REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 | [ X ] | |||
Pre-Effective Amendment No. | [ ] | |||
Post-Effective Amendment No. | 76 | [ X ] | ||
and/or | ||||
REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940 | [ X ] | |||
Amendment No. | 78 | [ X ] |
immediately upon filing pursuant to paragraph (b) | |
X | on February 28, 2022 pursuant to paragraph (b) |
60 days after filing pursuant to paragraph (a)(1) | |
on ____________ pursuant to paragraph (a)(1) | |
75 days after filing pursuant to paragraph (a)(2) | |
on ____________ pursuant to paragraph (a)(2) |
this post-effective amendment designates a new effective date for a previously filed post-effective amendment. |
Class A | Class C | Institutional Class | |||
Neuberger Berman Absolute Return Multi-Manager Fund | NABAX | NABCX | NABIX |
Fund Summary | |
| 2 |
| 18 |
| 19 |
| 35 |
| 35 |
| 36 |
| 36 |
| 39 |
Your Investment | |
| 42 |
| 43 |
| 48 |
| 49 |
| 49 |
| 50 |
| 54 |
| 55 |
| 57 |
| 58 |
| 59 |
| 59 |
| 59 |
| 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 | 1.96 | 1.96 | 1.85 |
Distribution and/or shareholder service (12b-1) fees | 0.25 | 1.00 | None |
Total other expenses | 1.11 | 1.11 | 1.09 |
Other expenses | 0.89 | 0.90 | 0.89 |
Dividend and interest expenses relating to short sales | 0.22 | 0.21 | 0.20 |
Acquired fund fees and expenses | 0.03 | 0.03 | 0.03 |
Total annual operating expenses | 3.35 | 4.10 | 2.97 |
Fee waivers and/or expense reimbursement | 0.78 | 0.79 | 0.77 |
Total annual operating expenses after fee waiver and/or expense reimbursement2 | 2.57 | 3.31 | 2.20 |
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 10/31/2025 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 | $820 | $1,329 | $2,018 | $3,845 |
Class C (assuming redemption) | $434 | $1,018 | $1,888 | $4,133 |
Class C (assuming no redemption) | $334 | $1,018 | $1,888 | $4,133 |
Institutional Class | $223 | $688 | $1,347 | $3,113 |
Absolute Return Multi-Manager Fund | 1 Year | 5 Years | Since Inception (5/15/2012) |
Institutional Class Return Before Taxes | 2.18 | 2.64 | 2.28 |
Institutional Class Return After Taxes on Distributions | 2.14 | 2.23 | 1.86 |
Institutional Class Return After Taxes on Distributions and Sale of Fund Shares | 1.32 | 1.88 | 1.61 |
Class A Return Before Taxes | -4.02 | 1.08 | 1.29 |
Class C Return Before Taxes | 0.07 | 1.53 | 1.15 |
HFRX® Global Hedge Fund Index (reflects deductions for fees and expenses, but not taxes) | 3.65 | 3.52 | 2.45 |
S&P 500® Index (reflects no deduction for fees, expenses or taxes) | 28.71 | 18.47 | 16.38 |
Bloomberg U.S. Aggregate Bond Index (reflects no deduction for fees, expenses or taxes) | -1.54 | 3.57 | 2.81 |
After-tax returns are shown for Institutional Class shares only and after-tax returns for other classes may vary. After-tax returns are calculated using the historical highest individual federal marginal income tax rates and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ from those shown. After-tax returns are not relevant to investors who hold their Fund shares through tax-deferred arrangements, such as 401(k) plans or individual retirement accounts. |
(1) | Shows what this ratio would have been if there had been no expense reimbursement/repayment and/or waiver of a portion of the management fee. |
(2) | Would have been lower/higher if the Manager had not reimbursed/recouped certain expenses. |
(3) | Calculated based on the average number of shares outstanding during each fiscal period. |
(4) | Does not include the effect of sales charges. |
YEAR ENDED OCTOBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
PER-SHARE DATA ($) | |||||
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 | 9.78 | 10.24 | 10.06 | 10.20 | 10.03 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | (0.05) | (0.03) | (0.03) | (0.10) | (0.23) |
Net gains (losses)—realized and unrealized | 0.51 | (0.15) | 0.17 | 0.20 | 0.85 |
Subtotal: income (loss) from investment operations | 0.46 | (0.18) | 0.14 | 0.10 | 0.62 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | — | — | 0.27 | 0.07 |
Net capital gain distributions | — | — | — | — | — |
Subtotal: distributions to shareholders | — | — | — | 0.27 | 0.07 |
Equals: | |||||
Share price (NAV) at end of year | 10.24 | 10.06 | 10.20 | 10.03 | 10.58 |
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 | 3.69 | 3.45 | 3.40 | 3.23 | 3.29 |
Net expenses (excluding expenses on securities sold short) — actual | 3.08 | 3.08 | 3.09 | 3.08 | 3.08 |
Gross expenses(1) | 3.82 | 3.65 | 3.71 | 3.82 | 4.07 |
Gross expenses (excluding expenses on securities sold short)(1) | 3.21 | 3.28 | 3.39 | 3.67 | 3.87 |
Net investment income (loss) — actual | (0.53) | (0.24) | (0.33) | (0.98) | (2.24) |
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) | 4.70 | (1.76) | 1.39 | 0.96 | 6.23 |
Net assets at end of year (in millions of dollars) | 17.9 | 11.6 | 7.7 | 4.7 | 3.0 |
Portfolio turnover rate (including securities sold short)(%) | 382 | 194 | 248 | 230 | 296 |
Portfolio turnover rate (excluding securities sold short)(%) | 357 | 179 | 246 | 219 | 308 |
(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 eighth 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. |
Method | Things to know | Instructions |
Sending us a check | Your first investment must be at least $1,000 Additional investments can be as little as $100 We cannot accept cash, money orders, starter checks, cashier’s checks, travelers checks, or other cash equivalents You will be responsible for any losses or fees resulting from a bad check; if necessary, we may sell other shares belonging to you in order to cover these losses All checks must be made out to “Neuberger Berman Funds”; we cannot accept checks made out to you or other parties and signed over to us |
Fill out the application and enclose your check If regular first-class mail, send to: Neuberger Berman Funds P.O. Box 219189 Kansas City, MO 64121-9189 If express delivery, registered mail, or certified mail, send to: Neuberger Berman Funds 430 West 7th Street Suite 219189 Kansas City, MO 64105-1407 |
Wiring money | All wires must be for at least $1,000 | Before wiring any money, call 800-877-9700 for an order confirmation Have your financial institution send your wire to DST Asset Manager Solutions Include your name, the Fund name, your account number and other information as requested |
Exchanging from another fund | All exchanges must be for at least $1,000 Both accounts involved must be registered in the same name, address and taxpayer identification number An exchange order cannot be cancelled or changed once it has been placed |
Call 800-877-9700 to place your order |
By telephone | We do not accept phone orders for a first investment Additional shares will be purchased when your order is received in proper form Not available on retirement accounts |
Call 800-877-9700 to notify us of your purchase Immediately follow up with a wire or electronic transfer |
Setting up systematic investments |
All investments must be at least $100 (and for Institutional Class, in addition to an initial minimum investment of at least $1 million) | Call 800-877-9700 for instructions |
■ | 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 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 7-year anniversary of the purchase date. To the extent that this prospectus elsewhere provides for a waiver with respect to exchanges of Class C shares or conversion of Class C shares following a shorter holding period, that waiver will apply. |
■ | 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). |
■ | Shares purchased through reinvestment of capital gains distributions and dividend reinvestment when purchasing shares of the same fund |
■ | Shares purchased by employees and registered representatives of Baird or its affiliate and their family members as designated by Baird |
■ | Shares purchased from the proceeds of redemptions from another Fund within the fund family, provided (1) the repurchase occurs within 90 days following the redemption, (2) the redemption and purchase occur in the same accounts, and (3) redeemed shares were subject to a front-end or deferred sales charge (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 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 Baird |
■ | Employer-sponsored retirement plans or charitable accounts in a transactional brokerage account at Baird, including 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 sold due to death or disability of the shareholder |
■ | Shares sold as part of a systematic withdrawal plan as described in the Fund’s Prospectus |
■ | Shares bought due to returns 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 age 72 as described in the Fund’s Prospectus |
■ | Shares sold to pay Baird fees but only if the transaction is initiated by Baird |
■ | Shares acquired through a right of reinstatement |
■ | Breakpoints as described in this Prospectus |
■ | Rights of accumulations 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 Baird. Eligible fund family assets not held at Baird may be included in the rights of accumulations calculation only if the shareholder notifies his or her financial advisor about such assets |
■ | Letters of Intent (LOI) allow for breakpoint discounts based on anticipated purchases within a fund family through Baird, over a 13-month period of time |
■ | Breakpoint pricing, otherwise known as volume pricing, at dollar thresholds as described in the prospectus. |
■ | The applicable sales charge on a purchase of Class A shares is determined by taking into account all share classes (except certain money market funds and any assets held in group retirement plans) 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”). If grouping assets as a shareholder, 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 ROA calculation is dependent on the shareholder notifying Edward Jones of such assets at the time of calculation. Money market funds are included only if such shares were sold with a sales charge at the time of purchase or acquired in exchange for shares purchased with a sales charge. |
■ | The employer maintaining a SEP IRA plan and/or SIMPLE IRA plan may elect to establish or change ROA for the IRA accounts associated with the plan to a plan-level grouping as opposed to including all share classes at a shareholder or pricing group level. |
■ | ROA is determined by calculating the higher of cost minus redemptions 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 Edward Jones of such assets at the time of calculation. Purchases made before the LOI is received by Edward Jones are not adjusted under the LOI and will not reduce the sales charge previously paid. Sales charges will be adjusted if LOI is not met. |
■ | If the employer maintaining a SEP IRA plan and/or SIMPLE IRA plan has elected to establish or change ROA for the IRA accounts associated with the plan to a plan-level grouping, LOIs will also be at the plan-level and may only be established by the employer. |
■ | 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 and remains in good standing pursuant to Edward Jones' policies and procedures. |
■ | 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 |
■ | Shares redeemed at the discretion of Edward Jones for Minimum Balances, as described below. |
■ | Initial purchase minimum: $250 |
■ | Subsequent purchase minimum: none |
■ | 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 LOI |
■ | 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 of the same fund. |
■ | 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. |
■ | 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 or through a 529 Plan |
■ | Shares purchased through a OPCO affiliated investment advisory program |
■ | 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 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 Restatement). |
■ | 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 OPCO |
■ | Employees and registered representatives of OPCO 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 |
■ | 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 prospectus |
■ | Shares sold to pay OPCO fees but only if the transaction is initiated by OPCO |
■ | Shares acquired through a right of reinstatement |
■ | Breakpoints as described in this 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 OPCO. Eligible fund family assets not held at OPCO may be included in the ROA calculation only if the shareholder notifies his or her financial advisor about such assets. |
■ | 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 | |
|
2 |
|
18 |
|
19 |
|
35 |
|
35 |
|
36 |
|
36 |
|
39 |
Your Investment | |
|
40 |
|
43 |
|
44 |
|
46 |
|
46 |
|
46 |
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 | 1.75 |
Distribution and/or shareholder service (12b-1) fees | None |
Total other expenses | 1.12 |
Other expenses | 0.92 |
Dividend and interest expenses relating to short sales | 0.20 |
Acquired fund fees and expenses | 0.03 |
Total annual operating expenses | 2.90 |
Fee waivers and/or expense reimbursement | 0.79 |
Total annual operating expenses after fee waiver and/or expense reimbursement1 | 2.11 |
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 1.87% of average net assets. This undertaking lasts until 10/31/2025 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 | $214 | $661 | $1,306 | $3,041 |
Absolute Return Multi-Manager Fund | 1 Year | 5 Years | Since Inception (5/15/2012) |
Return Before Taxes | 2.29 | 2.73 | 2.33 |
Return After Taxes on Distributions | 2.22 | 2.29 | 1.90 |
Return After Taxes on Distributions and Sale of Fund Shares | 1.40 | 1.94 | 1.64 |
HFRX® Global Hedge Fund Index (reflects deductions for fees and expenses, but not taxes) | 3.65 | 3.52 | 2.45 |
S&P 500® Index (reflects no deduction for fees, expenses or taxes) | 28.71 | 18.47 | 16.38 |
Bloomberg U.S. Aggregate Bond Index (reflects no deduction for fees, expenses or taxes) | -1.54 | 3.57 | 2.81 |
After-tax returns are calculated using the historical highest individual federal marginal income tax rates and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ from those shown. After-tax returns are not relevant to investors who hold their Fund shares through tax-deferred arrangements, such as 401(k) plans or individual retirement accounts. |
YEAR ENDED OCTOBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
PER-SHARE DATA ($) | |||||
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 | 10.17 | 10.77 | 10.71 | 10.98 | 10.81 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | 0.05 | 0.10 | 0.09 | 0.01 | (0.14) |
Net gains (losses)—realized and unrealized | 0.55 | (0.16) | 0.19 | 0.21 | 0.94 |
Subtotal: income (loss) from investment operations | 0.60 | (0.06) | 0.28 | 0.22 | 0.80 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | — | 0.01 | 0.39 | 0.20 |
Net capital gain distributions | — | — | — | — | — |
Subtotal: distributions to shareholders | — | — | 0.01 | 0.39 | 0.20 |
Equals: | |||||
Share price (NAV) at end of year | 10.77 | 10.71 | 10.98 | 10.81 | 11.41 |
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 | 2.37 | 2.26 | 2.22 | 2.01 | 2.07 |
Net expenses (excluding expenses on securities sold short)—actual | 1.90 | 1.90 | 1.88 | 1.87 | 1.87 |
Gross expenses(1) | 2.40 | 2.45 | 2.55 | 2.59 | 2.87 |
Gross expenses (excluding expenses on securities sold short)—actual(2) | 1.93 | 2.09 | 2.21 | 2.45 | 2.66 |
Net investment income (loss)—actual | 0.51 | 0.93 | 0.84 | 0.07 | (1.27) |
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) | 5.90 | (0.56) | 2.64 | 2.10 | 7.50 |
Net assets at end of year (in millions of dollars) | 12.7 | 15.3 | 1.4 | 1.6 | 3.6 |
Portfolio turnover rate (including securities sold short)(%) | 382 | 194 | 248 | 230 | 296 |
Portfolio turnover rate (excluding securities sold short)(%) | 357 | 179 | 246 | 219 | 308 |
(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. |
Fund Summary | |
|
2 |
|
17 |
|
18 |
|
34 |
|
34 |
|
35 |
|
35 |
|
39 |
Your Investment | |
|
40 |
|
42 |
|
43 |
|
45 |
|
45 |
|
46 |
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 | 1.70 |
Distribution and/or shareholder service (12b-1) fees | None |
Total other expenses | 1.11 |
Other expenses1 | 0.91 |
Dividend and interest expenses relating to short sales | 0.20 |
Acquired fund fees and expenses | 0.03 |
Total annual operating expenses | 2.84 |
Fee waivers and/or expense reimbursement | 1.70 |
Total annual operating expenses after fee waiver and/or expense reimbursement2 | 1.14 |
1 | “Other expenses” are based on estimated expenses for the current fiscal year; actual expenses may vary. |
2 | Neuberger Berman Investment Advisers LLC (“Manager”) has contractually agreed to waive its management fee for the Fund’s Class E shares. This undertaking lasts until 10/31/2023 and may not be terminated during its term without the consent of the Board of Trustees. |
1 Year | 3 Years | 5 Years | 10 Years | |
Class E | $116 | $719 | $1,348 | $3,043 |
Absolute Return Multi-Manager Fund | 1 Year | 5 Years | Since Inception (5/15/2012) |
Return Before Taxes | 2.18 | 2.64 | 2.28 |
Return After Taxes on Distributions | 2.14 | 2.23 | 1.86 |
Return After Taxes on Distributions and Sale of Fund Shares | 1.32 | 1.88 | 1.61 |
HFRX® Global Hedge Fund Index (reflects deductions for fees and expenses, but not taxes) | 3.65 | 3.52 | 2.45 |
S&P 500® Index (reflects no deduction for fees, expenses or taxes) | 28.71 | 18.47 | 16.38 |
Bloomberg U.S. Aggregate Bond Index (reflects no deduction for fees, expenses or taxes) | -1.54 | 3.57 | 2.81 |
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. |
(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. |
■ | 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 your 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 your 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 your 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 U.S. Equity Index PutWrite Strategy Fund | NUPAX | NUPCX | NUPIX |
Fund Summaries | |
|
2 |
|
13 |
|
27 |
|
38 |
|
47 |
|
48 |
|
66 |
|
68 |
|
69 |
|
73 |
Your Investment | |
|
85 |
|
86 |
|
91 |
|
92 |
|
93 |
|
94 |
|
97 |
|
99 |
|
101 |
|
102 |
|
103 |
|
103 |
|
103 |
|
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 | 1.21 | 0.34 |
Other expenses of Fund | 0.26 | 1.11 | 0.24 |
Other expenses of Subsidiary | 0.10 | 0.10 | 0.10 |
Total annual operating expenses | 1.37 | 2.97 | 0.99 |
Fee waiver and/or expense reimbursement | 0.27 | 1.11 | 0.25 |
Total annual operating expenses after fee waiver and/or expense reimbursement2 | 1.10 | 1.86 | 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 10/31/2025 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) | $289 | $585 | $1,250 | $3,034 |
Class C (assuming no redemption) | $189 | $585 | $1,250 | $3,034 |
Institutional Class | $76 | $237 | $470 | $1,141 |
Commodity Strategy Fund | 1 Year | 5 Years | Since Inception (8/27/2012) |
Institutional Class Return Before Taxes | 29.80 | 6.44 | -1.86 |
Institutional Class Return After Taxes on Distributions | 11.78 | 2.55 | -3.79 |
Institutional Class Return After Taxes on Distributions and Sale of Fund Shares | 17.41 | 3.30 | -2.18 |
Class A Return Before Taxes | 21.87 | 4.82 | -2.83 |
Class C Return Before Taxes | 28.00 | 6.28 | -1.94 |
Bloomberg Commodity Index (reflects no deduction for fees, expenses or taxes) | 27.11 | 3.66 | -3.39 |
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 |
Other expenses2 | 3.76 | 3.77 | 3.70 |
Acquired fund fees and expenses2 | 0.02 | 0.02 | 0.02 |
Total annual operating expenses | 4.84 | 5.60 | 4.42 |
Fee waiver and/or expense reimbursement | 3.70 | 3.71 | 3.64 |
Total annual operating expenses after fee waiver and/or expense reimbursement3 | 1.14 | 1.89 | 0.78 |
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. |
2 | “Other expenses” and “Acquired fund fees and expenses” have been restated and are based on estimated expenses for the current fiscal year. Actual expenses may vary. |
3 | 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 10/31/2025 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. |
1 Year | 3 Years | 5 Years | 10 Years | |
Class A | $685 | $916 | $1,940 | $4,514 |
Class C (assuming redemption) | $292 | $594 | $1,814 | $4,802 |
Class C (assuming no redemption) | $192 | $594 | $1,814 | $4,802 |
Institutional Class | $80 | $249 | $1,256 | $3,824 |
Global Allocation Fund | 1 Year | 5 Years | 10 Years |
Institutional Class Return Before Taxes | 13.95 | 9.74 | 7.23 |
Institutional Class Return After Taxes on Distributions | 9.26 | 7.78 | 5.71 |
Institutional Class Return After Taxes on Distributions and Sale of Fund Shares | 9.61 | 7.06 | 5.21 |
Class A Return Before Taxes | 7.00 | 8.06 | 6.22 |
Class C Return Before Taxes | 11.76 | 8.53 | 6.05 |
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 Global Aggregate Index (reflects no deduction for fees, expenses or taxes) | 8.78 | 10.11 | 7.91 |
MSCI All Country World Index (Net) (reflects reinvested dividends net of withholding taxes, but reflects no deduction for fees, expenses or taxes) | 18.54 | 14.40 | 11.85 |
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 | 1.35 | 1.35 | 1.24 |
Distribution and/or shareholder service (12b-1) fees | 0.25 | 1.00 | None |
Total other expenses | 0.36 | 0.36 | 0.36 |
Other expenses | 0.05 | 0.05 | 0.05 |
Dividend and interest expenses relating to short sales | 0.31 | 0.31 | 0.31 |
Total annual operating expenses | 1.96 | 2.71 | 1.60 |
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 | $763 | $1,155 | $1,571 | $2,729 |
Class C (assuming redemption) | $374 | $841 | $1,435 | $3,041 |
Class C (assuming no redemption) | $274 | $841 | $1,435 | $3,041 |
Institutional Class | $163 | $505 | $871 | $1,900 |
Long Short Fund | 1 Year | 5 Years | 10 Years |
Institutional Class Return Before Taxes | 9.00 | 9.22 | 7.41 |
Institutional Class Return After Taxes on Distributions | 8.71 | 8.63 | 7.07 |
Institutional Class Return After Taxes on Distributions and Sale of Fund Shares | 5.53 | 7.19 | 5.95 |
Class A Return Before Taxes | 2.43 | 7.55 | 6.40 |
Class C Return Before Taxes | 6.75 | 8.02 | 6.23 |
HFRX® Equity Hedge Index (reflects deductions for fees and expenses, but reflects no deduction for taxes) | 12.14 | 5.29 | 4.10 |
S&P 500® Index (reflects no deduction for fees, expenses or taxes) | 28.71 | 18.47 | 16.55 |
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 | 0.71 | 0.71 | 0.60 |
Distribution and/or shareholder service (12b-1) fees | 0.25 | 1.00 | None |
Other expenses | 0.11 | 0.15 | 0.10 |
Total annual operating expenses | 1.07 | 1.86 | 0.70 |
Fee waiver and/or expense reimbursement | 0.05 | 0.09 | 0.04 |
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 10/31/2025 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 | $1,117 | $1,792 |
Class C (assuming redemption) | $280 | $557 | $979 | $2,156 |
Class C (assuming no redemption) | $180 | $557 | $979 | $2,156 |
Institutional Class | $67 | $211 | $377 | $859 |
U.S. Equity Index PutWrite Strategy Fund | 1 Year | 5 Years | Since Inception (9/16/2016) |
Institutional Class Return Before Taxes | 18.21 | 9.30 | 9.56 |
Institutional Class Return After Taxes on Distributions | 12.03 | 7.11 | 7.47 |
Institutional Class Return After Taxes on Distributions and Sale of Fund Shares | 12.51 | 6.58 | 6.84 |
Class A Return Before Taxes | 10.91 | 7.61 | 7.95 |
Class C Return Before Taxes | 15.86 | 8.08 | 8.35 |
50% Cboe S&P 500 One-Week PutWrite Index/50% Cboe S&P 500 PutWrite Index (reflects no deduction for fees, expenses or taxes)* | 16.87 | 5.48 | 5.90 |
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) | 15.69 | 4.53 | 4.98 |
S&P 500® Index (reflects no deduction for fees, expenses or taxes) | 28.71 | 18.47 | 18.42 |
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. |
* | On February 28, 2022, the Fund began comparing its performance to the 50% Cboe S&P 500 One-Week PutWrite Index/50% Cboe S&P 500 PutWrite Index rather than the 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 because the 50% Cboe S&P 500 One-Week PutWrite Index/50% Cboe S&P 500 PutWrite Index has characteristics that are more representative of the Fund’s investment strategy than its previous index. |
YEAR ENDED OCTOBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
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 | 5.90 | 6.24 | 6.07 | 5.89 | 4.99 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | — | 0.06 | 0.09 | 0.02 | (0.05) |
Net gains (losses)—realized and unrealized | 0.34 | (0.01) | (0.14) | (0.85) | 2.72 |
Subtotal: income (loss) from investment operations | 0.34 | 0.05 | (0.05) | (0.83) | 2.67 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | 0.22 | 0.13 | 0.07 | 0.02 |
Subtotal: distributions to shareholders | — | 0.22 | 0.13 | 0.07 | 0.02 |
Equals: | |||||
Share price (NAV) at end of year | 6.24 | 6.07 | 5.89 | 4.99 | 7.64 |
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 | 1.21 | 1.10 | 1.09 | 1.10 | 1.10 |
Gross expenses(1) | 1.56 | 1.35 | 1.37 | 1.36 | 1.37 |
Net investment income (loss)—actual | (0.02) | 0.95 | 1.65 | 0.34 | (0.72) |
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) | 5.76 | 0.81 | (0.64) | (14.29) | 53.60 |
Net assets at end of year (in millions of dollars) | 42.4 | 47.9 | 22.5 | 18.4 | 26.7 |
Portfolio turnover rate (%) | 105 | 107 | 88 | 109 | 56 |
(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, | 2017 | 2018 | 2019 | 2020 | 2021(5) |
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 | 5.71 | 5.95 | 5.83 | 5.66 | 6.26 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | (0.05) | 0.01 | 0.05 | (0.01) | (0.07) |
Net gains (losses)—realized and unrealized | 0.29 | — | (0.14) | (0.84) | 1.43 |
Subtotal: income (loss) from investment operations | 0.24 | 0.01 | (0.09) | (0.85) | 1.36 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | 0.13 | 0.08 | 0.03 | — |
Subtotal: distributions to shareholders | — | 0.13 | 0.08 | 0.03 | — |
Equals: | |||||
Share price (NAV) at end of year | 5.95 | 5.83 | 5.66 | 4.78 | 7.62 |
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 | 2.03 | 1.85 | 1.84 | 1.86 | 1.86 |
Gross expenses(1) | 3.20 | 2.34 | 2.32 | 2.31 | 2.97 |
Net investment income (loss)—actual | (0.92) | 0.19 | 0.88 | (0.23) | (1.55) |
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) | 4.20 | 0.15 | (1.51) | (15.05) | 21.73 |
Net assets at end of year (in millions of dollars) | 0.0 | 0.0 | 0.0 | 0.0 | 0.0 |
Portfolio turnover rate (%) | 105 | 107 | 88 | 109 | 56 |
(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. |
(5) | Class C shares were fully redeemed on February 2, 2021. Operations recommenced on March 24, 2021. The Financial highlights presented are only for the period after commencement of operations. |
YEAR ENDED OCTOBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
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 | 5.99 | 6.36 | 6.19 | 6.00 | 5.08 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | 0.02 | 0.08 | 0.12 | 0.04 | (0.02) |
Net gains (losses)—realized and unrealized | 0.35 | (0.01) | (0.16) | (0.86) | 2.77 |
Subtotal: income (loss) from investment operations | 0.37 | 0.07 | (0.04) | (0.82) | 2.75 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | 0.24 | 0.15 | 0.10 | 0.03 |
Subtotal: distributions to shareholders | — | 0.24 | 0.15 | 0.10 | 0.03 |
Equals: | |||||
Share price (NAV) at end of year | 6.36 | 6.19 | 6.00 | 5.08 | 7.80 |
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 | 0.85 | 0.74 | 0.74 | 0.74 | 0.74 |
Gross expenses(1) | 1.18 | 0.98 | 0.96 | 0.99 | 0.99 |
Net investment income (loss)—actual | 0.36 | 1.31 | 1.99 | 0.74 | (0.36) |
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) | 6.18 | 1.19 | (0.41) | (13.98) | 54.44 |
Net assets at end of year (in millions of dollars) | 83.1 | 100.3 | 145.3 | 89.4 | 147.4 |
Portfolio turnover rate (%) | 105 | 107 | 88 | 109 | 56 |
(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, | 2017 | 2018 | 2019 | 2020 | 2021 |
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 | 10.40 | 12.04 | 11.05 | 11.55 | 11.33 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | 0.14 | 0.20 | 0.20 | 0.19 | 0.11 |
Net gains (losses)—realized and unrealized | 1.50 | (0.59) | 0.79 | (0.09) | 2.67 |
Subtotal: income (loss) from investment operations | 1.64 | (0.39) | 0.99 | 0.10 | 2.78 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | 0.18 | 0.20 | 0.18 | 0.19 |
Net capital gains | — | 0.42 | 0.29 | 0.14 | — |
Subtotal: distributions to shareholders | — | 0.60 | 0.49 | 0.32 | 0.19 |
Equals: | |||||
Share price (NAV) at end of year | 12.04 | 11.05 | 11.55 | 11.33 | 13.92 |
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 | 0.89 | 0.82 | 0.84 | 0.91 | 1.07 |
Net expenses (excluding expenses on securities sold short)—actual | 0.84 | 0.82 | 0.84 | 0.91 | 1.07 |
Gross expenses(1) | 4.10 | 3.46 | 3.74 | 4.24 | 4.82 |
Gross expenses (excluding expenses on securities sold short)(1) | 4.05 | 3.46 | 3.74 | 4.24 | 4.82 |
Net investment income (loss)—actual | 1.27 | 1.70 | 1.79 | 1.72 | 0.86 |
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) | 15.77 | (3.49) | 9.70 | 0.82 | 24.74 |
Net assets at end of year (in millions of dollars) | 3.9 | 2.8 | 2.1 | 1.2 | 1.3 |
Portfolio turnover rate (including securities sold short)(%) | 113(5) | 59(5) | 74(5) | 74(5) | 138 |
Portfolio turnover rate (excluding securities sold short)(%) | 101(5) | 59(5) | 74(5) | 74(5) | 138 |
(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 TBA roll transactions, including and excluding securities sold short, were 176% and 176%, respectively, for the year ended October 31, 2020, 159%, and 159%, respectively, for the year ended October 31, 2019, 129% and 129%, respectively, for the year ended October 31, 2018, and 165% and 154%, respectively, for the year ended October 31, 2017. |
YEAR ENDED OCTOBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
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 | 10.14 | 11.66 | 10.70 | 11.20 | 10.97 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | 0.05 | 0.11 | 0.11 | 0.10 | 0.02 |
Net gains (losses)—realized and unrealized | 1.47 | (0.58) | 0.79 | (0.09) | 2.58 |
Subtotal: income (loss) from investment operations | 1.52 | (0.47) | 0.90 | 0.01 | 2.60 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | 0.07 | 0.11 | 0.10 | 0.11 |
Net capital gains | — | 0.42 | 0.29 | 0.14 | — |
Subtotal: distributions to shareholders | — | 0.49 | 0.40 | 0.24 | 0.11 |
Equals: | |||||
Share price (NAV) at end of year | 11.66 | 10.70 | 11.20 | 10.97 | 13.46 |
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 | 1.63 | 1.57 | 1.59 | 1.66 | 1.81 |
Net expenses (excluding expenses on securities sold short)—actual | 1.59 | 1.57 | 1.59 | 1.66 | 1.81 |
Gross expenses(1) | 4.84 | 4.18 | 4.47 | 4.99 | 5.58 |
Gross expenses (excluding expenses on securities sold short)(1) | 4.79 | 4.18 | 4.47 | 4.99 | 5.58 |
Net investment income (loss)—actual | 0.50 | 0.92 | 1.01 | 0.89 | 0.12 |
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) | 14.99 | (4.25) | 8.97 | 0.01 | 23.84 |
Net assets at end of year (in millions of dollars) | 3.2 | 2.3 | 1.8 | 1.5 | 1.0 |
Portfolio turnover rate (including securities sold short)(%) | 113(5) | 59(5) | 74(5) | 74(5) | 138 |
Portfolio turnover rate (excluding securities sold short)(%) | 101(5) | 59(5) | 74(5) | 74(5) | 138 |
(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 TBA roll transactions, including and excluding securities sold short, were 176% and 176%, respectively, for the year ended October 31, 2020, 159%, and 159%, respectively, for the year ended October 31, 2019, 129% and 129%, respectively, for the year ended October 31, 2018, and 165% and 154%, respectively, for the year ended October 31, 2017. |
YEAR ENDED OCTOBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
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 | 10.49 | 12.14 | 11.15 | 11.65 | 11.42 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | 0.18 | 0.23 | 0.24 | 0.23 | 0.16 |
Net gains (losses)—realized and unrealized | 1.52 | (0.58) | 0.80 | (0.09) | 2.69 |
Subtotal: income (loss) from investment operations | 1.70 | (0.35) | 1.04 | 0.14 | 2.85 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | 0.05 | 0.22 | 0.25 | 0.23 | 0.23 |
Net capital gains | — | 0.42 | 0.29 | 0.14 | — |
Subtotal: distributions to shareholders | 0.05 | 0.64 | 0.54 | 0.37 | 0.23 |
Equals: | |||||
Share price (NAV) at end of year | 12.14 | 11.15 | 11.65 | 11.42 | 14.04 |
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 | 0.49 | 0.46 | 0.49 | 0.55 | 0.72 |
Net expenses (excluding expenses on securities sold short)—actual | 0.46 | 0.46 | 0.49 | 0.55 | 0.72 |
Gross expenses(1) | 3.59 | 3.04 | 3.35 | 3.86 | 4.40 |
Gross expenses (excluding expenses on securities sold short)(1) | 3.56 | 3.04 | 3.35 | 3.86 | 4.40 |
Net investment income (loss)—actual | 1.63 | 1.96 | 2.12 | 2.04 | 1.21 |
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) | 16.24 | (3.14) | 10.13 | 1.14 | 25.21 |
Net assets at end of year (in millions of dollars) | 13.9 | 13.8 | 12.0 | 7.1 | 8.7 |
Portfolio turnover rate (including securities sold short)(%) | 113(4) | 59(4) | 74(4) | 74(4) | 138 |
Portfolio turnover rate (excluding securities sold short)(%) | 101(4) | 59(4) | 74(4) | 74(4) | 138 |
(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 TBA roll transactions, including and excluding securities sold short, were 176% and 176%, respectively, for the year ended October 31, 2020, 159%, and 159%, respectively, for the year ended October 31, 2019, 129% and 129%, respectively, for the year ended October 31, 2018, and 165% and 154%, respectively, for the year ended October 31, 2017. |
YEAR ENDED OCTOBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
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 | 12.83 | 14.26 | 14.54 | 14.61 | 15.88 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | (0.02) | (0.02) | (0.01) | (0.07) | (0.08) |
Net gains (losses)—realized and unrealized | 1.45 | 0.30 | 0.84 | 1.69 | 2.56 |
Subtotal: income (loss) from investment operations | 1.43 | 0.28 | 0.83 | 1.62 | 2.48 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | — | — | — | — |
Capital gain distributions | — | — | 0.76 | 0.35 | 0.36 |
Subtotal: distributions to shareholders | — | — | 0.76 | 0.35 | 0.36 |
Equals: | |||||
Share price (NAV) at end of year | 14.26 | 14.54 | 14.61 | 15.88 | 18.00 |
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 | 2.16 | 1.96 | 2.13 | 2.15 | 1.96 |
Net expenses (excluding expenses on securities sold short)—actual | 1.68 | 1.67 | 1.69 | 1.67 | 1.64 |
Gross expenses | 2.16(1) | 1.96 | 2.13 | 2.15 | 1.96 |
Gross expenses (excluding expenses on securities sold short) | 1.68(1) | 1.67 | 1.69 | 1.67 | 1.64 |
Net investment income (loss)—actual | (0.18) | (0.13) | (0.08) | (0.43) | (0.46) |
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 (%)(4) | 11.15(2) | 2.01 | 6.54 | 11.31 | 15.82 |
Net assets at end of year (in millions of dollars) | 145.6 | 105.9 | 63.6 | 95.6 | 158.9 |
Portfolio turnover rate (including securities sold short)(%) | 80 | 83 | 66 | 81 | 60 |
Portfolio turnover rate (excluding securities sold short)(%) | 64 | 69 | 47 | 60 | 49 |
(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, | 2017 | 2018 | 2019 | 2020 | 2021 |
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 | 13.00 | 14.34 | 14.53 | 14.49 | 15.62 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | (0.13) | (0.13) | (0.12) | (0.17) | (0.20) |
Net gains (losses)—realized and unrealized | 1.47 | 0.32 | 0.84 | 1.65 | 2.51 |
Subtotal: income (loss) from investment operations | 1.34 | 0.19 | 0.72 | 1.48 | 2.31 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | — | — | — | — |
Capital gain distributions | — | — | 0.76 | 0.35 | 0.36 |
Subtotal: distributions to shareholders | — | — | 0.76 | 0.35 | 0.36 |
Equals: | |||||
Share price (NAV) at end of year | 14.34 | 14.53 | 14.49 | 15.62 | 17.57 |
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 | 2.90 | 2.71 | 2.88 | 2.90 | 2.71 |
Net expenses (excluding expenses on securities sold short)—actual | 2.43 | 2.42 | 2.44 | 2.41 | 2.39 |
Gross expenses | 2.90(1) | 2.71 | 2.88 | 2.90 | 2.71 |
Gross expenses (excluding expenses on securities sold short)—actual | 2.43(1) | 2.42 | 2.44 | 2.41 | 2.39 |
Net investment income (loss)—actual | (0.94) | (0.88) | (0.82) | (1.14) | (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 (%)(2)(4) | 10.31 | 1.27 | 5.79 | 10.42 | 14.98 |
Net assets at end of year (in millions of dollars) | 92.7 | 77.6 | 61.4 | 55.3 | 57.1 |
Portfolio turnover rate (including securities sold short)(%) | 80 | 83 | 66 | 81 | 60 |
Portfolio turnover rate (excluding securities sold short)(%) | 64 | 69 | 47 | 60 | 49 |
(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, | 2017 | 2018 | 2019 | 2020 | 2021 |
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 | 12.74 | 14.21 | 14.54 | 14.67 | 16.00 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | 0.02 | 0.03 | 0.04 | (0.01) | (0.02) |
Net gains (losses)—realized and unrealized | 1.45 | 0.30 | 0.85 | 1.69 | 2.59 |
Subtotal: income (loss) from investment operations | 1.47 | 0.33 | 0.89 | 1.68 | 2.57 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | — | — | — | — |
Capital gain distributions | — | — | 0.76 | 0.35 | 0.36 |
Subtotal: distributions to shareholders | — | — | 0.76 | 0.35 | 0.36 |
Equals: | |||||
Share price (NAV) at end of year | 14.21 | 14.54 | 14.67 | 16.00 | 18.21 |
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 | 1.80 | 1.60 | 1.78 | 1.80 | 1.59 |
Net expenses (excluding expenses on securities sold short)—actual | 1.32 | 1.31 | 1.33 | 1.30 | 1.28 |
Gross expenses | 1.80(1) | 1.60 | 1.78 | 1.80 | 1.59 |
Gross expenses (excluding expenses on securities sold short)—actual | 1.33(1) | 1.31 | 1.33 | 1.30 | 1.28 |
Net investment income (loss)—actual | 0.12 | 0.23 | 0.28 | (0.08) | (0.10) |
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) | 11.54 | 2.32 | 6.98 | 11.68 | 16.27 |
Net assets at end of year (in millions of dollars) | 2,853.0 | 2,847.3 | 2,098.0 | 3,631.6 | 5,191.6 |
Portfolio turnover rate (including securities sold short)(%) | 80 | 83 | 66 | 81 | 60 |
Portfolio turnover rate (excluding securities sold short)(%) | 64 | 69 | 47 | 60 | 49 |
(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, | 2017 | 2018 | 2019 | 2020 | 2021 |
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 | 10.09 | 11.33 | 10.64 | 11.27 | 10.91 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | 0.01 | 0.11 | 0.14 | 0.12 | (0.03) |
Net gains (losses)—realized and unrealized | 1.27 | (0.16) | 0.66 | 0.07 | 2.91 |
Subtotal: income from investment operations | 1.28 | (0.05) | 0.80 | 0.19 | 2.88 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | 0.01 | 0.05 | 0.17 | 0.12 | 0.00 |
Capital gain distributions | 0.03 | 0.59 | — | 0.43 | — |
Subtotal: distributions to shareholders | 0.04 | 0.64 | 0.17 | 0.55 | 0.00 |
Equals: | |||||
Share price (NAV) at end of year | 11.33 | 10.64 | 11.27 | 10.91 | 13.79 |
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 | 1.01 | 1.01 | 1.01 | 1.02 | 1.01 |
Gross expenses(1) | 1.35 | 1.11 | 1.12 | 1.11 | 1.07 |
Net investment income (loss)—actual | 0.13 | 0.97 | 1.30 | 1.08 | (0.27) |
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) | 12.70 | (0.55) | 7.63 | 1.71 | 26.40 |
Net assets at end of year (in millions of dollars) | 4.1 | 18.4 | 30.7 | 4.4 | 5.7 |
Portfolio turnover rate (%) | 0 | 56 | 31 | 41 | 38 |
(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 the fiscal period. |
(4) | Does not include the effect of sales charges. |
YEAR ENDED OCTOBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
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 | 10.08 | 11.24 | 10.51 | 11.14 | 10.78 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | (0.07) | 0.00 | 0.06 | 0.02 | (0.13) |
Net gains (losses)—realized and unrealized | 1.26 | (0.13) | 0.65 | 0.09 | 2.88 |
Subtotal: income from investment operations | 1.19 | (0.13) | 0.71 | 0.11 | 2.75 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | — | 0.01 | 0.08 | 0.04 | — |
Capital gain distributions | 0.03 | 0.59 | — | 0.43 | — |
Subtotal: distributions to shareholders | 0.03 | 0.60 | 0.08 | 0.47 | 2.75 |
Equals: | |||||
Share price (NAV) at end of year | 11.24 | 10.51 | 11.14 | 10.78 | 13.53 |
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 | 1.76 | 1.76 | 1.76 | 1.77 | 1.76 |
Gross expenses(1) | 2.12 | 1.89 | 1.92 | 1.89 | 1.85 |
Net investment income (loss)—actual | (0.63) | (0.04) | 0.54 | 0.22 | (1.04) |
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) | 11.81 | (1.30) | 6.86 | 1.00 | 25.51 |
Net assets at end of year (in millions of dollars) | 0.5 | 1.2 | 1.0 | 0.8 | 1.2 |
Portfolio turnover rate (%) | 0 | 56 | 31 | 41 | 38 |
(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 the fiscal period. |
(4) | Does not include the effect of sales charges. |
YEAR ENDED OCTOBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
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 period | 10.09 | 11.33 | 10.65 | 11.28 | 10.93 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | 0.05 | 0.12 | 0.18 | 0.14 | 0.01 |
Net gains (losses)—realized and unrealized | 1.26 | (0.13) | 0.66 | 0.10 | 2.92 |
Subtotal: income from investment operations | 1.31 | (0.01) | 0.84 | 0.24 | 2.93 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | 0.04 | 0.08 | 0.21 | 0.16 | 0.01 |
Capital gain distributions | 0.03 | 0.59 | — | 0.43 | 0.01 |
Subtotal: distributions to shareholders | 0.07 | 0.67 | 0.21 | 0.59 | 0.02 |
Equals: | |||||
Share price (NAV) at end of year | 11.33 | 10.65 | 11.28 | 10.93 | 13.84 |
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 | 0.65 | 0.65 | 0.65 | 0.66 | 0.65 |
Gross expenses(1) | 0.98 | 0.74 | 0.76 | 0.74 | 0.69 |
Net investment income (loss)—actual | 0.49 | 1.09 | 1.65 | 1.31 | 0.09 |
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) | 13.05 | (0.16) | 7.99 | 2.22 | 26.82 |
Net assets at end of year (in millions of dollars) | 152.0 | 217.6 | 236.8 | 235.6 | 287.2 |
Portfolio turnover rate (%) | 0 | 56 | 31 | 41 | 38 |
(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 the 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% for all Funds. (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 eighth 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 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. |
Method | Things to know | Instructions |
Sending us a check | Your first investment must be at least $1,000 Additional investments can be as little as $100 We cannot accept cash, money orders, starter checks, cashier’s checks, travelers checks, or other cash equivalents You will be responsible for any losses or fees resulting from a bad check; if necessary, we may sell other shares belonging to you in order to cover these losses All checks must be made out to “Neuberger Berman Funds”; we cannot accept checks made out to you or other parties and signed over to us |
Fill out the application and enclose your check If regular first-class mail, send to: Neuberger Berman Funds P.O. Box 219189 Kansas City, MO 64121-9189 If express delivery, registered mail, or certified mail, send to: Neuberger Berman Funds 430 West 7th Street Suite 219189 Kansas City, MO 64105-1407 |
Wiring money | All wires must be for at least $1,000 | Before wiring any money, call 800-877-9700 for an order confirmation Have your financial institution send your wire to DST Asset Manager Solutions Include your name, the Fund name, your account number and other information as requested |
Exchanging from another fund | All exchanges must be for at least $1,000 Both accounts involved must be registered in the same name, address and taxpayer identification number An exchange order cannot be cancelled or changed once it has been placed |
Call 800-877-9700 to place your order |
By telephone | We do not accept phone orders for a first investment Additional shares will be purchased when your order is received in proper form Not available on retirement accounts |
Call 800-877-9700 to notify us of your purchase Immediately follow up with a wire or electronic transfer |
Setting up systematic investments |
All investments must be at least $100 (and for Institutional Class, in addition to an initial minimum investment of at least $1 million) | Call 800-877-9700 for instructions |
■ | 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 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 7-year anniversary of the purchase date. To the extent that this prospectus elsewhere provides for a waiver with respect to exchanges of Class C shares or conversion of Class C shares following a shorter holding period, that waiver will apply. |
■ | 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). |
■ | Shares purchased through reinvestment of capital gains distributions and dividend reinvestment when purchasing shares of the same fund |
■ | Shares purchased by employees and registered representatives of Baird or its affiliate and their family members as designated by Baird |
■ | Shares purchased from the proceeds of redemptions from another Fund within the fund family, provided (1) the repurchase occurs within 90 days following the redemption, (2) the redemption and purchase occur in the same accounts, and (3) redeemed shares were subject to a front-end or deferred sales charge (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 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 Baird |
■ | Employer-sponsored retirement plans or charitable accounts in a transactional brokerage account at Baird, including 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 sold due to death or disability of the shareholder |
■ | Shares sold as part of a systematic withdrawal plan as described in the Fund’s Prospectus |
■ | Shares bought due to returns 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 age 72 as described in the Fund’s Prospectus |
■ | Shares sold to pay Baird fees but only if the transaction is initiated by Baird |
■ | Shares acquired through a right of reinstatement |
■ | Breakpoints as described in this Prospectus |
■ | Rights of accumulations 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 Baird. Eligible fund family assets not held at Baird may be included in the rights of accumulations calculation only if the shareholder notifies his or her financial advisor about such assets |
■ | Letters of Intent (LOI) allow for breakpoint discounts based on anticipated purchases within a fund family through Baird, over a 13-month period of time |
■ | Breakpoint pricing, otherwise known as volume pricing, at dollar thresholds as described in the prospectus. |
■ | The applicable sales charge on a purchase of Class A shares is determined by taking into account all share classes (except certain money market funds and any assets held in group retirement plans) 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”). If grouping assets as a shareholder, 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 ROA calculation is dependent on the shareholder notifying Edward Jones of such assets at the time of calculation. Money market funds are included only if such shares were sold with a sales charge at the time of purchase or acquired in exchange for shares purchased with a sales charge. |
■ | The employer maintaining a SEP IRA plan and/or SIMPLE IRA plan may elect to establish or change ROA for the IRA accounts associated with the plan to a plan-level grouping as opposed to including all share classes at a shareholder or pricing group level. |
■ | ROA is determined by calculating the higher of cost minus redemptions 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 Edward Jones of such assets at the time of calculation. Purchases made before the LOI is received by Edward Jones are not adjusted under the LOI and will not reduce the sales charge previously paid. Sales charges will be adjusted if LOI is not met. |
■ | If the employer maintaining a SEP IRA plan and/or SIMPLE IRA plan has elected to establish or change ROA for the IRA accounts associated with the plan to a plan-level grouping, LOIs will also be at the plan-level and may only be established by the employer. |
■ | 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 and remains in good standing pursuant to Edward Jones' policies and procedures. |
■ | 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 |
■ | Shares redeemed at the discretion of Edward Jones for Minimum Balances, as described below. |
■ | Initial purchase minimum: $250 |
■ | Subsequent purchase minimum: none |
■ | 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 LOI |
■ | 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 of the same fund. |
■ | 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. |
■ | 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 or through a 529 Plan |
■ | Shares purchased through a OPCO affiliated investment advisory program |
■ | 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 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 Restatement). |
■ | 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 OPCO |
■ | Employees and registered representatives of OPCO 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 |
■ | 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 prospectus |
■ | Shares sold to pay OPCO fees but only if the transaction is initiated by OPCO |
■ | Shares acquired through a right of reinstatement |
■ | Breakpoints as described in this 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 OPCO. Eligible fund family assets not held at OPCO may be included in the ROA calculation only if the shareholder notifies his or her financial advisor about such assets. |
■ | 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 U.S. Equity Index PutWrite Strategy Fund | NUPRX |
Fund Summaries | |
|
2 |
|
15 |
|
24 |
|
25 |
|
41 |
|
42 |
|
43 |
|
45 |
Your Investment | |
|
47 |
|
50 |
|
51 |
|
53 |
|
53 |
|
53 |
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 expenses1 | 4.12 |
Acquired fund fees and expenses1 | 0.02 |
Total annual operating expenses | 4.74 |
Fee waiver and/or expense reimbursement | 4.06 |
Total annual operating expenses after fee waiver and/or expense reimbursement2 | 0.68 |
1 | “Other expenses” and “Acquired fund fees and expenses” have been restated and are based on estimated expenses for the current fiscal year. Actual expenses may vary. |
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 0.65% of average net assets. This undertaking lasts until 10/31/2025 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. |
1 Year | 3 Years | 5 Years | 10 Years | |
Class R6 | $69 | $218 | $1,297 | $4,019 |
Global Allocation Fund | 1 Year | 5 Years | 10 Years |
Return Before Taxes | 14.05 | 9.80 | 7.26 |
Return After Taxes on Distributions | 9.32 | 7.82 | 5.73 |
Return After Taxes on Distributions and Sale of Fund Shares | 9.68 | 7.10 | 5.23 |
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 Global Aggregate Index (reflects no deduction for fees, expenses or taxes) | 8.78 | 10.11 | 7.91 |
MSCI All Country World Index (Net) (reflects reinvested dividends net of withholding taxes, but reflects no deduction for fees, expenses or taxes) | 18.54 | 14.40 | 11.85 |
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 | 0.10 |
Total annual operating expenses | 0.60 |
Fee waiver and/or expense reimbursement | 0.04 |
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 10/31/2025 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 | $322 | $738 |
U.S. Equity Index PutWrite Strategy Fund | 1 Year | 5 Years | Since Inception (9/16/2016) |
Return Before Taxes | 18.23 | 9.39 | 9.65 |
Return After Taxes on Distributions | 12.05 | 7.17 | 7.52 |
Return After Taxes on Distributions and Sale of Fund Shares | 12.53 | 6.63 | 6.89 |
50% Cboe S&P 500 One-Week PutWrite Index/50% Cboe S&P 500 PutWrite Index (reflects no deduction for fees, expenses or taxes)* | 16.87 | 5.48 | 5.90 |
42.5% Cboe S&P 500 One-Week PutWrite Index/42.5% Cboe S&P 500 PutWrite Index/7.5% Cboe Russell 2000 One-Week PutWrite Index/7.5% Cboe Russell 2000 PutWrite Index (reflects no deduction for fees, expenses or taxes) | 15.69 | 4.53 | 4.98 |
S&P 500® Index (reflects no deduction for fees, expenses or taxes) | 28.71 | 18.47 | 18.42 |
After-tax returns are calculated using the historical highest individual federal marginal income tax rates and do not reflect the impact of state and local taxes. Actual after-tax returns depend on an investor’s tax situation and may differ from those shown. After-tax returns are not relevant to investors who hold their Fund shares through tax-deferred arrangements, such as 401(k) plans or individual retirement accounts. Return After Taxes on Distributions and Sale of Fund Shares may be higher than other returns for the same period due to a tax benefit of realizing a capital loss upon the sale of Fund shares. |
* | On February 28, 2022, the Fund began comparing its performance to the 50% Cboe S&P 500 One-Week PutWrite Index/50% Cboe S&P 500 PutWrite Index rather than the 42.5% Cboe S&P 500 One-Week PutWrite Index/42.5% Cboe S&P 500 PutWrite Index/7.5% Cboe Russell 2000 One-Week PutWrite Index/7.5% Cboe Russell 2000 PutWrite Index because the 50% Cboe S&P 500 One-Week PutWrite Index/50% Cboe S&P 500 PutWrite Index has characteristics that are more representative of the Fund’s investment strategy than its previous index. |
YEAR ENDED OCTOBER 31, | 2019(1) | 2020 | 2021 |
PER-SHARE DATA ($) | |||
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 | 11.65 | 11.43 |
Plus: | |||
Income from investment operations | |||
Net investment income (loss)(6) | 0.16 | 0.23 | 0.17 |
Net gains (losses)—realized and unrealized | 0.93 | (0.07) | 2.69 |
Subtotal: income (loss) from investment operations | 1.09 | 0.16 | 2.86 |
Minus: | |||
Distributions to shareholders | |||
Income dividends | — | 0.24 | 0.24 |
Net capital gains | — | 0.14 | — |
Subtotal: distributions to shareholders | — | 0.38 | 0.24 |
Equals: | |||
Share price (NAV) at end of year | 11.65 | 11.43 | 14.05 |
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 | 0.39(4) | 0.45 | 0.61 |
Net expenses (excluding expenses on securities sold short)—actual | 0.39(4) | 0.45 | 0.61 |
Gross expenses(2) | 3.55(4) | 3.76 | 4.72 |
Gross expenses (excluding expenses on securities sold short)(2) | 3.55(4) | 3.76 | 4.72 |
Net investment income (loss)—actual | 1.78(4) | 2.06 | 1.31 |
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) | 10.32(5) | 1.32 | 25.32 |
Net assets at end of year (in millions of dollars) | 0.0 | 0.0 | 0.0 |
Portfolio turnover rate (including securities sold short)(%) | 74(5)(7) | 74(7) | 138 |
Portfolio turnover rate (excluding securities sold short)(%) | 74(5)(7) | 74(7) | 138 |
(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 TBA roll transactions, including and excluding securities sold short, were 176% and 176%, respectively, for the year ended October 31, 2020, and 159%, and 159%, respectively, for the year ended October 31, 2019. |
YEAR ENDED OCTOBER 31, | 2017 | 2018 | 2019 | 2020 | 2021 |
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 | 10.10 | 11.34 | 10.66 | 11.29 | 10.93 |
Plus: | |||||
Income from investment operations | |||||
Net investment income (loss)(3) | 0.06 | 0.12 | 0.19 | 0.14 | 0.02 |
Net gains (losses)—realized and unrealized | 1.26 | (0.12) | 0.66 | 0.10 | 2.93 |
Subtotal: income from investment operations | 1.32 | 0.00 | 0.85 | 0.24 | 2.95 |
Minus: | |||||
Distributions to shareholders | |||||
Income dividends | 0.05 | 0.09 | 0.22 | 0.17 | 0.02 |
Capital gain distributions | 0.03 | 0.59 | — | 0.43 | 0.01 |
Subtotal: distributions to shareholders | 0.08 | 0.68 | 0.22 | 0.60 | 0.03 |
Equals: | |||||
Share price (NAV) at end of year | 11.34 | 10.66 | 11.29 | 10.93 | 13.85 |
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 | 0.58 | 0.58 | 0.56 | 0.55 | 0.55 |
Gross expenses(1) | 0.93 | 0.68 | 0.66 | 0.64 | 0.59 |
Net investment income (loss)—actual | 0.55 | 1.12 | 1.75 | 1.31 | 0.17 |
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 (%)(2) | 13.08 | (0.09) | 8.08 | 2.23 | 27.01 |
Net assets at end of year (in millions of dollars) | 12.2 | 17.9 | 17.7 | 103.5 | 201.9 |
Portfolio turnover rate (%) | 0 | 56 | 31 | 41 | 38 |
(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 the 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. |
Fund
|
Institutional
Class
|
Class A
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Class C
|
Class R6
|
Class E
|
Neuberger Berman Absolute Return Multi-Manager Fund
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NABIX
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NABCX
|
NABAX
|
NRABX
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NABEX
|
1290 Avenue of the Americas, New York, NY 10104
Shareholder Services
800.877.9700
Institutional Services
800.366.6264
www.nb.com
|
Page | |
INVESTMENT INFORMATION
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1
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Investment Policies and Limitations
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1
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Cash Management and Temporary Defensive Positions
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4
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Additional Investment Information
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4
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PERFORMANCE INFORMATION
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86
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TRUSTEES AND OFFICERS
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86
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Information about the Board of Trustees
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87
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Information about the Officers of the Trust
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92
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The Board of Trustees
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94
|
INVESTMENT MANAGEMENT AND ADMINISTRATION SERVICES
|
103
|
Investment Manager and Administrator
|
103
|
Management and Administration Fees
|
106
|
Fund Accounting Agent
|
107
|
Contractual Expense Limitations
|
107
|
Subadvisers
|
108
|
Portfolio Manager Information
|
109
|
Other Investment Companies or Accounts Managed
|
114
|
Codes of Ethics
|
115
|
Management and Control of NBIA
|
115
|
DISTRIBUTION ARRANGEMENTS
|
115
|
Distributor
|
115
|
Additional Payments to Financial Intermediaries
|
117
|
Distribution Plan (Class A Only)
|
118
|
Distribution Plan (Class C Only)
|
119
|
Distribution Plan (Class A and Class C)
|
119
|
ADDITIONAL PURCHASE INFORMATION
|
120
|
Share Prices and Net Asset Value
|
120
|
Subscriptions in Kind
|
122
|
Financial Intermediaries
|
122
|
Automatic Investing and Dollar Cost Averaging
|
123
|
Sales Charges
|
123
|
ADDITIONAL EXCHANGE INFORMATION
|
123
|
ADDITIONAL REDEMPTION INFORMATION
|
125
|
Suspension of Redemptions
|
125
|
Redemptions in Kind
|
125
|
CONVERSION INFORMATION
|
125
|
DIVIDENDS AND OTHER DISTRIBUTIONS
|
127
|
ADDITIONAL TAX INFORMATION
|
127
|
Taxation of the Fund
|
127
|
Taxation of the Fund’s Shareholders
|
135
|
Special Tax Considerations Pertaining to Funds of Funds
|
137
|
FUND TRANSACTIONS
|
139
|
Portfolio Turnover
|
143
|
Proxy Voting
|
143
|
PORTFOLIO HOLDINGS DISCLOSURE
|
144
|
Portfolio Holdings Disclosure Policy
|
144
|
Public Disclosure
|
144
|
Selective Disclosure Procedures
|
145
|
Portfolio Holdings Approved Recipients
|
146
|
REPORTS TO SHAREHOLDERS
|
147
|
ORGANIZATION, CAPITALIZATION AND OTHER MATTERS
|
147
|
CUSTODIAN AND TRANSFER AGENT
|
148
|
INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
|
149
|
LEGAL COUNSEL
|
149
|
CONTROL PERSONS AND PRINCIPAL HOLDERS OF SECURITIES
|
149
|
REGISTRATION STATEMENT
|
149
|
FINANCIAL STATEMENTS
|
150
|
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.
|
47
|
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.
|
47
|
Director, UJA Federation of Greater New York, since 2019; 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.
|
47
|
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.
|
47 | 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.
|
47
|
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.
|
47
|
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.
|
47
|
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.
|
47
|
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.
|
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 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, eleven registered investment companies for which NBIA acts as investment manager and/or administrator.
|
47
|
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.
|
(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.
|
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, thirty
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, eleven registered investment companies for which NBIA acts as investment manager and/or administrator.
|
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, eleven 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)
|
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, thirty 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 – 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), thirty 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, thirty 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 2014; 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, eleven registered investment companies for which NBIA acts as investment manager and/or administrator; Vice President, thirty
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 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, eleven 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, thirty 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, eleven 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, eleven 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, eleven 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
|
$25,810
|
$240,000
|
Marc Gary
Trustee
|
$25,272
|
$235,000
|
Martha C. Goss
Trustee
|
$25,272
|
$235,000
|
Michael M. Knetter
Trustee
|
$25,272
|
$235,000
|
Deborah C. McLean
Trustee
|
$25,810
|
$240,000
|
George W. Morriss
Trustee
|
$25,674
|
$238,750
|
Tom D. Seip
Chairman of the Board and Trustee |
$28,264
|
$267,500
|
James G. Stavridis
Trustee
|
$23,659
|
$220,000
|
Candace L. Straight
Trustee1 |
$16,212
|
$150,000
|
Peter P. Trapp
Trustee2 |
$23,659
|
$220,000
|
Fund Trustees who are “Interested Persons”
|
||
Joseph V. Amato
President, Chief Executive Officer and Trustee
|
$0
|
$0
|
Fund
|
Class
|
Limitation Period
|
Expense Limitation
|
Absolute Return Multi-Manager Fund
|
Institutional
|
10/31/2025
|
1.97%
|
A
|
10/31/2025
|
2.33%
|
|
C
|
10/31/2025
|
3.08%
|
|
R6
|
10/31/2025
|
1.87%*
|
Expenses Reimbursed for Fiscal Years Ended
October 31,
|
||||
Fund
|
Class
|
2021
|
2020
|
2019
|
Absolute Return Multi-Manager Fund
|
Class A
|
$52,624
|
$48,102
|
$31,156
|
Class C
|
$29,872
|
$36,584
|
$28,605
|
|
Institutional Class
|
$522,331
|
$567,149
|
$508,701
|
|
Class R6
|
$20,018
|
$8,302
|
$24,431
|
Expenses Repaid for Fiscal Years Ended
October 31,
|
|||||
Fund
|
Class
|
2021
|
2020
|
2019
|
|
Absolute Return Multi-Manager Fund
|
Class A
|
$0
|
$0
|
$0
|
|
Class C
|
$0
|
$0
|
$0
|
||
Class R6
|
$0
|
$0
|
$0
|
||
Institutional Class
|
$0
|
$0
|
$0
|
Portfolio Manager
|
Fund(s) Managed
|
Jeffrey Majit
|
Neuberger Berman Absolute Return Multi-Manager Fund
|
David Kupperman
|
Neuberger Berman Absolute Return Multi-Manager Fund
|
Fred Ingham
|
Neuberger Berman Absolute Return Multi-Manager Fund
|
Type of Account
|
Number
of
Accounts
Managed
|
Total Assets
Managed
($ millions)
|
Number of Accounts
Managed for which
Advisory Fee is
Performance-Based
|
Assets Managed for
which Advisory Fee
is Performance-
Based ($ millions)
|
David Kupperman***
|
||||
Registered Investment Companies*
|
1
|
75
|
-
|
-
|
Other Pooled Investment Vehicles
|
15
|
3,374
|
-
|
-
|
Other Accounts**
|
6
|
3,953
|
-
|
-
|
Jeffrey Majit***
|
||||
Registered Investment Companies*
|
1
|
75
|
-
|
-
|
Other Pooled Investment Vehicles
|
15
|
3,374
|
-
|
-
|
Other Accounts**
|
6
|
3,953
|
-
|
-
|
Fred Ingham***
|
||||
Registered Investment Companies*
|
1
|
75
|
-
|
-
|
Other Pooled Investment Vehicles
|
15
|
3,374
|
-
|
-
|
Other Accounts**
|
6
|
3,953
|
-
|
-
|
Portfolio
Manager |
Fund Managed
|
Dollar Range of
Equity Securities
Owned in the
Fund
|
Fred Ingham
|
Neuberger Berman Absolute Return Multi-Manager Fund
|
C
|
David Kupperman
|
Neuberger Berman Absolute Return Multi-Manager Fund
|
E
|
Jeffrey Majit
|
Neuberger Berman Absolute Return Multi-Manager Fund
|
D
|
A = None
|
E = $100,001-$500,000 |
B = $1-$10,000
C = $10,001 - $50,000
D =$50,001-$100,000
|
F = $500,001-$1,000,000
G = Over $1,000,001
|
Portfolio
Manager
|
Fund Managed
|
Dollar Range of
Equity Securities
Owned in the
Fund
|
Fred Ingham
|
Neuberger Berman Absolute Return Multi-Manager Fund
|
C
|
David Kupperman
|
Neuberger Berman Absolute Return Multi-Manager Fund
|
G
|
Jeffrey Majit
|
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
|
2021
|
$1,214
|
$156
|
-
|
-
|
2020
|
$2,659
|
$226
|
-
|
-
|
|
2019
|
$ 8,291
|
$1,089
|
-
|
-
|
|
Absolute Return Multi-Manager Fund – Class C
|
2021
|
-
|
-
|
$897
|
-
|
2020
|
-
|
-
|
$60
|
-
|
|
2019
|
-
|
-
|
$28
|
-
|
|
Fiscal Year Ended
October 31,
|
|||
Fund
|
2021
|
2020
|
2019
|
Absolute Return Multi-Manager Fund
|
$16,915
|
$15,973
|
$24,798
|
Fiscal Year Ended
October 31,
|
|||
Fund
|
2021
|
2020
|
2019
|
Absolute Return Multi-Manager Fund
|
$37,895
|
$61,965
|
$93,005
|
Fund and Class
|
Name and Address
|
Percentage of
Shares Held
|
Neuberger Berman Absolute Return Multi-Manager Fund – Class A
|
MORGAN STANLEY SMITH BARNEY LLC
FOR THE EXCLUSIVE BENE OF ITS CUST
1 NEW YORK PLZ FL 12
NEW YORK NY 10004-1901
|
19.42%
|
MLPF&S FOR THE SOLE BENEFIT OF
ITS CUSTOMERS
ATTN FUND ADMINSTRATION (97NX1)
4800 DEER LAKE DR E FL 2
JACKSONVILLE FL 32246-6484
|
14.92%
|
|
AMERICAN ENTERPRISE INVESTMENT SVC
FBO # 41999970
707 2ND AVE S
MINNEAPOLIS MN 55402-2405
|
13.93%
|
|
WELLS FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE
EXCLUSIVE BENEFIT OF CUSTOMER
2801 MARKET ST
SAINT LOUIS MO 63103-2523
|
9.15%
|
Fund and Class | Name and Address |
Percentage of
Shares Held
|
PERSHING LLC
1 PERSHING PLZ
JERSEY CITY NJ 07399-0002
|
7.63%
|
|
Neuberger Berman Absolute Return Multi-Manager Fund – Class C
|
RAYMOND JAMES OMNIBUS FOR
MUTUAL FUNDS HOUSE ACCOUNT
ATTN COURTNEY WALLER
880 CARILLON PKWY
ST PETERSBURG FL 33716-1100
|
30.11%
|
UBS WM USA
OMNI ACCOUNT M/F
SPEC CDY A/C EBOC UBSFSI
1000 HARBOR BLVD
WEEHAWKEN NJ 07086-6761
|
18.30%
|
|
RBC CAPITAL MARKETS LLC
MUTUAL FUND OMNIBUS PROCESSING
OMNIBUS
ATTN MUTUAL FUND OPS MGR
60 S 6TH ST
MINNEAPOLIS MN 55402-4413
|
10.10%
|
|
LPL FINANCIAL
4707 EXECUTIVE DR
SAN DIEGO CA 92121-3091
|
10.09%
|
|
AMERICAN ENTERPRISE INVESTMENT SVC
707 2ND AVE S
MINNEAPOLIS MN 55402-2405
|
9.34%
|
|
WELLS FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE
EXCLUSIVE BENEFIT OF CUSTOMER
2801 MARKET ST
SAINT LOUIS MO 63103-2523
|
9.05%
|
|
Neuberger Berman Absolute Return Multi-Manager Fund – Institutional Class
|
UBS WM USA
OMNI ACCOUNT M/F
SPEC CDY A/C EBOC UBSFSI
1000 HARBOR BLVD
WEEHAWKEN NJ 07086-6761
|
19.51%
|
Fund and Class | Name and Address |
Percentage of
Shares Held
|
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
|
18.08%
|
|
CHARLES SCHWAB & CO INC
ATTN MUTUAL FUNDS
211 MAIN ST
SAN FRANCISCO CA 94105-1905
|
16.58%
|
|
LPL FINANCIAL
OMNIBUS CUSTOMER ACCOUNT
ATTN MUTUAL FUND TRADING
4707 EXECUTIVE DR
SAN DIEGO CA 92121-3091
|
14.68%
|
|
WELLS FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE
EXCLUSIVE BENEFIT OF CUSTOMER
2801 MARKET ST
SAINT LOUIS MO 63103-2523
|
7.65%
|
|
GERLACH & CO, LLC NON US CITIZENS
3800 CITIGROUP CENTER
BUILDING B3-14
TAMPA FL 33610
|
7.26%
|
|
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%
|
|
Neuberger Berman Absolute Return Multi-Manager Fund – Class E
|
NATIONAL FINANCIAL SVCS CORP
FOR EXCLUSIVE BENEFIT OF OUR
CUSTOMERS
SAL VELLA
499 WASHINGTON BLVD FL 5
JERSEY CITY NJ 07310-2010
|
99.99%
|
Fund and Class | Name and Address |
Percentage of
Shares Held
|
Neuberger Berman Absolute Return Multi-Manager Fund – Class R6
|
SEI PRIVATE TRUST COMPANY
C/O CIBC PRIVATE WEALTH GROUP
ONE FREEDOM VALLEY DRIVE
OAKS PA 19456-9989
|
99.40%
|
•
|
When a solicitor has been retained, the solicitor is called. At the solicitor’s direction, the
proxy is faxed.
|
•
|
In some circumstances VIFs can be faxed to Broadridge up until the time of the meeting.
|
•
|
Banks and brokerage firms using the services at Broadridge: Broadridge is notified that we wish to vote in person. Broadridge issues individual legal proxies and sends them
back via email or overnight (or the Adviser can pay messenger charges). A lead-time of at least two weeks prior to the meeting is needed to do this. Alternatively, the procedures detailed below for banks not using Broadridge may
be implemented.
|
•
|
Banks and brokerage firms issuing proxies directly: The bank is called and/or faxed and a legal proxy is requested.
|
•
|
All legal proxies should appoint: “Representative of [Adviser name] with full power of substitution.”
|
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
|
•
|
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.
|
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.
|
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.
|
|
|
|
|
|
|
|
|
II.
|
RESPONSIBILITY AND OVERSIGHT
|
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.
|
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.
|
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 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
|
Page |
|
INVESTMENT INFORMATION
|
1
|
Investment Policies and Limitations
|
1
|
Cash Management and Temporary Defensive Positions
|
6
|
Additional Investment Information
|
7
|
PERFORMANCE INFORMATION
|
92
|
TRUSTEES AND OFFICERS
|
93
|
Information about the Board of Trustees
|
93
|
Information about the Officers of the Trust
|
97
|
The Board of Trustees
|
100
|
INVESTMENT MANAGEMENT AND ADMINISTRATION SERVICES
|
109
|
Investment Manager and Administrator
|
109
|
Management and Administration Fees
|
111
|
Contractual Expense Limitations
|
113
|
Advisory Fee Waiver
|
115
|
Portfolio Manager Information
|
115
|
Other Investment Companies or Accounts Managed
|
122
|
Codes of Ethics
|
123
|
Management and Control of NBIA
|
123
|
DISTRIBUTION ARRANGEMENTS
|
123
|
Distributor
|
123
|
Additional Payments to Financial Intermediaries
|
127
|
Distribution Plan (Class A Only)
|
128
|
Distribution Plan (Class C Only)
|
129
|
Distribution Plan (Class A and Class C)
|
130
|
ADDITIONAL PURCHASE INFORMATION
|
130
|
Share Prices and Net Asset Value
|
130
|
Subscriptions in Kind
|
133
|
Financial Intermediaries
|
133
|
Automatic Investing and Dollar Cost Averaging
|
133
|
Sales Charges
|
134
|
ADDITIONAL EXCHANGE INFORMATION
|
134
|
ADDITIONAL REDEMPTION INFORMATION
|
135
|
Suspension of Redemptions
|
135
|
Redemptions in Kind
|
135
|
CONVERSION INFORMATION
|
136
|
DIVIDENDS AND OTHER DISTRIBUTIONS
|
137
|
ADDITIONAL TAX INFORMATION
|
138
|
Taxation of the Funds
|
138
|
Taxation of the Funds’ Shareholders
|
146
|
Special Tax Considerations Pertaining to Funds of Funds
|
149
|
FUND TRANSACTIONS
|
150
|
Portfolio Turnover
|
155
|
Proxy Voting
|
156
|
PORTFOLIO HOLDINGS DISCLOSURE
|
157
|
Portfolio Holdings Disclosure Policy
|
157
|
Public Disclosure
|
158
|
Selective Disclosure Procedures
|
158
|
Portfolio Holdings Approved Recipients
|
159
|
REPORTS TO SHAREHOLDERS
|
160
|
ORGANIZATION, CAPITALIZATION AND OTHER MATTERS
|
160
|
CUSTODIAN AND TRANSFER AGENT
|
161
|
INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
|
162
|
LEGAL COUNSEL
|
162
|
CONTROL PERSONS AND PRINCIPAL HOLDERS OF SECURITIES
|
162
|
REGISTRATION STATEMENT
|
170
|
FINANCIAL STATEMENTS
|
170
|
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
|
$232,238
|
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
|
$22,550
|
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
|
$6,736
|
Administrative fees not included in revenue split
|
$0
|
Indemnification fees not included in revenue split
|
$0
|
Rebate (paid to borrower)
|
$0
|
Other fees relating to the securities lending program that are not included in the revenue split
|
$0
|
Aggregate fees/compensation for securities lending activities
|
$29,286
|
Net income from securities lending activities
|
$202,952
|
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.
|
47
|
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.
|
47
|
Director, UJA Federation of Greater New York, since 2019; 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.
|
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.
|
47
|
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.
|
47
|
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.
|
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.
|
47
|
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.
|
47
|
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.
|
47
|
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.
|
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.
|
47
|
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.
|
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 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, eleven registered investment companies for which NBIA acts as investment manager and/or administrator.
|
47
|
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.
|
(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.
|
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, thirty 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, eleven registered investment companies
for which NBIA acts as investment manager and/or administrator.
|
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, eleven 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)
|
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, thirty
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 – 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), thirty 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, thirty 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)
|
Brian Kerrane (1969)
|
Chief Operating Officer since 2015 and Vice President since 2008
|
Managing Director, Neuberger Berman, since 2014; 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, eleven registered investment companies for which NBIA acts as investment manager and/or administrator; Vice President, thirty 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, eleven 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, thirty 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, eleven 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, eleven 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)
|
Frank Rosato (1971)
|
Assistant Treasurer since inception
|
Vice President, Neuberger Berman, since 2006; Vice President, NBIA, since 2006 and Employee since 1995; Assistant Treasurer, eleven 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
|
$25,810
|
$240,000
|
Marc Gary
Trustee
|
$25,272
|
$235,000
|
Martha C. Goss
Trustee
|
$25,272
|
$235,000
|
Michael M. Knetter
Trustee
|
$25,272
|
$235,000
|
Deborah C. McLean
Trustee
|
$25,810
|
$240,000
|
George W. Morriss
Trustee
|
$25,674
|
$238,750
|
Tom D. Seip
Chairman of the Board and Trustee |
$28,264
|
$267,500
|
James G. Stavridis
Trustee
|
$23,659
|
$220,000
|
Candace L. Straight
Trustee1 |
$16,212
|
$150,000
|
Peter P. Trapp
Trustee2 |
$23,659
|
$220,000
|
Fund Trustees who are “Interested Persons”
|
||
Joseph V. Amato
President, Chief Executive
Officer and Trustee
|
$0
|
$0
|
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
|
Fund Trustees who are “Interested Persons”
|
|
Joseph V. Amato
|
E
|
Fund
|
Class
|
2021
|
2020
|
2019
|
Commodity
Strategy Fund
|
Class A
|
$179,056
|
$148,871
|
$248,555
|
Class C
|
$177
|
$148
|
$189
|
|
Institutional
|
$784,958
|
$769,057
|
$760,916
|
|
Global Allocation
Fund
|
Class A
|
$10,675
|
$12,524
|
$19,637
|
Class C
|
$10,063
|
$13,481
|
$16,610
|
|
Institutional
|
$55,440
|
$71,141
|
$84,806
|
|
Class R6
|
$187
|
$161
|
$126
|
Fund
|
Class
|
2021
|
2020
|
2019
|
Long Short Fund
|
Class A
|
$1,908,400
|
$1,023,151
|
$939,267
|
Class C
|
$775,450
|
$796,919
|
$934,503
|
|
Institutional
|
$55,650,497
|
$35,444,208
|
$30,405,863
|
|
U.S. Equity Index
PutWrite
Strategy Fund
|
Class A
|
$33,955
|
$146,082
|
$173,640
|
Class C
|
$7,263
|
$6,640
|
$7,462
|
|
Institutional
|
$1,532,247
|
$1,425,537
|
$1,361,741
|
|
R6
|
$787,523
|
$129,183
|
$100,619
|
Fund
|
Class
|
Limitation Period
|
Expense Limitation
|
|
Commodity Strategy
|
Institutional
|
10/31/2025
|
0.73%
|
|
A
|
10/31/2025
|
1.09%
|
||
C
|
10/31/2025
|
1.84%
|
|
|
|
|
Fund
|
2021
|
2020
|
2019
|
Commodity Strategy Fund - Institutional Class
|
$115,697
|
$99,538
|
$96,122
|
Commodity Strategy Fund - Class A
|
$22,584
|
$16,638
|
$26,667
|
Commodity Strategy Fund - Class C
|
$23
|
$16
|
$20
|
Global Allocation Fund - Institutional Class
|
$3,743
|
$21,243
|
$32,733
|
Global Allocation Fund - Class A
|
$658
|
$3,230
|
$6,610
|
Global Allocation Fund - Class C
|
$749
|
$3,456
|
$5,574
|
Global Allocation Fund - Class R6
|
$15
|
$55
|
$55
|
Portfolio
Manager
|
Fund(s) Managed
|
Hakan Kaya
|
Neuberger Berman Commodity Strategy Fund
|
Erik Knutzen
|
Neuberger Berman Global Allocation Fund
|
Marc Regenbaum
|
Neuberger Berman Long Short Fund
|
Robert Surgent
|
Neuberger Berman Global Allocation Fund
|
David Wan
|
Neuberger Berman Commodity Strategy Fund
|
Eric Zhou
|
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund
|
Type of Account
|
Number
of
Accounts
Managed
|
Total Assets
Managed
($ millions)
|
Number of
Accounts Managed
for which Advisory
Fee is
Performance-
Based
|
Assets Managed for which
Advisory Fee is
Performance-Based
($ millions)
|
Derek Devens***
|
||||
Registered Investment Companies*
|
3
|
556
|
-
|
-
|
Other Pooled Investment Vehicles
|
4
|
2,337
|
-
|
-
|
Other Accounts**
|
75
|
4,957
|
-
|
-
|
Rory Ewing***
|
||||
Registered Investment Companies*
|
3
|
556
|
-
|
-
|
Other Pooled Investment Vehicles
|
4
|
2,337
|
-
|
-
|
Other Accounts**
|
64
|
4,928
|
-
|
-
|
Michael Foster***
|
||||
Registered Investment Companies*
|
2
|
228
|
-
|
-
|
Other Pooled Investment Vehicles
|
2
|
136
|
-
|
-
|
Other Accounts**
|
348
|
8,769
|
-
|
-
|
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)
|
Charles Kantor***
|
||||
Registered Investment Companies*
|
2
|
7,528
|
-
|
-
|
Other Pooled Investment Vehicles
|
11
|
2,636
|
-
|
-
|
Other Accounts**
|
2,394
|
4,529
|
-
|
-
|
Tokufumi Kato***
|
||||
Registered Investment Companies*
|
1
|
11
|
-
|
-
|
Other Pooled Investment Vehicles
|
49
|
2,932
|
-
|
-
|
Other Accounts**
|
148
|
5,057
|
4
|
89
|
Hakan Kaya***
|
||||
Registered Investment Companies*
|
2
|
199
|
-
|
-
|
Other Pooled Investment Vehicles
|
3
|
1,193
|
-
|
-
|
Other Accounts**
|
-
|
-
|
-
|
-
|
Erik Knutzen ***
|
||||
Registered Investment Companies*
|
1
|
11
|
-
|
-
|
Other Pooled Investment Vehicles
|
49
|
2,932
|
-
|
-
|
Other Accounts**
|
148
|
5,057
|
4
|
89
|
Marc Regenbaum***
|
||||
Registered Investment Companies*
|
2
|
7,528
|
-
|
-
|
Other Pooled Investment Vehicles
|
11
|
2,636
|
-
|
-
|
Other Accounts**
|
2,394
|
4,529
|
-
|
-
|
Robert Surgent***
|
||||
Registered Investment Companies*
|
1
|
11
|
-
|
-
|
Other Pooled Investment Vehicles
|
49
|
2,932
|
-
|
-
|
Other Accounts**
|
148
|
5,057
|
4
|
89
|
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)
|
Portfolio Manager
|
Fund(s) Managed
|
Dollar Range of Equity Securities Owned in the Fund
|
Derek Devens
|
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund
|
G
|
Rory Ewing
|
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund
|
E
|
Michael Foster
|
Neuberger Berman Commodity Strategy Fund
|
A
|
Charles Kantor
|
Neuberger Berman Long Short Fund
|
G
|
Tokufumi Kato
|
Neuberger Berman Global Allocation Fund
|
A
|
Hakan Kaya
|
Neuberger Berman Commodity Strategy Fund
|
C
|
Erik Knutzen
|
Neuberger Berman Global Allocation Fund
|
G
|
Marc Regenbaum
|
Neuberger Berman Long Short Fund
|
F
|
Robert Surgent
|
Neuberger Berman Global Allocation Fund
|
A
|
David Wan
|
Neuberger Berman Commodity Strategy Fund
|
B
|
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
|
Portfolio Manager
|
Fund(s) Managed
|
Dollar Range of Equity Securities Owned in the Fund
|
Derek Devens
|
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund
|
G
|
Rory Ewing
|
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund
|
E
|
Michael Foster
|
Neuberger Berman Commodity Strategy Fund
|
A
|
Charles Kantor
|
Neuberger Berman Long Short Fund
|
G
|
Tokufumi Kato
|
Neuberger Berman Global Allocation Fund
|
A
|
Hakan Kaya
|
Neuberger Berman Commodity Strategy Fund
|
C
|
Erik Knutzen
|
Neuberger Berman Global Allocation Fund
|
G
|
Marc Regenbaum
|
Neuberger Berman Long Short Fund
|
F
|
Robert Surgent
|
Neuberger Berman Global Allocation Fund
|
A
|
David Wan
|
Neuberger Berman Commodity Strategy Fund
|
B
|
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
October
31,
|
Amount Paid to
Distributor
|
Amount
Retained by
Distributor
|
Amount Paid
to Distributor
|
Amount Retained by Distributor
|
Commodity Strategy Fund – Class A
|
2021
|
$8,922
|
$1,042
|
$0
|
$0
|
2020
|
$2,491
|
$361
|
-
|
-
|
|
2019
|
$4,201
|
$646
|
-
|
-
|
Sales Charge Revenue
|
Deferred Sales Charge
Revenue
|
||||
Fund
|
Fiscal
Year
Ended
October
31,
|
Amount Paid to
Distributor
|
Amount
Retained by
Distributor
|
Amount Paid
to Distributor
|
Amount Retained by Distributor
|
Commodity Strategy Fund – Class C
|
2021
|
$0
|
$0
|
$0
|
$0
|
2020
|
-
|
-
|
-
|
-
|
|
2019
|
-
|
-
|
-
|
-
|
Global Allocation Fund – Class A
|
2021
|
$115
|
$15
|
$0
|
$0
|
2020
|
$1,281
|
$168
|
-
|
-
|
|
2019
|
$710
|
$110
|
-
|
-
|
|
Global Allocation Fund – Class C
|
2021
|
$0
|
$0
|
$0
|
$0
|
2020
|
-
|
-
|
-
|
-
|
|
2019
|
-
|
-
|
$19
|
-
|
|
Long Short Fund – Class A
|
2021
|
$161,399
|
$23,627
|
||
2020
|
$147,846
|
$23,417
|
-
|
-
|
|
2019
|
$107,112
|
$14,582
|
-
|
-
|
|
Long Short Fund – Class C
|
2021
|
$0
|
$0
|
$3,308
|
$0
|
2020
|
-
|
-
|
$4,975
|
-
|
|
2019
|
-
|
-
|
$5,653
|
-
|
Sales Charge Revenue
|
Deferred Sales Charge
Revenue
|
||||
Fund
|
Fiscal
Year
Ended
October
31,
|
Amount Paid to
Distributor
|
Amount
Retained by
Distributor
|
Amount Paid
to Distributor
|
Amount Retained by Distributor
|
U.S. Equity Index PutWrite Strategy Fund -- Class A
|
2021
|
$33,835
|
$4,302
|
$0
|
$0
|
U.S. Equity Index PutWrite Strategy Fund -- Class A
|
2020
|
$2,205
|
$880
|
-
|
-
|
2019
|
$12,729
|
$2,962
|
-
|
-
|
|
U.S. Equity Index PutWrite Strategy Fund -- Class C
|
2021
|
$0
|
$0
|
$0
|
$0
|
2020
|
-
|
-
|
$295
|
-
|
|
2019
|
-
|
-
|
$1,740
|
-
|
Class A
|
Fiscal Years Ended October 31,
|
||
2021
|
2020
|
2019
|
|
Commodity Strategy Fund
|
$58,917
|
$48,937
|
$81,888
|
Global Allocation Fund
|
$3,294
|
$3,864
|
$6,063
|
Long Short Fund
|
$352,522
|
$187,040
|
$171,454
|
U.S. Equity Index PutWrite Strategy Fund
|
$11,958
|
$51,550
|
$61,097
|
Class C
|
Fiscal Years Ended October 31,
|
||
2021
|
2020
|
2019
|
|
Commodity Strategy Fund
|
$234
|
$195
|
$250
|
Global Allocation Fund
|
$12,441
|
$16,629
|
$20,507
|
Long Short Fund
|
$573,660
|
$583,192
|
$679,758
|
U.S. Equity Index PutWrite Strategy Fund
|
$10,228
|
$9,360
|
$10,515
|
Fund and Class
|
Name and Address
|
Percentage of
Shares Held
|
Neuberger Berman Commodity Strategy Fund – Class A
|
CHARLES SCHWAB & CO INC
ATTN MUTUAL FUNDS
211 MAIN ST
SAN FRANCISCO CA 94105-1905
|
74.86%
|
TD AMERITRADE INC FOR THE
EXCLUSIVE BENEFIT OF OUR CLIENTS
PO BOX 2226
OMAHA NE 68103-2226
|
7.42%
|
|
Neuberger Berman Commodity Strategy Fund – Class C
|
PERSHING LLC
1 PERSHING PLZ
JERSEY CITY NJ 07399-0002
|
78.36%
|
NATIONAL FINANCIAL SERVICES LLC
499 WASHINGTON BLVD
JERSEY CITY NJ 07310-1995
|
21.63%
|
|
Neuberger Berman Commodity Strategy 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
|
39.90%
|
Fund and Class
|
Name and Address
|
Percentage of
Shares Held
|
CHARLES SCHWAB & CO INC
ATTN MUTUAL FUNDS
211 MAIN ST
SAN FRANCISCO CA 94105-1905
|
34.80%
|
|
LPL FINANCIAL
OMNIBUS CUSTOMER ACCOUNT
ATTN MUTUAL FUND TRADING
4707 EXECUTIVE DR
SAN DIEGO CA 92121-3091
|
7.54%
|
|
PFIZER INC & NORTHERN TRUST CO
MASTER TRUST AGREEMENT BETWEEN
C/O PFIZER INC
235 E 42ND ST 28TH FLOOR
NEW YORK NY 10017-5703
|
7.06%
|
|
Neuberger Berman Global Allocation Fund – Class A
|
RAYMOND JAMES OMNIBUS FOR
MUTUAL FUNDS HOUSE ACCOUNT
FIRM 92500015
ATTN COURTNEY WALLER
880 CARILLON PKWY
ST PETERSBURG FL 33716-1100
|
31.78%
|
AMERICAN ENTERPRISE INVESTMENT SVC
707 2ND AVE S
MINNEAPOLIS MN 55402-2405
|
20.34%
|
|
PERSHING LLC
1 PERSHING PLZ
JERSEY CITY NJ 07399-0002
|
16.07%
|
|
UBS WM USA
OMNI ACCOUNT M/F
SPEC CDY A/C EBOC UBSFSI
1000 HARBOR BLVD
WEEHAWKEN NJ 07086-6761
|
5.76%
|
|
Neuberger Berman Global Allocation Fund – Class C
|
LPL FINANCIAL
4707 EXECUTIVE DR
SAN DIEGO CA 92121-3091
|
26.46%
|
PERSHING LLC
1 PERSHING PLZ
JERSEY CITY NJ 07399-0002
|
22.08%
|
Fund and Class
|
Name and Address
|
Percentage of
Shares Held
|
Fund and Class
|
Name and Address
|
Percentage of
Shares Held
|
MLPF&S FOR THE SOLE BENEFIT OF
ITS CUSTOMERS
ATTN FUND ADMINISTRATION
4800 DEER LAKE DR E FL 2
JACKSONVILLE FL 32246-6484
|
22.06%
|
|
CHARLES SCHWAB & CO INC
ATTN MUTUAL FUNDS
211 MAIN ST
SAN FRANCISCO CA 94105-1905
|
9.75%
|
|
WELLS FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE
EXCLUSIVE BENEFIT OF CUSTOMER
2801 MARKET ST
SAINT LOUIS MO 63103-2523
|
8.57%
|
|
RAYMOND JAMES OMNIBUS FOR
MUTUAL FUNDS HOUSE ACCOUNT
ATTN COURTNEY WALLER
880 CARILLON PKWY
ST PETERSBURG FL 33716-1100
|
5.46%
|
|
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
|
23.70%
|
WELLS FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE
EXCLUSIVE BENEFIT OF CUSTOMER
2801 MARKET ST
SAINT LOUIS MO 63103-2523
|
18.35%
|
|
RAYMOND JAMES OMNIBUS FOR
MUTUAL FUNDS HOUSE ACCOUNT
ATTN COURTNEY WALLER
880 CARILLON PKWY
ST PETERSBURG FL 33716-1100
|
12.28%
|
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
|
11.87%
|
|
MORGAN STANLEY SMITH BARNEY LLC
FOR THE EXCLUSIVE BENE OF ITS CUST
1 NEW YORK PLZ FL 12
NEW YORK NY 10004-1901
|
8.77%
|
|
LPL FINANCIAL
4707 EXECUTIVE DR
SAN DIEGO CA 92121-3091
|
8.46%
|
|
AMERICAN ENTERPRISE INVESTMENT SVC
707 2ND AVE S
MINNEAPOLIS MN 55402-2405
|
5.65%
|
|
Neuberger Berman Long Short Fund – Institutional Class
|
MLPF&S FOR THE SOLE BENEFIT OF
ITS CUSTOMERS
ATTN FUND ADMINISTRATION
4800 DEER LAKE DR E FL 2
JACKSONVILLE FL 32246-6484
|
20.83%
|
JP MORGAN SECURITIES LLC
FOR THE EXCLUSIVE BENEFIT
OF OUR CUSTOMERS
4 CHASE METROTECH CTR
BROOKLYN NY 11245-0001
|
13.54%
|
|
WELLS FARGO BANK NA FBO
OMNIBUS ACCOUNT CASH/CASH
PO BOX 1533
MINNEAPOLIS MN 55480-1533
|
11.31%
|
|
MORGAN STANLEY SMITH BARNEY LLC
FOR THE EXCLUSIVE BENE OF ITS CUST
1 NEW YORK PLZ FL 12
NEW YORK NY 10004-1901
|
10.65%
|
Fund and Class
|
Name and Address
|
Percentage of
Shares Held
|
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
|
5.76%
|
|
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund – Class A
|
CHARLES SCHWAB & CO INC
ATTN MUTUAL FUNDS
211 MAIN ST
SAN FRANCISCO CA 94105-1905
|
33.32%
|
UBS WM USA
OMNI ACCOUNT M/F
SPEC CDY A/C EBOC UBSFSI
1000 HARBOR BLVD
WEEHAWKEN NJ 07086-6761
|
26.52%
|
|
AMERICAN ENTERPRISE INVESTMENT SVC
707 2ND AVE S
MINNEAPOLIS MN 55402-2405
|
17.42%
|
|
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund – Class C
|
AMERICAN ENTERPRISE INVESTMENT SVC
707 2ND AVE S
MINNEAPOLIS MN 55402-2405
|
35.34%
|
PERSHING LLC
1 PERSHING PLZ
JERSEY CITY NJ 07399-0002
|
16.57%
|
|
NATIONAL FINANCIAL SERVICES LLC
499 WASHINGTON BLVD
JERSEY CITY NJ 07310-1995
|
6.16%
|
|
UBS WM USA
OMNI ACCOUNT M/F
SPEC CDY A/C EBOC UBSFSI
1000 HARBOR BLVD
WEEHAWKEN NJ 07086-6761
|
5.43%
|
Fund and Class
|
Name and Address
|
Percentage of
Shares Held
|
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
|
59.88%
|
CHARLES SCHWAB & CO INC
ATTN MUTUAL FUNDS
211 MAIN ST
SAN FRANCISCO CA 94105-1905
|
10.40%
|
|
WELLS FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE
EXCLUSIVE BENEFIT OF CUSTOMER
2801 MARKET ST
SAINT LOUIS MO 63103-2523
|
7.56%
|
|
UBS WM USA
0O0 11011 6100
OMNI ACCOUNT M/F
SPEC CDY A/C EBOC UBSFSI
1000 HARBOR BLVD
WEEHAWKEN NJ 07086-6761
|
6.12%
|
|
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund – Class R6
|
DTE ENERGY COMPANY
AFFILIATES EMPLOYEE BENEFIT PLANS
MASTER TRUST
ATTN: GREG DUREN
1 ENERGY PLZ
DETROIT MI 48226-1221
|
20.30%
|
PFIZER INC & NORTHERN TRUST CO
MASTER TRUST AGREEMENT BETWEEN
C/O PFIZER INC
235 E 42ND ST 28TH FLOOR
NEW YORK NY 10017-5703
|
17.99%
|
|
JP MORGAN SECURITIES LLC
FOR THE EXCLUSIVE BENEFIT
OF OUR CUSTOMERS
4 CHASE METROTECH CTR
BROOKLYN NY 11245-0001
|
16.34%
|
Fund and Class
|
Name and Address
|
Percentage of
Shares Held
|
DOW EMPLOYEES PENSION PLAN TRUST
ATTN ERIC ROE
2211 HH DOW WAY SSC BLDG OFC 2539
MIDLAND MI 48674-0001
|
9.04%
|
|
ATTN MUTUAL FUNDS
SEI PRIVATE TRUST COMPANY
ONE FREEDOM VALLEY DRIVE
OAKS PA 19456-9989
|
7.69%
|
|
DETROIT EDISON QUALIFED NUCLEAR
DECOMMISSIONING TRUST
ATTN GREG DUREN
1 ENERGY PLZ
DETROIT MI 48226-1221
|
7.61%
|
|
DTE ENERGY COMPANY
MASTER VEBA TRUST
ATTN: GREG DUREN
1 ENERGY PLZ
DETROIT MI 48226-1221
|
6.62%
|
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
|
42.43%
|
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
|
33.71%
|
Fund
|
Name and Address
|
Percentage of
Shares Held
|
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
|
63.51%
|
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
|
35.42%
|
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. |
II. |
RESPONSIBILITY AND OVERSIGHT |
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. |
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.
|
Exhibit Number
|
Description
|
||
(a)
|
(1)
|
||
(2)
|
|||
(3)
|
|||
(b)
|
|||
(c)
|
(1)
|
||
(2)
|
|||
(d)
|
(1)
|
||
(2)
|
(i)
|
||
Exhibit Number |
Description
|
||
(ii)
|
|||
(3)
|
Exhibit Number |
Description |
|
(4)
|
||
(e)
|
(1)
|
|
(2)
|
||
(3)
|
||
(4)
|
||
(5)
|
Exhibit Number |
Description |
|
(6)
|
||
(f)
|
Bonus or Profit Sharing Contracts. None.
|
|
(g)
|
(1)
|
|
(2)
|
||
(h)
|
(1)
|
|
(2)
|
||
(3)
|
||
(4)
|
Exhibit Number |
Description |
|
(5)
|
||
(6)
|
||
(7)
|
||
(8)
|
||
(9)
|
||
(10)
|
||
(11)
|
||
(12)
|
Exhibit Number |
Description | |
(13)
|
||
(14)
|
||
(15)
|
||
(16)
|
||
(17)
|
||
(18)
|
||
(19)
|
||
(20)
|
||
(21)
|
||
(22)
|
||
(i)
|
||
(j)
|
||
(k)
|
Financial Statements Omitted from Prospectuses. None.
|
|
(l)
|
||
(m)
|
(1)
|
|
(2)
|
||
(n)
|
||
(o)
|
(1)
|
Exhibit Number |
Description | |
(2)
|
||
(p)
|
(1)
|
|
(2)
|
||
(3)
|
||
(4)
|
||
(5)
|
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,
eleven registered investment companies for which NBIA acts as investment manager and/or administrator; Chief Executive Officer and President, eleven 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.
|
Jennifer Blachford
Senior Vice President, NBIA |
Senior Vice President, 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.
|
Richard N. Bradt
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
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.
|
Timothy Creedon
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Kai Cui
Senior Vice President |
Portfolio Manager.
|
Robert W. D’Alelio
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
NAME | BUSINESS AND OTHER CONNECTIONS |
Derek Devens
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Daniel Doyle
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.
|
Rand W. Gesing
Senior Vice President, NBIA |
Senior Vice President, 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.
|
Jeffrey Hunn
Senior Vice President, NBIA |
Senior Vice President, NB BD LLC; Portfolio Manager.
|
William Hunter
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Fred Ingham
Managing Director, NBIA |
Portfolio Manager.
|
James L. Iselin
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Corey A. Issing
General Counsel – 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.
|
Tokufumi Kato
Managing Director, NBIA |
Portfolio Manager.
|
Hakan Kaya
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
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.
|
Eric Knutzen Managing Director, NBIA |
Managing Director, NB BD LLC; Multi-Asset Class Chief Investment Officer, Neuberger Berman Group LLC; Portfolio Manager. |
NAME | BUSINESS AND OTHER CONNECTIONS |
Christopher Kocinski
Managing Director, NBIA |
Managing Director, NB BD 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.
|
David Levine
Senior Vice President, NBIA |
Senior Vice President, NB BD LLC; 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.
|
James Lyman
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
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.
|
Jared Mann,
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
James F. McAree
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Kevin McCarthy
Senior Vice President, NBIA |
Senior Vice President, 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.
|
Thomas P. O’Reilly
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Eric J. Pelio
Senior Vice President, NBIA |
Senior Vice President, NB BD LLC; Portfolio Manager.
|
Alexandra Pomeroy
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
NAME | BUSINESS AND OTHER CONNECTIONS |
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; 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.
|
John San Marco
Senior Vice President, NBIA |
Senior Vice President, 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.
|
Ronald B. Silvestri
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Jonathan Shofet
Managing Director, NBIA |
Managing Director, NB BD LLC; Managing Director, NBAA.
|
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.
|
David Stonberg
Managing Director, NBIA |
Managing Director, NB BD LLC; Managing Director, NBAA.
|
Robert Surgent
Managing Director, NBIA |
Managing Director, NB BD LLC; Portfolio Manager.
|
Brad Tank
President - Fixed Income and Chief
Investment Officer - Fixed Income,
NBIA
|
Managing Director, NB BD LLC; Portfolio Manager.
|
Jason Tauber
Managing Director, NBIA |
Managing Director, NB BD LLC; 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. |
NAME | BUSINESS AND OTHER CONNECTIONS |
Anthony Tutrone
Managing Director, NBIA |
Managing Director, NB BD LLC; Chief Executive Officer and Managing Director, NBAA.
|
James Tyre
Senior Vice President, NBIA |
Senior Vice President, NB BD LLC; Portfolio Manager.
|
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
Senior Vice President, NBIA |
Senior Vice President, NB BD LLC; Portfolio Manager.
|
(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
|
Jennifer Blachford
|
Senior Vice President
|
None
|
James Bowden
|
Managing Director
|
None
|
Richard N. Bradt
|
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
|
Timothy Creedon
|
Managing Director
|
None
|
Robert W. D’Alelio
|
Managing Director
|
None
|
Derek Devens
|
Managing Director
|
None
|
Daniel Doyle
|
Managing Director
|
None
|
Ingrid Dyott
|
Managing Director
|
None
|
Steven Eisman
|
Managing Director
|
None
|
Michael Foster
|
Managing Director
|
None
|
Jacob Gamerman
|
Managing Director
|
None
|
Rand W. Gesing
|
Senior Vice President
|
None
|
Jennifer Gorgoll
|
Managing Director
|
None
|
Michael C. Greene
|
Managing Director
|
None
|
Jeffrey Hunn
|
Senior Vice President
|
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
|
Eric Knutzen
|
Managing Director
|
None
|
Christopher Kocinski
|
Managing Director
|
None
|
David Kupperman
|
Managing Director
|
None
|
Nathan Kush
|
Managing Director
|
None
|
Sajjad S. Ladiwala
|
Managing Director
|
None
|
David Levine
|
Senior Vice President
|
None
|
NAME | POSITIONS AND OFFICES WITH UNDERWRITER |
POSITIONS AND OFFICES WITH REGISTRANT |
Richard S. Levine
|
Managing Director
|
None
|
Joseph Lind
|
Managing Director
|
None
|
Brian Lord
|
Senior Vice President
|
None
|
James Lyman
|
Managing Director
|
None
|
Joseph P. Lynch
|
Managing Director
|
None
|
Jeffrey Majit
|
Managing Director
|
None
|
Jared Mann
|
Managing Director
|
None
|
James F. McAree
|
Managing Director
|
None
|
Kevin McCarthy
|
Senior Vice President
|
Non
|
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
|
Eric J. Pelio
|
Senior Vice President
|
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
|
Ronald B. Silvestri
|
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
|
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
|
Robert Surgent
|
Managing Director
|
None
|
Brad Tank
|
Managing Director
|
None
|
Jason Tauber
|
Managing Director
|
None
|
Shawn Trudeau
|
Senior Vice President
|
None
|
Kenneth J. Turek
|
Managing Director
|
None
|
Anthony Tutrone
|
Managing Director
|
None
|
James Tyre
|
Senior Vice President
|
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 |
NAME | POSITIONS AND OFFICES WITH UNDERWRITER |
POSITIONS AND OFFICES
WITH REGISTRANT |
Peter Von Lehe
|
Managing Director
|
None
|
David Yi Wan
|
Senior Vice President
|
None
|
Richard Werman
|
Managing Director
|
None
|
Eric Zhou
|
Senior Vice President
|
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.
|
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 25, 2022
|
Joseph V. Amato
|
||
/s/ John M. McGovern
|
Treasurer and Principal Financial and
Accounting Officer
|
February 25, 2022
|
John M. McGovern
|
||
/s/ Michael J. Cosgrove
|
Trustee
|
February 25, 2022
|
Michael J. Cosgrove*
|
||
/s/ Marc Gary
|
Trustee
|
February 25, 2022
|
Marc Gary*
|
||
/s/ Martha C. Goss
|
Trustee
|
February 25, 2022
|
Martha C. Goss*
|
||
/s/ Michael M. Knetter
|
Trustee
|
February 25, 2022
|
Michael M. Knetter*
|
||
/s/ Deborah C. McLean
|
Trustee
|
February 25, 2022
|
Deborah C. McLean*
|
||
/s/ George W. Morriss
|
Trustee
|
February 25, 2022
|
George W. Morriss*
|
||
/s/ Tom D. Seip
|
Chairman of the Board and Trustee
|
February 25, 2022
|
Tom D. Seip*
|
||
/s/ James G. Stavridis
|
Trustee
|
February 25, 2022
|
James G. Stavridis*
|
|
NEUBERGER BERMAN CAYMAN COMMODITY FUND I LTD.
|
|
|
By:
|
/s/ Joseph V. Amato
|
|
|
Name:
|
Joseph V. Amato
|
|
|
Title:
|
Director
|
Signature
|
Title
|
Date
|
/s/ Joseph V. Amato
|
Director, Neuberger Berman
Cayman Commodity Fund I Ltd.
|
February 25, 2022
|
Joseph V. Amato
|
|
|
|
|
|
/s/ George W. Morriss
|
Director, Neuberger Berman
Cayman Commodity Fund I Ltd.
|
February 25, 2022
|
|
||
George W. Morriss*
|
|
|
|
NEUBERGER BERMAN CAYMAN ARMM FUND I LTD.
|
|
|
By:
|
/s/ Joseph V. Amato
|
|
|
Name:
|
Joseph V. Amato
|
|
|
Title:
|
Director
|
Signature
|
Title
|
Date
|
/s/ Joseph V. Amato
|
Director, Neuberger Berman
Cayman ARMM Fund I Ltd.
|
February 25, 2022
|
|
||
Joseph V. Amato
|
|
|
|
|
|
/s/ George W. Morriss
|
Director, Neuberger Berman
Cayman ARMM Fund I Ltd.
|
February 25, 2022
|
|
||
George W. Morriss*
|
|
|
Exhibit
Number
|
Description
|
(h)(10)
|
|
(h)(11)
|
|
(h)(12)
|
|
(h)(13)
|
|
(h)(14)
|
|
(h)(15)
|
|
(h)(16)
|
|
(h)(17)
|
|
(h)(18)
|
|
(h)(19)
|
|
(h)(20)
|
|
(h)(21)
|
|
(h)(22)
|
|
(i)
|
|
(j)(1)
|
|
(j)(2)
|
|
(p)(2)
|
|
(p)(4)
|
|
Very truly yours,
NEUBERGER BERMAN ALTERNATIVE FUNDS,
on behalf of
NEUBERGER BERMAN GLOBAL ALLOCATION FUND
NEUBERGER BERMAN LONG SHORT FUND
NEUBERGER BERMAN U.S. EQUITY INDEX PUTWRITE STRATEGY FUND
|
|
By:
Name:
Title:
|
/s/ Joseph V. Amato
Joseph V. Amato
Chief Executive Officer and President |
NEUBERGER BERMAN INVESTMENT ADVISERS LLC | |
By:
Name:
Title:
|
/s/ Joseph V. Amato
Joseph V. Amato President and Chief Investment Officer -- Equities |
Fund
|
Class
|
Limitation
Period
|
Expense
Limitation
|
Neuberger Berman Global Allocation Fund
|
Class A
|
10/31/2025
|
1.11%
|
Class C
|
10/31/2025
|
1.86%
|
|
Institutional
|
10/31/2025
|
0.75%
|
|
Class R6
|
10/31/2025
|
0.65%
|
|
10/31/2025
|
|||
Neuberger Berman Long Short Fund
|
Class A
|
10/31/2025
|
2.06%
|
Class C
|
10/31/2025
|
2.81%
|
|
Institutional
|
10/31/2025
|
1.70%
|
|
10/31/2025
|
|||
10/31/2025
|
|||
10/31/2025
|
|||
Neuberger Berman U.S. Equity Index PutWrite Strategy Fund
|
Class A
|
10/31/2025
|
1.01%
|
Class C
|
10/31/2025
|
1.76%
|
|
Institutional
|
10/31/2025
|
0.65%
|
|
Class R6
|
10/31/2025
|
0.55%
|
|
Very truly yours,
NEUBERGER BERMAN ALTERNATIVE FUNDS,
on behalf of
NEUBERGER BERMAN COMMODITY STRATEGY FUND
|
|
|
By:
|
/s/ Joseph V. Amato
|
||
NEUBERGER BERMAN CAYMAN COMMODITY FUND I LTD. | |||
By:
|
/s/ Joseph V. Amato
Name: Joseph V. Amato
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 Commodity Strategy Fund*
|
Class A
|
10/31/2025
|
1.09%
|
Class C
|
10/31/2025
|
1.84%
|
|
Institutional
|
10/31/2025
|
0.73%
|
|
|
Very truly yours,
|
|
|
NEUBERGER BERMAN ALTERNATIVE FUNDS
on behalf of
NEUBERGER BERMAN ABSOLUTE RETURN MULTI-MANAGER FUND
|
|||
By:
|
/s/ Joseph V. Amato
|
||
Name: | Joseph V. Amato | ||
Title: | Chief Executive Officer and President | ||
NEUBERGER BERMAN CAYMAN ARMM FUND I LTD. | |||
By: | /s/ Joseph V. Amato | ||
Name: | Joseph V. Amato | ||
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
|
10/31/2025
|
2.33%
|
Class C
|
10/31/2025
|
3.08%
|
|
Institutional
|
10/31/2025
|
1.97%
|
|
Class R6
|
10/31/2025
|
1.87%
|
|
Very truly yours,
NEUBERGER BERMAN ALTERNATIVE FUNDS,
on behalf of
NEUBERGER BERMAN ABSOLUTE RETURN MULTI-MANAGER FUND
Name: Brian Kerrane
Title: Chief Operating Officer
|
Fund
|
Class
|
Limitation Period
|
Advisory Fee After
Waiver
|
Neuberger Berman Absolute Return Multi-Manager Fund
|
E
|
October 31, 2023
|
0.00%
|
1.
|
Terms of Investment.
|
(a)
|
In order to help reasonably address the risk of undue influence on an Acquired Fund by an Acquiring Fund, and to assist the Acquired Fund’s investment adviser with making the required findings under the Rule, each Acquiring Fund and
each Acquired Fund agree as follows:
|
(i)
|
In-kind redemptions. The Acquiring Fund acknowledges and agrees that, if and to the extent consistent with the Acquired Fund’s registration statement, as amended from time to time, the Acquired
Fund may honor any redemption request partially or wholly in-kind in the sole discretion of the Acquired Fund (which discretion of the Acquired Fund shall include the selection of portfolio securities to distribute in-kind), even where
such Acquired Fund does not ordinarily satisfy redemption requests in-kind (particularly in the case of Acquired Funds that are not exchange-traded funds).
|
(ii)
|
Timing/advance notice of redemptions.
|
1.
|
With respect to Enumerated Funds (as defined on Schedule B), the Acquiring Fund will use reasonable efforts to provide the required advanced notification specified in the 12d1-4 List (as defined below). Such notice shall be provided to
the Acquired Fund(s) whenever practicable and consistent with the Acquiring Fund’s best interests. This provision shall only apply in connection with any investment made by an Acquiring Fund in an Acquired Fund in excess of the limits in
Section 12(d)(1)(A)(i) of the 1940 Act. For the avoidance of doubt, in the instance where the Acquired Fund is an exchange-traded fund, the requirements of this paragraph (1) shall not apply to transactions in which an Acquiring Fund did
not know or have reason to know that such transaction would result in a redemption transaction with the Acquired Fund (such as where an Acquiring Fund sells shares in the secondary market).
|
2.
|
The Acquired Fund acknowledges and agrees that any notification provided pursuant to the foregoing is not a commitment to redeem and constitutes an estimate that may differ materially from the amount, timing and manner in which a
redemption request is submitted, if any.
|
(iii)
|
Scale of investment. Upon a reasonable request by an Acquired Fund, the Acquiring Fund will provide summary information regarding the anticipated timeline of its investment in the Acquired Fund
and the scale of its contemplated investments in the Acquired Fund.
|
(b)
|
In order to assist the Acquiring Fund’s investment adviser with evaluating the complexity of the structure and fees and expenses associated with an investment in an Acquired Fund, each Acquired Fund shall provide each Acquiring Fund
with information on the fees and expenses of the Acquired Fund reasonably requested by the Acquiring Fund with reference to the Rule. Such fee and expense information shall be limited to that which is made publicly available by the
Acquired Fund.
|
2.
|
Representations of the Acquired Funds.
|
3.
|
Representations of the Acquiring Funds.
|
(a)
|
In connection with any investment by an Acquiring Fund in an Acquired Fund in excess of the limitations in Section 12(d)(1)(A), the Acquiring Fund agrees to: (i) comply with all conditions of the Rule, as interpreted or modified by the
SEC or its Staff from time to time, applicable to Acquiring Funds; (ii) comply with its obligations under this Agreement; and (iii) promptly notify the Acquired Fund if such Acquiring Fund fails to comply with the Rule with respect to its
investment in such Acquired Fund, as interpreted or modified by the SEC or its Staff from time to time, or this Agreement.
|
(b)
|
An Acquiring Fund shall promptly notify an Acquired Fund:
|
i.
|
of any purchase or acquisition of shares in an Acquired Fund that causes such Acquiring Fund to hold 3% or more of such Acquired Fund’s total outstanding voting securities;
|
ii.
|
of any purchase or acquisition of shares in an Acquired Fund that causes such Acquiring Fund to hold 5% or more of such Acquired Fund’s total outstanding voting securities;
|
iii.
|
where an Acquiring Fund and its Advisory Group (as defined in the Rule), individually or in the aggregate, hold more than 25% of such Acquired Fund’s total outstanding voting securities; and
|
iv.
|
if at any time an Acquiring Fund no longer holds voting securities of an Acquired Fund in excess of an amount noted in (i), (ii), or (iii) above.
|
(c)
|
Notwithstanding anything herein to the contrary, any Acquiring Fund that has an “affiliated person” (as defined under the 1940 Act) that is: (i) a broker-dealer, (ii) a broker-dealer or bank that borrows as part of a securities lending
program, or (iii) a futures commission merchant or a swap dealer, will: (a) not make an investment in an Acquired Fund that causes such Acquiring Fund to hold 5% or more of such Acquired Fund’s total outstanding voting securities without
prior approval from the Acquired Fund, and (b) notify the Acquired Fund if any investment by the Acquiring Fund that complied with (a) at the time of purchase no longer complies.
|
(d)
|
The requirements set forth in Sections 3(b)(i), 3(b)(ii), and 3(c) shall not apply where the Acquiring Fund’s full portfolio is sub-advised by any affiliate of BlackRock, Inc.
|
(e)
|
An Acquiring Fund shall provide an Acquired Fund with information regarding the amount of such Acquiring Fund’s investments in the Acquired Fund, and information regarding affiliates of the Acquiring Fund, upon the Acquired Fund’s
reasonable request.
|
(f)
|
Each Acquiring Fund acknowledges that it may not rely on this Agreement to invest in the Ineligible Funds (as defined in Schedule B) and that the Enumerated Funds are subject to certain additional conditions described on the list of
Ineligible Funds and Enumerated Funds (the “12d1-4 List”). Each Acquiring Fund acknowledges that the 12d1-4 List is available as described in Schedule B, and
|
4.
|
Indemnification.
|
(a)
|
Each Acquiring Fund agrees to hold harmless and indemnify each Acquired Fund, including any of its principals, directors or trustees, officers, employees and agents, against and from any and all losses, expenses or liabilities incurred
by or claims or actions (“Claims”) asserted against the Acquired Fund, including any of their principals, directors or trustees, officers, employees and agents, to the extent such Claims result from a violation or alleged violation by
such Acquiring Fund of any provision of this Agreement, such indemnification to include any reasonable counsel fees and expenses incurred in connection with investigating and/or defending such Claims; provided that no Acquiring Fund shall
be liable for indemnifying any Acquired Fund for any Claims resulting from violations that occur directly as a result of incomplete or inaccurate information provided by the Acquired Fund to such Acquiring Fund pursuant to terms and
conditions of this Agreement.
|
(b)
|
Each Acquired Fund agrees to hold harmless and indemnify an Acquiring Fund, including any of its principals, directors or trustees, officers, employees and agents, against and from any and all losses, expenses or liabilities incurred
by or Claims asserted against the Acquiring Fund, including any of its principals, directors or trustees, officers, employees and agents, to the extent such Claims result from a violation or alleged violation by such Acquired Fund of any
provision of this Agreement, such indemnification to include any reasonable counsel fees and expenses incurred in connection with investigating and/or defending such Claims; provided that no Acquired Fund shall be liable for indemnifying
any Acquiring Fund for any Claims resulting from violations that occur directly as a result of incomplete or inaccurate information provided by the Acquiring Fund to such Acquired Fund pursuant to terms and conditions of this Agreement.
|
(c)
|
Any liability pursuant to the forgoing provisions shall be several and not joint. In any action involving the parties under this Agreement, the parties agree to look solely to the individual series of the Acquiring Fund(s) or Acquired
Fund(s) that is/are involved in the matter in controversy and not to any other series.
|
5.
|
Use of Name.
|
(a)
|
To the extent an Acquiring Fund refers to one or more Acquired Funds in any prospectus, statement of additional information or otherwise (but not in the financial statements of the Acquiring Fund when the Acquired Fund is listed as a
holding), each Acquiring Fund agrees to:
|
i.
|
Refer to such Acquired Fund by its legal name, for example, the “iShares® [Index Provider (when required)] [Exposure] ETF” (e.g., iShares U.S. Financial Services ETF or iShares Core S&P 500 ETF or iShares MSCI ACWI ETF) upon first
reference to such Acquired Fund, and by its legal name or its ticker symbol for subsequent references; and
|
ii.
|
include the following notice within reasonable proximity to the first reference to such Acquired Fund, as applicable:
|
(b)
|
No Acquiring Fund shall use the name or any tradename, trademark, service mark, symbol or any abbreviation, contraction or simulation thereof of the Acquired Fund, BlackRock or any of their affiliates in its shareholder communications,
advertising, sales literature and similar communications (other than a prospectus, statement of additional information, fact sheet or similar disclosure document, or shareholder report) unless it first receives prior written approval
(including approval through written electronic communications) of the Acquired Fund or BlackRock. Additionally, no Acquiring Fund shall use any logo of the Acquired Fund or of BlackRock without entering into a separate trademark license
agreement with BlackRock.
|
6.
|
Notices.
|
If to the Acquiring Funds:
|
If to the Acquired Funds:
|
As set forth on Schedule C
|
iShares ETFs:
Email: Group12d14@blackrock.com
BlackRock Mutual Funds and Active ETFs:
Email: GroupOfficeofRegisteredFunds@blackrock.com
|
7.
|
Additional Acquiring Funds.
|
8.
|
Governing Law; Counterparts.
|
(a)
|
This Agreement will be governed by Delaware law without regard to choice of law principles.
|
(b)
|
This Agreement may be executed in two or more counterparts, each of which shall be deemed an original, but all of which together shall constitute one and the same instrument. An electronic copy of a
signature received in Portable Document Format (PDF) or a copy of a signature received via a fax machine shall be deemed to be of the same force and effect as an original signature on an original executed document.
|
9.
|
Term and Termination; Assignment; Amendment.
|
(a)
|
This Agreement shall be effective for the duration of the Acquired Funds’ and the Acquiring Funds’ reliance on the Rule, as interpreted or modified by the SEC or its Staff from time to time. While the terms of the Agreement shall only
be applicable to investments in Funds made in reliance on the Rule, as interpreted or modified by the SEC or its Staff from time to time, the Agreement shall continue in effect until terminated pursuant to Section 9(b).
|
(b)
|
This Agreement shall continue until terminated in writing by either party upon 30 days’ notice to the other party. Upon termination of this Agreement, the Acquiring Fund may not purchase additional shares of the Acquired Fund beyond
the Section 12(d)(1)(A) limits in reliance on the Rule.
|
(c)
|
This Agreement may not be assigned by either party without the prior written consent of the other.
|
(d)
|
Other than as set forth in Sections 6 and 7 above, this Agreement may be amended only by a writing that is signed by each affected party.
|
(e)
|
In the case of any Acquiring Fund or Acquired Fund organized as a Massachusetts business trust (each, a “Massachusetts Trust”), a copy of the Declaration of Trust of each Massachusetts Trust is on file with the Secretary of The
Commonwealth of Massachusetts, and notice is hereby given that no trustee, officer, employee, agent, employee or shareholder of a Massachusetts Trust shall have any personal liability under this Agreement, and that this Agreement is
binding only upon the assets and property of the applicable series of each Massachusetts Trust. For the avoidance of doubt, no director, trustee, officer, employee, agent, employee or shareholder of any other Registrant shall have any
personal liability under this Agreement, and that this Agreement is binding only upon the assets and property of the applicable series of each such Registrant.
|
10.
|
Termination of Prior Agreements. The execution of this Agreement shall be deemed to constitute the termination as of the Effective Date of any and all prior agreements between an Acquiring Fund and an Acquired Fund that relates to the
investment by any Acquiring Fund in any Acquired Fund in reliance on a participation agreement, exemptive order or other arrangement among the parties intended to achieve compliance with Section 12(d)(1) of the 1940 Act (the “Prior
Section 12 Agreements”). The parties hereby waive any notice
|
By: |
/s/ Brian Kerrane |
|
|
|
|
Name: |
Brian Kerrane |
|
|
|
|
Title: |
Vice President |
|
By: |
/s/ Jennifer McGovern |
|
Name: |
Jennifer McGovern |
|
Title: |
Vice President |
|
By: |
/s/ Paul C. Lohrey |
|
Name: |
Paul C. Lohrey |
|
Title: |
Assistant Secretary |
|
Fund Name
|
Ticker
|
CUSIP
|
Neuberger Berman Long Short Fund
Institutional Class
|
NLSIX | 64128R608 |
1. |
Terms of Investment
|
2. |
Representations of the Acquired Funds.
|
3. |
Representations and warranties of the Acquiring Funds.
|
4. |
Termination of Purchasing Fund Agreement.
|
5. |
Notices.
|
If to the Acquiring Fund: | If to the Acquired Fund: |
|
|
Neuberger Berman - Mutual Funds
c/o Neuberger Berman Investment Advisors LLC
1290 Avenue of the Americas
New York, NY 10104
Attn: General Counsel
Email: NB_Fund_of_Funds@nb.com
|
Invesco ETFs
3500 Lacey Road, Suite 700
Attn: General Counsel
Email: 12d-1request@invesco.com
With a copy to: Client Contracts
Email: dealersupport@invesco.com
|
6. |
Term and Termination; Assignment; Amendment
|
7. |
Miscellaneous
|
Brian Kerrane |
Brian Kerrane |
/s/ Brian Kerrane |
|
Name of Authorized Signer | Signature |
|
|
Title:Vice President |
|
|
|
Adam Henkel |
Adam Henkel |
/s/ Adam Henkel |
|
Name of Authorized Signer | Signature |
|
|
Title:Vice President |
|
|
|
1. |
Terms of Investment
|
2. |
Covenants of the Acquired Fund
|
3. |
Covenants of the Acquiring Fund
|
4. |
Notices
|
If to the Acquiring Fund:
|
If to the Acquired Fund:
|
Neuberger Berman - Mutual Funds
Attn: Mutual Fund Administration
1290 Avenue of the Americas
New York, NY 10104
Email: NB_Fund_of_Funds@nb.com
With a copy to:
Neuberger Berman -
General Counsel, Mutual Funds
1290 Avenue of the Americas
New York, NY 10104
Email: NB_Fund_of_Funds@nb.com
|
State Street Global Advisors
One Iron Street
Boston, MA 02210
Attn: Global Funds Management
Email: NewFoFRule@SSGA.com
With a copy to:
State Street Global Advisors
One Iron Street
Boston, MA 02210
Attn: Legal Department
Email: NewFoFRule@SSGA.com
|
5. |
Term and Termination; Assignment; Amendment
|
6. |
Indemnification
|
7. |
Additional Funds
|
8. |
Severability
|
9. |
Governing Law
|
10. |
Consequential Damages
|
11. |
Entire Agreement
|
By: |
/s/ Ann M. Carpenter |
|
|
|
|
Name:
|
Ann M. Carpenter |
|
Title: |
Deputy Treasurer |
|
By: |
/s/ Brian Kerrane |
|
|
|
|
Name:
|
Brian Kerrane |
|
Title: |
COO Funds - Vice President |
|
Fund Name
|
Ticker
|
Trust Name
|
The Communication Services Select Sector SPDR Fund
|
XLC
|
The Select Sector SPDR Trust
|
The Consumer Discretionary Select Sector SPDR Fund
|
XLY
|
The Select Sector SPDR Trust
|
The Consumer Staples Select Sector SPDR Fund
|
XLP
|
The Select Sector SPDR Trust
|
The Energy Select Sector SPDR Fund
|
XLE
|
The Select Sector SPDR Trust
|
The Financial Select Sector SPDR Fund
|
XLF
|
The Select Sector SPDR Trust
|
The Health Care Select Sector SPDR Fund
|
XLV
|
The Select Sector SPDR Trust
|
The Industrial Select Sector SPDR Fund
|
XLI
|
The Select Sector SPDR Trust
|
The Materials Select Sector SPDR Fund
|
XLB
|
The Select Sector SPDR Trust
|
The Real Estate Select Sector SPDR Fund
|
XLRE
|
The Select Sector SPDR Trust
|
The Technology Select Sector SPDR Fund
|
XLK
|
The Select Sector SPDR Trust
|
The Utilities Select Sector SPDR Fund
|
XLU
|
The Select Sector SPDR Trust
|
1. |
Terms of Investment
|
2. |
Covenants of the Acquired Fund
|
3. |
Covenants of the Acquiring Fund
|
4. |
Notices
|
If to the Acquiring Fund:
|
If to the Acquired Fund:
|
Neuberger Berman - Mutual Funds
Attn: Mutual Fund Administration
1290 Avenue of the Americas
New York, NY 10104
Email: NB_Fund_of_Funds@nb.com
|
State Street Global Advisors
One Iron Street Boston, MA 02210
Attn: Global Funds Management
Email: NewFoFRule@SSGA.com
|
With a copy to:
Neuberger Berman -
General Counsel, Mutual Funds
1290 Avenue of the Americas
New York, NY 10104
Email: NB_Fund_of_Funds@nb.com
|
With a copy to:
State Street Global Advisors
One Iron Street
Boston, MA 02210
Attn: Legal Department
Email: NewFoFRule@SSGA.com
|
5. |
Term and Termination; Assignment; Amendment
|
6. |
Indemnification
|
7. |
Additional Funds; Removal of Funds
|
8. |
Severability
|
9. |
Governing Law
|
10. |
Consequential Damages
|
11. |
Entire Agreement
|
By: |
/s/ Ann M. Carpenter |
|
|
|
|
Name:
|
Ann M. Carpenter |
|
Title: |
Vice President / Deputy Treasurer |
|
By: |
/s/ Brian Kerrane |
|
|
|
|
Name:
|
Brian Kerrane |
|
Title: |
COO - Funds – Vice President |
|
Fund Name |
Ticker |
Trust |
SPDR Dow Jones International Real Estate ETF
|
RWX
|
SPDR Index Shares Funds
|
SPDR Dow Jones Global Real Estate ETF
|
RWO
|
SPDR Index Shares Funds
|
SPDR EURO STOXX 50 ETF
|
FEZ
|
SPDR Index Shares Funds
|
SPDR MSCI ACWI ex-US ETF
|
CWI
|
SPDR Index Shares Funds
|
SPDR Portfolio MSCI Global Stock Market ETF
|
SPGM
|
SPDR Index Shares Funds
|
SPDR MSCI ACWI Low Carbon Target ETF
|
LOWC
|
SPDR Index Shares Funds
|
SPDR MSCI EAFE Fossil Fuel Reserves Free ETF
|
EFAX
|
SPDR Index Shares Funds
|
SPDR MSCI EAFE StrategicFactors ETF
|
QEFA
|
SPDR Index Shares Funds
|
SPDR MSCI Emerging Markets Fossil Fuel Reserves Free ETF
|
EEMX
|
SPDR Index Shares Funds
|
SPDR MSCI Emerging Markets StrategicFactors ETF
|
QEMM
|
SPDR Index Shares Funds
|
SPDR MSCI World StrategicFactors ETF
|
QWLD
|
SPDR Index Shares Funds
|
SPDR S&P Emerging Asia Pacific ETF
|
GMF
|
SPDR Index Shares Funds
|
SPDR S&P North American Natural Resources ETF
|
NANR
|
SPDR Index Shares Funds
|
SPDR S&P China ETF
|
GXC
|
SPDR Index Shares Funds
|
SPDR Portfolio Developed World ex-US ETF
|
SPDW
|
SPDR Index Shares Funds
|
SPDR S&P International Small Cap ETF
|
GWX
|
SPDR Index Shares Funds
|
SPDR Portfolio Emerging Markets ETF
|
SPEM
|
SPDR Index Shares Funds
|
SPDR S&P Emerging Markets Dividend ETF
|
EDIV
|
SPDR Index Shares Funds
|
SPDR S&P Emerging Markets Small Cap ETF
|
EWX
|
SPDR Index Shares Funds
|
SPDR S&P Global Dividend ETF
|
WDIV
|
SPDR Index Shares Funds
|
SPDR S&P Global Infrastructure ETF
|
GII
|
SPDR Index Shares Funds
|
SPDR S&P Global Natural Resources ETF
|
GNR
|
SPDR Index Shares Funds
|
SPDR S&P International Dividend ETF
|
DWX
|
SPDR Index Shares Funds
|
SPDR Portfolio Europe ETF
|
SPEU
|
SPDR Index Shares Funds
|
SPDR Bloomberg Barclays 1-10 Year TIPS ETF
|
TIPX
|
SPDR Series Trust
|
SPDR Bloomberg Barclays 1-3 Month T-Bill ETF
|
BIL
|
SPDR Series Trust
|
SPDR Bloomberg Barclays Short Term International Treasury Bond ETF
|
BWZ
|
SPDR Series Trust
|
SPDR Portfolio Short Term Treasury ETF
|
SPTS
|
SPDR Series Trust
|
SPDR Portfolio Intermediate Term Treasury ETF
|
SPTI
|
SPDR Series Trust
|
SPDR Bloomberg Barclays 3-12 Month T-Bill ETF
|
BILS
|
SPDR Series Trust
|
SPDR Bloomberg Barclays Emerging Markets Local Bond ETF
|
EBND
|
SPDR Series Trust
|
SPDR Bloomberg Barclays Emerging Markets USD Bond ETF
|
EMHC
|
SPDR Series Trust
|
SPDR Bloomberg Barclays International Corporate Bond ETF
|
IBND
|
SPDR Series Trust
|
SPDR Bloomberg Barclays International Treasury Bond ETF
|
BWX
|
SPDR Series Trust
|
SPDR Bloomberg Barclays High Yield Bond ETF
|
JNK
|
SPDR Series Trust
|
SPDR Portfolio Intermediate Term Corporate Bond ETF
|
SPIB
|
SPDR Series Trust
|
SPDR Portfolio Long Term Corporate Bond ETF
|
SPLB
|
SPDR Series Trust
|
SPDR Portfolio Long Term Treasury ETF
|
SPTL
|
SPDR Series Trust
|
SPDR Nuveen Bloomberg Barclays Short Term Municipal Bond ETF
|
SHM
|
SPDR Series Trust
|
SPDR Nuveen Bloomberg Barclays Municipal Bond ETF
|
TFI
|
SPDR Series Trust
|
SPDR Nuveen Bloomberg Barclays High Yield Municipal Bond ETF
|
HYMB
|
SPDR Series Trust
|
SPDR Portfolio Short Term Corporate Bond ETF
|
SPSB
|
SPDR Series Trust
|
SPDR Portfolio Aggregate Bond ETF
|
SPAB
|
SPDR Series Trust
|
SPDR Bloomberg Barclays Convertible Securities ETF
|
CWB
|
SPDR Series Trust
|
SPDR Bloomberg Barclays Investment Grade Floating Rate ETF
|
FLRN
|
SPDR Series Trust
|
SPDR Portfolio TIPS ETF
|
SPIP
|
SPDR Series Trust
|
SPDR Portfolio Mortgage Backed Bond ETF
|
SPMB
|
SPDR Series Trust
|
SPDR Portfolio Corporate Bond ETF
|
SPBO
|
SPDR Series Trust
|
SPDR Bloomberg Barclays Short Term High Yield Bond ETF
|
SJNK
|
SPDR Series Trust
|
SPDR Bloomberg SASB Corporate Bond ESG Select ETF
|
RBND
|
SPDR Series Trust
|
SPDR Dow Jones REIT ETF
|
RWR
|
SPDR Series Trust
|
SPDR FactSet Innovative Technology ETF
|
XITK
|
SPDR Series Trust
|
SPDR FTSE International Government Inflation-Protected Bond ETF
|
WIP
|
SPDR Series Trust
|
SPDR Global Dow ETF
|
DGT
|
SPDR Series Trust
|
SPDR Portfolio High Yield Bond ETF
|
SPHY
|
SPDR Series Trust
|
SPDR ICE Preferred Securities ETF
|
PSK
|
SPDR Series Trust
|
SPDR MSCI USA StrategicFactors ETF
|
QUS
|
SPDR Series Trust
|
SPDR NYSE Technology ETF
|
XNTK
|
SPDR Series Trust
|
SPDR Russell 1000 Low Volatility Focus ETF
|
ONEV
|
SPDR Series Trust
|
SPDR Russell 1000 Momentum Focus ETF
|
ONEO
|
SPDR Series Trust
|
SPDR Russell 1000 Yield Focus ETF
|
ONEY
|
SPDR Series Trust
|
SPDR S&P 1500 Value Tilt ETF
|
VLU
|
SPDR Series Trust
|
SPDR S&P 1500 Momentum Tilt ETF
|
MMTM
|
SPDR Series Trust
|
SPDR S&P 500 ESG ETF
|
EFIV
|
SPDR Series Trust
|
SPDR S&P 500 Fossil Fuel Reserves Free ETF
|
SPYX
|
SPDR Series Trust
|
SPDR Portfolio S&P 500 Growth ETF
|
SPYG
|
SPDR Series Trust
|
SPDR Portfolio S&P 500 High Dividend ETF
|
SPYD
|
SPDR Series Trust
|
SPDR Portfolio S&P 500 ETF
|
SPLG
|
SPDR Series Trust
|
SPDR Portfolio S&P 500 Value ETF
|
SPYV
|
SPDR Series Trust
|
SPDR S&P Aerospace & Defense ETF
|
XAR
|
SPDR Series Trust
|
SPDR S&P Bank ETF
|
KBE
|
SPDR Series Trust
|
SPDR S&P Biotech ETF
|
XBI
|
SPDR Series Trust
|
SPDR S&P Capital Markets ETF
|
KCE
|
SPDR Series Trust
|
SPDR Portfolio S&P 1500 Composite Stock Market ETF
|
SPTM
|
SPDR Series Trust
|
SPDR S&P Health Care Equipment ETF
|
XHE
|
SPDR Series Trust
|
SPDR S&P Health Care Services ETF
|
XHS
|
SPDR Series Trust
|
SPDR S&P Dividend ETF
|
SDY
|
SPDR Series Trust
|
SPDR S&P Homebuilders ETF
|
XHB
|
SPDR Series Trust
|
SPDR S&P Insurance ETF
|
KIE
|
SPDR Series Trust
|
SPDR S&P Internet ETF
|
XWEB
|
SPDR Series Trust
|
SPDR S&P Kensho Clean Power ETF
|
CNRG
|
SPDR Series Trust
|
SPDR S&P Kensho Final Frontiers ETF
|
ROKT
|
SPDR Series Trust
|
SPDR S&P Kensho Future Security ETF
|
FITE
|
SPDR Series Trust
|
SPDR S&P Kensho Intelligent Structures ETF
|
SIMS
|
SPDR Series Trust
|
SPDR S&P Kensho New Economies Composite ETF
|
KOMP
|
SPDR Series Trust
|
SPDR S&P Kensho Smart Mobility ETF
|
HAIL
|
SPDR Series Trust
|
SPDR S&P Metals & Mining ETF
|
XME
|
SPDR Series Trust
|
SPDR S&P 400 Mid Cap Growth ETF
|
MDYG
|
SPDR Series Trust
|
SPDR S&P 400 Mid Cap Value ETF
|
MDYV
|
SPDR Series Trust
|
SPDR Portfolio S&P 400 Mid Cap ETF
|
SPMD
|
SPDR Series Trust
|
SPDR S&P Oil & Gas Equipment & Services ETF
|
XES
|
SPDR Series Trust
|
SPDR S&P Oil & Gas Exploration & Production ETF
|
XOP
|
SPDR Series Trust
|
SPDR S&P Pharmaceuticals ETF
|
XPH
|
SPDR Series Trust
|
SPDR S&P Regional Banking ETF
|
KRE
|
SPDR Series Trust
|
SPDR S&P Retail ETF
|
XRT
|
SPDR Series Trust
|
SPDR S&P Semiconductor ETF
|
XSD
|
SPDR Series Trust
|
SPDR S&P 600 Small Cap ETF
|
SLY
|
SPDR Series Trust
|
SPDR S&P 600 Small Cap Growth ETF
|
SLYG
|
SPDR Series Trust
|
SPDR Portfolio S&P 600 Small Cap ETF
|
SPSM
|
SPDR Series Trust
|
SPDR S&P 600 Small Cap Value ETF
|
SLYV
|
SPDR Series Trust
|
SPDR S&P Software & Services ETF
|
XSW
|
SPDR Series Trust
|
SPDR S&P Telecom ETF
|
XTL
|
SPDR Series Trust
|
SPDR S&P Transportation ETF
|
XTN
|
SPDR Series Trust
|
SPDR SSGA Gender Diversity Index ETF
|
SHE
|
SPDR Series Trust
|
SPDR SSGA US Large Cap Low Volatility Index ETF
|
LGLV
|
SPDR Series Trust
|
SPDR SSGA US Small Cap Low Volatility Index ETF
|
SMLV
|
SPDR Series Trust
|
SPDR Nuveen Municipal Bond ETF
|
MBND
|
SSGA Active Trust
|
SPDR DoubleLine Total Return Tactical ETF
|
TOTL
|
SSGA Active Trust
|
SPDR SSGA Ultra Short Term Bond ETF
|
ULST
|
SSGA Active Trust
|
SPDR DoubleLine Emerging Markets Fixed Income ETF
|
EMTL
|
SSGA Active Trust
|
SPDR Blackstone Senior Loan ETF
|
SRLN
|
SSGA Active Trust
|
1. |
Terms of Investment
|
2. |
Covenants of the Acquired Fund
|
3. |
Covenants of the Acquiring Fund
|
4. |
Notices
|
If to the Acquiring Fund:
|
If to the Acquired Fund:
|
Neuberger Berman - Mutual Funds
Attn: Mutual Fund Administration
1290 Avenue of the Americas
New York, NY 10104
Email: NB_Fund_of_Funds@nb.com
|
State Street Global Advisors
One Iron Street
Boston, MA 02210
Attn: Global Funds Management
Email: NewFoFRule@SSGA.com
|
With a copy to:
Neuberger Berman -
General Counsel, Mutual Funds
1290 Avenue of the Americas
New York, NY 10104
Email: NB_Fund_of_Funds@nb.com
|
With a copy to:
State Street Global Advisors
One Iron Street
Boston, MA 02210
Attn: Legal Department
Email: NewFoFRule@SSGA.com
|
5. |
Term and Termination; Assignment; Amendment
|
6. |
Indemnification
|
7. |
Additional Funds
|
8. |
Severability
|
9. |
Governing Law
|
10. |
Consequential Damages
|
11. |
Entire Agreement
|
By: |
STATE STREET GLOBAL ADVISORS TRUST COMPANY, not in its general corporate capacity but solely as Trustee of each Acquired Fund
|
|
By: |
/s/ Ellen M Needham |
|
|
|
|
Name:
|
Ellen M Needham |
|
Title: |
Senior Managing Director |
|
By: |
/s/ Brian Kerrane |
|
|
|
|
Name:
|
Brian Kerrane |
|
Title: |
COO Funds – Vice President |
|
If to the Acquiring Fund:
Neuberger Berman Mutual Funds
c/o Mutual Fund Administration
1290 Avenue of the Americas
New York, NY 10104
Email: NB_Fund_of_Funds@nb.com
With a copy to:
Neuberger Berman -
General Counsel, Mutual Funds
1290 Avenue of the Americas
New York, NY 10104
|
If to the Acquired Fund:
VanEck Compliance Department
c/o Van Eck Associates Corporation 666 Third Avenue, 9th Floor
New York, NY 10017
Email: compliance@vaneck.com
With a copy to:
Van Eck Associates Corporation
Attn: Legal Dept.
666 Third Avenue, 9th Floor
New York, NY 10017
Email: legalnotices@vaneck.com
|
Signature
|
Name
|
Title
|
/s/ Laura I. Martínez
|
Laura I. Martínez
|
Vice President &
Associate General Counsel
|
1. |
Terms of Investment.
|
2. |
Representations of the Vanguard Funds.
|
3. |
Representations of the Investing Funds.
|
4. |
Indemnification.
|
5. |
Notices.
|
If to an Investing Fund:
|
If to a Vanguard Fund: |
|
|
Neuberger Berman Investment Advisers LLC
c/o Mutual Fund Administration
1290 Avenue of the Americas
New York, NY 10104
Attn: General Counsel – Mutual Funds
Email: NB_Fund_of_Funds@nb.com
|
ETF Counsel
The Vanguard Group, Inc.
Legal Department, V26
400 Devon Park Drive
Wayne, PA 19087
Fax: (610) 669-6600
Email: 12d1_Notices@vanguard.com
|
6. |
Term and Termination; Governing Law.
|
7. |
Miscellaneous.
|
Name of Authorized Signer | Signature | |
Title: Assistant Secretary | Michael Drayo | /s/ Michael Drayo |
By: |
/s/ Brian Kerrane |
|
|
|
|
Name:
|
Brian Kerrane |
|
Title: |
Vice President |
|
Acquiring Funds
|
Neuberger Berman Alternative Funds;
Neuberger Berman Equity Funds;
Neuberger Berman Income Funds ;
Neuberger Berman Advisors Management Trust; and
Neuberger Berman ETF Trust,
each on behalf of each of their current and future series
.
|
|
Large Cap
|
Ticker
|
Exp. Ratio %
|
U.S. LargeCap |
EPS | 0.08 | |
U.S. Quality Dividend Growth |
DGRW | 0.28 | |
U.S. Multifactor | USMF | 0.28 |
|
Mid & Small Cap
|
Ticker
|
Exp. Ratio %
|
U.S. MidCap | EZM | 0.38 | |
U.S. SmallCap | EES | 0.38 | |
U.S. SmallCap Quality Dividend Growth | DGRS | 0.38 |
Large Cap |
Ticker
|
Exp. Ratio %
|
|
U.S. LargeCap Dividend | DLN | 0.28 | |
U.S. Total Dividend | DTD | 0.28 | |
U.S. High Dividend | DHS | 0.38 | |
U.S. AI Enhanced Value | AIVL | 0.38 | |
U.S. Value | WTV |
0.12 |
Mid & Small Cap |
Ticker
|
Exp. Ratio %
|
|
U.S. MidCap Dividend | DON | 0.38 | |
U.S. SmallCap Dividend | DES | 0.38 |
Emerging Markets | Ticker | Exp. Ratio % | |
Emerging Markets High Dividend | DEM | 0.63 | |
Emerging Markets Quality Dividend Growth | DGRE | 0.32 | |
Emerging Markets Multifactor | EMMF |
0.48 |
|
Emerging Markets SmallCap Dividend | DGS |
0.58 |
International | Ticker | Exp. Ratio % | |
International Equity | DWM | 0.48 | |
International Multifactor | DWMF |
0.38 | |
Dynamic Currency Hedged International Equity | DDWM |
0.40 |
|
International LargeCap Dividend | DOL |
0.48 |
|
International AI Enhanced Value | AIVI |
0.58 |
|
International High Dividend | DTH | 0.58 | |
International Hedged Quality Dividend Growth | IHDG |
0.58 |
|
International Quality Dividend Growth | IQDG | 0.42 |
International Mid & Small Cap | Ticker | Exp. Ratio % | |
International SmallCap Dividend | DLS | 0.58 | |
Dynamic Currency Hedged International SmallCap Equity | DDLS | 0.48 | |
International MidCap Dividend | DIM | 0.58 |
Global | Ticker | Exp. Ratio % | |
Global ex-U.S. Quality Dividend Growth | DNL | 0.42 | |
Global High Dividend | DEW | 0.58 | |
Global ex-U.S. Real Estate | DRW | 0.58 |
Regional/Single Country | Ticker | Exp. Ratio % | |
Japan Hedged Equity | DXJ | 0.48 | |
Europe Hedged Equity | HEDJ | 0.58 | |
Europe Quality Dividend Growth | EUDG | 0.58 | |
Germany Hedged Equity | DXGE |
0.48 |
Regional/Single Country Small Cap | Ticker |
Exp. Ratio % | |
Japan SmallCap Dividend |
DFJ | 0.58 | |
Japan Hedged SmallCap Equity | DXJS | 0.58 | |
Europe SmallCap Dividend | DFE | 0.58 | |
Europe Hedged SmallCap Equity | EUSC |
0.58 |
Ticker | Exp. Ratio % | ||
U.S. ESG | RESP | 0.28 | |
Emerging Markets ESG | RESE | 0.32 | |
International ESG | RESD | 0.30 | |
Emerging Markets ex-State-Owned Enterprises | XSOE | 0.32 | |
China ex-State-Owned Enterprises | CXSE |
0.32 |
|
India ex-State-Owned Enterprises | IXSE |
0.58 |
Interest Rate Strategies | Ticker | Exp. Ratio % | |
Interest Rate Hedged U.S. Aggregate Bond | AGZD | 0.23 | |
Interest Rate Hedged High Yield Bond | HYZD | 0.43 |
Currency Strategies | Ticker | Exp. Ratio % | |
Emerging Currency Strategy | CEW | 0.55 | |
Bloomberg U.S. Dollar Bullish | USDU | 0.51 | |
Chinese Yuan Strategy | CYB | 0.45 |
Managed Futures | Ticker |
Exp. Ratio % | |
Managed Futures Strategy | WTMF | 0.65 |
Option-Based | Ticker | Exp. Ratio % | |
CBOE S&P 500 PutWrite Strategy | PUTW | 0.44 |
Commodity | Ticker | Exp. Ratio % | |
Enhanced Commodity Strategy1 | GCC | 0.55 |
Credit | Ticker | Exp. Ratio % | |
Alternative Income* | HYIN | 3.20 |
Target Range | Ticker | Exp. Ratio % | |
Target Range | GTR |
0.70 |
Core | Ticker | Exp. Ratio % | |
U.S. Efficient Core2 | NTSX | 0.20 | |
International Efficient Core |
NTSI | 0.26 |
|
Emerging Markets Efficient Core | NTSE | 0.38 |
Tactical | Ticker | Exp. Ratio % | |
Efficient Gold Plus Gold Miners Strategy | GMDN | 0.45 |
|
Ticker | Exp. Ratio % | |
Cloud Computing | WCLD | 0.45 | |
Cybersecurity | WCBR |
0.45 | |
BioRevolution | WDNA | 0.45 | |
Artificial Intelligence and Innovation | WTAI | 0.45 |
EXHIBIT (i) |
|
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 25, 2022
Page 2
|
|
Very truly yours,
/s/ K&L Gates LLP
|
|
/s/ TAIT, WELLER & BAKER LLP |
1.
|
The Companies named or described at the top of page one of the Code and all entities that are under common management with these Companies or otherwise agree to be subject to the Code ("Affiliates"). A
listing of the Affiliates, which is periodically updated, is attached as Exhibit A.
|
2. |
Any officer, director or employee of any Company, Affiliate or Fund Client (as defined below) whose job regularly involves him/her in the investment process. This includes the formulation and making of investment recommendations and
decisions, the purchase and sale of securities for Clients and the utilization of information about investment recommendations, decisions and trades. Due to the manner in which the Companies and the Affiliates conduct their business, every
employee should assume that he or she is subject to the Code unless the Compliance Officer specifies otherwise.1
|
3. |
With respect to all of the Companies, Affiliates and Fund Clients, any natural person who Controls any of the Companies, Affiliates or Fund Clients and who obtains information regarding the Companies' or the Affiliates' investment
recommendations or decisions. However, a person whose Control arises only as a result of his or her official position with such entity is excluded. Disinterested directors of Fund Clients and Independent Directors, for example, are excluded
from coverage under this item.
|
4. |
As an exception, the Code does not apply to any director, officer or employee of any Fund Client (such as certain of The Teton Westwood Funds) with respect to which the Companies' services do not
involve the formulation or making of investment recommendations or decisions or the execution of portfolio transactions if that person is also a director, officer or employee of any entity that does perform such services (such as Westwood
Management Corp.). These individuals are covered by codes of ethics adopted by such entities.
|
1. |
Access Persons. The (i)
Companies, (ii) the persons described in items (A)2 and (A)3 above and (iii) such person’s Immediate Family, other than those excluded by item (A)4 above.
|
2. |
Access Person Account. Other
than Client Accounts, includes all advisory, brokerage, trust or other accounts over which one or more Access Persons has (i) a substantial proportionate economic interest or (ii) Control. Control is defined as having investment and/or
trade discretion over the account.
|
3. |
Affiliated Mutual Funds.
Registered open-end investment companies or series thereof advised or sub-advised by any of the Companies or their Affiliates.
|
4. |
Associate Portfolio Managers.
Access Persons who are engaged in securities research and analysis for designated Clients or are responsible for investment recommendations for designated Clients but who are not principally responsible for investment decisions with respect
to any Client Accounts.
|
5. |
Clients. Persons that have
investment advisory accounts maintained with any of the Companies or Affiliates by any person, other than Access Person Accounts. However, Fund Clients covered by item (A)(4) above are considered Client Accounts only with respect to
employees specifically identified by the Compliance Officer as having regular information regarding investment recommendations or decisions or portfolio transactions for such Fund Clients.
|
6. |
Client Accounts. Shall mean
accounts of Clients (i) that are Controlled by an Access Person and (ii) in which no Access Person has a substantial proportionate economic interest; provided that, the Client pays a management,
advisory or any other similar arms-length fee to the Access Person and the beneficiary of the Client Account is not an Immediate Family member of an Access Person.
|
7. |
Companies. The companies named or described at the top of page one of the Code.
|
8. |
Compliance Officer. The
persons designated as the compliance officers of the Companies.
|
9. |
Covered Persons. The
Companies, the Access Persons and the persons described in items A(3) and (A)4 above.
|
10. |
Fund Clients. Clients that
are Affiliated Mutual Funds, Private Fund Clients or a series thereof.
|
11. |
Immediate Family. An Access
Person’s spouse and Minor Descendants; provided that, with respect to accounts for the benefit of Minor Descendants who are not also Minor Children, an Access Person Controls such account.
|
12. |
Independent Directors. A
director of any of the Companies or Affiliates, other than an investment advisor to a Fund Client, who would not be an "interested person" of any of such entities under Section 2(a)(19) of the Investment Company Act of 1940 but for the fact
that he or she serves as such a director and may own beneficially securities of any such entity constituting less than 5% of the voting securities thereof and may be an associated person of or own securities in a broker-dealer or parent
company thereof and who does not have any involvement in the day-to-day activities of any of the Companies or Fund Clients.
|
13. |
Minor Children. A child,
whether natural or via adoption, of an Access Person, under the age of twenty-one years.
|
14. |
Minor Descendants. Direct
descendants of an Access Person, whether natural or via adoption, under the age of twenty-one years.
|
15. |
Portfolio Managers. Access
Persons who are principally responsible for investment decisions with respect to any Client Accounts.
|
16. | Private Fund Client. Any Client the securities of which were offered or sold pursuant to Section 3(c)(1) or the 3(c)(7) of the Investment Company Act of 1940, as amended. |
17. |
Security. Any financial
instrument treated as a security for investment purposes and any related instrument such as a futures, forward or swap contract entered into with respect to one or more securities, a basket of or an index of securities or components of
securities. However, the term security does not include securities issued by the Government of the United States, bankers' acceptances, bank certificates of deposit, commercial paper and high quality short-term debt instruments, including
repurchase agreements, or shares of registered open-end investment companies. Shares of affiliated registered open-end investment companies are not securities but are subject to special rules under this Code.
|
C. |
Blackout Period
|
◾
|
Shares purchased by reinvestment of dividends or capital gain distributions;
|
◾
|
Shares purchased in rollover transactions;
|
◾
|
Shares purchased for automatic contribution election; and
|
◾
|
Shares purchased for automated account rebalance.
|
1.
|
Publicly traded non-convertible fixed income Securities rated at least "A";
|
2.
|
Publicly traded equity Securities having a market capitalization in excess of $1.0 billion;3
|
3.
|
Publicly traded equity Securities having a market capitalization in excess of $500 million if the transaction in question and the aggregate amount of such Securities and any related Securities purchased and
sold for the Access Person Account in question during the preceding 30 calendar days does not exceed 100 shares;
|
4.
|
Municipal Securities; and
|
5.
|
Securities transactions that the Compliance Officer concludes are being effected for federal, state or local income tax purposes.
|
6. |
The exercise of rights that were received pro rata with other security holders is exempt.
|
7. |
Securities issued by the United States Government, banker’s acceptances, bank certificates of deposit and commercial paper.
|
1. |
No Securities may be purchased or sold for any Access Person Account other than through the trading desk of G.research, LLC, unless express permission is granted by the Compliance Officer. Such permission may be granted only on the
condition that the third party broker supply the Compliance Officer, on a timely basis, duplicate copies of confirmations of all personal Securities transactions for such Access Person in the accounts maintained with such third party broker
and copies of periodic statements for all such accounts.
|
2. |
No Securities may be purchased or sold for any Access Person Account unless the particular transaction has been approved in writing by the Compliance Officer or, in his or her absence, the General Counsel of GAMCO Investors, Inc.,
Associated Capital Group, Inc. or their designees; or via an automated Compliance pre-clearance system. The Compliance Officer or a designee shall review reports from the trading desk (or, if applicable, confirmations from brokers) to assure
that all transactions effected for Access Person Accounts are effected in compliance with this Code. A Trading Approval Form, attached as Exhibit B, must be completed
|
and submitted to the Compliance Officer or a designee for approval prior to entry of an order.
|
3. |
After reviewing the proposed trade, the level of potential investment interest on behalf of Clients in the Security in question and the Companies' restricted lists, the Compliance Officer shall approve (or disapprove) a trading order on
behalf of an Access Person as expeditiously as possible. The Compliance Officer will generally approve transactions described in paragraph (G) above unless the Security in question or a related security is on the Restricted List or the
Compliance Officer believes for any other reason that the Access Person Account should not trade in such Security at such time.
|
4. |
Once an Access Person's Trading Approval Form is approved, the form must be forwarded to the trading desk (or, if a third party broker is permitted, to the Compliance Officer) for execution on the same day. If the Access Person's trading
order request is not approved, or is not executed on the same day it is approved, the clearance lapses although such trading order request may be resubmitted at a later date.
|
5. |
In the absence of the Compliance Officer, an Access Person may submit his or her Trading Approval Form to the General Counsel of GAMCO Investors, Inc., Associated Capital Group, Inc. or a designee; or via an automated Compliance
pre-clearance system. Trading approval for the Compliance Officer must be obtained from the General Counsel, and trading approval for the General Counsel must be obtained from the Compliance Officer or a designee. In no case will the
Trading Desk accept an order for an Access Person Account unless it is accompanied by a signed Trading Approval Form; or a Trading Approval Form generated by an automated Compliance pre-clearance system that approves the trade.
|
6.
|
The Compliance Officer shall review all Trading Approval Forms, all initial, quarterly and annual disclosure certifications and the trading activities on behalf of all Client Accounts with a view to ensuring
that all Covered Persons are complying with the spirit as well as the detailed requirements of this Code. The Compliance Officer will review all transactions in the market making accounts of G.research, LLC. and the error accounts of the
Companies and the Affiliates in order to ensure that such transactions are bona fide market making or error transactions or are conducted in accordance with the requirements of this Article II.
|
A.
|
Every Covered Person must submit a quarterly report (a form of which is appended as Exhibit C) containing the information set forth in paragraph (B) below with respect to transactions in
any Security or Affiliated Mutual Fund in which such Covered Person has or by reason of such transaction acquires, any direct or indirect beneficial ownership (as defined in Exhibit D) in the Security, or Affiliated Mutual Fund and with
respect to any account established by the Covered Person in which any Securities or Affiliated Mutual Funds were held for the direct or indirect benefit of the Covered Person; provided, however, that:
|
1.
|
a Covered Person who is required to make reports only because he or she is a director of one of the Fund Clients and who is a "disinterested" director thereof or who is an Independent Director need not make a
report with respect to any transactions other than those where he or she knew or should have known in the course of his or her duties as a director that any Fund Client has made or makes a purchase or sale of the same or a related Security,
or the investment adviser of any such Fund Client has considered causing any Fund Client to purchase or sell the same or a related Security, within 15 days before or after the purchase or sale of such Security or related Security by such
director.
|
2.
|
a Covered Person need not make a report with respect to any transaction effected for, and Securities and Affiliated Mutual Funds held in, any account over which such person does not have any direct or
indirect influence or control; and
|
3.
|
A Covered Person need not make a report with respect to any transaction in securities issued by the United States Government, banker’s acceptances, bank certificates of deposit and commercial paper.
|
4.
|
a Covered Person will be deemed to have complied with the requirements of this Article IV insofar as the Compliance Officer receives in a timely fashion duplicate monthly or quarterly brokerage statements or
transaction confirmations on which all transactions required to be reported hereunder are described.
|
B.
|
A Covered Person must submit the report required by this Article to the Compliance Officer no later than 30 days after the end of the calendar quarter in which the transaction or account
to which the report relates was effected or established, and the report must contain the date that the report is submitted.
|
1.
|
This report must contain the following information with respect to transactions:
|
a.
|
The date of the transaction, the title and number of shares and the principal amount of each Security and Affiliated Mutual Fund involved;
|
b.
|
The nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition);
|
c.
|
The price at which the transaction was effected; and
|
d.
|
The name of the broker, dealer or bank with or through whom the transaction was effected.
|
2.
|
This report must contain the following information with respect to accounts established:
|
C. |
Any report submitted to comply with the requirements of this Article IV may contain a statement that the report shall not be construed as an admission by the person making such report that he or she has any direct or indirect beneficial
ownership in the Security or Affiliated Mutual Fund to which the report relates. A person need not make any report under this Article IV with respect to transactions
|
effected for, and Securities, and Affiliated Mutual Funds held in, any account over which the person has no direct or indirect influence or control.
|
D. |
No later than 10 days after beginning employment with any of the Companies or Affiliates or otherwise becoming a Covered Person, each Covered Person (except for a "disinterested" director of the Fund Client or an Independent Director who
is required to submit reports under this Article IV solely by reason of being such a director) must submit a report, which must be current as of a date no more than 45 days prior to the date of beginning employment, containing the following
information:
|
1.
|
The title, number of shares and principal amount of each Security and Affiliated Mutual Fund in which the Covered Person had any direct or indirect beneficial ownership when the person
became a Covered Person;
|
2.
|
The name of any broker, dealer or bank with whom the Covered Person maintained an account in which any Securities and Affiliated Mutual Fund were held for the direct or indirect benefit of the Covered Person
as of the date the person became a Covered Person; and
|
3.
|
The date that the report is submitted.
|
E. |
Annually each Covered Person must certify that he or she has read and understood the Code and recognizes that he or she is subject to such Code. In addition, annually each Covered Person must certify that he or she has disclosed or
reported all personal Securities and Affiliated Mutual Fund transactions required to be disclosed or reported under the Code. Furthermore, each Covered Person (except for a "disinterested" director of the Fund Client or an Independent
Director who is required to submit reports under this Article IV solely by reason of being such a director) annually must submit a report containing the following information (which information must be current as of a date no more than 45
days before the report is submitted):
|
1.
|
The title, number of shares and principal amount of each Security and Affiliated Mutual Fund in which the Covered Person had any direct or indirect beneficial ownership held in an account
not previously disclosed other than a G.research, affiliated funds or a firm-sponsored retirement plan account;
|
2.
|
The name of any broker, dealer or bank with whom the Covered Person maintains an account in which any Securities and Affiliated Mutual Funds are held for the direct or indirect benefit of the Covered Person
in an account
|
|
other than a G.research, affiliated funds or a firm-sponsored retirement plan account; and
|
3.
|
The date that the report is submitted.
|
F. |
At least annually (or quarterly in the case of Items 4 and 5 below), each of the Companies that has a Fund Client or that provides principal underwriting services for a Fund Client shall, together with each Fund Client, furnish a written
report to the Board of Directors of the Fund Client that:
|
2. |
Certifies that the Companies have developed procedures concerning Covered Persons' personal trading activities and reporting requirements relevant to such Fund Clients that are reasonably necessary to prevent violations of the Code;
|
3. |
Recommends changes, if any, to the Fund Clients' or the Companies' Codes of Ethics or procedures;
|
4. |
Provides a summary of any material or substantive violations of this Code by Covered Persons with respect to such Fund Clients which occurred during the past quarter and the nature of any remedial action taken; and
|
5. |
Describes any material or significant exceptions to any provisions of this Code of Ethics as determined under Article VI below.
|
G. |
The Compliance Officer shall notify each employee of any of the Companies or Affiliates as to whether such person is considered to be an Access Person or Covered Person and shall notify each other person that is considered to be an Access
Person or Covered Person.
|
A.
|
Records of all violations of the Code and any action taken as a result of such violation;
|
B.
|
Records of all written acknowledgements of receipt of the Code for all Access Persons for a five-year period;
|
C.
|
A list of all staff members who are or have been Access Persons during the past five years; and
|
D.
|
Records of any decision and supporting reasons for approving the acquisition of securities by Access Persons in limited offerings.
|
Associated Capital Group, Inc.
|
Gabelli & Partners GmbH
Gabelli & Partners Italia LLC
Gabelli & Partners Italia L.P.
Gabelli & Partners Italia Management LLC
Gabelli & Partners Italia S.R.L.
|
Gabelli Arbitrage Holdings LLC
|
Gabelli Associates Fund
|
Gabelli Associates Fund II, LP
|
Gabelli Associates Limited
|
Gabelli Associates Limited II E
|
Gabelli Entertainment and Telecommunication Acquisition Corp.
Gabelli Fixed Income LLC
|
Gabelli Fund, LDC
|
Gabelli Global Partners, Ltd.
|
Gabelli Global Partners Master Fund, Ltd.
|
Gabelli Intermediate Credit Fund, LP
Gabelli Intermediate Credit Fund, Ltd.
|
Gabelli International Limited
Gabelli Investment Partners International LLC
Gabelli Japan K.K.
|
Gabelli Multimedia Partners, LP
|
Gabelli Performance Partnership LP
Gabelli Securities International Limited (U.K.)
|
Gabelli Securities International, Ltd. (Bermuda)
|
Gabelli Trading Holdings LLC
GAMA Capital Opportunities Ltd.
|
GAMA Capital Opportunities Master Ltd.
|
GAMA Capital Partners LP
GAMA Funds Holdings GmbH
GAMA Funds LLC
|
GAMA Select Energy Plus Master Fund, Ltd.
|
GAMCO Acquisitions LLC
|
GAMCO Asset Management (UK) Ltd.
|
GAMCO International Partners LLC
|
GAMCO Investors, Inc.
|
GAMCO Medical Opportunities, LP
|
Gemini Capital Management LLC
|
Gemini Capital Management Partners, LP
|
Gemini Global Partners, LP
Greenwich Acquisition LLC
Greenwich PMV Acquisition Corp.
|
Institutional Services Holdings, LLC
Morgan Group Holding Co.
|
MJG Associates, Inc.
MJG IV Ltd.
PMV Consumer Acquisition Corp.
PMV Consumer Acquisition Holding Company LLC
|
TRANSACTIONS
|
||||||
Securities
(Name and
Symbol)
|
Date of
Transaction
|
Whether Purchase, Sale,
Short Sale or Other
Type of Disposition or
Acquisition
|
Quantity of Securities
|
Price per Share
or Other Unit
|
Name of Broker/Dealer
with or through Whom
the Transaction
was Effected
|
Nature of
Ownership of Securities
|
NEW ACCOUNTS ESTABLISHED
|
||
Name of Broker, Dealer or Bank
|
Account Number
|
Date Account Established
|
☐
|
I do NOT have any accounts managed by a third party or trustee.3
|
☐ | I do have account(s) managed by a third party or trustee and I do NOT have trade or investment discretion over the account(s). I did not direct, suggest or consult a third party or trustee to make any purchases or sales of securities in the account(s) or trust during the previous calendar quarter.3 |
☐ | I do have account(s) managed by a third party or trustee and I have investment and/or trade discretion over at least one of the accounts or trusts and did direct, suggest or consult the manager to make purchases or sales of securities in the account(s) or trust(s) during the previous calendar quarter.3 |
SECURITIES HOLDINGS
|
|||
Securities (Name and Symbol)
|
Quantity of Securities
|
Name of Broker/Dealer Where
Securities Are Held
|
Nature of Ownership of
Securities
|
ACCOUNTS
|
|||
Name of Broker, Dealer or Bank
|
Account Number
|
☐
|
I do NOT have any accounts managed by a third party or trustee.3 |
☐
|
I do have account(s) managed by a third party or trustee and I do NOT have trade or investment discretion over the account(s). I did not direct, suggest or consult a third party or trustee to make any purchases or sales of securities in the account(s) or trust during the previous calendar quarter.3 |
☐
|
I do have account(s) managed by a third party or trustee and I have investment and/or trade discretion over at least one of the accounts or trusts and did direct, suggest or consult the manager to make purchases or sales of securities in the account(s) or trust(s) during the previous calendar quarter.3 |
A.
|
I (a Covered Person) hereby certify that I have read and understand the Code of Ethics, and recog-nize that I am subject to and I am in Compliance with its provi-sions. In addi-tion, I
hereby certify that I have dis-closed or reported all personal trans-actions in Securities and Affiliated Mutual Funds required to be disclosed or reported under the Code of Ethics. In addition, I have read and understand the firms’
Compliance Policies & Procedures Manual, Supervisory Policies & Procedures Manual, Code of Business Conduct, IT Staff Awareness and Whistleblower Policy posted on the firms’ Intranet website, and recognize that I am subject to and I
am in compliance with its provisions;
|
B.
|
Within the last ten years there have been no com-plaints or disciplinary actions filed against me by any regulated securities or commodities ex-change, any self-regulatory securities or commodi-ties
orga-nization, any attorney general, or any govern-mental office or agency regulating insurance, secu-rities, commodities or financial transac-tions in the United States, in any state of the United States, or in any other country;
|
C.
|
I have not within the last ten years been convicted of or acknowledged commission of any felony or misdemeanor arising out of my conduct as an employ-ee, salesperson, officer, director, insur-ance agent,
broker, dealer, underwriter, investment manager or investment advisor; and
|
D.
|
I have not been denied permission or otherwise enjoined by order, judgment or decree of any court of competent jurisdiction, regulated secu-rities or commodi-ties ex-change, self-regulatory securities or
commodities organi-zation or other federal or state regulatory author-ity from acting as an investment advisor, securities or commodities broker or dealer, commodity pool operator or trading advisor or as an affiliated person or employee of
any investment company, bank, insurance company or com-modity bro-ker, dealer, pool operator or trading advisor, or from engaging in or continuing any conduct or prac-tice in connection with any such activity or the purchase or sale of any
security.
|
E.
|
Unless I am exempt from filing an Annual Holdings Report (as a "disinterested" director of a Fund Client or an Independent Director of an Affiliate), I have attached a completed Annual Outside Accounts/Holdings Report which is accurate
as of a date no more than 45 days ago.
|
Print Name:
|
_______________________________________________
|
Signature: |
_______________________________________________ |
Date: |
_______________________________________________ |
Name: (Last name, First)
|
Job Title/Department:
|
_____________________________________________ |
_________________________________________________ |
☐ |
Neither I nor anyone in my immediate family has Reportable Securities Accounts.1
|
☐ |
I have Reportable Securities Account(s)1 for my immediate family or myself outside the firm that was/were previously disclosed and approved by the Legal/Compliance department. The account(s)
is/are listed below:
|
☐ |
In 20xx, the following Reportable Securities Account(s)1 listed below was/were opened for my immediate family or myself and not previously disclosed to and approved by the Legal/Compliance
Department:
|
•
|
Advisory, brokerage, trust, mutual fund, or other accounts that you currently have open or are intending to open outside the firms, where you or your immediate family
have a substantial proportionate economic interest or control.
|
o
|
“Immediate family” is defined as your spouse and minor descendants. With respect to accounts for the benefit of minor descendants who are not also minor children, any account that you control.
|
o
|
A “substantial proportionate economic interest” will generally be 25% of the equity in the account in the case of any single Access Person or 25% of the equity in the account in the case of all Access Persons
in the aggregate. Interests in private fund clients and similar indirect means of ownership of underlying securities shall also be treated as Access Person Accounts.
|
•
|
Any outside account of an Access Person that is managed by a third party, or in the case of a trust where an access person is the grantor or beneficiary that provides a trustee with management authority over
the trust, the access person should not, in any way, directly or indirectly have influence or control over the personal account/trust. [Note: a hedge fund would be considered an account managed by a third party if it is managed as a
separate account, but would not be a separate account if you are a limited partner. An investment in a mutual fund managed by a third party would not be a separate account because it is not solely for your benefit].
|
Print Your Name:
|
Signature:
|
Date:
|
1. Account Title:
|
Account Number:
|
|
Firm Name:
|
|
Firm Address:
|
|
For Internal Use Only↓
|
|
Receiving Statements & Confirms?
|
|
2. Account Title:
|
|
Account Number:
|
|
Firm Name:
|
|
Firm Address:
|
|
For Internal Use Only↓
|
|
Receiving Statements & Confirms?
|
|
3. Account Title:
|
|
Account Number:
|
|
Firm Name:
|
|
Firm Address:
|
|
For Internal Use Only↓
|
|
Receiving Statements & Confirms?
|
|
4. Account Title:
|
|
Account Number:
|
|
Firm Name:
|
|
Firm Address:
|
|
For Internal Use Only↓
|
|
Receiving Statements & Confirms?
|
|
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.
|
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.
|
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.
|
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
D..
|
Employees shall promptly report any suspected violations to appropriate persons inside the Company.
Employees shall be held accountable for adhering to the Code of Ethics.
|
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 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.
|
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.
|
• |
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.
|
• |
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.
|
D. |
Outside Business Activities
|
E. |
Prohibition on Brokerage for Fund Sales
|
A. |
primarily be responsible for administering and enforcing the provisions of this Code.
|
B. |
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 Certificate of Compliance with the Code of
Ethics via ComplySci.
|
C. |
determine whether any particular Personal Securities Transactions should be exempted pursuant to the provisions of this Code of Ethics;
|
D. |
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;
|
E. |
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;
|
F. |
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;
|
G. |
review any other statements, records and reports required by this Code of Ethics; and
|
H. |
review on a regular basis and update as necessary, 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 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. |
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.
|
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.
|
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.
|
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.
|
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. |
Notwithstanding this policy, all employees retain their right to report any violation to U.S. federal and state regulatory and law enforcement authorities at any time.
|
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.
|
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.
|
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
en 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.
|