 to 2006; formerly,
Director, Summit Global Partners (insurance brokerage firm), 2000 to 2005.
|
Peter P. Trapp (1944)
|
Trustee since inception
|
Retired; formerly, Regional Manager for Mid-Southern Region, Ford Motor Credit Company, September 1997 to 2007; formerly, President, Ford Life Insurance Company, April 1995 to August 1997.
|
51
|
None.
|
Name,
(Year of Birth), and Address (1) |
Position(s)
and Length of Time Served (2) |
Principal Occupation(s) (3) |
Number
of Funds in Fund Complex Overseen by Fund Trustee |
Other Directorships Held Outside Fund
Complex by Fund Trustee (3) |
Fund Trustees who are “Interested Persons”
|
||||
Joseph V. Amato*
(1962)
|
Chief Executive Officer and President since 2018 and Trustee since 2009
|
President and Director, Neuberger Berman Group LLC, since 2009; President and Chief Executive Officer, Neuberger Berman BD LLC (“Neuberger Berman”) and Neuberger Berman Holdings LLC (including its predecessor, Neuberger Berman
Inc.), since 2007; Chief Investment Officer (Equities) and President (Equities), NBIA (formerly, Neuberger Berman Fixed Income LLC and including predecessor entities), since 2007, and Board Member of NBIA since 2006; formerly, Global
Head of Asset Management of Lehman Brothers Holdings Inc.’s (“LBHI”) Investment Management Division, 2006 to 2009; formerly, member of LBHI’s Investment Management Division’s Executive Management Committee, 2006 to 2009; formerly,
Managing Director, Lehman Brothers Inc. (“LBI”), 2006 to 2008; formerly, Chief Recruiting and Development Officer, LBI, 2005 to 2006; formerly, Global Head of LBI’s Equity Sales and a Member of its Equities Division Executive Committee,
2003 to 2005; President and Chief Executive Officer, ten registered investment companies for which NBIA acts as investment manager and/or administrator.
|
51
|
Member of Board of Advisors, McDonough School of Business, Georgetown University, since 2001; Member of New York City Board of Advisors, Teach for America, since 2005; Trustee, Montclair Kimberley Academy (private school), since
2007; Member of Board of Regents, Georgetown University, since 2013.
|
Robert Conti* (1956)
|
Trustee since
2008;
prior thereto,
Chief
Executive
Officer and
President from
2008 to 2018
|
Retired; formerly, Managing Director, Neuberger Berman, 2007 to 2018; formerly, President—Mutual Funds, NBIA, 2008 to 2018; formerly, Senior Vice President, Neuberger Berman, 2003 to 2006; formerly, Vice President, Neuberger Berman,
1999 to 2003.
|
51
|
Director, Staten Island Mental Health Society, since 1994; formerly, Chairman of the Board, Staten Island Mental Health Society, 2008 to 2011; formerly, Member of the Board of Governors, Investment Company Institute.
|
(1)
|
The business address of each listed person is 1290 Avenue of the Americas, New York, NY 10104.
|
(2)
|
Pursuant to the Trust’s Amended and Restated Trust Instrument (“Trust Instrument”), subject to any limitations on the term of service imposed by the By-Laws or any retirement policy adopted by the Fund
Trustees, each Fund Trustee shall hold office for life or until his or her successor is elected or the Trust terminates; except that (a) any Fund Trustee may resign by delivering a written resignation; (b) any Fund Trustee may be removed
with or without cause at any time by a written instrument signed by at least two-thirds of the other Fund Trustees; (c) any Fund Trustee who requests to be retired, or who has become unable to serve, may be retired by a written instrument
signed by a majority of the other Fund Trustees; and (d) any Fund Trustee may be removed at any shareholder meeting by a vote of at least two-thirds of the outstanding shares.
|
(3)
|
Except as otherwise indicated, each individual has held the positions shown during at least the last five years.
|
*
|
Indicates a Fund Trustee who is an “interested person” within the meaning of the 1940 Act. Mr. Amato is an interested person of the Trust by virtue of the fact that he is an officer of NBIA and/or its affiliates. Mr. Conti is an
interested person of the Trust by virtue of the fact that he was an officer of NBIA and/or its affiliates until June 2018.
|
Name, (Year of Birth), and Address (1)
|
Position(s) and Length of
Time Served (2) |
Principal Occupation(s) (3)
|
Claudia A. Brandon (1956)
|
Executive Vice President since 2008 and Secretary since inception
|
Senior Vice President, Neuberger Berman, since 2007 and Employee since 1999; Senior Vice President, NBIA, since 2008 and Assistant Secretary since 2004; formerly, Vice President, Neuberger Berman, 2002 to 2006; formerly, Vice
President – Mutual Fund Board Relations, NBIA, 2000 to 2008; formerly, Vice President, NBIA, 1986 to 1999 and Employee, 1984 to 1999; Executive Vice President and Secretary, twenty-nine registered investment companies for which NBIA
acts as investment manager and/or administrator.
|
Agnes Diaz (1971)
|
Vice President since 2013
|
Senior Vice President, Neuberger Berman, since 2012; Senior Vice President, NBIA, since 2012 and Employee since 1996; formerly, Vice President, Neuberger Berman, 2007 to 2012; Vice President, ten registered investment companies for
which NBIA acts as investment manager and/or administrator.
|
Name, (Year of Birth), and Address (1)
|
Position(s) and Length of
Time Served (2) |
Principal Occupation(s) (3)
|
Anthony DiBernardo (1979)
|
Assistant Treasurer since 2011
|
Senior Vice President, Neuberger Berman, since 2014; Senior Vice President, NBIA, since 2014, and Employee since 2003; formerly, Vice President, Neuberger Berman, 2009 to 2014; Assistant Treasurer, ten registered investment
companies for which NBIA acts as investment manager and/or administrator.
|
Savonne L. Ferguson (1973)
|
Chief Compliance Officer since 2018
|
Senior Vice President, Chief Compliance Officer (Mutual Funds) and Associate General Counsel, NBIA, since November 2018; formerly, Vice President T. Rowe Price Group, Inc. (2018), Vice President and Senior Legal Counsel, T. Rowe
Price Associates, Inc. (2014-2018), Vice President and Director of Regulatory Fund Administration, PNC Capital Advisors, LLC (2009-2014), Secretary, PNC Funds and PNC Advantage Funds (2010-2014); Chief Compliance Officer, twenty-nine
registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Corey A. Issing
(1978)
|
Chief Legal Officer since 2016 (only for purposes of sections 307 and 406 of the Sarbanes-Oxley Act of 2002)
|
General Counsel and Head of Compliance – Mutual Funds since 2016 and Managing Director, NBIA, since 2017; formerly, Associate General Counsel (2015 to 2016), Counsel (2007 to 2015), Senior Vice President (2013-2016), Vice President
(2009 – 2013); Chief Legal Officer (only for purposes of sections 307 and 406 of the Sarbanes-Oxley Act of 2002), twenty-nine registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Name, (Year of Birth), and Address (1)
|
Position(s) and Length of
Time Served (2) |
Principal Occupation(s) (3)
|
Sheila R. James (1965)
|
Assistant Secretary since inception
|
Vice President, Neuberger Berman, since 2008 and Employee since 1999; Vice President, NBIA, since 2008; formerly, Assistant Vice President, Neuberger Berman, 2007; Employee, NBIA, 1991 to 1999; Assistant Secretary, twenty-nine
registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Brian Kerrane (1969)
|
Chief Operating Officer since 2015 and Vice President since 2008
|
Managing Director, Neuberger Berman, since 2013; Chief Operating Officer – Mutual Funds and Managing Director, NBIA, since 2015; formerly, Senior Vice President, Neuberger Berman, 2006 to 2014; Vice President, NBIA, 2008 to 2015 and
Employee since 1991; Chief Operating Officer, ten registered investment companies for which NBIA acts as investment manager and/or administrator; Vice President, twenty-nine registered investment companies for which NBIA acts as
investment manager and/or administrator.
|
Anthony Maltese (1959)
|
Vice President since 2015
|
Senior Vice President, Neuberger Berman, since 2014 and Employee since 2000; Senior Vice President, NBIA, since 2014; Vice President, ten registered investment companies for which NBIA acts as investment manager and/or
administrator.
|
Josephine Marone (1963)
|
Assistant Secretary since 2017
|
Senior Paralegal, Neuberger Berman, since 2007 and Employee since 2007; Assistant Secretary, twenty-nine registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Owen F. McEntee, Jr. (1961)
|
Vice President since 2008
|
Vice President, Neuberger Berman, since 2006; Vice President, NBIA, since 2006 and Employee since 1992; Vice President, ten registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Name, (Year of Birth), and Address (1)
|
Position(s) and Length of
Time Served (2) |
Principal Occupation(s) (3)
|
John M. McGovern (1970)
|
Treasurer and Principal Financial and Accounting Officer since inception
|
Senior Vice President, Neuberger Berman, since 2007; Senior Vice President, NBIA, since 2007 and Employee since 1993; formerly, Vice President, Neuberger Berman, 2004 to 2006; formerly, Assistant Treasurer, 2002 to 2005; Treasurer
and Principal Financial and Accounting Officer, twenty-nine registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Frank Rosato (1971)
|
Assistant Treasurer since inception
|
Vice President, Neuberger Berman, since 2006; Vice President, NBIA, since 2006 and Employee since 1995; Assistant Treasurer, ten registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Niketh Velamoor (1979)
|
Anti-Money Laundering Compliance Officer since 2018
|
Senior Vice President and Associate General Counsel, Neuberger Berman, since July 2018; Assistant United States Attorney, Southern District of New York, 2009 to 2018; Anti-Money Laundering Compliance Officer, four registered
investment companies for which NBIA acts as investment manager and/or administrator.
|
(1)
|
The business address of each listed person is 1290 Avenue of the Americas, New York, NY 10104.
|
(2)
|
Pursuant to the By‑Laws of the Trust, each officer elected by the Fund Trustees shall hold office until his or her successor shall have been elected and qualified or until his or her earlier death, inability to serve, or resignation.
Officers serve at the pleasure of the Fund Trustees and may be removed at any time with or without cause.
|
(3)
|
Except as otherwise indicated, each individual has held the positions shown during at least the last five years.
|
Name and Position with the Trust
|
Aggregate
Compensation
from the Trust |
Total Compensation from Investment
Companies in the Neuberger Berman
Fund Complex Paid to Fund Trustees
|
Independent Fund Trustees
|
||
Michael J. Cosgrove
Trustee
|
$35,625
|
$230,000
|
Marc Gary
Trustee
|
$34,851
|
$225,000
|
Martha C. Goss
Trustee
|
$34,851
|
$225,000
|
Name and Position with the Trust
|
Aggregate
Compensation
from the Trust |
Total Compensation from Investment
Companies in the Neuberger Berman
Fund Complex Paid to Fund Trustees
|
Michael M. Knetter
Trustee
|
$34,851
|
$225,000
|
Deborah C. McLean
Trustee
|
$35,625
|
$230,000
|
George W. Morriss
Trustee
|
$34,851
|
$225,000
|
Tom D. Seip
Chairman of the Board and Trustee |
$40,272
|
$260,000
|
James G. Stavridis
Trustee
|
$32,527
|
$210,000
|
Candace L. Straight
Trustee |
$32,527
|
$210,000
|
Peter P. Trapp
Trustee |
$32,527
|
$210,000
|
Fund Trustees who are “Interested Persons”
|
||
Joseph V. Amato
President, Chief Executive Officer and Trustee
|
$0
|
$0
|
Robert Conti
Trustee |
$32,527
|
$210,000
|
Name of Fund Trustee
|
Aggregate Dollar Range of Equity Securities Held in all
Registered Investment Companies Overseen by Fund
Trustee in Family of Investment Companies
|
Independent Fund Trustees
|
|
Michael J. Cosgrove
|
E
|
Marc Gary
|
E
|
Martha C. Goss
|
E
|
Michael M. Knetter
|
E
|
Deborah C. McLean
|
E
|
George W. Morriss
|
E
|
Tom D. Seip
|
E
|
James G. Stavridis
|
E
|
Candace L. Straight
|
E
|
Peter P. Trapp
|
E
|
Fund Trustees who are “Interested Persons”
|
|
Joseph V. Amato
|
E
|
Robert Conti
|
E
|
Management and Administration Fees
Accrued for Fiscal Years Ended October 31, |
||||
Fund
|
Class
|
2019
|
2018
|
2017
|
Commodity Strategy Fund
|
Class A
|
$248,555
|
$363,404
|
$312,578
|
Class C
|
$189
|
$248
|
$400
|
|
Institutional
|
$760,916
|
$620,748
|
$454,836
|
|
Global Allocation Fund
|
Class A
|
$19,637
|
$27,817
|
$38,857
|
Class C
|
$16,610
|
$22,395
|
$32,648
|
|
Institutional
|
$84,806
|
$101,275
|
$91,100
|
|
Class R6
|
$126
|
$N/A^
|
$ N/A^
|
|
Long Short Fund
|
Class A
|
$939,267
|
$1,719,637
|
$2,205,028
|
Class C
|
$934,503
|
$1,196,173
|
$1,414,510
|
|
Institutional
|
$30,405,863
|
$39,357,289
|
$29,201,308
|
|
Multi-Asset Income Fund
|
Class A
|
$4,582
|
$5,347
|
$4,208
|
Class C
|
$5,173
|
$5,161
|
$4,929
|
|
Institutional
|
$100,105
|
$108,880
|
$94,166
|
|
R6
|
$19,737
|
$21,452
|
$20,984
|
Management and Administration Fees
Accrued for Fiscal Years Ended October 31, |
||||
Fund
|
Class
|
2019
|
2018
|
2017
|
Multi-Style Premia Fund
|
Class A
|
$516
|
$104
|
N/A^
|
Class C
|
$214
|
$104
|
N/A^
|
|
Institutional
|
$119,307
|
$55,422
|
N/A^
|
|
Class R6
|
$166
|
$83
|
N/A^
|
|
U.S. Equity Index PutWrite Strategy Fund
|
Class A
|
$173,640
|
$63,897
|
$14,623
|
Class C
|
$7,462
|
$6,841
|
$1,256
|
|
Institutional
|
$1,361,741
|
$1,654,905
|
$539,522
|
|
R6
|
$100,619
|
$91,253
|
$48,321
|
Fund
|
Class
|
Limitation Period
|
Expense
Limitation
|
|
Commodity Strategy
|
Institutional
|
10/31/2023
|
0.73%
|
|
A
|
10/31/2023
|
1.09%
|
||
C
|
10/31/2023
|
1.84%
|
||
Global Allocation
|
Institutional
|
10/31/2023
|
0.75%
|
|
A
|
10/31/2023
|
1.11%
|
||
C
|
10/31/2023
|
1.86%
|
||
R6
|
10/31/2023
|
0.65%*
|
||
Long Short
|
Institutional
|
10/31/2023
|
1.70%
|
|
A
|
10/31/2023
|
2.06%
|
||
C
|
10/31/2023
|
2.81%
|
||
Multi-Asset Income
|
Institutional
|
10/31/2023
|
0.65%
|
|
A
|
10/31/2023
|
1.02%
|
||
C
|
10/31/2023
|
1.77%
|
||
R6
|
10/31/2023
|
0.55%*
|
||
Multi-Style Premia
|
Institutional
|
10/31/2023
|
0.95%
|
|
A
|
10/31/2023
|
1.31%
|
||
C
|
10/31/2023
|
2.06%
|
||
R6
|
10/31/2023
|
0.85%*
|
||
U.S. Equity Index PutWrite Strategy
|
Institutional
|
10/31/2023
|
0.65%
|
|
A
|
10/31/2023
|
1.01%
|
||
C
|
10/31/2023
|
1.76%
|
||
R6
|
10/31/2023
|
0.55%*
|
Expenses Reimbursed for Fiscal Years
Ended October 31, |
||||
Fund
|
Class
|
2019
|
2018
|
2017
|
Commodity Strategy Fund
|
Class A
|
$88,930
|
$118,368
|
$131,093
|
Class C
|
$118
|
$159
|
$545
|
Expenses Reimbursed for Fiscal Years
Ended October 31, |
||||
Fund
|
Class
|
2019
|
2018
|
2017
|
Institutional
|
$267,105
|
$227,405
|
$211,468
|
|
Global Allocation Fund
|
Class A
|
$63,743
|
$79,935
|
$131,054
|
Class C
|
$53,469
|
$63,702
|
$110,994
|
|
Institutional
|
$314,674
|
$329,169
|
$346,296
|
|
Class R6
|
$604
|
N/A^
|
N/A^
|
|
Long Short Fund
|
Class A
|
$0
|
$0
|
$0
|
Class C
|
$0
|
$0
|
$0
|
|
Institutional
|
$0
|
$0
|
$0
|
|
Multi-Asset Income Fund
|
Class A
|
$12,485
|
$14,442
|
$14,267
|
Class C
|
$13,719
|
$13,693
|
$16,358
|
|
Institutional
|
$317,506
|
$345,192
|
$372,208
|
|
Class R6
|
$74,701
|
$77,052
|
$94,517
|
|
Multi-Style Premia Fund
|
Class A
|
$2,208
|
$667
|
N/A^
|
Class C
|
$810
|
$666
|
N/A^
|
|
Institutional
|
$521,081
|
$372,173
|
N/A^
|
|
Class R6
|
$3,935
|
$667
|
N/A^
|
|
U.S. Equity Index PutWrite Strategy Fund
|
Class A
|
$27,065
|
$8,937
|
$6,844
|
Class C
|
$1,602
|
$1,190
|
$628
|
|
Institutional
|
$245,105
|
$238,341
|
$290,602
|
|
Class R6
|
$21,621
|
$16,306
|
$31,856
|
Expenses Reimbursed for Fiscal Years Ended October 31,
|
||||
Fund
|
2019
|
2018
|
2017
|
|
Commodity Strategy
|
$96,122
|
$80,525
|
$60,839
|
|
Portfolio Manager
|
Fund(s) Managed
|
Ray Carroll
|
Neuberger Berman Multi-Style Premia Fund
|
Derek Devens
|
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund
|
Ajay Jain
|
Neuberger Berman Global Allocation Fund
Neuberger Berman Multi-Asset Income Fund
|
Charles Kantor
|
Neuberger Berman Long Short Fund
|
Hakan Kaya
|
Neuberger Berman Commodity Strategy Fund
|
Erik Knutzen
|
Neuberger Berman Global Allocation Fund
Neuberger Berman Multi-Asset Income Fund
|
Frank Maeba
|
Neuberger Berman Multi-Style Premia Fund
|
Marc Regenbaum
|
Neuberger Berman Long Short Fund
|
Gideon Schapiro
|
Neuberger Berman Multi-Style Premia Fund
|
Thomas Sontag
|
Neuberger Berman Commodity Strategy Fund
|
Bradley Tank
|
Neuberger Berman Global Allocation Fund
Neuberger Berman Multi-Asset Income Fund
|
David Wan
|
Neuberger Berman Commodity Strategy Fund
|
Type of Account
|
Number
of Accounts Managed |
Total Assets
Managed ($ millions) |
Number of
Accounts Managed for which Advisory Fee is Performance- Based |
Assets Managed for which
Advisory Fee is Performance-Based ($ millions) |
Ray Carroll
|
||||
Registered Investment Companies*
|
5
|
56
|
-
|
-
|
Other Pooled Investment Vehicles
|
28
|
3,643
|
1
|
395
|
Other Accounts**
|
19
|
864
|
8
|
542
|
Derek Devens***
|
||||
Registered Investment Companies*
|
3
|
338
|
-
|
-
|
Other Pooled Investment Vehicles
|
5
|
2,084
|
-
|
-
|
Other Accounts**
|
61
|
1,562
|
1
|
0
|
Type of Account
|
Number
of Accounts Managed |
Total Assets
Managed ($ millions) |
Number of
Accounts Managed for which Advisory Fee is Performance- Based |
Assets Managed for which
Advisory Fee is Performance-Based ($ millions) |
Simon Griffiths
|
||||
Registered Investment Companies*
|
5
|
56
|
-
|
-
|
Other Pooled Investment Vehicles
|
28
|
3,643
|
1
|
395
|
Other Accounts**
|
19
|
864
|
8
|
542
|
Ajay Jain***
|
||||
Registered Investment Companies*
|
2
|
39
|
-
|
-
|
Other Pooled Investment Vehicles
|
8
|
1,638
|
-
|
-
|
Other Accounts**
|
10
|
4,841
|
3
|
2,899
|
Charles Kantor***
|
||||
Registered Investment Companies*
|
3
|
3,562
|
-
|
-
|
Other Pooled Investment Vehicles
|
4
|
365
|
-
|
-
|
Other Accounts**
|
2,031
|
2,721
|
-
|
-
|
Hakan Kaya***
|
||||
Registered Investment Companies*
|
1
|
168
|
-
|
-
|
Other Pooled Investment Vehicles
|
3
|
1,103
|
-
|
-
|
Other Accounts**
|
-
|
-
|
-
|
-
|
Erik Knutzen ***
|
||||
Registered Investment Companies*
|
2
|
39
|
-
|
-
|
Other Pooled Investment Vehicles
|
8
|
1,638
|
-
|
-
|
Other Accounts**
|
10
|
4,841
|
3
|
2,899
|
Frank Maeba
|
||||
Registered Investment Companies*
|
5
|
56
|
-
|
-
|
Other Pooled Investment Vehicles
|
28
|
3,643
|
1
|
395
|
Other Accounts**
|
19
|
864
|
8
|
542
|
Type of Account
|
Number
of Accounts Managed |
Total Assets
Managed ($ millions) |
Number of
Accounts Managed for which Advisory Fee is Performance- Based |
Assets Managed for which
Advisory Fee is Performance-Based ($ millions) |
Marc Regenbaum***
|
||||
Registered Investment Companies*
|
3
|
3,562
|
-
|
-
|
Other Pooled Investment Vehicles
|
4
|
365
|
-
|
-
|
Other Accounts**
|
2,031
|
2,721
|
-
|
-
|
Gideon Schapiro
|
||||
Registered Investment Companies*
|
5
|
56
|
-
|
-
|
Other Pooled Investment Vehicles
|
28
|
3,643
|
1
|
395
|
Other Accounts**
|
19
|
864
|
8
|
542
|
Thomas Sontag***
|
||||
Registered Investment Companies*
|
7
|
2,284
|
-
|
-
|
Other Pooled Investment Vehicles
|
11
|
649
|
-
|
-
|
Other Accounts**
|
114
|
6,014
|
-
|
-
|
Brad Tank***
|
||||
Registered Investment Companies*
|
11
|
5,532
|
-
|
-
|
Other Pooled Investment Vehicles
|
25
|
4,666
|
1
|
1,846
|
Other Accounts**
|
41
|
4,465
|
14
|
534
|
David Wan***
|
||||
Registered Investment Companies*
|
1
|
168
|
-
|
-
|
Other Pooled Investment Vehicles
|
3
|
1,103
|
-
|
-
|
Other Accounts**
|
-
|
-
|
-
|
-
|
Portfolio Manager
|
Fund Managed
|
Dollar Range of Equity
Securities Owned in the
Fund
|
Ray Carroll
|
Neuberger Berman Multi-Style Premia Fund
|
A
|
Derek Devens
|
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund
|
E
|
Simon Griffiths
|
Neuberger Berman Multi-Style Premia Fund
|
A
|
Ajay Jain
|
Neuberger Berman Global Allocation Fund
|
E
|
Neuberger Berman Multi-Asset Income Fund
|
A
|
|
Charles Kantor
|
Neuberger Berman Long Short Fund
|
G
|
Hakan Kaya
|
Neuberger Berman Commodity Strategy Fund
|
B
|
Erik Knutzen
|
Neuberger Berman Global Allocation Fund
|
G
|
Neuberger Berman Multi-Asset Income Fund
|
G
|
Frank Maeba
|
Neuberger Berman Multi-Style Premia Fund
|
A
|
Marc Regenbaum
|
Neuberger Berman Long Short Fund
|
F
|
Gideon Schapiro
|
Neuberger Berman Multi-Style Premia Fund
|
A
|
Thomas Sontag
|
Neuberger Berman Commodity Strategy Fund
|
A
|
Bradley Tank
|
Neuberger Berman Global Allocation Fund
|
G
|
Neuberger Berman Multi-Asset Income Fund
|
A
|
|
David Wan
|
Neuberger Berman Commodity Strategy Fund
|
B
|
A = None
|
E = $100,001-$500,000
|
B = $1-$10,000
|
F = $500,001-$1,000,000
|
C = $10,001 - $50,000
|
G = Over $1,000,001
|
D =$50,001-$100,000
|
Sales Charge Revenue
|
Deferred Sales Charge
Revenue |
||||
Fund
|
Fiscal Year
Ended Oct. 31, |
Amount Paid to
Distributor |
Amount
Retained by Distributor |
Amount Paid
to Distributor |
Amount
Retained by Distributor |
Commodity Strategy Fund – Class A
|
2019
|
$4,201
|
$646
|
-
|
-
|
2018
|
$1,150
|
$150
|
-
|
-
|
|
2017
|
-
|
-
|
-
|
-
|
|
Commodity Strategy Fund – Class C
|
2019
|
-
|
-
|
-
|
-
|
2018
|
-
|
-
|
$30
|
-
|
|
2017
|
-
|
-
|
-
|
-
|
|
Global Allocation Fund – Class A
|
2019
|
$710
|
$110
|
-
|
-
|
Sales Charge Revenue
|
Deferred Sales Charge
Revenue |
||||
Fund
|
Fiscal Year
Ended Oct. 31, |
Amount Paid to
Distributor |
Amount
Retained by Distributor |
Amount Paid
to Distributor |
Amount
Retained by Distributor |
2018
|
$1,500
|
$300
|
-
|
-
|
|
2017
|
$27,304
|
$3,816
|
-
|
-
|
|
Global Allocation Fund – Class C
|
2019
|
-
|
-
|
$19
|
-
|
2018
|
-
|
-
|
$77
|
-
|
|
2017
|
-
|
-
|
$1,595
|
-
|
|
Long Short Fund – Class A
|
2019
|
$107,112
|
$14,582
|
-
|
-
|
2018
|
$156,863
|
$26,230
|
-
|
-
|
|
2017
|
$174,792
|
$23,948
|
-
|
-
|
|
Long Short Fund – Class C
|
2019
|
-
|
-
|
$5,653
|
-
|
2018
|
-
|
-
|
$2,074
|
-
|
|
2017
|
-
|
-
|
$10,222
|
-
|
|
Multi-Asset Income Fund -- Class A
|
2019
|
$357
|
$21
|
-
|
-
|
Sales Charge Revenue
|
Deferred Sales Charge
Revenue |
||||
Fund
|
Fiscal Year
Ended Oct. 31, |
Amount Paid to
Distributor |
Amount
Retained by Distributor |
Amount Paid
to Distributor |
Amount
Retained by Distributor |
2018
|
$207
|
$39
|
-
|
-
|
|
2017
|
-
|
-
|
-
|
-
|
|
Multi-Asset Income Fund -- Class C
|
2019
|
-
|
-
|
-
|
-
|
2018
|
$207
|
$39
|
-
|
-
|
|
2017
|
-
|
-
|
-
|
-
|
|
Multi-Style Premia Fund – Class A
|
2019
|
-
|
-
|
-
|
-
|
2018
|
-
|
-
|
-
|
-
|
|
2017
|
-
|
-
|
-
|
-
|
|
Multi-Style Premia Fund – Class C
|
2019
|
-
|
-
|
-
|
-
|
2018
|
-
|
-
|
-
|
-
|
|
2017
|
-
|
-
|
-
|
-
|
|
U.S. Equity Index PutWrite Strategy Fund -- Class A
|
2019
|
$12,729
|
$2,962
|
-
|
-
|
2018
|
$60,135
|
$7,957
|
-
|
-
|
|
2017
|
$27,662
|
$3,412
|
-
|
-
|
|
U.S. Equity Index PutWrite Strategy Fund -- Class C
|
2019
|
-
|
-
|
$1,740
|
-
|
2018
|
-
|
-
|
-
|
-
|
Sales Charge Revenue
|
|||||
Fund
|
Fiscal Year
Ended Oct. 31, |
Amount Paid to
Distributor |
Amount
Retained by Distributor |
Amount Paid
to Distributor |
Amount
Retained by Distributor |
2017
|
-
|
-
|
$25
|
-
|
Class A
|
Fiscal Year Ended October 31,
|
||
2019
|
2018
|
2017
|
|
Commodity Strategy Fund
|
$81,888
|
$119,547
|
$95,349
|
Global Allocation Fund
|
$6,063
|
$8,589
|
$11,409
|
Long Short Fund
|
$171,454
|
$315,198
|
$401,927
|
Multi-Asset Income Fund
|
$1,591
|
$1,857
|
$1,462
|
Multi-Style Premia Fund
|
$140
|
$28
|
N/A^
|
U.S. Equity Index PutWrite Strategy Fund
|
$61,097
|
$22,413
|
$5,152
|
Class C
|
Fiscal Year Ended October 31,
|
||
2019
|
2018
|
2017
|
|
Commodity Strategy Fund
|
$250
|
$327
|
$466
|
Global Allocation Fund
|
$20,507
|
$27,669
|
$38636
|
Long Short Fund
|
$679,758
|
$876,909
|
$1,030,536
|
Multi-Asset Income Fund
|
$7,184
|
$7,169
|
$6,850
|
Multi-Style Premia Fund
|
$235
|
$114
|
N/A^
|
U.S. Equity Index PutWrite Strategy Fund
|
$10,515
|
$9,623
|
$1,766
|
Fund and Class
|
Name and Address
|
Percentage of
Shares Held |
PFIZER INC & NORTHERN TRUST CO
MASTER TRUST AGREEMENT BETWEEN
C/O PFIZER INC
235 E 42ND ST 28TH FLOOR
NEW YORK NY 10017-5703
|
6.32%
|
|
Neuberger Berman Global
Allocation Fund – Class A
|
UMB BANK NA
CUST IRA FBO
DAVID H LACOOK
HOUSTON TX 77092-8425
|
32.11%
|
RAYMOND JAMES OMNIBUS FOR
MUTUAL FUNDS HOUSE ACCOUNT
FIRM 92500015
ATTN COURTNEY WALLER
880 CARILLON PKWY
ST PETERSBURG FL 33716-1100
|
20.97%
|
|
AMERICAN ENTERPRISE INVESTMENT SVC
FBO # 41999970
707 2ND AVE S
MINNEAPOLIS MN 55402-2405
|
9.16%
|
|
PERSHING LLC
1 PERSHING PLZ
JERSEY CITY NJ 07399-0002
|
6.58%
|
|
UBS WM USA
0O0 11011 6100
OMNI ACCOUNT M/F
SPEC CDY A/C EBOC UBSFSI
1000 HARBOR BLVD
WEEHAWKEN NJ 07086-6761
|
5.80%
|
|
Neuberger Berman Global
Allocation Fund – Class C
|
PERSHING LLC
1 PERSHING PLZ
JERSEY CITY NJ 07399-0002
|
34.17%
|
RAYMOND JAMES OMNIBUS FOR
MUTUAL FUNDS HOUSE ACCOUNT
FIRM 92500015
ATTN COURTNEY WALLER
880 CARILLON PKWY
ST PETERSBURG FL 33716-1100
|
24.27%
|
Fund and Class
|
Name and Address
|
Percentage of
Shares Held |
MORGAN STANLEY SMITH BARNEY LLC
FOR THE EXCLUSIVE BENE OF ITS CUST
1 NEW YORK PLZ FL 12
NEW YORK NY 10004-1901
|
10.88%
|
|
UBS WM USA
0O0 11011 6100
OMNI ACCOUNT M/F
SPEC CDY A/C EBOC UBSFSI
1000 HARBOR BLVD
WEEHAWKEN NJ 07086-6761
|
10.05%
|
|
CHARLES SCHWAB & CO INC
ATTN MUTUAL FUNDS
211 MAIN ST
SAN FRANCISCO CA 94105-1905
|
9.84%
|
|
PERSHING LLC
1 PERSHING PLZ
JERSEY CITY NJ 07399-0002
|
5.29%
|
|
RAYMOND JAMES OMNIBUS FOR
MUTUAL FUNDS HOUSE ACCOUNT
FIRM 92500015
ATTN COURTNEY WALLER
880 CARILLON PKWY
ST PETERSBURG FL 33716-1100
|
5.08%
|
|
Neuberger Berman Long
Short Fund – Class C
|
MERRILL LYNCH PIERCE FENNER &
SMITH INC FUND ADMINISTRATION
ATTN SERVICE TEAM
4800 DEER LAKE DR E FL 2
JACKSONVILLE FL 32246-6484
|
23.94%
|
WELLS FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE
EXCLUSIVE BENEFIT OF CUSTOMER
2801 MARKET ST
SAINT LOUIS MO 63103-2523
|
15.25%
|
Fund and Class
|
Name and Address
|
Percentage of
Shares Held |
Neuberger Berman U.S.
Equity Index PutWrite
Strategy Fund – Class C
|
AMERICAN ENTERPRISE INVESTMENT SVC
FBO # 41999970
707 2ND AVE S
MINNEAPOLIS MN 55402-2405
|
32.81%
|
PERSHING LLC
1 PERSHING PLZ
JERSEY CITY NJ 07399-0002
|
17.41%
|
|
NATIONAL FINANCIAL SERVICES LLC
499 WASHINGTON BLVD
JERSEY CITY NJ 07310-1995
|
5.93%
|
|
UBS WM USA
0O0 11011 6100
OMNI ACCOUNT M/F
SPEC CDY A/C EBOC UBSFSI
1000 HARBOR BLVD
WEEHAWKEN NJ 07086-6761
|
5.21%
|
|
Neuberger Berman U.S.
Equity Index PutWrite
Strategy Fund – Institutional
Class
|
NATIONAL FINANCIAL SERVICES LLC
FOR THE EXCLUSIVE BENEFIT OF
OUR CUSTOMERS
ATTN MUTUAL FUNDS DEPT 4TH FL
499 WASHINGTON BLVD
JERSEY CITY NJ 07310-1995
|
59.31%
|
CHARLES SCHWAB & CO INC
ATTN MUTUAL FUNDS
211 MAIN ST
SAN FRANCISCO CA 94105-1905
|
12.89%
|
|
MAC & CO A/C 223901
ATTN: MUTUAL FUND OPERATIONS
500 GRANT STREET
ROOM 151-1010
PITTSBURGH PA 15219-2502
|
6.04%
|
|
Neuberger Berman U.S.
Equity Index PutWrite
Strategy Fund – Class R6
|
PFIZER INC & NORTHERN TRUST CO
MASTER TRUST AGREEMENT BETWEEN
C/O PFIZER INC
235 E 42ND ST 28TH FLOOR
NEW YORK NY 10017-5703
|
73.96%
|
Fund and Class
|
Name and Address
|
Percentage of
Shares Held |
JP MORGAN SECURITIES LLC
FOR THE EXCLUSIVE BENEFIT
OF OUR CUSTOMERS
4 CHASE METROTECH CTR
BROOKLYN NY 11245-0001
|
19.62%
|
Fund
|
Name and Address
|
Percentage of
Shares Held |
Neuberger Berman Commodity Strategy Fund
|
CHARLES SCHWAB & CO INC
ATTN MUTUAL FUNDS
211 MAIN ST
SAN FRANCISCO CA 94105-1905
|
43.29%
|
NATIONAL FINANCIAL SERVICES LLC
FOR THE EXCLUSIVE BENEFIT OF
OUR CUSTOMERS
ATTN MUTUAL FUNDS DEPT
499 WASHINGTON BLVD FL 4
JERSEY CITY NJ 07310-1995
|
31.81%
|
|
Neuberger Berman Global Allocation Fund
|
NATIONAL FINANCIAL SERVICES LLC
FOR THE EXCLUSIVE BENEFIT OF
OUR CUSTOMERS
ATTN MUTUAL FUNDS DEPT
499 WASHINGTON BLVD FL 4
JERSEY CITY NJ 07310-1995
|
64.60%
|
Neuberger Berman Multi-Asset Income Fund
|
NATIONAL FINANCIAL SERVICES LLC
FOR THE EXCLUSIVE BENEFIT OF
OUR CUSTOMERS
ATTN MUTUAL FUNDS DEPT
499 WASHINGTON BLVD FL 4
JERSEY CITY NJ 07310-1995
|
98.29%
|
Fund
|
Name and Address
|
Percentage of
Shares Held |
Neuberger Berman Multi-Style Premia Fund
|
NATIONAL FINANCIAL SERVICES LLC
FOR THE EXCLUSIVE BENEFIT OF
OUR CUSTOMERS
ATTN MUTUAL FUNDS DEPT
499 WASHINGTON BLVD FL 4
JERSEY CITY NJ 07310-1995
|
96.67%
|
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund
|
NATIONAL FINANCIAL SERVICES LLC
FOR THE EXCLUSIVE BENEFIT OF
OUR CUSTOMERS
ATTN MUTUAL FUNDS DEPT
499 WASHINGTON BLVD FL 4
JERSEY CITY NJ 07310-1995
|
49.38%
|
APRIL 2019 |
|
PROXY VOTING POLICIES AND PROCEDURES
|
|
I. |
INTRODUCTION AND GENERAL PRINCIPLES
|
|
A. |
Certain subsidiaries of Neuberger Berman Group LLC (“NB”) have been delegated the authority and responsibility to vote the proxies of their respective investment advisory clients.
|
|
B. |
NB understands that proxy voting is an integral aspect of investment management. Accordingly, proxy voting must be conducted with the same degree of prudence and loyalty accorded any fiduciary or other
obligation of an investment manager.
|
|
C. |
NB believes that the following policies and procedures are reasonably expected to ensure that proxy matters are conducted in the best interest of clients, in accordance with NB’s fiduciary duties,
applicable rules under the Investment Advisers Act of 1940, fiduciary standards and responsibilities for ERISA clients set out in Department of Labor interpretations, the UK Stewardship Code, the Japan Stewardship Code and other
applicable laws and regulations.
|
|
D. |
In instances where NB does not have authority to vote client proxies, it is the responsibility of the client to instruct the relevant custody bank or banks to mail proxy material directly to such client.
|
|
E. |
In all circumstances, NB will comply with specific client directions to vote proxies, whether or not such client directions specify voting proxies in a manner that is different from NB’s policies and
procedures.
|
|
F. |
NB will seek to vote all shares under its authority so long as that action is not in conflict with client instructions.
There may be circumstances under which NB may abstain from voting a client proxy, such as when NB believes voting would not be in clients’ best interests
(e.g., not voting in countries with share blocking or meetings in which voting would entail additional costs). NB understands that it must weigh the costs and benefits of voting proxy
proposals relating to foreign securities and make an informed decision with respect to whether voting a given proxy proposal is prudent and solely in the interests of the clients and, in the case of an ERISA client and other
accounts and clients subject to similar local laws, a plan’s participants and beneficiaries. NB’s decision in such circumstances will take into account
the effect that the proxy vote, either by itself or together with other votes,
is expected to have on the value of the client’s investment and whether this expected effect would outweigh the cost of voting.
|
|
A. |
NB has designated a Governance & Proxy Committee (“Proxy Committee”) with the responsibility for: (1) developing, authorizing, implementing and updating NB’s policies and procedures; (2)
administering and overseeing the governance and proxy voting processes; and (3) engaging and overseeing any third-party vendors as voting delegates to review, monitor and/or vote proxies. NB, at the recommendation of the Proxy
Committee, has retained Glass, Lewis & Co., LLC (“Glass Lewis”) as its voting delegate.
|
|
B. |
The Proxy Committee will meet as frequently and in such manner as necessary or appropriate to fulfill its responsibilities.
|
|
C. |
The members of the Proxy Committee will be appointed from time to time and will include the Chief Investment Officer (Equities), the Head of Global Equity Research, the Head of ESG Investing, and senior
portfolio managers. A senior member of the Legal and Compliance Department will advise the Proxy Committee and may be included for purposes of ensuring a quorum.
|
|
D. |
In the event that one or more members of the Proxy Committee are not independent with respect to a particular matter, the remaining members of the Proxy Committee shall constitute an ad hoc independent
subcommittee of the Proxy Committee, which will have full authority to act upon such matter.
|
|
III. |
PROXY VOTING GUIDELINES
|
|
A. |
The Proxy Committee developed the Governance and Proxy Voting Guidelines (“Voting Guidelines”) based on our Governance and Engagement Principles. These Guidelines are updated as appropriate and generally
on an annual basis. With input from certain of our investment professionals, the modifications are intended to reflect emerging corporate governance issues and themes. The Proxy Committee recognizes that in certain circumstances
it may be in the interests of our clients to deviate from our Voting Guidelines.
|
|
B. |
Our views regarding corporate governance and engagement, and the related stewardship actions, are led by our ESG Investing group, in consultation with professionals in the Legal & Compliance and
Global Equity Research groups, among others. These insightful, experienced and dedicated groups enable us to think strategically about engagement and stewardship priorities.
|
PROXY VOTING POLICIES AND PROCEDURES
|
|
C. |
We believe NB’s Voting Guidelines generally represent the voting positions most likely to support our clients’ best economic interests across a range of sectors and contexts. These guidelines are not
intended to constrain our consideration of the specific issues facing a particular company on a particular vote, and so there will be times when we deviate from the Voting Guidelines.
|
|
D. |
In the event that a senior investment professional at Neuberger Berman believes that it is in the best interest of a client or clients to vote proxies in a manner inconsistent with NB’s Voting
Guidelines, the investment professional will submit in writing the basis for his or her recommendation. The Proxy Committee will review this recommendation in the context of the specific
circumstances of the situation and with the intention of remaining consistent with our Engagement Principles.
|
|
IV. |
PROXY VOTING PROCEDURES
|
|
A. |
NB will vote client proxies in accordance with a client’s specific request even if it is in a manner inconsistent with NB’s policies and procedures. Such specific requests should be made in writing
by the individual client or by an authorized officer, representative or named fiduciary of a client.
|
|
B. |
NB has engaged Glass
Lewis as its advisor and voting agent to: (1) provide research on proxy matters; (2) vote proxies in accordance with NB’s Voting Guidelines or as otherwise instructed and submit such proxies in a timely manner; (3) handle
other administrative functions of proxy voting; (4) maintain records of proxy statements received in connection with proxy votes and provide copies of such proxy statements promptly upon request; and (5) maintain records of
votes cast.
|
|
C. |
Except in instances where clients have retained voting authority, NB will instruct custodians of client accounts to forward all proxy statements and materials received in respect of client accounts
to Glass Lewis.
|
|
D. |
Notwithstanding the foregoing, NB retains final authority and fiduciary responsibility for proxy voting.
|
|
V. |
CONFLICTS OF INTEREST
|
|
A. |
Glass Lewis will vote proxies in accordance with the Voting Guidelines described in Section III or, in instances where
a material conflict has been determined to exist, as Glass Lewis recommends. NB believes that this process is reasonably designed to address material
conflicts of interest that may arise in conjunction with proxy voting decisions. Potential conflicts considered by the Proxy Committee when it is determining whether to deviate from NB’s Voting Guidelines include, among others: a material client relationship with the corporate issuer being considered; personal or business relationships
between the portfolio managers and an executive officer; director, or director nominee of the issuer; joint business ventures; or a direct
transactional relationship between the issuer and senior executives of NB.
|
|
B. |
In the event that an NB Investment Professional believes that it is in the best interest of a client or clients to vote proxies in a manner inconsistent with the Voting Guidelines described in
Section III, such NB Investment Professional will contact a member of the Legal & Compliance Department advising the Proxy Committee and complete and sign a questionnaire in the form adopted from time to time. Such
questionnaires will require specific information, including the reasons the NB Investment Professional believes a proxy vote in this manner is in the best interest of a client or clients and disclosure of specific ownership,
business or personal relationship, or other matters that may raise a potential material conflict of interest with respect to the voting of the proxy. The Proxy Committee will meet with the NB Investment Professional to
review the completed questionnaire and consider such other matters as it deems appropriate to determine that there is no material conflict of interest with respect to the voting of the proxy in the requested manner. The
Proxy Committee shall document its consideration of such other matters. In the event that the Proxy Committee determines that such vote will not present a material conflict, the Proxy Committee will make a determination
whether to vote such proxy as recommended by the NB Investment Professional. In the event of a determination to vote the proxy as recommended by the NB Investment Professional, an authorized member of the Legal &
Compliance Department advising the Proxy Committee will instruct Glass Lewis to vote in such manner with respect to the client or clients. In the event that the Proxy Committee determines that the voting of a proxy as
recommended by the NB Investment Professional would not be appropriate, the Proxy Committee will:
|
|
(i) |
take no further action, in which case Glass Lewis shall vote such proxy in accordance with the Voting Guidelines;
|
|
(ii) |
disclose such conflict to the client or clients and obtain written direction from the client with respect to voting the proxy;
|
|
(iii) |
suggest that the client or clients engage another party to determine how to vote the proxy; or
|
|
(iv) |
engage another independent third party to determine how to vote the proxy. A record of the Proxy Committee’s determinations shall be prepared and maintained in accordance with applicable policies.
|
|
C. |
In the event that the Voting Guidelines described in Section III do not address how a proxy should be voted and Glass Lewis refrains from making a recommendation as to how such proxy should be voted,
the Proxy Committee will make a determination as to how the proxy should be voted. The Proxy Committee will consider such matters as it deems appropriate to determine how such proxy should be voted including whether there is a
material conflict of interest with respect to the voting of the proxy in accordance with its decision. The Proxy Committee shall document its consideration of such matters, and an authorized member of the Legal &
Compliance Department advising the Proxy Committee will instruct Glass Lewis to vote in such manner with respect to such client or clients.
|
|
D. |
Material conflicts cannot be resolved by simply abstaining from voting.
|
|
|
|
PROXY VOTING POLICIES AND PROCEDURES
|
|
VI. |
RECORDKEEPING
|
VII. |
ENGAGEMENT AND MONITORING
|
VIII. |
SECURITIES LENDING
|
IX. |
DISCLOSURE
|
|
|
Item 28.
|
Exhibits.
|
Exhibit
Number
|
Description | ||
(2)
|
(i)
|
(a) Sub-Advisory Agreement between NB Management, NBAIM and Cramer Rosenthal McGlynn LLC with respect to Neuberger Berman Absolute Return Multi-Manager Fund. Incorporated by Reference to Post-Effective Amendment No. 17 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed May 15, 2012). | |
(b) Amendment No. 1 to Sub-Advisory Agreement between NB Management, NBAIM and Cramer Rosenthal McGlynn LLC with respect to Neuberger Berman Absolute Return Multi-Manager Fund. Incorporated by Reference to Post-Effective Amendment No. 31 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed December 18, 2013). | |||
(c) Amendment No. 2 to Sub-Advisory Agreement between NB Management, NBAIM and Cramer Rosenthal McGlynn LLC with respect to Neuberger Berman Absolute Return Multi-Manager Fund. Incorporated by Reference to Post-Effective Amendment No. 31
to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed December 18, 2013).
|
|||
(d) Amendment No. 3 to Sub-Advisory Agreement between NB Management, NBAIM and Cramer Rosenthal McGlynn LLC for Neuberger Berman Absolute Return Multi-Manager Fund. Incorporated by
Reference to Post-Effective Amendment No. 72 to Neuberger Berman Advisers Management Trust’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed April 30, 2014).
|
|||
(ii)
|
(a) Sub-Advisory Agreement between NB Management, NBAIM and GAMCO Asset Management, Inc. with respect to Neuberger Berman Absolute Return Multi-Manager Fund. Incorporated by Reference to Post-Effective Amendment No. 17 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed May 15, 2012). | ||
(b) Amendment No. 1 to Sub-Advisory Agreement between NB Management, NBAIM and GAMCO Asset Management, Inc. for Neuberger Berman Absolute Return Multi-Manager Fund and Absolute Return Multi-Manager Portfolio. Incorporated by Reference to Post-Effective Amendment No. 72 to Neuberger Berman Advisers Management Trust’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed April 30, 2014). | |||
(iii) Sub-Advisory Agreement between NB Management, NBAIM and Good Hill Partners LP with respect to Neuberger Berman Absolute Return Multi-Manager Fund. Incorporated by Reference to Post-Effective Amendment No. 31 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed December 18, 2013). | |||
(iv) Sub-Advisory Agreement between NB Management, NBAIM and Portland Hill Capital LLP. with respect to Neuberger Berman Absolute Return Multi-Manager Fund. Incorporated by
Reference to Post-Effective Amendment No. 50 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed February 26, 2016).
|
|||
(a) Novation of Sub-Advisory Agreement entered into as of December 30, 2016, by and among NBIA and Portland Hill Capital LLP. Incorporated by Reference to Post-Effective Amendment No. 56 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed February 24, 2017). | |||
(v) Form of Novation of Sub-Advisory Agreement entered into as of January 1, 2016, by and among NB Management, NBAIM, NBIA and, respectively, Cramer Rosenthal McGlynn LLC, GAMCO Asset Management, Inc., Good Hill Partners LP, and Portland Hill Capital LLP with respect to Neuberger Berman Absolute Return Multi-Manager Fund. Incorporated by Reference to Post-Effective Amendment No. 50 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed February 26, 2016). |
Exhibit
Number
|
Description
|
|
(vi) Sub-Advisory Agreement between NBIA and P/E Global LLC with respect to Neuberger Berman Absolute Return Multi-Manager Fund and Absolute Return Multi-Manager Portfolio. Incorporated by Reference to Post-Effective Amendment No. 58 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed April 3, 2017). | ||
(vii) Sub-Advisory Agreement between NBIA and BH-DG Systematic Trading LLP with respect to Neuberger Berman Absolute Return Multi-Manager Fund. Incorporated by Reference to Post-Effective Amendment No. 63 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed February 27, 2018). | ||
(3)
|
(i) Management Agreement between NB Management and the wholly owned subsidiary of Neuberger Berman Commodity Strategy Fund. Incorporated by Reference to Post-Effective Amendment No. 19 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed August 27, 2012). | |
(ii) Novation of Management Agreement entered into as of January 1, 2016, by and among NB Management, NBIA, and the wholly owned subsidiary of Neuberger Berman Commodity Strategy Fund. Incorporated by Reference to Post-Effective Amendment No. 50 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed February 26, 2016). | ||
(4)
|
(i) Management Agreement between NB Management and the wholly owned subsidiary of Neuberger Berman Absolute Return Multi-Manager Fund. Incorporated by Reference to Post-Effective Amendment No. 50 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed February 26, 2016). | |
(ii) Novation of Management Agreement entered into as of January 1, 2016, by and among NB Management, NBIA, and the wholly owned subsidiary of Neuberger Absolute Return Multi-Manager Fund. Incorporated by Reference to Post-Effective Amendment No. 50 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed February 26, 2016). | ||
(5)
|
Management Agreement between NB Management, NBIA, and the wholly owned subsidiary of Neuberger Berman Multi-Style Premia Fund. Incorporated by Reference to Post-Effective Amendment No. 69 to Registrant’s Registration Statement on Form
N-1A, File Nos. 333-122847 and 811-21715 (Filed February 25, 2019).
|
|
(e)
|
(1)
|
(i) Distribution and Services Agreement Between Registrant and NB Management with respect to Class A Shares. Incorporated by Reference to Post-Effective Amendment No. 7 to Registrant’s Registration Statement on Form N-1A, File Nos.
333-122847 and 811-21715 (Filed December 29, 2010).
|
(ii) Amended Distribution and Services Agreement Schedule with respect to Class A Shares. Incorporated by Reference to Post-Effective Amendment No. 62 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715
(Filed January 19, 2018).
|
||
(2)
|
(i) Distribution and Services Agreement Between Registrant and NB Management with respect to Class C Shares. Incorporated by Reference to Post-Effective Amendment No. 7 to Registrant’s Registration Statement on Form N-1A, File Nos.
333-122847 and 811-21715 (Filed December 29, 2010).
|
|
(ii) Amended Distribution and Services Agreement Schedule with respect to Class C Shares. Incorporated by Reference to Post-Effective Amendment No. 62 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715
(Filed January 19, 2018).
|
||
(3)
|
(i) Distribution Agreement Between Registrant and NB Management with respect to Institutional Class Shares. Incorporated by Reference to Post-Effective Amendment No. 7 to Registrant’s Registration Statement on Form N-1A, File Nos.
333-122847 and 811-21715 (Filed December 29, 2010).
|
Exhibit
Number
|
Description | |
(ii) Amended Distribution Agreement Schedule with respect to Institutional Class Shares. Incorporated by Reference to Post-Effective Amendment No. 62 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715
(Filed January 19, 2018).
|
||
(4)
|
(i) Distribution Agreement Between Registrant and NB Management with respect to Class R6 Shares. Incorporated by Reference to Post-Effective Amendment No. 33 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and
811-21715 (Filed December 30, 2013).
|
|
(ii) Amended Distribution Agreement Schedule with respect to Class R6 Shares. Incorporated by Reference to Post-Effective Amendment No. 62 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed
January 19, 2018).
|
||
(5)
|
(i) Novation of Distribution and Services Agreement entered into as of July 1, 2016, by and among Registrant, NB Management, and NB LLC with Respect to all Series whether now existing or hereafter established that are subject to the
Distribution and Services Agreements dated December 29, 2010 for Class A and Class C Shares by and between Registrant and NB Management. Incorporated by Reference to Post-Effective Amendment No. 58 to Registrant’s Registration Statement on
Form N-1A, File Nos. 333-122847 and 811-21715 (Filed April 3, 2017).
(ii) Novation of Distribution Agreement entered into as of July 1, 2016, by and among Registrant, NB Management, and NB LLC with Respect to all Series whether now existing or hereafter established that are subject to the Distribution and
Services Agreements dated December 29, 2010 for Institutional Class Shares and December 31, 2013 for Class R6 Shares by and between Registrant and NB Management. Incorporated by Reference to Post-Effective Amendment No. 58 to Registrant’s
Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed April 3, 2017).
|
|
(f)
|
Bonus or Profit Sharing Contracts. None.
|
|
(g)
|
(1)
|
(i) Custodian Contract Between Registrant and State Street Bank and Trust Company. Incorporated by Reference to Pre-Effective Amendment No. 2 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed
December 15, 2006).
|
(ii) Side Letter to Custodian Contract Between Registrant and State Street Bank and Trust Company. Incorporated by Reference to Post-Effective Amendment No. 19 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and
811-21715 (Filed August 27, 2012).
|
||
(2)
|
Custodian Contract Between Registrant and JP Morgan Chase Bank, N.A. Incorporated by Reference to Post-Effective Amendment No. 17 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and
811-21715 (Filed May 15, 2012).
|
|
(h)
|
(1)
|
Transfer Agency and Service Agreement between Registrant and State Street Bank and Trust Company. Incorporated by Reference to Post-Effective Amendment No. 116 to the Registration Statement on Form N-1A of Neuberger Berman Equity Funds,
File Nos. 2-11357 and 811-00582 (Filed June 2, 2006).
|
(2)
|
(i) Administration Agreement Between Registrant and NB Management with respect to Class A Shares. Incorporated by Reference to Post-Effective Amendment No. 7 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and
811-21715 (Filed December 29, 2010).
|
|
(ii) Amended Administration Agreement Schedule A with respect to Class A Shares. Incorporated by Reference to Post-Effective Amendment No. 62 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed
January 19, 2018).
|
||
(iii) Amended Administration Agreement Schedule B with respect to Class A Shares. Incorporated by Reference to Post-Effective Amendment No. 60 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed
December 22, 2017).
|
Exhibit
Number
|
Description
|
|
(3)
|
(i) Administration Agreement Between Registrant and NB Management with respect to Class C Shares. Incorporated by Reference to Post-Effective Amendment No. 7 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and
811-21715 (Filed December 29, 2010).
|
|
(ii) Amended Administration Agreement Schedule A with respect to Class C Shares. Incorporated by Reference to Post-Effective Amendment No. 62 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed
January 19, 2018).
|
||
(iii) Amended Administration Agreement Schedule B with respect to Class C Shares. Incorporated by Reference to Post-Effective Amendment No. 60 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed
December 22, 2017).
|
||
(4)
|
(i) Administration Agreement Between Registrant and NB Management with respect to Institutional Class Shares. Incorporated by Reference to Post-Effective Amendment No. 7 to Registrant’s Registration Statement on Form N-1A, File Nos.
333-122847 and 811-21715 (Filed December 29, 2010).
|
|
(ii) Amended Administration Agreement Schedule A with respect to Institutional Class Shares. Incorporated by Reference to Post-Effective Amendment No. 62 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and
811-21715 (January 19, 2018).
|
||
(iii) Amended Administration Agreement Schedule B with respect to Institutional Class Shares. Incorporated by Reference to Post-Effective Amendment No. 60 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and
811-21715 (Filed December 22, 2017).
|
||
(5)
|
(i) Administration Agreement between NB Management and the wholly owned subsidiary of Neuberger Berman Commodity Strategy Fund. Incorporated by Reference to Post-Effective Amendment No. 19 to Registrant’s Registration Statement on Form
N-1A, File Nos. 333-122847 and 811-21715 (Filed August 27, 2012).
|
|
(ii) Novation of Administration Agreement entered into as of January 1, 2016, by and among NB Management, NBIA, and the wholly owned subsidiary of Neuberger Berman Commodity Strategy Fund. Incorporated by Reference to Post-Effective
Amendment No. 50 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed February 26, 2016).
|
||
(6)
|
(i) Administration Agreement between NB Management and the wholly owned subsidiary of Neuberger Berman Absolute Return Multi-Manager Fund. Incorporated by Reference to Post-Effective Amendment No. 50 to Registrant’s Registration Statement
on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed February 26, 2016).
|
|
(ii) Novation of Administration Agreement entered into as of January 1, 2016, by and among NB Management, NBIA, and the wholly owned subsidiary of Neuberger Absolute Return Multi-Manager Fund. Incorporated by Reference to Post-Effective
Amendment No. 50 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed February 26, 2016).
|
||
(7)
|
Administration Agreement between NB Management, NBIA, and the wholly owned subsidiary of Neuberger Berman Multi-Style Premia Fund. Incorporated by Reference to Post-Effective Amendment No. 69 to Registrant’s Registration Statement on Form
N-1A, File Nos. 333-122847 and 811-21715 (Filed February 25, 2019).
|
|
(8)
|
(i) Administration Agreement Between Registrant and NB Management with respect to Class R6 Shares. Incorporated by Reference to Post-Effective Amendment No. 33 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and
811-21715 (Filed December 30, 2013).
|
|
(ii) Amended Administration Agreement Schedule A with respect to Class R6 Shares. Incorporated by Reference to Post-Effective Amendment No. 62 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed
January 19, 2018).
|
Exhibit
Number
|
Description | |
|
(iii) Amended Administration Agreement Schedule B with respect to Class R6 Shares. Incorporated by Reference to Post-Effective Amendment No. 60 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed
December 22, 2017).
|
|
(iv) Amended Administration Agreement Schedules A and B with Respect to Class R6 Shares. Incorporated by Reference to Post-Effective Amendment No. 69 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715
(Filed February 25, 2019).
|
||
(9)
|
Novation of Administration Agreement entered into as of January 1, 2016, by and among Registrant, NB Management, and NBIA with Respect to all Series whether now existing or hereafter established that are subject to the Administration
Agreements dated December 29, 2010 for Institutional Class, Class A and Class C Shares, and December 31, 2013 for Class R6 Shares by and between Registrant and NB Management. Incorporated by Reference to Post-Effective Amendment No. 50 to
Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed February 26, 2016).
|
|
(10)
|
Expense Limitation Agreement with respect to Neuberger Berman Global Allocation Fund, Neuberger Berman Long Short Fund, Neuberger Berman Multi-Asset Income Fund, and Neuberger Berman U.S. Equity Index PutWrite Strategy Fund. (Filed
herewith).
|
|
(11)
|
Expense Limitation Agreement with respect to Neuberger Berman Commodity Strategy Fund. (Filed herewith).
|
|
(12)
|
Expense Limitation Agreement with respect to Neuberger Berman Absolute Return Multi-Manager Fund. (Filed herewith).
|
|
(13)
|
Expense Limitation Agreement with respect to Neuberger Berman Multi-Style Premia Fund. (Filed herewith).
|
|
(i)
|
Opinion and Consent of K&L Gates LLP with Respect to Securities Matters of Registrant. (Filed herewith).
|
|
(j)
|
(1)
|
Consent of Ernst & Young LLP, Independent Registered Public Accounting Firm. (Filed herewith). |
(2)
|
Consent of Tait, Weller & Baker LLP, Independent Registered Public Accounting Firm. (Filed herewith). | |
(k)
|
Financial Statements Omitted from Prospectuses. None.
|
|
(l)
|
Letter of Investment Intent. Incorporated by Reference to Pre-Effective Amendment No. 2 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed December 15, 2006).
|
|
(m)
|
(1)
|
(i) Plan pursuant to Rule 12b-1 with respect to Class A Shares. Incorporated by Reference to Post-Effective Amendment No. 7 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed December 29, 2010).
|
(ii) Amended Schedule A to the Plan Pursuant to Rule 12b-1 with Respect to Class A Shares. Incorporated by Reference to Post-Effective Amendment No. 62 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715
(Filed January 19, 2018).
|
||
(2)
|
(i) Plan pursuant to Rule 12b-1 with respect to Class C Shares. Incorporated by Reference to Post-Effective Amendment No. 7 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed December 29, 2010).
|
|
(ii) Amended Schedule A to the Plan Pursuant to Rule 12b-1 with Respect to Class C Shares. Incorporated by Reference to Post-Effective Amendment No. 62 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715
(Filed January 19, 2018).
|
||
(n)
|
Plan pursuant to Rule 18f-3. (Filed herewith).
|
|
(o)
|
(1)
|
Powers of Attorney for Registrant. Incorporated by Reference to Post-Effective Amendment No. 83 to the Registration Statement on Form N-1A of Neuberger Berman Advisers Management Trust, File Nos. 002-88566
and 811-04255 (Filed April 20, 2018).
|
Exhibit
Number
|
Description
|
|
(2)
|
(i) Powers of Attorney for Neuberger Berman Cayman Commodity Fund I Ltd. Incorporated by Reference to Post-Effective Amendment No. 69 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed February
25, 2019).
|
|
(ii) Powers of Attorney for Neuberger Berman Cayman ARMM Fund I Ltd. Incorporated by Reference to Post-Effective Amendment No. 69 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed February 25,
2019).
|
||
(iii) Powers of Attorney for Neuberger Berman Cayman MSP Fund I Ltd. Incorporated by Reference to Post-Effective Amendment No. 69 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed February 25,
2019).
|
||
(p)
|
(1)
|
Code of Ethics for Registrant, NB Management, NBFI and NBAIM. Incorporated by Reference to Post-Effective Amendment No. 77 to the Registration Statement on Form N-1A of Neuberger Berman Advisers Management
Trust, File Nos. 002-88566 and 811-04255 (Filed April 22, 2016).
|
(2)
|
Code of Ethics for Cramer Rosenthal McGlynn LLC. (Filed herewith).
|
|
(3)
|
Code of Ethics for GAMCO Asset Management, Inc. Incorporated by Reference to Post-Effective Amendment No. 11 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed
January 18, 2012).
|
|
(4)
|
Code of Ethics for Good Hill Partners LP. (Filed herewith).
|
|
(5)
|
Code of Ethics for Portland Hill Asset Management Limited. Incorporated by Reference to Post-Effective Amendment No. 50 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed February 26, 2016).
|
|
(6)
|
Code of Ethics for P/E Global, LLC. (Filed herewith).
|
|
(7)
|
Code of Ethics for BH-DG Systematic Trading LLP. Incorporated by Reference to Post-Effective Amendment No. 63 to Registrant’s Registration Statement on Form N-1A, File Nos. 333-122847 and 811-21715 (Filed February 27, 2018).
|
Item 29.
|
Persons Controlled By or Under Common Control with Registrant.
|
Item 30.
|
Indemnification.
|
Item 31.
|
Business and Other Connections of Investment Adviser and Sub-Adviser.
|
NAME
|
BUSINESS AND OTHER CONNECTIONS
|
Joseph V. Amato
President – Equities and Chief Investment Officer – Equities, NBIA
|
Chief Executive Officer and President, Neuberger Berman Holdings LLC (including its predecessor, Neuberger Berman Inc.); President and Director of Neuberger Berman Group LLC; Chief Executive Officer and President, NB BD LLC; Trustee, ten
registered investment companies for which NBIA acts as investment manager and/or administrator; Chief Executive Officer and President, ten registered investment companies for which NBIA acts as investment manager and/or administrator;
Portfolio Manager.
|
Thanos Bardas
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Ashok Bhatia
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
James Bowden
Managing Director, NBIA
|
Managing Director, NB BD LLC; Managing Director, NB Alternatives Advisers LLC (“NBAA”).
|
Claudia A. Brandon
Senior Vice President, NBIA |
Senior Vice President, NB BD LLC; Executive Vice President and Secretary, twenty-nine registered investment companies for which NBIA acts as investment manager and/or administrator.
|
David M. Brown
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Chad Bruso
Senior Vice President, NBIA |
Senior Vice President, NB BD LLC; Portfolio Manager.
|
John Buser
Managing Director, NBIA
|
Managing Director, NB BD LLC; President and Managing Director, NBAA.
|
Stephen J. Casey
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Brad E. Cetron
Chief Compliance Officer, Head of Compliance and Managing Director of Compliance, NBIA
|
Chief Compliance Officer and Managing Director, NB BD LLC.
|
Elias Cohen
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
William R. Covode
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
NAME |
BUSINESS AND OTHER CONNECTIONS
|
Timothy Creedon
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Robert W. D’Alelio
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Derek Devens
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Ingrid Dyott
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Steven Eisman
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Rory Ewing
Senior Vice President, NBIA |
Senior Vice President, NB BD LLC; Portfolio Manager.
|
Savonne L. Ferguson
Chief Compliance Officer – Mutual Funds, Associate General Counsel, and Senior Vice President, NBIA |
Chief Compliance Officer, twenty-nine registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Michael Foster
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Jacob Gamerman
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Jennifer Gorgoll
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Michael C. Greene
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
William Hunter
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
James L. Iselin
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Corey A. Issing
General Counsel and Head of
Compliance – Mutual Funds and
Managing Director, NBIA
|
Chief Legal Officer (only for purposes of sections 307 and 406 of the Sarbanes-Oxley Act of 2002), twenty-nine registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Brian C. Jones
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Charles Kantor
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Hakan Kaya
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
NAME
|
BUSINESS AND OTHER CONNECTIONS
|
Brian Kerrane
Chief Operating Officer – Mutual Funds and Managing Director, NBIA
|
Managing Director, NB BD LLC; Chief Operating Officer, and Vice President, twenty-nine registered investment companies for which NBIA acts as investment manager and/ or administrator.
|
David A. Kiefer
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Eric Knutzen
Managing Director, NBIA
|
Managing Director, NB BD LLC; Multi-Asset Class Chief Investment Officer, Neuberger Berman Group LLC; Portfolio Manager.
|
David Kupperman
Managing Director, NBIA |
Managing Director, NB BD LLC; Managing Director, NBAIM; Portfolio Manager.
|
Nathan Kush
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Sajjad S. Ladiwala
Managing Director, NBIA |
Managing Director, NB BD LLC; Associate Portfolio Manager; Portfolio Manager.
|
Richard S. Levine
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Joseph Lind
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Brian Lord
Chief Compliance Officer – Fixed Income and Senior Vice President, NBIA
|
Senior Vice President, NB BD LLC.
|
Joseph P. Lynch
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Jeffrey Majit
Managing Director, NBIA |
Managing Director, NB BD LLC; Managing Director, NBAIM; Portfolio Manager.
|
James F. McAree
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Matthew McGinnis
Senior Vice President, NBIA
|
Senior Vice President, NB BD LLC; Portfolio Manager.
|
S. Blake Miller
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Norman Milner
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Trevor Moreno
Vice President, NBIA |
Senior Vice President, NB BD LLC; Portfolio Manager.
|
Richard S. Nackenson
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Benjamin H. Nahum
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
NAME
|
BUSINESS AND OTHER CONNECTIONS
|
Thomas P. O’Reilly
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Alexandra Pomeroy
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Douglas A. Rachlin
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Hari Ramanan
Managing Director, NBIA |
Portfolio Manager.
|
Marc Regenbaum
Managing Director, NBIA
|
Managing Director, NB BD LLC; Associate Portfolio Manager.
|
Brett S. Reiner
Managing Director, NBIA |
Managing Director, NB BD LLC; Associate Portfolio Manager.
|
Joana Rocha Schaff
Managing Director, NBIA
|
Managing Director, NB BD LLC; Managing Director, NBAA.
|
Conrad A. Saldanha
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Eli M. Salzmann
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Benjamin E. Segal
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Linda Sharaby
Secretary and Managing Director, NBIA |
Managing Director and Secretary, NB BD LLC; Managing Director and Secretary, Neuberger Berman Holdings LLC.
|
Steve Shigekawa
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Jonathan Shofet
Managing Director, NBIA
|
Managing Director, NB BD LLC; Managing Director, NBAA.
|
Yves C. Siegel
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Brian Smith
Managing Director, NBIA
|
Managing Director, NB BD LLC; Chief Operating Officer and Managing Director, NBAA.
|
Amit Solomon
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Thomas A. Sontag
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Gregory G. Spiegel
Managing Director, NBIA |
Managing Director, NB BD LLC; Associate Portfolio Manager.
|
NAME
|
BUSINESS AND OTHER CONNECTIONS
|
David Stonberg
Managing Director, NBIA
|
Managing Director, NB BD LLC; Managing Director, NBAA.
|
Brad Tank
President - Fixed Income and Chief Investment Officer - Fixed Income, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Gillian Tiltman
Senior Vice President, NBIA |
Senior Vice President, NBEL; Portfolio Manager.
|
Shawn Trudeau
|
Senior Vice President, NB BD LLC; Portfolio Manager.
|
Kenneth J. Turek
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Anthony Tutrone
Managing Director, NBIA
|
Managing Director, NB BD LLC; Chief Executive Officer and Managing Director, NBAA.
|
Gorky Urquieta
Managing Director, NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Judith M. Vale
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Niketh Velamoor
Senior Vice President, and Associate General Counsel, NBIA
|
Senior Anti-Corruption and Anti-Money Laundering Officer and Senior Vice President, NB BD LLC; Anti-Money Laundering Compliance Officer, four registered investment companies for which NBIA acts as investment manager and/or administrator.
|
Leo Anthony Viola
Treasurer and Senior Vice President, NBIA |
Treasurer and Senior Vice President, NB BD LLC; Treasurer, NBAA.
|
Peter Von Lehe
Managing Director, NBIA
|
Managing Director, NB BD LLC; Managing Director, NBAA.
|
David Yi Wan
Senior Vice President, NBIA
|
Senior Vice President, NB BD LLC; Portfolio Manager.
|
Eric Zhou
Vice President, NBIA
|
Vice President, NB BD LLC; Portfolio Manager.
|
Item 32.
|
Principal Underwriters.
|
(a)
|
Neuberger Berman BD LLC, the principal underwriter distributing securities of the Registrant, is also the principal underwriter and distributor for each of the following investment companies:
|
(b)
|
Set forth below is information concerning the directors and officers of the Registrant’s principal underwriter. The principal business address of each of the persons listed is 1290 Avenue of the Americas, New York, New York 10104-0002,
which is also the address of the Registrant’s principal underwriter.
|
NAME
|
POSITIONS AND OFFICES
WITH UNDERWRITER |
POSITIONS AND OFFICES
WITH REGISTRANT |
Joseph V. Amato
|
Chief Executive Officer and President
|
President, Chief Executive Officer and Trustee
|
Thanos Bardas
|
Managing Director
|
None
|
Ashok Bhatia
|
Managing Director
|
None
|
James Bowden
|
Managing Director
|
None
|
Claudia A. Brandon
|
Senior Vice President
|
Executive Vice President and Secretary
|
David M. Brown
|
Managing Director
|
None
|
Chad Bruso
|
Senior Vice President
|
None
|
John Buser
|
Managing Director
|
None
|
Stephen J. Casey
|
Managing Director
|
None
|
Brad E. Cetron
|
Chief Compliance Officer and Managing Director
|
None
|
Elias Cohen
|
Managing Director
|
None
|
William R. Covode
|
Managing Director
|
None
|
NAME
|
POSITIONS AND OFFICES
WITH UNDERWRITER |
POSITIONS AND OFFICES
WITH REGISTRANT |
Timothy Creedon
|
Managing Director
|
None
|
Robert W. D’Alelio
|
Managing Director
|
None
|
Derek Devens
|
Managing Director
|
None
|
Ingrid Dyott
|
Managing Director
|
None
|
Steven Eisman
|
Managing Director
|
None
|
Michael Foster
|
Managing Director
|
None
|
Jacob Gamerman
|
Managing Director
|
None
|
Jennifer Gorgoll
|
Managing Director
|
None
|
Michael C. Greene
|
Managing Director
|
None
|
William Hunter
|
Managing Director
|
None
|
James L. Iselin
|
Managing Director
|
None
|
Brian C. Jones
|
Managing Director
|
None
|
Charles Kantor
|
Managing Director
|
None
|
Hakan Kaya
|
Managing Director
|
None
|
Brian Kerrane
|
Managing Director
|
Chief Operating Officer and Vice President
|
David A. Kiefer
|
Managing Director
|
None
|
Eric Knutzen
|
Managing Director
|
None
|
David Kupperman
|
Managing Director
|
None
|
Nathan Kush
|
Managing Director
|
None
|
Sajjad S. Ladiwala
|
Managing Director
|
None
|
Richard S. Levine
|
Managing Director
|
None
|
Joseph Lind
|
Managing Director
|
None
|
Brian Lord
|
Senior Vice President
|
None
|
Joseph P. Lynch
|
Managing Director
|
None
|
Jeffrey Majit
|
Managing Director
|
None
|
James F. McAree
|
Managing Director
|
None
|
Matthew McGinnis
|
Senior Vice President
|
None
|
S. Blake Miller
|
Managing Director
|
None
|
Norman Milner
|
Managing Director
|
None
|
Trevor Moreno
|
Senior Vice President
|
None
|
Richard S. Nackenson
|
Managing Director
|
None
|
Benjamin H. Nahum
|
Managing Director
|
None
|
Thomas P. O’Reilly
|
Managing Director
|
None
|
Alexandra Pomeroy
|
Managing Director
|
None
|
Douglas A. Rachlin
|
Managing Director
|
None
|
Marc Regenbaum
|
Managing Director
|
None
|
Brett S. Reiner
|
Managing Director
|
None
|
Henry Rosenberg
|
Senior Vice President
|
None
|
Conrad A. Saldanha
|
Managing Director
|
None
|
Eli M. Salzmann
|
Managing Director
|
None
|
Benjamin E. Segal
|
Managing Director
|
None
|
Linda Sharaby
|
Secretary and Managing Director
|
None
|
Steve Shigekawa
|
Managing Director
|
None
|
Jonathan Shofet
|
Managing Director
|
None
|
Yves C. Siegel
|
Managing Director
|
None
|
NAME
|
POSITIONS AND OFFICES
WITH UNDERWRITER |
POSITIONS AND OFFICES
WITH REGISTRANT |
Brian Smith
|
Managing Director
|
None
|
Amit Solomon
|
Managing Director
|
None
|
Thomas A. Sontag
|
Managing Director
|
None
|
Gregory G. Spiegel
|
Managing Director
|
None
|
David Stonberg
|
Managing Director
|
None
|
Brad Tank
|
Managing Director
|
None
|
Shawn Trudeau
|
Senior Vice President
|
None
|
Kenneth J. Turek
|
Managing Director
|
None
|
Anthony Tutrone
|
Managing Director
|
None
|
Gorky Urquieta
|
Managing Director
|
None
|
Judith M. Vale
|
Managing Director
|
None
|
Niketh Velamoor
|
Senior Anti-Corruption and Anti-Money Laundering Officer and Senior Vice President
|
Anti-Money Laundering Compliance Officer
|
Leo Anthony Viola
|
Treasurer and Senior Vice President
|
None
|
Peter Von Lehe
|
Managing Director
|
None
|
David Yi Wan
|
Senior Vice President
|
None
|
Richard Werman
|
Managing Director
|
None
|
|
(c) |
No commissions or other compensation were received directly or indirectly from the Registrant by any principal underwriter who was not an affiliated person of the Registrant.
|
Item 33.
|
Location of Accounts and Records.
|
Item 34.
|
Management Services.
|
Item 35.
|
Undertakings.
|
NEUBERGER BERMAN ALTERNATIVE FUNDS
|
||
By:
|
/s/ Joseph V. Amato
|
|
Name:
|
Joseph V. Amato
|
|
Title:
|
President and Chief Executive Officer
|
Signature
|
Title
|
Date
|
/s/ Joseph V. Amato
|
President, Chief Executive Officer
and Trustee
|
February 26, 2020
|
Joseph V. Amato
|
||
/s/ John M. McGovern
|
Treasurer and Principal Financial and
Accounting Officer
|
February 26, 2020
|
John M. McGovern
|
||
/s/ Robert Conti
|
Trustee
|
February 26, 2020
|
Robert Conti*
|
||
/s/ Michael J. Cosgrove
|
Trustee
|
February 26, 2020
|
Michael J. Cosgrove*
|
||
/s/ Marc Gary
|
Trustee
|
February 26, 2020
|
Marc Gary*
|
||
/s/ Martha C. Goss
|
Trustee
|
February 26, 2020
|
Martha C. Goss*
|
||
/s/ Michael M. Knetter
|
Trustee
|
February 26, 2020
|
Michael M. Knetter*
|
||
/s/ Deborah C. McLean
|
Trustee
|
February 26, 2020
|
Deborah C. McLean*
|
||
/s/ George W. Morriss
|
Trustee
|
February 26, 2020
|
George W. Morriss*
|
||
/s/ Tom D. Seip
|
Chairman of the Board and Trustee
|
February 26, 2020
|
Tom D. Seip*
|
||
/s/ James G. Stavridis
|
Trustee
|
February 26, 2020
|
James G. Stavridis*
|
||
/s/ Candace L. Straight
|
Trustee
|
February 26, 2020
|
Candace L. Straight*
|
||
/s/ Peter P. Trapp
|
Trustee
|
February 26, 2020
|
Peter P. Trapp*
|
|
NEUBERGER BERMAN CAYMAN COMMODITY FUND I LTD.
|
|
|
By:
|
/s/ Robert Conti
|
|
|
Name:
|
Robert Conti
|
|
|
Title:
|
Director
|
|
Signature
|
Title
|
Date
|
/s/ Robert Conti
|
Director, Neuberger Berman
Cayman Commodity Fund I Ltd.
|
February 26, 2020
|
Robert Conti
|
|
|
|
|
|
/s/ George W. Morriss
|
Director, Neuberger Berman
Cayman Commodity Fund I Ltd.
|
February 26, 2020
|
|
||
George W. Morriss
|
|
|
|
NEUBERGER BERMAN CAYMAN ARMM FUND I LTD.
|
|
|
By:
|
/s/ Robert Conti
|
|
|
Name:
|
Robert Conti
|
|
|
Title:
|
Director
|
Signature
|
Title
|
Date
|
/s/ Robert Conti
|
Director, Neuberger Berman
Cayman ARMM Fund I Ltd.
|
February 26, 2020
|
|
||
Robert Conti
|
|
|
|
|
|
/s/ George W. Morriss
|
Director, Neuberger Berman
Cayman ARMM Fund I Ltd.
|
February 26, 2020
|
|
||
George W. Morriss
|
|
|
|
NEUBERGER BERMAN CAYMAN MSP FUND I LTD.
|
|
|
By:
|
/s/ Robert Conti
|
|
|
Name:
|
Robert Conti
|
|
|
Title:
|
Director
|
|
Signature
|
Title
|
Date
|
/s/Robert Conti
|
Director, Neuberger Berman
Cayman MSP Fund I Ltd.
|
February 26, 2020
|
Robert Conti
|
|
|
|
|
|
/s/ George W. Morriss
|
Director, Neuberger Berman
Cayman MSP Fund I Ltd.
|
February 26, 2020
|
|
||
George W. Morriss
|
|
|
Exhibit
Number
|
Description
|
(h)(10)
|
Expense Limitation Agreement with respect to Neuberger Berman Global Allocation Fund, Neuberger Berman Long Short Fund, Neuberger Berman Multi-Asset Income Fund, and Neuberger Berman U.S. Equity Index PutWrite Strategy Fund.
|
(h)(11)
|
Expense Limitation Agreement with respect to Neuberger Berman Commodity Strategy Fund.
|
(h)(12)
|
Expense Limitation Agreement with respect to Neuberger Berman Absolute Return Multi-Manager Fund.
|
(h)(13)
|
Expense Limitation Agreement with respect to Neuberger Berman Multi-Style Premia Fund.
|
(i)
|
Opinion and Consent of K&L Gates LLP with Respect to Securities Matters of Registrant.
|
(j)(1)
|
Consent of Ernst & Young LLP, Independent Registered Public Accounting Firm.
|
(j)(2)
|
Consent of Tait, Weller & Baker LLP, Independent Registered Public Accounting Firm.
|
(n)
|
Plan pursuant to Rule 18f-3.
|
(p)(2)
|
Code of Ethics for Cramer Rosenthal McGlynn LLC.
|
(p)(4)
|
Code of Ethics for Good Hill Partners LP.
|
(p)(6)
|
Code of Ethics for P/E Global, LLC.
|
Fund
|
Class
|
Limitation
Period
|
Expense
Limitation
|
Neuberger Berman Commodity Strategy Fund*
|
Class A
|
10/31/2023
|
1.09%
|
Class C
|
10/31/2023
|
1.84%
|
|
Institutional
|
10/31/2023
|
0.73%
|
|
|
By: /s/ Joseph V. Amato |
|
Name: Joseph V. Amato |
|
|
|
Title: Chief Executive Officer and President |
|
|
NEUBERGER BERMAN CAYMAN ARMM FUND I LTD.
|
|
|
|
|
By: /s/Robert Conti |
Name: Robert Conti | |
Title: Director
|
|
By: /s/ Joseph V. Amato
|
|
Name: Joseph V. Amato |
Title: President and Chief Investment Officer -- Equities
|
Fund
|
Class
|
Limitation
Period
|
Expense
Limitation
|
Neuberger Berman Absolute Return Multi-Manager Fund*
|
Class A
|
10/31/2023
|
2.33%
|
Class C
|
10/31/2023
|
3.08%
|
|
Institutional
|
10/31/2023
|
1.97%
|
|
Class R6
|
10/31/2023
|
1.87%
|
|
Very truly yours,
|
|
|
|
|
|
NEUBERGER BERMAN ALTERNATIVE FUNDS,
|
|
|
on behalf of
|
|
|
NEUBERGER BERMAN MULTI-STYLE PREMIA FUND
|
|
|
|
|
|
|
By: /s/ Joseph V. Amato
|
|
|
|
|
|
Name: Joseph V. Amato
|
|
|
|
|
|
Title: Chief Executive Officer and President
|
|
NEUBERGER BERMAN CAYMAN MSP FUND I LTD.,
|
|
|
|
|
|
|
By: /s/ Robert Conti
|
|
|
|
|
|
Name: Robert Conti
|
|
|
|
|
|
Title: Director
|
NEUBERGER BERMAN INVESTMENT ADVISERS LLC
|
|
|
|
|
|
By:
|
/s/ Joseph V. Amato
|
|
|
Name:
|
Joseph V. Amato
|
|
|
Title:
|
President and Chief Investment Officer -- Equities
|
Fund
|
Class
|
Limitation
Period
|
Expense
Limitation
|
|
|
|
|
Neuberger Berman Multi-Style Premia Fund*
|
Class A
|
10/31/2023
|
1.31%
|
|
Class C
|
10/31/2023
|
2.06%
|
|
Institutional
|
10/31/2023
|
0.95%
|
|
Class R6
|
10/31/2023
|
0.85%
|
|
K&L GATES LLP
1601 K STREET, N.W.
WASHINGTON, DC 20006-1600
T 202.778.9000 F 202.778.9100 klgates.com
|
|
(i) |
the prospectuses and statements of additional information (collectively, the “Prospectuses”)
filed as part of the Post-Effective Amendment;
|
|
(ii) |
the Trust’s certificate of trust, governing instrument, and bylaws in effect on the date of this opinion letter; and
|
|
(iii) |
the resolutions adopted by the trustees of the Trust relating to the Post‑Effective Amendment, the establishment of the Shares of each series and class, and the
authorization for issuance and sale of the Shares.
|
|
February 24, 2020
Page 2
|
|
Very truly yours,
/s/ K&L Gates LLP
|
•
|
Neuberger Berman Absolute Return Multi-Manager Fund
|
•
|
Neuberger Berman Commodity Strategy Fund
|
•
|
Neuberger Berman Global Allocation Fund
|
•
|
Neuberger Berman Multi-Asset Income Fund
|
•
|
Neuberger Berman Multi-Style Premia Fund
|
•
|
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund
|
|
/s/ Ernst & Young LLP
|
/s/ TAIT WELLER & BAKER LLP
|
|
A. |
Code of Ethics / Personal Securities Trading
|
|
• |
At all times, place the interests of the Client Accounts before his or her personal interests;
|
|
• |
Conduct all personal securities transactions in a manner consistent with this Code, so as to avoid any actual or potential conflicts of interest, or an abuse of the individual’s position of trust and
responsibility; and
|
|
• |
Not take any inappropriate advantage of his or her position with or on behalf of CRM or the Client Accounts.
|
|
• |
direct obligations of the Government of the U.S.;
|
|
• |
bankers’ acceptances, bank certificates of deposit, commercial paper and high quality short-term debt instruments, including repurchase agreements;
|
|
• |
shares issued by money market funds;
|
|
• |
shares issued by open-end funds (mutual funds) other than exchange traded funds (“ETFs”) or Reportable Funds.
|
|
• |
which he or she knows or should have known at the time of such purchase or sale is or has been considered for purchase or sale by any Client Accounts, within the most recent seven (7) trading days, or
|
|
• |
which is or has been purchased or sold by any Client Accounts within the most recent seven (7) trading days.
|
|
• |
the market capitalization of the issuer of the security is at least $500 million; and
|
|
• |
the CRM trading desk executes the Employee order. This means the Employee Account must be at MSSB or be an account that can settle via a custodian bank.
|
|
• |
Employ any device, scheme or artifice to defraud the Reportable Fund;
|
|
• |
Make any untrue statement of a material fact to the Reportable Fund or omit to state to the Reportable Fund a material fact necessary in order to make the statements made, in light of the circumstances under
which they are made, not misleading;
|
|
• |
Engage in any act, practice or course of business which would operate as a fraud or deceit upon the Reportable Fund; or
|
|
• |
Engage in any manipulative practice with respect to the Reportable Fund.
|
|
• |
Transactions which are part of an automatic investment plan.
|
|
• |
Transactions in securities other than the Covered Securities.
|
|
• |
Transactions effected in any account over which the Employee has no direct or indirect influence or control.
|
|
o |
“Direct or indirect influence” is considered to be had over any account for which an employee suggests purchases or sales of investments for the account, directs purchases or sales of investments or consults
with the manager of the account as to the particular allocation of investments to be made in the account.3
|
|
o |
Employees who have accounts over which they have no direct or indirect influence or control will be required to provide quarterly certifications as shown as part of Appendix
E.
|
|
• |
Whether the proposed activity may interfere materially with any of the employee’s responsibilities to CRM or its advisory clients;
|
|
• |
Potential conflicts of interest or appearance of conflicts of interest and whether such conflicts might be mitigated;
|
|
• |
Potential regulatory concerns relating to the Outside Business Activity;
|
|
• |
Consideration of other Outside Business Activities of the CRM employee.
|
|
• |
a copy of CRM’s Code of Ethics that is in effect, or at any time within the past five years, was in effect;
|
|
• |
a record of any violation of the Code of Ethics, and of any action taken as a result of the violation, for at least five years after the end of the fiscal year in which the violation occurs;
|
|
• |
a record of all initial compliance reports, quarterly compliance reports, annual holding reports, and related certifications and acknowledgements received from Employees for at least five years;
|
|
• |
a record of all related reports to Fund Boards for at least five years after the end of the fiscal year in which the report is made;
|
|
• |
a record of the names of persons who are currently, or within the past five years were, Access Persons of CRM; and
|
|
• |
a record of any decision, and the reasons supporting the decision, to approve the decision, to approve the acquisition of securities by Access Persons in IPOs and Private Placements, for at least five years
after the end of the fiscal year in which the approval is granted.
|
|
• |
trading by an insider while in possession of material non-public information; or
|
|
• |
trading by a non-insider while in possession of material non-public information, where the information was either disclosed to the non-insider in violation of an insider’s duty to keep it confidential or was
misappropriated; or
|
|
• |
communicating material non-public information to others.
|
|
• |
civil injunctions;
|
|
• |
treble damages;
|
|
• |
disgorgement of profits;
|
|
• |
jail sentences;
|
|
• |
fines for the person who committed the violation of up to three times the profit gained or loss avoided, whether or not the person actually benefited; and
|
|
• |
fines for the employer or other controlling person of up to the greater of $1,000,000 or three times the profit gained or loss avoided.
|
|
• |
Is the information material? Is this information that an investor would consider important in making his/her investment decision? Is this information that would
substantially affect the market price of the securities if generally disclosed?
|
|
• |
Is the information non-public? To whom has this information been provided? Has the information been effectively communicated
to the marketplace by being published in Reuters Economic Services, The Wall Street Journal or other publications of general circulation?
|
|
• |
report the matter immediately to Compliance Personnel;
|
|
• |
refrain from purchasing or selling the securities in a personal securities transaction or on behalf of others, including CRM’s client accounts;
|
|
• |
refrain from communicating the information inside or outside CRM, other than to Compliance Personnel; and
|
|
• |
after Compliance Personnel have reviewed the issue, the employee will be instructed to continue the prohibitions against trading and communications, or will be allowed to trade on and communicate the
information.
|
|
• |
A CRM research analyst may not consult with any consultant from an expert network who is a current employee, officer or director of a publicly traded company or has served as an employee, officer or director
of a publicly traded company during the six month period preceding the proposed consultation.
|
|
• |
Prior to commencing discussions with consultants from an expert network, the CRM research analyst shall read the following disclosure statement:
“At the outset of this call, [I/we] would like to make it clear that [I/we] do not want to discuss any information which might be deemed material and non-public, or which you may have a
duty to keep confidential.”
|
|
• |
CRM research analysts or a designee shall maintain a log of all consultations conducted with a consultant from an expert network. This log shall include the following information:
|
|
o |
Purpose/topic to which the call primarily relates, including the relevant tickers (if applicable)
|
|
o |
Date of the consultation
|
|
o |
CRM participant(s)
|
|
o |
Name of expert consultant(s) and background
|
|
• |
All expert network providers must be approved by CRM’s Compliance Committee before a research analyst is allowed to participate in any consultations with such provider.
|
|
• |
The date of the conference;
|
|
• |
The entity sponsoring the conference;
|
|
• |
The company and representatives with whom an analyst participated in a one-on- one meeting; and
|
|
• |
The CRM analyst(s) who participated in the one-on-one meeting.
|
|
(a) |
the Employee is prohibited from entering into that personal transaction; or
|
|
(b) |
it involves the misuse or improper disclosure of confidential information; and
|
|
(a) |
current or prospective advisory clients of CRM;
|
|
(b) |
securities brokers or dealers, and other vendors of products or services to CRM;
|
|
(c) |
entities acting as intermediaries through which CRM mutual funds are offered to the public such as, for example, mutual fund “supermarkets”; and
|
|
(d) |
public companies and other issuers of securities that are held in, or that are being considered as investments for, CRM client accounts.
|
|
(a) |
elected or appointed officials of, and candidates for elective office with, domestic or foreign governments, their agencies and instrumentalities;
|
|
(b) |
business enterprises owned or operated by domestic or foreign governments, their agencies or instrumentalities;
|
|
(c) |
domestic or foreign political parties; and
|
|
(d) |
officials of public international organizations.
|
|
(i) |
representatives of both CRM and the Covered Person or Government-Related Person participate together in the meals and entertainment, although it is not necessary that they be together at all times--for
example, if they travel separately to an event; and
|
|
(ii) |
meals and entertainment are not supplied at a location that many people would consider disreputable or clearly unsuitable for business meetings, such as a strip club.
|
Initial |
1.
|
I have received and read the Code of Ethics (distributed via e-mail) and have completed the Initial Compliance Training
session. I understand that the Code of Ethics applies to me and to all accounts in which I have any direct or indirect beneficial ownership interest. I understand that the Code of Ethics applies to accounts held by (or for the benefit of) my
spouse, domestic partner and/or any children or relatives who reside in my primary residence.
|
|
|
|||
Initial |
2.
|
In accordance with the Code of Ethics, I will take steps to promptly fully disclose all Covered Securities (as defined in the Code of Ethics) in which I have any direct or indirect beneficial ownership interest
and, pursuant to the Code of Ethics, will establish a personal securities account with an approved brokerage firm from which to effect all transactions in Covered Securities and/or have received approval from the Chief Compliance Officer
(“CCO”) to maintain a non-discretionary account(s). I will report all transactions in Covered Securities as required under the periodic reporting provisions of the Code of Ethics. I will obtain prior written authorization for required
transactions in Covered Securities from the CCO.
|
|
|
|||
Initial |
3.
|
I will continue to comply with all provisions of the Code of Ethics, including the prohibitions against trading based upon material nonpublic information. I will comply with CRM’s written policies and
procedures, particularly as it relates to my role at CRM.
|
|
|
|||
Initial |
4.
|
I have read and received training on CRM’s Sensitive Payments Policy which is contained in the Code of Ethics, (distributed via
e-mail). Pursuant to the policy, I have reported all reportable political contributions that I have given in [ YEAR ], as indicated in the attached activity report, if applicable.
|
|
|
|||
Initial |
5.
|
I have received and read CRM’s Internet and Electronic Communications Usage Policy relating to usage of e-mail and internet (distributed
via e-mail), as well as CRM’s policy on the use of social media, including training relating to those policies. I agree to observe those policies and will comply with their conditions in the [ YEAR ] calendar year.
|
|
|
|||
Initial |
6.
|
I have received and completed the attached Outside Business Activity form and understand my ongoing reporting requirement regarding CRM’s Outside Business Activity Policy.
|
|
|
|||
Initial |
7.
|
I have received and read CRM’s Rule 506(d) Policy/Disciplinary History Disclosure (distributed via e- mail) and have
reported and will report any disqualifying event to the Firm’s CCO.
|
|
|
|||
Initial |
8.
|
I have received and read CRM’s Bring Your Own Device (BYOD) Policy (distributed via e-mail) and have observed will continue
to observe and comply with this policy.
|
|
|
|||
Initial |
9.
|
I have received and completed the CRM Certificate Regarding Personal Non-Discretionary Accounts and understand my ongoing reporting requirement regarding CRM’s policy on securities held in accounts over which
reporting persons have no influence or control.
|
|
|
CRM
Account
|
Employee
|
Bank
|
Account Name
|
Bank Account #
|
Signature:
|
It is the policy of CRM that, prior to any employee engaging in any outside business or business- related activity (whether compensated or not),
the employee is required to obtain approval from: his or her supervisor and a member of the CRM Compliance Committee. This includes serving as a director of a board of any company, whether public or non-public, or as an advisory
member or consultant to any type of company or entity (non-profit or otherwise).
|
||
|
|
|
☐
|
Yes, I have outside business affiliations
|
|
|
(Please list all business affiliations you may have below)
|
|
|
|
|
☐
|
No, I do not have any outside business affiliations
|
|
|
|
|
Business Affiliations:
|
|
|
|
|
|
|
|
|
If answering Yes to the above question, have you obtained the approval your supervisor and a member of the CRM Compliance Committee?
|
||
|
|
|
☐ |
Yes, I have obtained approval.
|
|
☐ |
No, I have not obtained approval.
|
|
☐ |
Not Applicable
|
|
|
|
|
Print Name:
|
|
|
|
|
|
|
|
Signed:
|
|
|
|
|
|
|
|
Date:
|
|
|
|
|
Initial |
1.
|
I have received and read the Code of Ethics (distributed via e-mail) and have completed the Annual Compliance Training session. I understand that the Code of Ethics
applies to me and to all accounts in which I have any direct or indirect beneficial ownership interest. I understand that the Code of Ethics applies to accounts held by (or for the benefit of) my spouse, domestic partner and/or any children
or relatives who reside in my primary residence.
|
|
|
|||
Initial |
2.
|
In accordance with the Code of Ethics, I have fully disclosed all Covered Securities (as defined in the Code of Ethics) in which I have any direct or indirect beneficial ownership interest and, pursuant to the
Code of Ethics, have established a personal securities account with an approved brokerage firm from which to effect all transactions in Covered Securities and/or have received approval from the Chief Compliance Officer (“CCO”) to maintain a
non-discretionary account(s). I have reported and will report all transactions in Covered Securities as required under the periodic reporting provisions of the Code of Ethics. I have obtained and will obtain prior written authorization for
required transactions in Covered Securities from the CCO.
|
|
|
|||
Initial |
3.
|
I have complied with, and will continue to comply with, all provisions of the Code of Ethics, including the prohibitions against trading based upon material nonpublic information. I also have complied with
CRM’s written policies and procedures, particularly as it relates to my role at CRM.
|
|
|
|||
Initial |
4.
|
I have read and received training on CRM’s Sensitive Payments Policy which is contained in the Code of Ethics, (distributed via e-mail). Pursuant to the policy, I have
reported all reportable business gifts and entertainment that I have received in [ YEAR ], as indicated in the attached activity report, if applicable.
|
|
|
|||
Initial |
5.
|
I have received and read CRM’s Internet and Electronic Communications Usage Policy relating to usage of e-mail and internet (distributed via e-mail), as well as CRM’s
policy on the use of social media, including training relating to those policies. I have observed those policies and have been in compliance for the [ YEAR ] calendar year and will continue to observe and comply with their conditions in
the [ YEAR] calendar year.
|
|
|
|||
Initial |
6.
|
I have received and completed the attached Outside Business Activity form and understand my ongoing reporting requirement regarding CRM’s Outside Business Activity Policy.
|
|
|
|||
Initial |
7.
|
I have received and read CRM’s Rule 506(d) Policy/Disciplinary History Disclosure (distributed via e- mail) and have reported and will report any disqualifying event to
the Firm’s CCO.
|
|
|
|||
Initial |
8.
|
I have received and read CRM’s Bring Your Own Device (BYOD) Policy (distributed via e-mail) and have observed and been in compliance with this policy and will continue
to observe and comply with this policy.
|
|
|
|||
Initial |
9.
|
I have previously received and completed the CRM Certificate Regarding Personal Non-Discretionary Accounts and understand my ongoing reporting requirement regarding CRM’s policy on securities held in accounts
over which reporting persons have no influence or control.
|
|
|
CRM
Account
|
Employee
|
Bank
|
Account Name
|
Bank Account #
|
Signature:
|
It is the policy of CRM that, prior to any employee engaging in any outside business or business- related activity (whether compensated or not), the employee is required to obtain
approval from: his or her supervisor and a member of the CRM Compliance Committee. This includes serving as a director of a board of any company, whether public or non-public, or as an advisory member or consultant to any type
of company or entity (non-profit or otherwise).
|
||
|
|
|
☐
|
Yes, I have outside business affiliations
|
|
|
(Please list all business affiliations you may have below)
|
|
|
|
|
☐
|
No, I do not have any outside business affiliations
|
|
|
|
|
Business Affiliations:
|
|
|
|
|
|
|
|
|
If answering Yes to the above question, have you obtained the approval your supervisor and a member of the CRM Compliance Committee?
|
||
|
|
|
☐ |
Yes, I have obtained approval.
|
|
☐ |
No, I have not obtained approval.
|
|
☐ |
Not Applicable
|
|
|
|
|
Print Name:
|
|
|
|
|
|
|
|
Signed:
|
|
|
|
|
|
|
|
Date:
|
|
|
|
|
|
1. |
I have not suggested, nor will I suggest in the future, that the trustee or third-party discretionary manager make any particular purchases or sales of securities for my account(s)
during the period [_____________], 20 [___]– [_____________], 20 [____].
|
|
2. |
I have not directed, nor will I direct in the future, the trustee or third-party manager to make any particular purchases or sales of securities for my account(s) during the period
[_____________], 20 [___]– [_____________], 20 [____].
|
|
3. |
I did not consult, nor will I consult in the future, with the trustee or third-party discretionary manager as to the particular allocation of investments to be made in my account(s)
during the period [_____________], 20 [___]– [_____________], 20 [____].
|
Signature:
|
Section
|
Page
|
|
|
|
|
SECTION 1: INTRODUCTION AND OVERVIEW |
4
|
|
|
|
|
SECTION 2: GENERAL STANDARDS OF BUSINESS CONDUCT |
4
|
|
2.1
|
General Policy
|
5 |
2.2
|
Guiding Principals and Standards of Conduct | 6 |
2.3
|
Sub-Advisory Compliance Requirements and Certifications to Investment Companies | 6 |
SECTION 3: CONFLICTS OF INTERESTS | 7 | |
3.1
|
Identification and Resolution of Potential Conflicts of Interest | 7 |
3.2
|
Disclosure of Personal Interests in Transactions | 8 |
3.3 | Gifts and Entertainment Policies and Restrictions | 8 |
3.4
|
Political Contributions | 11 |
3.5 | Outside Business Activities | 13 |
3.6
|
Disclosure of Conflicts of Interest | 14 |
SECTION 4: PERSONAL SECURITIES TRANSACTIONS, REPORTING AND CERTIFICATIONS | 15 | |
4.1
|
Reportable Securities
|
15
|
4.2
|
Exempt Securities
|
15 |
4.3 |
Beneficial Ownership
|
16 |
4.4
|
Initial and Annual Holdings Report and Certification of Compliance
|
16 |
4.5 |
Quarterly Securities Transactions Report
|
17 |
4.6
|
Personal Accounts Managed By Third Parties and Trust Accounts
|
18 |
4.7
|
Temporary Employees, Interns and Consultants | 18 |
4.8
|
Confidentiality of Reports
|
19 |
SECTION 4: PERSONAL SECURITIES TRANSACTION POLICIES | 19 | |
5.1
|
Personal Trading Policy | 19 |
5.2
|
Pre-Clearance Procedures | 20 |
5.3 | Pre-Clearance of Limited Offerings and Initial Public Offerings | 20 |
5.4
|
Restricted List
|
21 |
SECTION 5: ADMINISTRATION AND ENFORCEMENT OF THE CODE OF ETHICS
|
23
|
|
6.1
|
Training and Eduction
|
23
|
6.2
|
Compliance Reviews
|
23 |
6.3
|
Remedial Actions
|
24 |
6.4
|
Reporting of Violations
|
24 |
SECTION 7: INSIDER TRADING
|
25 | |
SECTION 8: FPA PREVENTION OF BRIBERY
|
25 | |
RECORD KEEPING
|
25
|
|
APPENDICES
|
||
|
||
Appendix A: INITIAL SECURITIES HOLDINGS REPORT AND CERTIFICATION
|
26
|
|
Appendix B: ANNUAL SECURITIES HOLDINGS REPORT AND CERTIFICTION
|
27 | |
Appendix C: LIMITED OFFERING & IPO REQUEST AND REPORTING FORM
|
28 | |
Appendix D: QUARTERLY SECURITIES TRANSACTIONS REPORT
|
29 | |
Appendix E: SAMPLE BROKERAGE LETTER
|
30 | |
Appendix F: POLICIES AND PROCEDURES TO DETECT AND PREVENT INSIDER TRADING
|
31 | |
Appendix G: TRADE AUTHORIZATION REQUEST FORM
|
36 | |
Appendix H: ACESS PERSON INITIALANNUAL CERTIFICATION FOR THIRD PARTY DISCRETIONARY AND TRUST ACCOUNTS
|
37 | |
Appendix I: POLITICAL CONTRIBUTON REPORTING/DISCLOSURE FORM
|
38 |
|
1. |
INTRODUCTION AND OVERVIEW
|
|
2. |
GENERAL STANDARDS OF BUSINESS CONDUCT
|
|
2.1 |
General Policy
|
|
• |
Place client interests ahead of Good Hill’s interests – As a fiduciary, Good Hill must serve its clients’ best interests. In other words, Good Hill employees may not benefit at the expense of
clients. This concept is particularly relevant when employees are making personal investments in securities traded by Good Hill’s clients.
|
|
• |
Engage in personal investing that is in full compliance with the Code of Ethics – Employees must review and abide by Good Hill’s Personal Securities Transaction and Insider Trading Policies.
|
|
• |
Avoid taking advantage of the employee’s position – Employees must not accept investment opportunities, gifts, entertainment or other gratuities from individuals seeking to conduct business
with Good Hill, or on behalf of a client, where such opportunities, gifts, entertainment or gratuities could create the appearance of impropriety or might otherwise influence a decision to conduct business with such other party.
|
|
• |
Maintain full compliance with the federal securities laws3 – It is Good Hill’s policy that employees must abide by
the standards set forth in Rule 204A-1 (the “code of ethics rule”) for SEC registered investment advisers under the Advisers Act.
|
|
2.2 |
Guiding Principles and Standards of Conduct
|
|
• |
act with integrity, competence, diligence, respect, and in an ethical manner with the public, clients, prospective clients, employers, employees, colleagues in the investment profession, and other participants in the global capital
markets;
|
|
• |
place the integrity of the investment profession, the interests of clients, and the interests of Good Hill above one’s own personal interests;
|
|
• |
adhere to the fundamental standard that the employee or consultant should not take inappropriate advantage of his position;
|
|
• |
conduct all personal securities transactions in a manner consistent with this policy;
|
|
• |
use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities;
|
|
• |
practice and encourage others to practice in a professional and ethical manner that will reflect credit on themselves and the profession;
|
|
• |
promote the integrity of, and uphold the rules governing, capital markets;
|
|
• |
maintain and improve his professional competence and strive to maintain and improve the competence of other investment professionals; and
|
|
• |
comply with applicable provisions of the federal securities laws.
|
|
2.3 |
Sub-Advisory Compliance Requirements and Certifications to Investment Companies
|
|
• |
provide a copy of the Code of Ethics and changes thereof to the Investment Company’s Chief Compliance Officer and the Board of Directors when requested;
|
|
• |
provide a copy, with reasonable notice, of any material changes to the Code of Ethics; and
|
|
• |
provide periodic certifications and reports to the Investment Company regarding the Code of Ethics and any violations thereof as requested.
|
|
3. |
CONFLICTS OF INTERESTS
|
|
• |
Good Hill or its employees receive compensation or other financial benefits (such as discounts on products and services) from an issuer or affiliates of issuers of securities owned by a client.
|
|
• |
Good Hill or its employees engage in outside business activities involving an issuer or affiliate of an issuer of securities owned by a client. Also reference Section 3.5 - Outside Business Activities.
|
|
• |
Employees serve on the board or an advisory committee of a private or public company issuer in which a client is invested. Also reference Section 3.5 - Outside Business Activities.
|
|
• |
Employees (and/or their family members) serve as officers, directors and/or board members of publicly-traded companies. Also reference Section 3.5 - Outside Business Activities.
|
|
• |
Employees become personally involved in joint business ventures with an issuer or affiliate of an issuer of securities owned by a client.
|
|
• |
Good Hill or its employees lend money to a client or investor.
|
|
• |
Employees are directly entitled to receive fees or other benefits from a client or investor.
|
|
• |
A third-party investor, co-investor (or entity related to such investor) provides products or services to Good Hill or its employees.
|
|
• |
Employees (and/or their family members) are employed by another investment adviser or broker dealer.
|
|
• |
Employees (and/or their family members) work at a company with which Good Hill conducts or seeks to conduct business.
|
|
• |
Good Hill conducts principal transactions, which may include loans, between a Supervised Person’s personal account or ownership entity or proprietary account and a client.
|
|
3.2 |
Disclosure of Personal Interest in Transactions
|
|
3.3 |
Gifts and Entertainment Policies and Restrictions
|
|
1. |
Gifts
|
|
2. |
Entertainment
|
|
3.4 |
Political Contributions
|
|
• |
The Political Contributions Rule states that if a Covered Associate, as defined below, makes a contribution, including a gift, subscription, loan advance or anything of value, other than de minimis
contributions, which are defined as $350 if the employee is entitled to vote for the candidate and $150 if the employee is not entitled to vote for the candidate, to an official of a Government Entity, then Good Hill is prohibited from
receiving compensation from that entity (e.g. as a client) for 2 years. Good Hill will also need to look back for a 2 year period from the time of the contribution. Any compensation received by Good Hill that violates the 2 year
restriction may need to be refunded.
|
|
• |
The Political Contributions Rule applies to “contributions” made on or after March 14, 2011, by Covered Associates of investment advisers who advise “Government Entities” as defined below.
|
|
• |
“Contributions” are defined as any gift, subscription, loan, advance or anything of value. The Political Contributions Rule applies to contributions made directly and indirectly.
|
|
• |
“Covered Associates” include partners, executive officers, vice presidents in charge of a principal business unit, or persons with similar functions and persons who solicit Government Entities (and their
supervisors).
|
|
• |
“Government Entities” include any state or political subdivision (i.e., local or municipal) including: (i) an agency or authority of a state, local or municipal subdivision; (ii) a plan or program of a
state, local or municipal subdivision; and (iii) officers, agents or employees of a state, local or municipal subdivision acting in their official capacity.
|
|
• |
The Political Contributions Rule generally also prohibits payments to third parties for soliciting advisory business unless the solicitor is an adviser or a broker-dealer.
|
|
• |
While the Political Contributions Rule generally applies to contributions to state or local officials, it also applies to federal officials running for state office and state officials running for federal office.
|
|
• |
Covered Associates should be aware that certain state and local government jurisdictions may have additional regulations and restrictions including potential registration requirements that apply to the
receipt of political contributions to officials of those jurisdictions.
|
|
• |
The Chief Compliance Officer will train all employees initially and annually with respect to the requirements of the Political Contributions Rule.
|
|
• |
The names, titles, business and residence addresses of all Covered Associates.
|
|
• |
All direct or indirect contributions made by Good Hill or any of its Covered Associates to an official of a government entity, or direct or indirect payments to a political party of a state or political
subdivision thereof, or to a political action committee. Records relating to the contributions and payments must be listed in chronological order and indicate (1) the name and title of each contributor; (2) the name and title (including
any city/county/state or other political subdivision) of each recipient of a contribution or payment; (3) the amount and date of each contribution or payment; and (4) whether any such contribution was the subject of the exception for
certain returned contributions pursuant to Rule 206(4)-5(b)(2) under the Advisers Act.
|
|
• |
All Government Entities to which Good Hill provides or has provided investment advisory services, that are currently or were investors in any covered investment pool to which Good Hill provides or has provided investment advisory
services, as applicable, in the past five years, but not prior to September 13, 2010.
|
|
• |
The name and business address of each regulated person to whom Good Hill provides or agrees to provide, directly or indirectly, payment to solicit a government entity for investment advisory services.
|
|
• |
List of Government Entities that are Clients / Investors.
|
|
3.5 |
Outside Business Activities
|
|
• |
Employment for compensation by any other entity, including board memberships, advisory positions, trade group positions;
|
|
• |
Active involvement in any other business including part-time, evening or weekend employment;
|
|
• |
Active involvement in any activities related to personal investments such as local businesses, real estate investments or family businesses;
|
|
• |
Serving as an officer, director, partner, etc. in any public or private entity;
|
|
• |
Providing any advice about investments; and
|
|
• |
Any public speaking or writing beyond the scope of Good Hill activities.
|
|
3.6 |
Disclosure of Conflicts of Interest
|
|
4. |
PERSONAL SECURITIES TRANSACTIONS, REPORTING AND CERTIFICATIONS
|
|
4.1 |
Reportable Securities
|
|
4.2 |
Exempt Securities
|
|
4.3 |
Beneficial Ownership
|
|
• |
securities held by members of employees’ immediate family sharing the same household. Immediate family means any relative, spouse or significant other, or relative of the spouse or significant other of an employee;
|
|
• |
an employee’s interest as a general partner in securities held by a general or limited partnership; and
|
|
• |
an employee’s interest as a manager/member in the securities held by a limited liability company.
|
|
• |
ownership of securities as a trustee where either the employee or members of their immediate family have a vested interest in the principal or income of the trust;
|
|
• |
ownership of a vested beneficial interest in a trust; and
|
|
• |
an employee’s status as a settler of a trust, unless the consent of all of the beneficiaries is required in order for the employee to revoke the trust.
|
|
4.4 |
Initial and Annual Holdings Report and Certification of Compliance
|
|
4.5 |
Quarterly Securities Transactions Report
|
|
• |
Transactions effected pursuant to an automatic investment plan.
|
|
• |
Open-end mutual funds transactions as part of an account held at a mutual fund company where the employee does not have the ability to execute other types of securities transactions in the account.
|
|
• |
401K plan accounts where such accounts are limited to selected investments in open- end mutual funds sponsored by the 401K plan provider.
|
|
4.6 |
Personal Accounts Managed By Third Parties and Trust Accounts
|
|
4.7 |
Temporary Employees, Interns and Consultants
|
|
4.8 |
Confidentiality of Reports
|
|
5. |
PERSONAL SECURITIES TRANSACTION POLICIES
|
|
• |
Trading the same securities as positioned in client Funds and accounts. Any evidence of front running, piggybacking or trading based on the trading patterns and historical trades of any client trading
could be grounds for dismissal.
|
|
• |
Communicating to others confidential information concerning Good Hill and its clients or other material, non-public information where both federal law and Good Hill’s policy prohibit employees from
trading on the basis of material, non-public information. If an employee receives information or recommendations from a broker, bank, corporate employee, research vendors or other source and has any doubt whether such information could
be material, non-public information, the employee must immediately convey such information to the General Counsel, Chief Compliance Officer and the Chief Operating Officer and not act on the information or disclose it to anyone before
receiving prior approval from the Chief Operating Officer.
|
|
• |
Conducting excessive trading that could conflict with the securities traded by clients, distract an employee’s job responsibilities and/or create the appearance that could compromise Good Hill and its
employee’s fiduciary duty to clients.
|
|
5.2 |
Pre-Clearance Procedures
|
|
• |
Securities exempt from the personal holdings reporting requirements (Section 4.2 of this Code of Ethics).
|
|
• |
Exchange Traded Funds (ETFs) – investment and index funds that trade on an exchange.
|
|
• |
All equity stocks and options related securities (other than those on the Restricted List).
|
|
• |
Commodities and futures.
|
|
• | Cryptocurrencies - digital tokens / virtual currencies and other digital assets |
|
5.3 |
Pre-Clearance of Limited Offerings and Initial Public Offerings6
|
|
5.4 |
Restricted List
|
|
• |
Where Good Hill employees receive material non-public information about a company that has issued publicly traded securities (a “Public Company”).
|
|
• |
Where Good Hill becomes bound by a fiduciary obligation or other duty (for example, because an employee has become a board member of an investment Fund or other private or Public Company).
|
|
• |
Where Good Hill employees receive material non-public information or other confidential information as a result of signing a confidentiality agreement.
|
|
• |
Where Good Hill clients or employees are restricted from trading securities or funds due to sub-advisory relationships to investment companies.
|
|
• |
Where Good Hill may obtain material non-public information about a company as result of a relationship with a third party.
|
|
• |
Other similar events as deemed by the Principal Officer, Chief Operating Officer, General Counsel and/or the Chief Compliance Officer, if necessary.
|
|
6. |
ADMINISTRATION AND ENFORCEMENT OF THE CODE OF ETHICS
|
|
6.1 |
Training and Education
|
|
6.2 |
Compliance Reviews
|
|
• |
Compliance with the Code of Ethics for the period under review;
|
|
• |
Violations of the Code of Ethics for the period under review;
|
|
• |
Sanctions imposed under the Code of Ethics during the period under review; and
|
|
• |
Changes in policies and procedures recommended for the Code of Ethics.
|
|
6.3 |
Remedial Actions
|
|
6.4 |
Reporting of Violations
|
|
7. |
INSIDER TRADING
|
|
8. |
FCPA PREVENTION OF BRIBERY
|
|
9. |
RECORD KEEPING
|
|
• |
A copy of all Codes of Ethics in effect within the past five years.
|
|
• |
Original reports, records or markings of all violations of the Code of Ethics.
|
|
• |
Copies of all initial, annual and quarterly reports made by Supervised Persons.
|
|
• |
A copy of all written acknowledgments for all persons who currently are, or within the past five years were, Supervised Persons, certifying receipt of the Compliance Manual and the Code of Ethics.
|
|
• |
A record of the names of persons who currently are, or within the past five years were, Supervised Persons.
|
Name of Account
Holder
|
Account
Number
|
Brokerage Firm
|
Date Account
Opened
|
Duplicate Copies
of statements sent
to CCO? (Yes or
No)*
|
Title of
Security
|
Type of
Security
|
Exchange
Ticker or
CUSIP
No.
|
No. of
Shares
|
Principal
Amount
|
Trade
Date
|
Interest
Rate and
Maturity
Date
|
Nature of
Transaction
(Purchase/
Sale/gift,
etc.)
|
Price
|
Broker,
Dealer or
Bank
Involved
|
Nature of
Ownership
(Direct,
Spouse,
etc.)
|
Signature:__________________________________
|
|
Print Name:____________________________________________
|
|
|
|
Reviewed By:____________________________ Date:____________________
|
|
|
Name of Account
Holder
|
Account Number
|
Brokerage Firm
|
Date Account
Opened
|
Duplicate Copies of
statements sent to
CCO? (Yes or No)*
|
Title of
Security
|
Type of
ecurity
|
Exchange
Ticker or
CUSIP
No.
|
No. of
Shares
|
Principal
Amount
|
Trade Date
|
Interest
Rate and
Maturity
Date
|
Nature of
Transaction
(Purchase/
Sale/gift,
etc.)
|
Price
|
Broker,
Dealer or
Bank
Involved
|
Nature of
Ownership
(Direct,
Spouse,
etc.)
|
Signature:__________________________________
|
|
Print Name:____________________________________________
|
|
|
|
|
|
Reviewed By:____________________________ Date:____________________
|
|
|
Name of Issuer |
|
|
|
|
|
|
|
|
|
Type of Security: |
|
|
|
|
Public Offering Date | ||||
(for proposed IPO investments only) |
|
1. |
I am not investing in this limited offering or IPO to profit improperly from my position as a Good Hill employee;
|
|
2. |
The investment opportunity did not arise by virtue of my activities on behalf of a Good Hill client; and
|
|
3. |
To the best of my knowledge, no Good Hill clients have any foreseeable interest in purchasing this security.
|
Date:__________________________________
|
Signature: ______________________________
|
|
|
|
|
|
|
Print Name: ________________________________________________
|
|
|
Internal Use Only
_____ Approved ________Not Approved
Person Approving _________
Reasons Supporting Decision to Approve/Not Approve ____________________________
|
SECURITY
|
TICK
ER/
CUSIP
|
DATE
|
SHARES
|
PRINCIPAL
AMOUNT
|
BUY/SELL
|
PRICE
|
CUSTODIAN
|
Date:__________________________________
|
Signature: ______________________________
|
|
|
|
|
|
|
Print Name: ________________________________________________
|
|
|
|
• |
trading by an insider while in possession of material, non-public information;
|
|
• |
trading by a non-insider while in possession of material, non-public information, where the information was disclosed to the non-insider in violation of an insider’s duty to keep it confidential; or
|
|
• |
communicating material, non-public information to others in breach of a fiduciary duty.
|
|
• |
information relating to a company’s results and operations;
|
|
• |
dividend or earnings announcements (dividend changes, earnings results, changes in previously released earnings estimates);
|
|
• |
write-downs or write-offs of assets;
|
|
• |
additions to reserves for bad debts or contingent liabilities;
|
|
• |
expansion or curtailment of company or major division operations;
|
|
• |
merger and joint venture announcements;
|
|
• |
new product/service announcements;
|
|
• |
discovery or research developments;
|
|
• |
criminal, civil and government investigations and indictments;
|
|
• |
pending labor disputes;
|
|
• |
debt service or liquidity problems;
|
|
• |
bankruptcy or insolvency problems;
|
|
• |
tender offers, stock repurchase plans, etc.; or
|
|
• |
recapitalization.
|
|
• |
shall not trade the securities of any company in which he is deemed an insider who may possess material, non-public information about the company;
|
|
• |
shall not trade the securities of any company except in accordance with Good Hill’s Personal Securities Transaction Policy and the securities laws;
|
|
• |
shall submit personal brokerage statements in accordance with the Personal Security Transaction Policy;
|
|
• |
shall not discuss any potentially material, non-public information with colleagues, except as specifically required by his position;
|
|
• |
shall immediately report the potential receipt of non-public information to the General Counsel, Chief Compliance Officer and Good Hill’s principal officers in accordance with the Restricted List policy; and
|
|
• |
shall not proceed with any research, trading or other investment advisory activities until the General Counsel, Chief Compliance Officer and Good Hill’s principal officers inform the employee of the appropriate course of action.
|
Does any Good Hill client currently hold a position of any kind in this issuer?
|
Yes
|
No
|
||
Do you, or to your knowledge upon due inquiry, does any other person associated with Good Hill possess material, non-public information regarding the security or the issuer of the
security?
|
Yes
|
No
|
||
To your knowledge upon due inquiry, are there any outstanding purchase or sell orders for this security (or any equivalent security) by any Good Hill client?
|
Yes
|
No
|
||
To your knowledge upon due inquiry are the securities (or equivalent securities) being considered for purchase or sale by one or more Good Hill clients?
|
Yes
|
No
|
||
Is the basis for your interest in this transaction derived from any discussions with other Good Hill personnel?
|
Yes
|
No
|
Employee
|
|||||
PRINT NAME
|
SIGNATURE
|
DATE
|
|
1. |
I have not previously and will not suggest purchases or sales of investments to the third party discretionary manager or Trustee;
|
|
2. |
I have not or will not direct purchase or sales with regards to my personal accounts;
|
|
3. |
I have not or will not consult with the third party discretionary manager or Trustee as to the particular allocation of investments to be made in the account.
|
Account Holder Name | Account # | Brokerage Firm | Date Acct Opened |
|
Signature: _________________________________________
|
|
|
Print Name: _________________________________________
|
Name: |
|
Title (if any): |
|
Residence Address for Voting Purposes: |
|
|
|
Recipient Name/Date
of Contribution
|
Candidate for
Which Office and
Current Office
Held if applicable
|
Entitled to vote
for Candidate?
|
Current
Office
holder
Other
|
(CHECK ONE)
Political
|
Federal or
State
(specify)
|
Dollar
Amount
|
||
Candidate | PAC |
Party
|
||||||
Attestation: I certify that the information provided by me in this statement is true and accurate to the best of my knowledge and the proposed contribution was not
solicited by Good Hill Partners LP or any Good Hill employee.
|
|||||
Employee Signature
|
Printed Name
|
Date
|
|||
Approval Required:
|
|||||
Signature
|
Printed Name
|
Date
|
38
|
Page
|
I.
|
Compliance with Governing Laws and Regulations
|
||
A.
|
Employees shall maintain knowledge of and shall comply with all applicable laws, rules and regulation of any government, governmental agency and regulatory organization governing his or her professional,
financial, or business activities, with particular attention to CFTC, NFA and SEC dictates and the Federal Securities Laws.
|
||
B.
|
Employees shall not knowingly participate in, or assist, any acts in violation of any applicable law, rule, or regulation of any government, governmental agency, or regulatory organization governing his or her
professional, financial, or business activities.
|
||
C.
|
Employees shall not take any action based on Client or firm confidential information.
|
||
II.
|
Investment Recommendations and Actions
|
||
A.
|
Only NFA Associated Persons with at least two years of experience may make investment recommendations for Client portfolios.
|
||
B.
|
An employee shall make full, fair, accurate, timely and understandable disclosure in reports.
|
||
C.
|
An employee shall exercise diligence and thoroughness in making investment recommendations to Clients, or in taking investments action for Clients.
|
||
D.
|
An employee shall have a reasonable and adequate basis for such recommendations and actions, supported by data and research.
|
||
E.
|
An employee shall make diligent efforts to avoid any material misrepresentation in any report or investment.
|
||
F.
|
Each employee shall maintain appropriate records to support recommendations and to document trading activity.
|
||
G.
|
Employees shall consider the specific needs and requests of individual Clients when making investment decisions.
|
||
H.
|
Employees shall distinguish between facts and opinions when presenting investment recommendation. All data must include time frame, assumptions, and cite sources.
|
||
I.
|
Employees shall disclose to Clients the basic format and principles of the investment process by which securities are selected and portfolios constructed and shall promptly disclose to Clients any changes that
might significantly affect those processes.
|
||
J.
|
An employee shall not make any statements, orally or in writing, which misrepresent 1) the services the firm is capable of performing, 2) the qualifications of such employee or the firm, and/or 3) the expected
performance of an investment.
|
||
K.
|
An employee shall not make, orally or in writing, statements which misrepresent the investment performance that the employee or the firm has accomplished or can reasonably be expected to achieve.
|
||
L.
|
An employee shall make every reasonable effort to ensure that all performance
|
information communicated to Clients is fair, accurate, and complete. | |||
M.
|
An employee shall act fairly with all Clients when disseminating information or taking action.
|
||
III.
|
Relationships with Others
|
||
A.
|
Employees shall preserve the confidentiality of information communicated by a Client concerning matters within the scope of the confidential relationship, unless that information concerns illegal activities on
the part of the Client.
|
||
B.
|
Employees shall take care to maintain independence and objectivity.
|
||
IV.
|
Professional Misconduct
|
||
A.
|
Employees shall not commit a criminal act that upon conviction materially reflects adversely on his honest, trustworthiness, or fitness to the financial industry.
|
||
B.
|
Employees shall not engage in conduct involving dishonesty, fraud, deceit, or misrepresentation.
|
||
C.
|
Employees shall promptly report any suspected violations to appropriate persons inside the Company.
|
||
D.
|
Employees shall be held accountable for adhering to the Code of Ethics.
|
||
V.
|
Personal Securities and Other Transactions
|
||
A.
|
Employees are required to conduct all Personal Securities Transactions in compliance with this Code of Ethics and should not take any action in connection with Personal Securities Transactions that could cause
the appearance of unfairness or impropriety relative to Clients.
|
||
B.
|
Ambiguous situations should be brought to the attention of the Chief Compliance Officer and should be resolved in favor of Clients’ interests.
|
||
C.
|
Employees must also: (i) have all Personal Securities Transactions involving Pre-Cleared Securities pre-approved; (ii) report all their Personal Securities Transactions involving Reportable Securities to the
Company periodically; and (iii) certify their compliance with this Code on at least an annual basis in the form attached hereto as EXHIBIT D or via ComplySci.
|
||
D.
|
Employees may only effect a Personal Securities Transaction in a Pre-Cleared Security if it has been pre-approved by the Chief Compliance Officer.
|
||
E.
|
The Chief Compliance Officer will examine the impact of any proposed Personal Securities Transaction involving a Pre-Cleared Security in light of the provisions of this Code and the facts and circumstances
surrounding the proposed transaction. In the event that an employee effects an unapproved or otherwise prohibited Personal Securities Transaction in a Pre-Cleared Security, such employee may be required at the discretion of the Chief
Compliance Officer to close out his or her position in the Pre-Cleared Security and to disgorge any profit from the transaction. Such activity may subject the employee to additional reprimand, up to and including termination of such Access
Person’s employment.
|
||
F.
|
The Chief Compliance Officer or her designee’s prior approval is required for each Personal Securities Transaction involving Pre-Cleared Securities. An employee shall obtain approval via ComplySci. Pre-approval
must be obtained prior to the execution of the proposed Personal Securities Transaction in a Pre-Cleared Security. The Company will maintain a record of all such pre-clearances.
|
||
G.
|
Employees may not purchase and sell, or sell and purchase the same Sub-Advised Mutual Fund in any 30-day period, regardless of whether those transactions occurred in a single account (e.g., a brokerage account,
a 401(k) account) or across multiple accounts in which the employee has beneficial interest. This prohibition will not apply with respect to automatic reinvestments of dividends, income or interest received from the Sub-Advised Mutual Fund.
|
||
H.
|
Employees may not open a futures trading account with a futures commission merchant.
|
VI.
|
Reporting Requirements
|
||
A.
|
Initial Securities Holdings Report. Within 10 days of the date an Access Person of the Company first becomes an Access Person, such Access Person must submit a report to the Company listing all Reportable
Securities and Securities accounts in which he or she has a direct or indirect Beneficial Ownership.
|
||
B.
|
Annual Securities Holdings Report. Within 30 days after the end of each calendar year, each Access Person shall submit a report to the Company listing all Reportable Securities and Securities accounts in which
such Access Person has a direct or indirect Beneficial Ownership. The information must be current as of a date no more than 45 days before the report is submitted.
|
||
C.
|
Securities Holdings Report. Each Securities Holdings Report required to be delivered by this Code shall be submitted via ComplySci.
|
||
D.
|
Quarterly Securities Transaction Reports. Within 30 days after the end of each calendar quarter, each Access Person must either (I) submit a report to the Company listing information about each transaction
involving a Reportable Security in which such Access Person had, or as a result of the transaction, acquired, direct or indirect Beneficial Ownership during such calendar quarter or (II) comply with Section VI.E below. Each Quarterly
Securities Transaction Report required to be delivered by this Code shall be submitted via ComplySci. If an Access Person had no reportable transactions or did not open any new Securities accounts during the applicable quarter, such Access
Person must still submit a report stating such.
|
||
E.
|
Brokerage Statements. All Access Persons who do not comply with Section VI.D, must have copies of all monthly or quarterly account statements relating to Personal Securities Transactions in all Securities
accounts in which the Access Person had a direct or indirect Beneficial Ownership interest sent directly to the Company no later than 30 days after the end of each calendar quarter.
|
||
F.
|
The requirements set forth in this Section IV do not require any Access Person to submit any report with respect to Securities held in accounts over which the Access Person had no direct or indirect influence
or control or any transaction report with respect to transactions effected pursuant to an automatic investment plan.
|
||
G.
|
All reports and any other information will be treated as confidential unless such information is required to be disclosed to certain regulatory or other authorities by operation of law.
|
||
VII.
|
Conflicts of Interest.
|
||
Employees must place the interests of the Company’s Clients first. As a fiduciary, an employee must scrupulously avoid serving his or her own personal interests ahead of the interests of the Company’s Clients.
An employee may not cause a Client to take action, or not to take action, for his or her own personal benefit rather than the benefit of the Client.
|
|||
A.
|
Priority of Transactions
|
|
•
|
An employee shall ensure that transactions for customers and employer have priority over transactions or other investments of which he or she is a beneficial owner, so that personal investments do not adversely
affect Client transactions.
|
||
|
• |
An employee, when making investment recommendations, or taking investment actions, shall disclose to Clients any material conflict of interest relating to the employee, and any material beneficial ownership of
securities or other
|
investments that could reasonably be expected to impair the employee’s ability to render unbiased and objective advice. | |||
B.
|
Compensation
|
|
• |
An employee shall inform his or her customers, Clients and employer of compensation or other benefit arrangements in connection with services provided to them, which are in addition to compensation from them
for such services.
|
||
|
• |
An employee shall make proper disclosure to a prospective Client or customer of any consideration paid or other benefit delivered to others for recommending his services to that prospective Client or customer.
|
||
|
• |
An employee shall not undertake independent practice which could result in compensation or other benefit in competition with the Company or its affiliate unless he or she has received written consent from both
his employer and the person for whom he undertakes independent employment.
|
C.
|
Gifts and Entertainment
|
||
|
No employee may accept or offer gifts and/or meals and entertainment from persons or entities that currently or may in the future do business with the Company unless the entertainment is valued at less than
$2,000 per person, per year or the gifts are valued at less than $175 per person, per year. Discretion should be used in accepting invitations for dinners, entertainment, golf outings, sporting events, theater and other events. Under no
circumstances shall any employee accept airfare and/or hotel accommodations from any person or entity doing business with the Company or accept or offer any gifts, favors or gratuities that could be viewed as influencing decision-making or
otherwise could be considered as creating a conflict of interest on the part of the recipient.
|
||
D.
|
Outside Business Activities
|
||
|
No employee may serve on the board of directors or other governing board of any for-profit entity, unless he or she has received the prior written approval of the Company’s CCO. Approval will not be given
unless a determination is made that the employee’s service on the board would be consistent with the interests of the Company’s Clients. Employees shall report all other outside business activities annually on the Annual Outside Activities
Questionnaire submitted via ComplySci as described in the Policy Regarding Compliance Monitoring.
|
||
E.
|
Prohibition on Brokerage for Fund Sales
|
||
|
In accordance with Rule 12b-1(h)(1) promulgated under the Investment Company Act, neither the Company nor any of its affiliates may compensate any broker/dealer for any promotion or sale of a Sub-Advised Mutual
Fund’s shares by directing to the broker/dealer (i) the Sub-Advised Mutual Fund’s portfolio transactions or (ii) any remuneration, including but not limited to any commission, mark-up, mark-down or other fee (or portion thereof) received or
to be received from the Sub-Advised Mutual Fund’s portfolio transactions effected through any other broker/dealer. This policy does not prohibit the Company from executing portfolio transactions through broker/dealers who also promote or sell
the Sub-Advised Mutual Fund’s shares so long as both the following requirements are met:
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• The persons responsible for selecting broker/dealers to effect the Sub-Advised Mutual Fund’s portfolio transactions (“trading responsible personnel”) do not take into account, in making those
decisions, broker/dealers’ promotion or sales of the Sub-Advised Mutual Fund’s shares.
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• The Sub-Advised Mutual Fund, the Company and the Sub-Advised Mutual Fund’s principal underwriter do not enter into any formal or informal written or oral agreement or other understanding under which
the Sub-Advised Mutual Fund or the Company directs, or is expected to direct, brokerage transactions or revenue generated by those transactions to a selling broker/dealer in recognition of the promotion or sale of the Sub-Advised Mutual
Fund’s shares.
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To the extend any of the Company’s employees acquire access to information about the amount of shares of the Sub-Advised Mutual Fund sold by a particular broker/dealer, such employees are prohibited from
sharing such information with the Company’s trading responsible personnel.
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VIII.
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Code Enforcement
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The Chief Compliance Officer and the Company’s compliance department shall:
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A.
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primarily be responsible for administering and enforcing the provisions of this Code.
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B.
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maintain a current list of all Access Persons; supervise, implement and enforce the terms of this Code; provide each Access Person with a current copy of this Code of Ethics and any amendments thereto; notify
each person who becomes an Access Person of the reporting requirements and other obligations under this Code of Ethics at the time such person becomes an Access Person; require each Access Person to submit a signed Certificate of Compliance
with the Code of Ethics attached hereto as EXHIBIT D or submit such certification via ComplySci.
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C.
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determine whether any particular Personal Securities Transactions should be exempted pursuant to the provisions of this Code of Ethics;
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D.
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maintain files of statements and other information to be reviewed for the purpose of monitoring compliance with this Code of Ethics, which information shall be kept confidential by the Company, except as
required to enforce this Code of Ethics, or to participate in any investigation concerning violations of applicable laws;
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E.
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review all Securities Holdings Reports required to be provided by each Access Person pursuant to this Code of Ethics: (a) for each new Access Person, to determine if any conflict of interest or other violation
of this Code of Ethics results from such person becoming an Access Person; and (b) for all Access Persons, to determine whether a violation of this Code of Ethics has occurred;
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F.
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review on a quarterly basis all Securities reported on the Quarterly Securities Transaction Reports required to be provided by each Access Person pursuant to this Code of Ethics for such calendar quarter to
determine whether a Code of Ethics violation may have occurred;
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G.
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review any other statements, records and reports required by this Code of Ethics; and
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H.
|
review on a regular basis and update as necessary, this Code of Ethics.
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||
IX.
|
Violations of this Code of Ethics
|
||
A.
|
If the Chief Compliance Officer determines that a violation of this Code of Ethics has occurred, the Chief Compliance Officer shall prepare a record of explanatory material regarding such violation and shall
immediately take remedial or corrective action in consultation with senior management if necessary. The Chief Compliance
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Officer shall ensure that another employee monitors the CCO’s own Securities holdings and transactions in accordance with the reporting requirements set forth in this policy. | |||
B.
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If the Chief Compliance Officer finds that an Access Person has violated this Code of Ethics, the Chief Compliance Officer will discuss with Senior Management of the Company and potentially impose sanctions
appropriate in view of the facts and circumstances. Sanctions with respect to any Access Person may include written warning, suspension or termination of employment, a letter of censure and/or restitution of an amount equal to the difference
between the price paid or received by the offending Access Person. In addition, the Company reserves the right to require the offending Access Person to reverse, cancel or freeze, at the Access Person’s expense, any transaction or position in
a specific Security if the Company believes the transaction or position violates this Code of Ethics and/or the Company’s general fiduciary duty to its Clients, or otherwise appears improper.
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X.
|
Freedom to Report Violations
|
||
A.
|
All employees, contractors, subcontractors or agents are required to promptly report “apparent” or “suspected” violations in addition to actual or known violations of this Code as well as the overall Manual to
the Company’s CCO. Examples of the types of reporting required include, but are not limited to, noncompliance with applicable laws, rules and regulations; fraud or illegal acts involving any aspect of the operating entity’s business; material
misstatements in regulatory filings, internal books and records, client records or reports; activity that is harmful to clients, including shareholders of any collective investment vehicle; and deviations from required controls and procedures
that safeguard clients and the operating entity. All such reports will be treated confidentially to the extent permitted by law and investigated promptly and appropriately. Retaliation against an individual who reports a violation is
prohibited and constitutes a further violation of this Code. Employees are encouraged to seek advice from the Company’s CCO with respect to any action which may violate the Code.
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B.
|
Any Reporting Person believing a violation is occurring or has occurred is encouraged to report that information to the Company’s CCO. Except as may be required by applicable law, the CCO shall keep the name of
the Reporting Person confidential.
|
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C.
|
Upon receiving information about a suspected violation, the CCO shall undertake a preliminary investigation to determine if the information can be substantiated. Reporting Persons will be kept informed of the
status of the investigation by the CCO. The CCO will report details of the violation to the persons under investigation, appropriate management, and as necessary, other appropriate U.S. federal and state regulatory and law enforcement
authorities.
|
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D.
|
In order to monitor whether the Reporting Person is being subjected to reprisals or retaliation, the CCO shall from time to time contact the Reporting Person to determine whether any changes in the Reporting
Person’s work situation has occurred as a result of providing such information. If the CCO determines that any reprisal or retaliation has occurred, a report of this shall be made to the Management Committee.
|
||
E.
|
Any Reporting Person who feels he or she has been the subject of reprisal or retaliation because of his or her providing information should immediately notify the CCO.
|
F.
|
Any employee who is dissatisfied with the results of any internal investigation initiated because of their report retains their right to report any good faith violation to appropriate U.S. federal and state
regulatory and law enforcement authorities.
|
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G.
|
The Company and its officers, employees, contractors, subcontractors and agents are prohibited from discharging, demoting, suspending, threatening, harassing, or in any other manner discriminating against
Reporting Persons in the terms and conditions of employment because of any lawful act done by Reporting Persons to provide information, cause information to be provided, or otherwise assist in an investigation regarding any conduct which the
Reporting Persons reasonably believes constitutes a violation. Reporting Persons have the option, and are encouraged to report any violation to the CCO with confidentiality. This policy is intended to create an environment where employees can
act without fear of reprisal or retaliation.
|
||
XI.
|
Escalation Procedures
|
||
No employee, including Senior Management, may inappropriately circumvent the Company’s internal controls system, knowingly violate applicable laws, rules and regulations, engage in fraud or illegal acts
involving any aspect of the operating entity’s business, knowingly make material misstatements in regulatory filings, internal books and records, client records or reports or engage in any activity that is knowingly harmful to clients,
including shareholders of any collective investment vehicle. To the extent, any employee engages in any of the aforementioned activities, the following escalation procedures shall apply:
|
|||
A.
|
If the employee suspected of the violation is not a member of Senior Management, then the CCO shall discuss the suspected violation with Senior Management and determine appropriate sanctions if necessary.
|
||
B.
|
If the employee suspected of the violation is a member of Senior Management or the CCO, then the violation shall be reported to the chairman of the Company’s Advisory Board. The Advisory Board shall be
responsible for investigating the suspected violation and determining whether a violation occurred. If the Advisory Board determines that the CCO committed a violation, then the Advisory Board shall determine the appropriate sanctions. If the
Advisory Board determines that a member of Senior Management committed a violation, then the Advisory Board shall determine the appropriate sanctions and, if the Advisory Board deems the violation to be material, report the matter to the
Company’s regulator.
|
||
XII. |
Recordkeeping
|
||
The Company will maintain records in accordance with the Company’s Recordkeeping Policy, and specifically shall maintain:
|
|||
A.
|
a copy of this Code of Ethics and any other preceding Code of Ethics that, at any time within the past 5 years, has been in effect in an easily accessible place;
|
||
B.
|
a record of any Code of Ethics violation and of any sanctions imposed for a period of not less than 5 years following the end of the fiscal year in which the violation occurred, the first 2 years in an easily
accessible place;
|
||
C.
|
a copy of each report made by an Access Person under this Code of Ethics for a period of not less than 5 years from the end of the fiscal year in which it is made, the first 2 years in an easily accessible
place;
|
||
D.
|
a record of all persons who are, or within the past 5 years have been, required to submit reports under this Code of Ethics, or who are or were responsible for reviewing these reports for a period of at least 5
years after the end of the fiscal year in which the report was submitted, the first 2 years in an easily accessible place; and
|
E.
|
record of any decision to approve the acquisition by an Access Person of Pre-Cleared Securities, for a period of at least 5 years after the end of the fiscal year in which the approval is granted, the first 2
years in an easily accessible place.
|
||
F.
|
Copies of all written acknowledgements of the Code of Ethics for all employees shall be submitted in writing or via ComplySci.
|