As filed with the Securities and Exchange Commission on February 1, 2018.
Registration Nos. 2-99356
811-04367
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, DC 20549
FORM N-1A
REGISTRATION STATEMENT
UNDER
THE SECURITIES ACT OF 1933 | ☒ |
Pre-Effective Amendment No. | ☐ | |||
Post-Effective Amendment No. 315 | ☒ |
and/or
REGISTRATION STATEMENT
UNDER | ||||
THE INVESTMENT COMPANY ACT OF 1940 | ☒ |
Amendment No. 319 | ☒ |
(Check Appropriate Box or Boxes)
COLUMBIA FUNDS SERIES TRUST I
(Exact Name of Registrant as Specified in Charter)
225 Franklin Street, Boston, Massachusetts 02110
(Address of Principal Executive Officers) (Zip Code)
Registrants Telephone Number, Including Area Code: (800) 345-6611
Christopher O. Petersen, Esq.
c/o Columbia Management Investment Advisers, LLC
225 Franklin Street
Boston, Massachusetts 02110
(Name and Address of Agent for Service)
Approximate Date of Proposed Public Offering:
It is proposed that this filing will become effective (check appropriate box)
☐ | Immediately upon filing pursuant to paragraph (b) |
☐ | On (date) pursuant to paragraph (b) |
☐ | 60 days after filing pursuant to paragraph (a)(1) |
☐ | On (date) pursuant to paragraph (a)(1) |
☒ | 75 days after filing pursuant to paragraph (a)(2) |
☐ | On (date) pursuant to paragraph (a)(2) of rule 485. |
If appropriate, check the following box:
☐ | This post-effective amendment designates a new effective date for a previously filed post-effective amendment. |
This Post-Effective Amendment relates solely to the Registrants Multi-Manager International Equity Strategies Fund series. Information contained in the Registrants Registration Statement relating to any other series of the Registrant is neither amended nor superseded hereby.
Class | Ticker Symbol | |
Institutional (Class Inst) | [_____] |
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3 |
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3 |
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3 |
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9 |
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9 |
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19 |
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23 |
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25 |
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2 | Prospectus 2018 |
Shareholder Fees (fees paid directly from your investment) | |
Class Inst | |
Maximum sales charge (load) imposed on purchases (as a % of offering price) | None |
Maximum deferred sales charge (load) imposed on redemptions (as a % of the lower of the original purchase price or current net asset value) | None |
Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment) | |
Class Inst | |
Management fees | [_____]% |
Distribution and/or service (12b-1) fees | [_____]% |
Other expenses (a) | [_____]% |
Total annual Fund operating expenses | [_____]% |
(a) | Other expenses are based on estimated amounts for the Fund’s current fiscal year. |
■ | you invest $10,000 in the Fund for the periods indicated, |
■ | your investment has a 5% return each year, and |
■ | the Fund’s total annual operating expenses remain the same as shown in the Annual Fund Operating Expenses table above. |
1 year | 3 years | |
Class Inst (whether or not shares are redeemed) | $[_____] | $[_____] |
Prospectus 2018 | 3 |
4 | Prospectus 2018 |
Prospectus 2018 | 5 |
6 | Prospectus 2018 |
Prospectus 2018 | 7 |
8 | Prospectus 2018 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
[______] | [______] | [______] | [______], 2018 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
[______] | [______] | [______] | [______], 2018 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
[______] | [______] | [______] | [______], 2018 |
Prospectus 2018 | 9 |
10 | Prospectus 2018 |
Prospectus 2018 | 11 |
12 | Prospectus 2018 |
■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). |
Prospectus 2018 | 13 |
Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
14 | Prospectus 2018 |
Prospectus 2018 | 15 |
16 | Prospectus 2018 |
Prospectus 2018 | 17 |
18 | Prospectus 2018 |
Prospectus 2018 | 19 |
20 | Prospectus 2018 |
Prospectus 2018 | 21 |
Multi-Manager International Equity Strategies Fund | |
Class Inst | [_____]% |
22 | Prospectus 2018 |
Prospectus 2018 | 23 |
Annual Management Fee, as a % of Daily Net Assets: | |
$[_______] | [___]% |
$[_______] | [___]% |
$[_______] | [___]% |
$[_______] | [___]% |
$[_______] | [___]% |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
[______] | [______] | [______] | [______], 2018 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
[______] | [______] | [______] | [______], 2018 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
[______] | [______] | [______] | [______], 2018 |
24 | Prospectus 2018 |
■ | compensation and other benefits received by the Investment Manager and other Ameriprise Financial affiliates related to the management/administration of a Columbia Fund and the sale of its shares; |
■ | the allocation of, and competition for, investment opportunities among the Fund, other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates, or Ameriprise Financial itself and its affiliates; |
■ | separate and potentially divergent management of a Columbia Fund and other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates; |
■ | regulatory and other investment restrictions on investment activities of the Investment Manager and other Ameriprise Financial affiliates and accounts advised/managed by them; |
■ | insurance and other relationships of Ameriprise Financial affiliates with companies and other entities in which a Columbia Fund invests; and |
Prospectus 2018 | 25 |
■ | regulatory and other restrictions relating to the sharing of information between Ameriprise Financial and its affiliates, including the Investment Manager, and a Columbia Fund. |
26 | Prospectus 2018 |
Prospectus 2018 | 27 |
Eligible
Investors
and Minimum Initial Investments (a) |
Investment
Limits |
Conversion
Features |
Front-End
Sales Charges |
Contingent
Deferred Sales Charges (CDSCs) |
Maximum
Distribution and Service Fees |
Class A shares of the Fund are available only through certain wrap fee programs sponsored and/or managed by Ameriprise Financial or its affiliates. Eligible investors are subject to a minimum initial investment requirement of $100. | None | None | None | None |
0.25%
distribution
and/or service fees |
Class Inst shares of the Fund are available only through certain wrap fee programs sponsored and/or managed by Ameriprise Financial or its affiliates. Eligible investors are subject to a minimum initial investment requirement of $100. | None | None | None | None | None |
(a) | See Buying, Selling and Exchanging Shares — Transaction Rules and Policies for more details on the eligible investors and minimum initial and subsequent investment and account balance requirements. |
Distribution
Fee |
Service
Fee |
Combined
Total |
|
Class A | up to 0.25% | up to 0.25% | 0.25% |
Class Inst | none | none | none |
28 | Prospectus 2018 |
Prospectus 2018 | 29 |
30 | Prospectus 2018 |
Prospectus 2018 | 31 |
32 | Prospectus 2018 |
■ | negative impact on the Fund's performance; |
■ | potential dilution of the value of the Fund's shares; |
■ | interference with the efficient management of the Fund's portfolio, such as the need to maintain undesirably large cash positions, the need to use its line of credit or the need to buy or sell securities it otherwise would not have bought or sold; |
■ | losses on the sale of investments resulting from the need to sell securities at less favorable prices; |
■ | increased taxable gains to the Fund's remaining shareholders resulting from the need to sell securities to meet sell orders; and |
■ | increased brokerage and administrative costs. |
Prospectus 2018 | 33 |
34 | Prospectus 2018 |
■ | Once the Transfer Agent or your financial intermediary receives your buy order in “good form,” your purchase will be made at the next calculated public offering price per share, which is the net asset value per share plus any sales charge that applies (i.e., the trade date). |
■ | You generally buy shares of Multi-Manager Strategies Funds at net asset value per share because no front-end sales charge applies to purchases of shares of Multi-Manager Strategies Funds. |
■ | The Distributor and the Transfer Agent reserve the right to cancel your order if the Fund does not receive payment within two business days of receiving your purchase order. The Fund will return any payment received for orders that have been cancelled, but no interest will be paid on that money. |
■ | Financial intermediaries are responsible for sending your purchase orders to the Transfer Agent and ensuring that the Fund receives your money on time. |
■ | Shares purchased are recorded on the books of the Fund. The Fund does not issue certificates. |
Prospectus 2018 | 35 |
■ | Once the Transfer Agent or your financial intermediary receives your redemption order in “good form,” your shares will be sold at the next calculated NAV per share (i.e., the trade date). |
■ | If you sell your shares that are held in a Direct-at-Fund Account, we will normally send the redemption proceeds by mail or electronically transfer them to your bank account the next business day after the trade date. Note that your bank may take up to three business days to post an electronic funds transfer from your account. |
■ | If you sell your shares through a financial intermediary, the Funds will normally send the redemption proceeds to your financial intermediary within two business days after the trade date. |
■ | No interest will be paid on uncashed redemption checks. |
■ | Other restrictions may apply to retirement accounts. For information about these restrictions, contact your retirement plan administrator. |
36 | Prospectus 2018 |
■ | For broker-dealer and wrap fee accounts: The Fund reserves the right to redeem your shares if your account falls below the Fund's minimum initial investment requirement. The Fund will notify your broker-dealer prior to redeeming shares, and will provide details on how to avoid such redemption. |
■ | Exchanges are made at the NAV next calculated after your exchange order is received in “good form” (i.e., the trade date). |
■ | Once the Fund receives your exchange request in “good form,” you cannot cancel it after the market closes. |
■ | The rules for buying shares of a Fund generally apply to exchanges into that Fund, including, if your exchange creates a new Fund account, it must satisfy the minimum investment amount, unless a waiver applies. |
■ | Shares of the purchased Fund may not be used on the same day for another exchange or sale. |
■ | You may make exchanges only into a Fund that is legally offered and sold in your state of residence. Contact the Transfer Agent or your financial intermediary for more information. |
■ | You generally may make an exchange only into a Fund that is accepting investments. |
■ | The Fund may change or cancel your right to make an exchange by giving the amount of notice required by regulatory authorities (generally 60 days for a material change or cancellation). |
■ | Unless your account is part of a tax-advantaged arrangement, an exchange for shares of another Fund is a taxable event, and you may recognize a gain or loss for tax purposes. |
■ | You may only exchange shares of a Multi-Manager Strategies Fund for the same class of shares of another Multi-Manager Strategies Fund. |
Prospectus 2018 | 37 |
■ | It can earn income on its investments. Examples of fund income are interest paid on money market instruments and bonds, and dividends paid on common stocks. |
■ | A mutual fund can also have capital gains if the value of its investments increases. While a fund continues to hold an investment, any gain is generally unrealized. If the fund sells an investment, it generally will realize a capital gain if it sells that investment for a higher price than its adjusted cost basis, and will generally realize a capital loss if it sells that investment for a lower price than its adjusted cost basis. Capital gains and losses are either short-term or long-term, depending on whether the fund holds the securities for one year or less (short-term) or more than one year (long-term). |
Declaration and Distribution Schedule | |
Declarations | [______] |
Distributions | [______] |
38 | Prospectus 2018 |
■ | The Fund intends to qualify and to be eligible for treatment each year as a regulated investment company. A regulated investment company generally is not subject to tax at the fund level on income and gains from investments that are distributed to shareholders. However, the Fund's failure to qualify for treatment as a regulated investment company would result in Fund-level taxation, and consequently, a reduction in income available for distribution to you and in the NAV of your shares. Even if the Fund qualifies for treatment as a regulated investment company, the Fund may be subject to federal excise tax on certain undistributed income or gains. |
■ | Otherwise taxable distributions generally are taxable to you when paid, whether they are paid in cash or automatically reinvested in additional Fund shares. Dividends paid in January are deemed paid on December 31 of the prior year if the dividend was declared and payable to shareholders of record in October, November, or December of such prior year. |
■ | Distributions of the Fund's ordinary income and net short-term capital gain, if any, generally are taxable to you as ordinary income. Distributions of the Fund's net long-term capital gain, if any, generally are taxable to you as long-term capital gain. Whether capital gains are long-term or short-term is determined by how long the Fund has owned the investments that generated them, rather than how long you have owned your shares. |
■ | From time to time, a distribution from the Fund could constitute a return of capital, which is not taxable to you so long as the amount of the distribution does not exceed your tax basis in your Fund shares. A return of capital reduces your tax basis in your Fund shares, with any amounts exceeding such basis generally taxable as capital gain. |
■ | If you are an individual and you meet certain holding period and other requirements for your Fund shares, a portion of your distributions may be treated as “qualified dividend income” taxable at the lower net long-term capital gain rates instead of the higher ordinary income rates. Qualified dividend income is income attributable to the Fund's dividends received from certain U.S. and foreign corporations, as long as the Fund meets certain holding period and other requirements for the stock producing such dividends. |
■ | Certain high-income individuals (as well as estates and trusts) are subject to a 3.8% tax on net investment income. For individuals, the 3.8% tax applies to the lesser of (1) the amount (if any) by which the taxpayer's modified adjusted gross income exceeds certain threshold amounts or (2) the taxpayer's “net investment income.” |
Net investment income generally includes for this purpose dividends, including any capital gain dividends, paid by the Fund, and net gains recognized on the sale, redemption or exchange of shares of the Fund. |
■ | Certain derivative instruments when held in the Fund's portfolio subject the Fund to special tax rules, the effect of which may be to, among other things, accelerate income to the Fund, defer Fund losses, cause adjustments in the holding periods of Fund portfolio securities, or convert capital gains into ordinary income, short-term capital losses into long-term capital losses or long-term capital gains into short-term capital gains. These rules could therefore affect the amount, timing and/or character of distributions to shareholders. |
■ | Generally, a Fund realizes a capital gain or loss on an option when the option expires, or when it is exercised, sold or otherwise terminated. However, if an option is a “section 1256 contract,” which includes most traded options on a broad-based index, and the Fund holds such option at the end of its taxable year, the Fund is deemed to sell such option at fair market value at such time and recognize any gain or loss thereon, which is generally deemed to be 60% long-term and 40% short-term capital gain or loss, as described further in the SAI. |
■ | Income and proceeds received by the Fund from sources within foreign countries may be subject to foreign taxes. If at the end of the taxable year more than 50% of the value of the Fund's assets consists of securities of foreign corporations, and the Fund makes a special election, you will generally be required to include in your income for U.S. federal income tax purposes your share of the qualifying foreign income taxes paid by the Fund in respect of its foreign portfolio securities. You may be able to claim a foreign tax credit or deduction in respect of this amount, subject to certain limitations. There is no assurance that the Fund will make this election for a taxable year, even if it is eligible to do so. |
Prospectus 2018 | 39 |
■ | A sale, redemption or exchange of Fund shares is a taxable event. This includes redemptions where you are paid in securities. Your sales, redemptions and exchanges of Fund shares (including those paid in securities) usually will result in a taxable capital gain or loss to you, equal to the difference between the amount you receive for your shares (or are deemed to have received in the case of exchanges) and your adjusted tax basis in the shares, which is generally the amount you paid (or are deemed to have paid in the case of exchanges) for them. Any such capital gain or loss generally will be long-term capital gain or loss if you have held your Fund shares for more than one year at the time of sale or exchange. In certain circumstances, capital losses may be converted from short-term to long-term; in other circumstances, capital losses may be disallowed under the “wash sale” rules. |
■ | For sales, redemptions and exchanges of shares that were acquired in a non-qualified account after 2011, the Fund generally is required to report to shareholders and the Internal Revenue Service (IRS) cost basis information with respect to those shares. The Fund uses average cost basis as its default method of calculating cost basis. For more information regarding average cost basis reporting, other available cost basis methods, and selecting or changing to a different cost basis method, please see the SAI, columbiathreadneedle.com/us, or contact the Fund at 800.345.6611. If you hold Fund shares through a financial intermediary (e.g., a brokerage firm), you should contact your financial intermediary to learn about its cost basis reporting default method and the reporting elections available to your account. |
■ | The Fund is required by federal law to withhold tax on any taxable or tax-exempt distributions and redemption proceeds paid to you (including amounts paid to you in securities and amounts deemed to be paid to you upon an exchange of shares) if: you have not provided a correct TIN or have not certified to the Fund that withholding does not apply, the IRS has notified us that the TIN listed on your account is incorrect according to its records, or the IRS informs the Fund that you are otherwise subject to backup withholding. |
40 | Prospectus 2018 |
Prospectus 2018 | 41 |
Columbia Bond Fund | ||
Class A: CNDAX | Class Adv: CNDRX | Class C: CNDCX |
Class Inst: UMMGX | Class Inst2: CNFRX | Class Inst3: CBFYX |
Class R: CBFRX | Class T: CBDWX | Class V: CNDTX |
Columbia California Tax-Exempt Fund*** | ||
Class A: CLMPX | Class Adv: CCARX | Class C: CCAOX |
Class Inst: CCAZX | Class Inst2: CCAUX | Class Inst3: CCXYX |
Columbia Contrarian Core Fund | ||
Class A: LCCAX | Class Adv: CORRX | Class C: LCCCX |
Class Inst: SMGIX | Class Inst2: COFRX | Class Inst3: COFYX |
Class K*: CCRFX | Class R: CCCRX | Class T: CTRWX |
Class V: SGIEX | ||
Columbia Corporate Income Fund | ||
Class A: LIIAX | Class Adv: CIFRX | Class C: CIOCX |
Class Inst: SRINX | Class Inst2: CPIRX | Class Inst3: CRIYX |
Class T: CPIWX | ||
Columbia Disciplined Small Core Fund | ||
Class A: LSMAX | Class Adv: CFFRX | Class C: LSMCX |
Class Inst: SMCEX | Class Inst2: CLLRX | Class Inst3: CPFRX |
Class T: CSCWX | Class V: SSCEX | |
Columbia Diversified Absolute Return Fund | ||
Class A: CDUAX | Class Adv: CDUFX | Class C: CDUCX |
Class Inst: CDUZX | Class Inst2: CDUGX | Class Inst3: CDAYX |
Class T: CDUWX | ||
Columbia Diversified Real Return Fund | ||
Class A: CDRAX | Class Adv: CDRRX | Class C: CDRCX |
Class Inst: CDRZX | Class Inst2: CDRFX | Class Inst3: CDRYX |
Class T: CDTWX | ||
Columbia Dividend Income Fund | ||
Class A: LBSAX | Class Adv: CVIRX | Class C: LBSCX |
Class Inst: GSFTX | Class Inst2: CDDRX | Class Inst3: CDDYX |
Class R: CDIRX | Class T: CDVWX | Class V: GEQAX |
Columbia Emerging Markets Fund | ||
Class A: EEMAX | Class Adv: CEMHX | Class C: EEMCX |
Class Inst: UMEMX | Class Inst2: CEKRX | Class Inst3: CEKYX |
Class K*: CEKMX | Class R: CEMRX | Class T: CEMWX |
Columbia Global Dividend Opportunity Fund | ||
Class A: CSVAX | Class Adv: CGOLX | Class C: CSRCX |
Class Inst: CSVFX | Class Inst2: CADPX | Class Inst3: CLSYX |
Class R: CSGRX | Class T: CTVWX | |
Columbia Global Energy and Natural Resources Fund | ||
Class A: EENAX | Class Adv: CENRX | Class C: EENCX |
Class Inst: UMESX | Class Inst2: CNRRX | Class Inst3: CGEYX |
Class K*: CEGFX | Class R: CETRX | Class T**: — |
Columbia Global Technology Growth Fund | ||
Class A: CTCAX | Class Adv: CTYRX | Class C: CTHCX |
Class Inst: CMTFX | Class Inst2: CTHRX | Class Inst3: CGTUX |
Class T**: — |
Columbia Greater China Fund | ||
Class A: NGCAX | Class Adv: CGCHX | Class C: NGCCX |
Class Inst: LNGZX | Class Inst2: CGCRX | Class Inst3: CGCYX |
Class T: CGCWX | ||
Columbia High Yield Municipal Fund | ||
Class A: LHIAX | Class Adv: CHIYX | Class C: CHMCX |
Class Inst: SRHMX | Class Inst2: CHMYX | Class Inst3: CHHYX |
Columbia Large Cap Growth Fund | ||
Class A: LEGAX | Class Adv: CCGRX | Class C: LEGCX |
Class E: CLGEX | Class Inst: GEGTX | Class Inst2: CLWFX |
Class Inst3: CGFYX | Class K*: CLRUX | Class R: CGWRX |
Class T: CLGWX | Class V: GAEGX | |
Columbia Mid Cap Growth Fund | ||
Class A: CBSAX | Class Adv: CPGRX | Class C: CMCCX |
Class Inst: CLSPX | Class Inst2: CMGVX | Class Inst3: CMGYX |
Class K*: CMCKX | Class R: CMGRX | Class T: CMRWX |
Class V: CBSTX | ||
Columbia Multi-Asset Income Fund | ||
Class A: CLNAX | Class Adv: CLNFX | Class C: CLCNX |
Class Inst: CLNZX | Class Inst2: CLNVX | Class Inst3: CMUYX |
Class T: CLNWX | ||
Columbia New York Tax-Exempt Fund*** | ||
Class A: COLNX | Class Adv: CNYEX | Class C: CNYCX |
Class Inst: CNYZX | Class Inst2: CNYRX | Class Y: CNTYX |
Columbia Pacific/Asia Fund | ||
Class A: CASAX | Class Adv: CPRAX | Class C: CASCX |
Class Inst: USPAX | Class Inst3: CPAYX | Class T: CPAWX |
Columbia Real Estate Equity Fund | ||
Class A: CREAX | Class Adv: CRERX | Class C: CRECX |
Class Inst: CREEX | Class Inst2: CRRVX | Class Inst3: CREYX |
Class K*: CRRFX | Class R: CRSRX | Class T: CREWX |
Columbia Select Large Cap Growth Fund | ||
Class A: ELGAX | Class Adv: CSRRX | Class C: ELGCX |
Class Inst: UMLGX | Class Inst2: CGTRX | Class Inst3: CCWRX |
Class R: URLGX | Class T: CSLWX | |
Columbia Small Cap Growth Fund I | ||
Class A: CGOAX | Class Adv: CHHRX | Class C: CGOCX |
Class Inst: CMSCX | Class Inst2: CSCRX | Class Inst3: CSGYX |
Class K*: CSCKX | Class R: CCRIX | Class T**: — |
Columbia Small Cap Value Fund I | ||
Class A: CSMIX | Class Adv: CVVRX | Class C: CSSCX |
Class Inst: CSCZX | Class Inst2: CUURX | Class Inst3: CSVYX |
Class R: CSVRX | Class T**: — | |
Columbia Solutions Aggressive Portfolio | ||
Columbia Solutions Conservative Portfolio | ||
Columbia Strategic Income Fund | ||
Class A: COSIX | Class Adv: CMNRX | Class C: CLSCX |
Class Inst: LSIZX | Class Inst2: CTIVX | Class Inst3: CPHUX |
Class K*: CSIVX | Class R: CSNRX | Class T: CTTWX |
Columbia Tax-Exempt Fund | ||
Class A: COLTX | Class Adv: CTERX | Class C: COLCX |
Class Inst: CTEZX | Class Inst2: CADMX | Class Inst3: CTEYX |
Columbia Total Return Bond Fund | ||
Class A: LIBAX | Class Adv: CBNRX | Class C: LIBCX |
Class Inst: SRBFX | Class Inst2: CTBRX | Class T: CIBWX |
Class Inst3: CTBYX | Class R: CIBRX | Class K*: CIBKX |
Columbia U.S. Social Bond Fund | ||
Class A: CONAX | Class Adv: CONFX | Class C: CONCX |
Class Inst: CONZX | Class Inst2: COVNX | Class Inst3: CONYX |
Columbia U.S. Treasury Index Fund | ||
Class A: LUTAX | Class C: LUTCX | Class Inst: IUTIX |
Class Inst2: CUTRX | Class Inst3: CUTYX | Class Inst2: CUTRX |
Multi-Manager Alternative Strategies Fund | ||
Class A: CPASX | Class Inst: CZAMX | |
Multi-Manager Directional Alternative Strategies Fund | ||
Class A: CDAAX | Class Inst: CDAZX | |
Multi-Manager Growth Strategies Fund | ||
Class A: CSLGX | Class Inst: CZMGX | |
Multi-Manager International Equity Strategies Fund | ||
Class Inst: [_____] | ||
Multi-Manager Small Cap Equity Strategies Fund | ||
Class A: CSCEX | Class Inst: CZMSX | |
Multi-Manager Total Return Bond Strategies Fund | ||
Class A: CMCPX | Class Inst: CTRZX |
* | Effective on or about March 9, 2018, shares held by Class K shareholders will be exchanged for Class Adv shares of the same Fund in a tax-free transaction with no impact on the fees and expenses paid by shareholders, and Class K shares of the Fund will no longer be offered for sale. |
** | This share class is not currently available for purchase. |
*** | Effective on or about January 22, 2018, each Fund’s name is changed as follows: from Columbia California Tax-Exempt Fund to Columbia Strategic California Municipal Income Fund, and from Columbia New York Tax-Exempt Fund to Columbia Strategic New York Municipal Income Fund. Accordingly, on such date, all references throughout the SAI to each fund are superseded and replaced with Columbia Strategic California Municipal Income Fund or Strategic CA Municipal Income Fund and Columbia Strategic New York Municipal Income Fund or Strategic NY Municipal Income Fund. |
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Statement of Additional Information – [____, 2018] | 1 |
■ | the organization of the Trust; |
■ | the Funds' investments; |
■ | the Funds' investment adviser, investment subadviser(s) (if any) and other service providers, including roles and relationships of Ameriprise Financial and its affiliates, and conflicts of interest; |
■ | the governance of the Funds; |
■ | the Funds' brokerage practices; |
■ | the share classes offered by the Funds; |
■ | the purchase, redemption and pricing of Fund shares; and |
■ | the application of U.S. federal income tax laws. |
1933 Act | Securities Act of 1933, as amended |
1934 Act | Securities Exchange Act of 1934, as amended |
1940 Act | Investment Company Act of 1940, as amended |
Adaptive Retirement Funds | The Funds within the Columbia Funds Complex that include “Adaptive Retirement” within the fund name. |
Analytic Investors | Analytic Investors, LLC |
Administrative Services Agreement | The Administrative Services Agreement, as amended, if applicable, between the Trust, on behalf of the Funds, and the Investment Manager |
Ameriprise Financial | Ameriprise Financial, Inc. |
AQR | AQR Capital Management, LLC |
BANA | Bank of America, National Association |
Statement of Additional Information – [____, 2018] | 2 |
Bank of America | Bank of America Corporation |
BMO | BMO Asset Management Corp. |
Board | The Trust’s Board of Trustees |
Boston Partners | Boston Partners, a d.b.a. of Boston Partners Global Investors, Inc. |
Business Day | Any day on which the NYSE is open for business. A business day typically ends at the close of regular trading on the NYSE, usually at 4:00 p.m. Eastern time. If the NYSE is scheduled to close early, the business day will be considered to end as of the time of the NYSE’s scheduled close. The Fund will not treat an intraday unscheduled disruption in NYSE trading or an intraday unscheduled closing as a close of regular trading on the NYSE for these purposes and will price its shares as of the regularly scheduled closing time for that day (typically, 4:00 p.m. Eastern time). Notwithstanding the foregoing, the NAV of Fund shares may be determined at such other time or times (in addition to or in lieu of the time set forth above) as the Fund’s Board may approve or ratify. On holidays and other days when the NYSE is closed, the Fund's NAV is not calculated and the Fund does not accept buy or sell orders. However, the value of the Fund's assets may still be affected on such days to the extent that the Fund holds foreign securities that trade on days that foreign securities markets are open. |
CEA | Commodity Exchange Act |
CFST | Columbia Funds Series Trust |
CFST I | Columbia Funds Series Trust I |
CFST II | Columbia Funds Series Trust II |
CFTC | The United States Commodities Futures Trading Commission |
CMOs | Collateralized mortgage obligations |
Code | Internal Revenue Code of 1986, as amended |
Codes of Ethics | The codes of ethics adopted by the Funds, the Investment Manager, Columbia Management Investment Distributors, Inc. and/or any sub-adviser, as applicable, pursuant to Rule 17j-1 under the 1940 Act |
Columbia Funds or Columbia Funds Complex | The fund complex, including the Funds, that is comprised of the registered investment companies, including traditional mutual funds, closed-end funds, and ETFs, advised by the Investment Manager or its affiliates |
Columbia Management | Columbia Management Investment Advisers, LLC |
Conestoga | Conestoga Capital Advisors, LLC |
Custodian | JPMorgan Chase Bank, N.A. |
DGHM | Dalton, Greiner, Hartman, Maher & Co., LLC |
Distribution Agreement | The Distribution Agreement between the Trust, on behalf of its Funds, and the Distributor |
Distribution Plan(s) | One or more of the plans adopted by the Board pursuant to Rule 12b-1 under the 1940 Act for the distribution of the Funds’ shares |
Distributor | Columbia Management Investment Distributors, Inc. |
DST | DST Asset Manager Solutions, Inc. |
EAM | EAM Investors, LLC |
FDIC | Federal Deposit Insurance Corporation |
Federated | Federated Investment Management Company |
FHLMC | The Federal Home Loan Mortgage Corporation |
Fitch | Fitch, Inc. |
FNMA | Federal National Mortgage Association |
The Fund(s) or a Fund | One or more of the open-end management investment companies listed on the front cover of this SAI |
GNMA | Government National Mortgage Association |
Statement of Additional Information – [____, 2018] | 3 |
Independent Trustees | The Trustees of the Board who are not “interested persons” (as defined in the 1940 Act) of the Funds |
Interested Trustees | The Trustees of the Board who are currently deemed to be “interested persons” (as defined in the 1940 Act) of the Funds |
Investment Management Services Agreement | The Investment Management Services Agreement, as amended, if applicable, between the Trust, on behalf of its Funds, and the Investment Manager |
Investment Manager | Columbia Management Investment Advisers, LLC |
IRS | United States Internal Revenue Service |
JPMorgan | JPMorgan Chase Bank, N.A., the Funds' custodian |
LIBOR | London Interbank Offered Rate |
Loomis Sayles | Loomis, Sayles & Company, L.P. |
Los Angeles Capital | Los Angeles Capital Management and Equity Research, Inc. |
Manulife | Manulife Asset Management (US) LLC |
Management Agreement | The Management Agreements, as amended, if applicable, between the Trust, on behalf of the Funds, and the Investment Manager |
Moody’s | Moody’s Investors Service, Inc. |
Multi-Manager Strategies Funds | Multi-Manager Alternative Strategies Fund, Multi-Manager Directional Alternative Strategies Fund, Multi-Manager Growth Strategies Fund, Multi-Manager International Equity Strategies Fund, Multi-Manager Small Cap Equity Strategies Fund, Multi-Manager Total Return Bond Strategies Fund and Multi-Manager Value Strategies Fund. Shares of the Multi-Manager Strategies Funds are offered only through certain wrap fee programs sponsored and/or managed by Ameriprise Financial, Inc. or its affiliates. |
NASDAQ | National Association of Securities Dealers Automated Quotations system |
NAV | Net asset value per share of a Fund |
NRSRO | Nationally recognized statistical ratings organization (such as, for example, Moody’s, Fitch or S&P) |
NSCC | National Securities Clearing Corporation |
NYSE | New York Stock Exchange |
Previous Adviser | Columbia Management Advisors, LLC, the investment adviser of certain Columbia Funds prior to May 1, 2010 when Ameriprise Financial acquired the long-term asset management business of the Previous Adviser, which was an indirect wholly-owned subsidiary of Bank of America. |
Previous Distributor | Columbia Management Distributors, Inc., the distributor of certain Columbia Funds prior to May 1, 2010 when Ameriprise Financial acquired the long-term asset management business of the Previous Adviser, which was an indirect wholly-owned subsidiary of Bank of America. |
Previous Transfer Agent | Columbia Management Services, Inc., the transfer agent of certain Columbia Funds prior to May 1, 2010 when Ameriprise Financial acquired the long-term asset management business of the Previous Adviser, which was an indirect wholly-owned subsidiary of Bank of America. |
PGIM | PGIM, Inc., the asset management arm of Prudential Financial, Inc. |
Statement of Additional Information – [____, 2018] | 4 |
S&P | Standard & Poor’s, a division of The McGraw-Hill Companies, Inc. (“Standard & Poor’s” and “S&P” are trademarks of The McGraw-Hill Companies, Inc. and have been licensed for use by the Investment Manager. The Columbia Funds are not sponsored, endorsed, sold or promoted by Standard & Poor’s and Standard & Poor’s makes no representation regarding the advisability of investing in the Columbia Funds) |
SAI | This Statement of Additional Information, as amended and supplemented from time-to-time |
SEC | United States Securities and Exchange Commission |
Shares | Shares of a Fund |
Solution Series Funds | Columbia Solutions Aggressive Portfolio and Columbia Solutions Conservative Portfolio |
Subadvisory Agreement | The Subadvisory Agreement among the Trust on behalf of the Fund(s), the Investment Manager and a Fund’s investment subadviser(s), as the context may require |
Subsidiary | One or more wholly-owned subsidiaries of a Fund |
TCW | TCW Investment Management Company LLC |
Threadneedle | Threadneedle International Limited |
Transfer Agency Agreement | The Transfer and Dividend Disbursing Agent Agreement between the Trust, on behalf of its Funds, and the Transfer Agent |
Transfer Agent | Columbia Management Investment Services Corp. |
Trustee(s) | One or more members of the Board |
Trust | Columbia Funds Series Trust I, the registered investment company in the Columbia Funds Complex to which this SAI relates |
VP – Managed Volatility Funds | Any variable portfolio fund that includes the words “Managed Risk,” “Managed Volatility,” or “U.S. Flexible” as part of the Fund’s name |
Wasatch | Wasatch Advisors Inc |
Water Island | Water Island Capital, LLC |
Statement of Additional Information – [____, 2018] | 5 |
Fund Name: | Referred to as: | |
CMG Ultra Short Term Bond Fund | Ultra Short Term Bond Fund | |
Columbia Adaptive Retirement 2020 Fund | Adaptive Retirement 2020 Fund | |
Columbia Adaptive Retirement 2030 Fund | Adaptive Retirement 2030 Fund | |
Columbia Adaptive Retirement 2040 Fund | Adaptive Retirement 2040 Fund | |
Columbia Adaptive Retirement 2050 Fund | Adaptive Retirement 2050 Fund | |
Columbia Adaptive Retirement 2060 Fund | Adaptive Retirement 2060 Fund | |
Columbia Adaptive Risk Allocation Fund | Adaptive Risk Allocation Fund | |
Columbia Alternative Beta Fund | Alternative Beta Fund | |
Columbia AMT-Free Connecticut Intermediate Muni Bond Fund | AMT-Free CT Intermediate Muni Bond Fund | |
Columbia AMT-Free Intermediate Muni Bond Fund | AMT-Free Intermediate Muni Bond Fund | |
Columbia AMT-Free Massachusetts Intermediate Muni Bond Fund | AMT-Free MA Intermediate Muni Bond Fund | |
Columbia AMT-Free New York Intermediate Muni Bond Fund | AMT-Free NY Intermediate Muni Bond Fund | |
Columbia AMT-Free Oregon Intermediate Muni Bond Fund | AMT-Free OR Intermediate Muni Bond Fund | |
Columbia Balanced Fund | Balanced Fund | |
Columbia Bond Fund | Bond Fund | |
Columbia California Tax-Exempt Fund* | CA Tax-Exempt Fund | |
Columbia Contrarian Core Fund | Contrarian Core Fund | |
Columbia Corporate Income Fund | Corporate Income Fund | |
Columbia Disciplined Small Core Fund | Disciplined Small Core Fund | |
Columbia Diversified Absolute Return Fund | Diversified Absolute Return Fund | |
Columbia Diversified Real Return Fund | Diversified Real Return Fund | |
Columbia Dividend Income Fund | Dividend Income Fund | |
Columbia Emerging Markets Fund | Emerging Markets Fund | |
Columbia Global Dividend Opportunity Fund | Global Dividend Opportunity Fund | |
Columbia Global Energy and Natural Resources Fund | Global Energy and Natural Resources Fund | |
Columbia Global Technology Growth Fund | Global Technology Growth Fund | |
Columbia Greater China Fund | Greater China Fund | |
Columbia High Yield Municipal Fund | HY Municipal Fund | |
Columbia Large Cap Growth Fund | Large Cap Growth Fund | |
Columbia Mid Cap Growth Fund | Mid Cap Growth Fund | |
Columbia Multi-Asset Income Fund | Multi-Asset Income Fund | |
Columbia New York Tax-Exempt Fund* | NY Tax-Exempt Fund | |
Columbia Pacific/Asia Fund | Pacific/Asia Fund | |
Columbia Real Estate Equity Fund | Real Estate Equity Fund | |
Columbia Select Large Cap Growth Fund | Select Large Cap Growth Fund | |
Columbia Small Cap Growth Fund I | Small Cap Growth Fund I | |
Columbia Small Cap Value Fund I | Small Cap Value Fund I | |
Columbia Solutions Aggressive Portfolio | Solutions Aggressive Portfolio | |
Columbia Solutions Conservative Portfolio | Solutions Conservative Portfolio | |
Columbia Strategic Income Fund | Strategic Income Fund | |
Columbia Tax-Exempt Fund | Tax-Exempt Fund | |
Columbia Total Return Bond Fund | Total Return Bond Fund | |
Columbia U.S. Social Bond Fund | U.S. Social Bond Fund |
Statement of Additional Information – [____, 2018] | 6 |
Fund Name: | Referred to as: | |
Columbia U.S. Treasury Index Fund | U.S. Treasury Index Fund | |
Multi-Manager Alternative Strategies Fund | MM Alternative Strategies Fund | |
Multi-Manager Directional Alternative Strategies Fund | MM Directional Alternative Strategies Fund | |
Multi-Manager Growth Strategies Fund | MM Growth Strategies Fund | |
Multi-Manager International Equity Strategies Fund | MM International Equity Strategies Fund | |
Multi-Manager Small Cap Equity Strategies Fund | MM Small Cap Equity Strategies Fund | |
Multi-Manager Total Return Bond Fund | MM Total Return Bond Strategies Fund |
* | Effective on or about January 22, 2018, each Fund’s name is changed as follows: from Columbia California Tax-Exempt Fund to Columbia Strategic California Municipal Income Fund, and from Columbia New York Tax-Exempt Fund to Columbia Strategic New York Municipal Income Fund. Accordingly, on such date, all references throughout the SAI to each fund are superseded and replaced with Columbia Strategic California Municipal Income Fund or Strategic CA Municipal Income Fund and Columbia Strategic New York Municipal Income Fund or Strategic NY Municipal Income Fund. |
Statement of Additional Information – [____, 2018] | 7 |
Fund | Fiscal Year End | Prospectus Date |
Date
Began
Operations* |
Diversified** | Fund Investment Category*** |
Adaptive Retirement 2020 Fund | March 31 | 10/23/2017 | 10/24/2017 | No | Fund-of-funds – alternative |
Adaptive Retirement 2030 Fund | March 31 | 10/23/2017 | 10/24/2017 | No | Fund-of-funds – alternative |
Adaptive Retirement 2040 Fund | March 31 | 10/23/2017 | 10/24/2017 | No | Fund-of-funds – alternative |
Adaptive Retirement 2050 Fund | March 31 | 10/23/2017 | 10/24/2017 | No | Fund-of-funds – alternative |
Adaptive Retirement 2060 Fund | March 31 | 10/23/2017 | 10/24/2017 | No | Fund-of-funds – alternative |
Adaptive Risk Allocation Fund | May 31 | 8/1/2017 | 6/19/2012 | No | Alternative |
Alternative Beta Fund | May 31 | 10/1/2017 | 1/28/2015 | No | Alternative |
AMT-Free CT Intermediate Muni Bond Fund | October 31 | 3/1/2017 | 8/1/1994 | No | Tax-exempt fixed-income |
AMT-Free Intermediate Muni Bond Fund | October 31 | 3/1/2017 | 6/14/1993 | Yes | Tax-exempt fixed-income |
AMT-Free MA Intermediate Muni Bond Fund | October 31 | 3/1/2017 | 6/14/1993 | No | Tax-exempt fixed-income |
AMT-Free NY Intermediate Muni Bond Fund | October 31 | 3/1/2017 | 12/31/1991 | No | Tax-exempt fixed-income |
AMT-Free OR Intermediate Muni Bond Fund | July 31 | 11/1/2017 | 7/2/1984 | Yes | Tax-exempt fixed-income |
Balanced Fund | August 31 | 1/1/2018 | 10/1/1991 | Yes | Equity/Taxable fixed-income |
Bond Fund | April 30 | 9/1/2017 | 1/9/1986 | Yes | Taxable fixed-income |
CA Tax-Exempt Fund | October 31 | 3/1/2017 | 6/16/1986 | No | Tax-exempt fixed-income |
Contrarian Core Fund | August 31 | 1/1/2018 | 12/14/1992 | Yes | Equity |
Corporate Income Fund | April 30 | 9/1/2017 | 3/5/1986 | Yes | Taxable fixed-income |
Disciplined Small Core Fund | August 31 | 1/1/2018 | 12/14/1992 | Yes | Equity |
Diversified Absolute Return Fund | May 31 | 10/1/2017 | 2/19/2015 | Yes | Alternative |
Diversified Real Return Fund | January 31 | 6/1/2017 | 3/11/2014 | Yes | Fund-of-funds-fixed income |
Dividend Income Fund | May 31 | 10/1/2017 | 3/4/1998 | Yes | Equity |
Emerging Markets Fund | August 31 | 1/1/2018 | 1/2/1998 | Yes | Equity |
Global Dividend Opportunity Fund | August 31 | 1/1/2018 | 11/9/2000 | Yes | Equity |
Global Energy and Natural Resources Fund | August 31 | 1/1/2018 | 12/31/1992 | No | Equity |
Global Technology Growth Fund | August 31 | 1/1/2018 | 11/9/2000 | Yes | Equity |
Greater China Fund | August 31 | 1/1/2018 | 5/16/1997 | No | Equity |
HY Municipal Fund | May 31 | 10/1/2017 | 3/5/1984 | Yes | Tax-exempt fixed-income |
Large Cap Growth Fund | July 31 | 11/1/2017 | 12/14/1990 | Yes | Equity |
Mid Cap Growth Fund | August 31 | 1/1/2018 | 11/20/1985 | Yes | Equity |
MM Alternative Strategies Fund | August 31 | 1/1/2018 | 4/23/2012 | No | Alternative |
MM Directional Alternative Strategies Fund | April 30 | 9/1/2017 | 10/17/2016 | No | Alternative |
MM Growth Strategies Fund | March 31 | 8/1/2017 | 4/20/2012 | Yes | Equity |
Statement of Additional Information – [____, 2018] | 8 |
Fund | Fiscal Year End | Prospectus Date |
Date
Began
Operations* |
Diversified** | Fund Investment Category*** |
MM International Equity Strategies Fund | [______] | [______] | [_____] | Yes | Equity |
MM Small Cap Equity Strategies Fund | August 31 | 1/1/2018 | 4/20/2012 | Yes | Equity |
MM Total Return Bond Strategies Fund | August 31 | 1/1/2018 | 4/20/2012 | Yes | Taxable fixed-income |
Multi-Asset Income Fund | April 30 | 9/1/2017 | 3/27/2015 | Yes | Flexible |
NY Tax-Exempt Fund | October 31 | 3/1/2017 | 9/26/1986 | No | Tax-exempt fixed-income |
Pacific/Asia Fund | March 31 | 8/1/2017 | 12/31/1992 | Yes | Equity |
Real Estate Equity Fund | December 31 | 5/1/2017 | 4/1/1994 | No | Equity |
Select Large Cap Growth Fund | March 31 | 8/1/2017 | 10/1/1997 | Yes | Equity |
Small Cap Growth Fund I | August 31 | 1/1/2018 | 10/1/1996 | Yes | Equity |
Small Cap Value Fund I | April 30 | 9/1/2017 | 7/25/1986 | Yes | Equity |
Solutions Aggressive Portfolio | March 31 | 10/23/2017 | 10/24/2017 | No | Alternative |
Solutions Conservative Portfolio | March 31 | 10/23/2017 | 10/24/2017 | No | Alternative |
Strategic Income Fund | August 31 (a) | 1/1/2018 | 4/21/1977 | Yes | Taxable fixed-income |
Tax-Exempt Fund | July 31 | 11/1/2017 | 11/21/1978 | Yes | Tax-exempt fixed-income |
Total Return Bond Fund | April 30 | 9/1/2017 | 12/5/1978 | Yes | Taxable fixed-income |
U.S. Social Bond Fund | July 31 | 11/1/2017 | 3/26/2015 | No | Tax-exempt fixed-income |
U.S. Treasury Index Fund | April 30 | 9/1/2017 | 6/4/1991 | Yes | Taxable fixed-income |
Ultra Short Term Bond Fund | July 31 | 11/1/2017 | 3/8/2004 | Yes | Taxable fixed-income |
* | Certain Funds reorganized into series of the Trust. The date of operations for these Funds represents the date on which the predecessor funds began operation. |
** | A “diversified” Fund may not, with respect to 75% of its total assets, invest more than 5% of its total assets in securities of any one issuer or purchase more than 10% of the outstanding voting securities of any one issuer, except obligations issued or guaranteed by the U.S. Government, its agencies or instrumentalities and except securities of other investment companies. A “non-diversified” Fund may invest a greater percentage of its total assets in the securities of fewer issuers than a “diversified” fund, which increases the risk that a change in the value of any one investment held by the Fund could affect the overall value of the Fund more than it would affect that of a “diversified” fund holding a greater number of investments. Accordingly, a “non-diversified” Fund’s value will likely be more volatile than the value of a more diversified fund. |
*** | The Fund Investment Category is used as a convenient way to describe Funds in this SAI and should not be deemed a description of the Fund’s principal investment strategies, which are described in the Fund’s prospectus. |
Fund* | Effective Date of Name Change | Previous Fund Name |
Adaptive Risk Allocation | October 1, 2014 | Columbia Risk Allocation Fund |
Alternative Beta Fund | October 1, 2016 | Columbia Adaptive Alternatives Fund |
AMT-Free CT Intermediate Muni Bond Fund | July 7, 2014 | Columbia Connecticut Intermediate Municipal Bond Fund |
AMT-Free Intermediate Muni Bond Fund | July 7, 2014 | Columbia Intermediate Municipal Bond Fund |
AMT-Free MA Intermediate Muni Bond Fund | July 7, 2014 | Columbia Massachusetts Intermediate Municipal Bond Fund |
AMT-Free NY Intermediate Muni Bond Fund | July 7, 2014 | Columbia New York Intermediate Municipal Bond Fund |
AMT-Free OR Intermediate Muni Bond Fund | July 7, 2014 | Columbia Oregon Intermediate Municipal Bond Fund |
Disciplined Small Core Fund | April 18, 2016 | Columbia Small Cap Core Fund |
Statement of Additional Information – [____, 2018] | 9 |
Fund* | Effective Date of Name Change | Previous Fund Name |
Global Energy and Natural Resources Fund | August 5, 2013 | Columbia Energy and Natural Resources Fund |
Global Technology Growth Fund | July 7, 2014 | Columbia Technology Fund |
MM Alternative Strategies Fund |
February
28, 2017
October 12, 2016 |
Active
Portfolios
®
Multi-Manager Alternatives Fund
Active Portfolios ® Multi-Manager Alternative Strategies Fund |
MM Directional Alternative Strategies Fund | February 28, 2017 | Active Portfolios ® Multi-Manager Directional Alternatives Fund |
MM Growth Strategies Fund |
February
28, 2017
December 11, 2013 |
Active
Portfolios
®
Multi-Manager Growth Fund
Columbia Active Portfolios ® – Select Large Cap Growth Fund |
MM Small Cap Equity Strategies Fund | February 28, 2017 | Active Portfolios ® Multi-Manager Small Cap Equity Strategies Fund |
MM Total Return Bond Strategies Fund |
February
28, 2017
April 11, 2016 |
Active
Portfolios
®
Multi-Manager Total Return Bond Fund
Active Portfolios ® Multi-Manager Core Plus Bond Fund |
Total Return Bond Fund | February 19, 2016 | Columbia Intermediate Bond Fund |
* | Effective on or about January 22, 2018, Columbia California Tax-Exempt Fund’s name is changed to Columbia Strategic California Municipal Income Fund and Columbia New York Tax-Exempt Fund’s name is changed to Columbia Strategic New York Municipal Income Fund. |
Statement of Additional Information – [____, 2018] | 10 |
Statement of Additional Information – [____, 2018] | 11 |
A. | Buy or sell real estate |
A1 – | The Fund may not purchase or sell real estate, except each Fund may: (i) purchase securities of issuers which deal or invest in real estate, (ii) purchase securities which are secured by real estate or interests in real estate and (iii) hold and dispose of real estate or interests in real estate acquired through the exercise of its rights as a holder of securities which are secured by real estate or interests therein. |
A2 – | The Fund will not buy or sell real estate, unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the Fund from investing in: (i) securities or other instruments backed by real estate or interests in real estate, (ii) securities or other instruments of issuers or entities that deal in real estate or are engaged in the real estate business, (iii) real estate investment trusts (REITs) or entities similar to REITs formed under the laws of non-U.S. countries or (iv) real estate or interests in real estate acquired through the exercise of its rights as a holder of securities secured by real estate or interests therein. |
B. | Buy or sell physical commodities |
B1 – | The Fund may not purchase or sell commodities, except that each Fund may to the extent consistent with its investment objective: (i) invest in securities of companies that purchase or sell commodities or which invest in such |
Statement of Additional Information – [____, 2018] | 12 |
programs, (ii) purchase and sell options, forward contracts, futures contracts, and options on futures contracts and (iii) enter into swap contracts and other financial transactions relating to commodities. (a) This limitation does not apply to foreign currency transactions including without limitation forward currency contracts. | |
B2 – | The Fund may invest up to 25% of its total assets in one or more wholly-owned subsidiaries that may invest in commodities, thereby indirectly gaining exposure to commodities, and may, to the extent consistent with its investment objective, (i) invest in securities of companies that purchase or sell commodities or which invest in such programs, (ii) purchase and sell options, forward contracts, futures contracts, and options on futures contracts and (iii) enter into swap contracts and other financial transactions relating to commodities. (a) This policy does not limit foreign currency transactions including without limitation forward currency contracts. |
B3 – | The Fund will not purchase or sell commodities, except to the extent permitted by applicable law from time to time. |
B4 – | The Fund will not purchase or sell commodities, except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief, as interpreted or modified by regulatory authority having jurisdiction, from time to time. |
B5 – | The Fund will not purchase or sell commodities, except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
(a) | For purposes of the fundamental investment policy on buying and selling physical commodities above, at the time of the establishment of the restriction for certain Funds, swap contracts on financial instruments or rates were not within the understanding of the term “commodities.” Notwithstanding any federal legislation or regulatory action by the CFTC that subjects such swaps to regulation by the CFTC, these Funds will not consider such instruments to be commodities for purposes of this restriction. |
C. | Issuer Diversification* |
C1 – | The Fund may not purchase securities (except securities issued or guaranteed by the U.S. Government, its agencies or instrumentalities) of any one issuer if, as a result, more than 5% of its total assets will be invested in the securities of such issuer or it would own more than 10% of the voting securities of such issuer, except that: (i) up to 25% of its total assets may be invested without regard to these limitations and (ii) a Fund’s assets may be invested in the securities of one or more management investment companies to the extent permitted by the 1940 Act, the rules and regulations thereunder, or any applicable exemptive relief. |
C2 – | The Fund may not, as a matter of fundamental policy, purchase securities (except securities issued or guaranteed by the U.S. Government, its agencies or instrumentalities) of any one issuer if, as a result, more than 5% of its total assets will be invested in the securities of such issuer or it would own more than 10% of the voting securities of such issuer, except that: (i) up to 50% of its total assets may be invested without regard to these limitations and (ii) the Fund’s assets may be invested in the securities of one or more management investment companies to the extent permitted by the 1940 Act, the rules and regulations thereunder, or any applicable exemptive relief. |
C3 – | The Fund will not make any investment inconsistent with its classification as a diversified company under the 1940 Act. |
C4 – | The Fund will not purchase securities (except securities issued or guaranteed by the U.S. Government, its agencies or instrumentalities) of any one issuer if, as a result, more than 5% of its total assets will be invested in the securities of such issuer or it would own more than 10% of the voting securities of such issuer, except that: (a) up to 25% of its total assets may be invested without regard to these limitations; and (b) a Fund’s assets may be invested in the securities of one or more management investment companies to the extent permitted by the 1940 Act, the rules and regulations thereunder, or any applicable exemptive relief, as interpreted or modified by regulatory authority having jurisdiction, from time to time. |
C5 – | The Fund will not purchase securities (except securities issued or guaranteed by the U.S. Government, its agencies or instrumentalities) of any one issuer if, as a result, more than 5% of its total assets will be invested in the securities of such issuer or it would own more than 10% of the voting securities of such issuer, except that: (a) up to 25% of its total assets may be invested without regard to these limitations; and (b) a Fund’s assets may be invested in the securities of one or more management investment companies to the extent permitted by the 1940 Act, the rules and regulations thereunder, or any applicable exemptive relief. |
* | For purposes of applying the limitation set forth in its issuer diversification policy above, a Fund does not consider futures or swaps central counterparties, where the Fund has exposure to such central counterparties in the course of making investments in futures and securities, to be issuers. |
D. | Concentration* |
D1 – | The Fund may not purchase any securities which would cause 25% or more of the value of its total assets at the time of purchase to be invested in the securities of one or more issuers conducting their principal business activities in the |
Statement of Additional Information – [____, 2018] | 13 |
same industry, provided that: (i) there is no limitation with respect to obligations issued or guaranteed by the U.S. Government, any state or territory of the United States or any of their agencies, instrumentalities or political subdivisions; and (ii) notwithstanding this limitation or any other fundamental investment limitation, assets may be invested in the securities of one or more management investment companies or subsidiaries to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. | |
D2 – | The Fund may not purchase any securities which would cause 25% or more of the value of its total assets at the time of purchase to be invested in the securities of one or more issuers conducting their principal business activities in the same industry, provided that: (i) there is no limitation with respect to obligations issued or guaranteed by the U.S. Government, any state or territory of the United States or any of their agencies, instrumentalities or political subdivisions; (ii) notwithstanding this limitation or any other fundamental investment limitation, assets may be invested in the securities of one or more management investment companies or subsidiaries to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief; and (iii) under normal market conditions, the Fund will invest at least 25% of the value of its total assets at the time of purchase in the securities of issuers conducting their principal business activities in the energy and other natural resources groups of industries. (a) |
D3 – | The Fund will invest at least 65% of the value of its total assets in securities of companies principally engaged in the real estate industry. |
D4 – | The Fund will, under normal market conditions, invest at least 25% of the value of its total assets at the time of purchase in the securities of issuers conducting their principal business activities in the technology and related group of industries, provided that: (i) there is no limitation with respect to obligations issued or guaranteed by the U.S. Government, any state or territory of the United States or any of their agencies, instrumentalities or political subdivisions; and (ii) notwithstanding this limitation or any other fundamental investment limitation, assets may be invested in the securities of one or more management investment companies or subsidiaries to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
D5 – | The Fund may not purchase any securities which would cause 25% or more of the value of its total assets at the time of purchase to be invested in the securities of one or more issuers conducting their principal business activities in the same industry, provided that: (i) there is no limitation with respect to obligations issued or guaranteed by the U.S. Government, any state, municipality or territory of the United States, or any of their agencies, instrumentalities or political subdivisions; and (ii) notwithstanding this limitation or any other fundamental investment limitation, assets may be invested in the securities of one or more management investment companies or subsidiaries to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. The Fund will consider the concentration policies of any underlying funds in which it invests when evaluating compliance with its concentration policy. |
D6 – | The Fund will not purchase any securities which would cause 25% or more of the value of its total assets at the time of purchase to be invested in the securities of one or more issuers conducting their principal business activities in the same industry, provided that: (i) there is no limitation with respect to obligations issued or guaranteed by the U.S. Government, any state, municipality or territory of the United States or any of their agencies, instrumentalities or political subdivisions; and (ii) notwithstanding this limitation or any other fundamental investment limitation, assets may be invested in the securities of one or more investment companies or subsidiaries to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief, as interpreted or modified by regulatory authority having jurisdiction, from time to time. The Fund will consider the concentration policies of any underlying funds in which it invests when evaluating compliance with its concentration policy. |
D7 – | The Fund will not purchase any securities which would cause 25% or more of the value of its total assets at the time of purchase to be invested in the securities of one or more issuers conducting their principal business activities in the same industry, provided that: (i) there is no limitation with respect to obligations issued or guaranteed by the U.S. Government, any state or territory of the United States or any of their agencies, instrumentalities or political subdivisions; and (ii) notwithstanding this limitation or any other fundamental investment limitation, assets may be invested in the securities of one or more investment companies or subsidiaries to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
* | For purposes of applying the limitation set forth in its concentration policy, above, a Fund will generally use the industry classifications provided by the Global Industry Classification System (GICS) for classification of issuers of equity securities and the classifications provided by the Barclays Capital Aggregate Bond Index for classification of issues of fixed-income securities. To the extent that a Fund’s concentration policy requires the Fund to consider the concentration policies of any underlying funds in which it invests, the Fund will consider the portfolio positions at the time of purchase, which in the case of unaffiliated underlying funds is based on portfolio information made publicly available by them. A Fund does not consider futures or swaps clearinghouses or securities clearinghouses, where the Fund has exposure to such clearinghouses in the course of making investments in futures and securities, to be part of any industry. |
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(a) | In determining whether Global Energy and Natural Resources Fund has invested at least 25% of the value of its total assets in the securities of one or more issuers conducting their principal business activities in the energy and other natural resources groups of industries, the Investment Manager currently uses the GICS produced by S&P and MSCI Inc. The Investment Manager currently considers companies in each of the indicated GICS industry groups to be within the energy and other natural resources groups of industries: (i) Energy, (ii) Utilities, and (iii) Materials, but limited to companies in the following GICS industries and sub-industries: the Chemicals industry (companies that primarily produce or distribute industrial and basic chemicals, including the Commodity Chemicals, Diversified Chemicals, Fertilizers & Agriculture Chemicals, Industrial Gases, and Specialty Chemicals sub-industries), the Metals & Mining industry (companies that primarily produce, process, extract, or distribute precious or basic metals or minerals, including the Aluminum, Diversified Metals & Mining, Gold, Precious Metals & Minerals, and Steel sub-industries), and the Paper & Forest Products industry (companies that primarily cultivate or manufacture timber or wood-related products or paper products, including the Forest Products and Paper Products sub-industries). |
E. | Invest 80% |
E1 – | The Fund will, under normal circumstances, invest at least 80% of its total assets in state bonds, subject to applicable state requirements. |
E2 – | Under normal circumstances, the Fund invests at least 80% of net assets in municipal securities that pay interest exempt from federal income tax (including the federal alternative minimum tax) and Connecticut individual income tax. These securities are issued by the State of Connecticut and its political subdivisions, agencies, authorities and instrumentalities, by other qualified issuers (such as Guam, Puerto Rico and the U.S. Virgin Islands) and by mutual funds that invest in such securities. Dividends derived from interest on municipal securities other than such securities will generally be exempt from regular federal income tax (including the federal alternative minimum tax) but subject to Connecticut personal income tax. The Fund may comply with this 80% policy by investing in a partnership, trust or regulated investment company which invests in such securities, in which case the Fund’s investment in such entity shall be deemed to be an investment in the underlying securities in the same proportion as such entity’s investment in such securities bears to its net assets. |
E3 – | As a matter of fundamental policy, under normal circumstances, the Fund invests at least 80% of net assets in municipal securities that pay interest exempt from federal income tax (including the federal alternative minimum tax). These securities are issued by states and their political subdivisions, agencies, authorities and instrumentalities, by other qualified issuers (such as Guam, Puerto Rico and the U.S. Virgin Islands) and by mutual funds that invest in such securities. The Fund may comply with this 80% policy by investing in a partnership, trust, or regulated investment company which invests in such securities, in which case the Fund’s investment in such entity shall be deemed to be an investment in the underlying securities in the same proportion as such entity’s investment in such securities bears to its net assets. |
E4 – | Under normal circumstances, the Fund invests at least 80% of net assets in municipal securities that pay interest exempt from federal income tax (including the federal alternative minimum tax) and Massachusetts individual income tax. These securities are issued by the Commonwealth of Massachusetts and its political subdivisions, agencies, authorities and instrumentalities, by other qualified issuers (such as Guam, Puerto Rico and the U.S. Virgin Islands) and by mutual funds that invest in such securities. Dividends derived from interest on municipal securities other than such securities will generally be exempt from regular federal income tax (including the federal alternative minimum tax) but may be subject to Massachusetts personal income tax. The Fund may comply with this 80% policy by investing in a partnership, trust, or regulated investment company which invests in such securities, in which case the Fund’s investment in such entity shall be deemed to be an investment in the underlying securities in the same proportion as such entity’s investment in such securities bears to its net assets. |
E5 – | As a matter of fundamental policy, under normal circumstances, the Fund invests at least 80% of net assets in municipal securities that pay interest exempt from federal income tax (including the federal alternative minimum tax) and New York State individual income tax. These securities are issued by the State of New York and its political subdivisions, agencies, authorities and instrumentalities and by other qualified issuers (such as Guam, Puerto Rico and the U.S. Virgin Islands). Dividends derived from interest on municipal securities other than such securities will generally be exempt from regular federal income tax (including the federal alternative minimum tax) but may be subject to New York State and New York City personal income tax. The Fund may comply with this 80% policy by investing in a partnership, trust or regulated investment company which invests in such securities, in which case the Fund’s investment in such entity shall be deemed to be an investment in the underlying securities in the same proportion as such entity’s investment in such securities bears to its net assets. |
E6 – | Under normal circumstances, the Fund invests at least 80% of its net assets in municipal securities issued by the State of Oregon and its political subdivisions, agencies, authorities and instrumentalities. |
E7 – | Under normal circumstances, the Fund invests at least 80% of its net assets in equity securities of companies principally engaged in the real estate industry, including REITs. |
E8 – | Under normal circumstances, the Fund invests at least 80% of its total assets in tax-exempt bonds. |
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E9 – | Under normal circumstances, the Fund invests at least 80% of net assets in equity securities (including, but not limited to, common stocks, preferred stocks and securities convertible into common or preferred stocks) of technology companies that may benefit from technological improvements, advancements or developments. |
F. | Act as an underwriter |
F1 – | The Fund may not underwrite any issue of securities issued by other persons within the meaning of the 1933 Act except when it might be deemed to be an underwriter either: (i) in connection with the disposition of a portfolio security; or (ii) in connection with the purchase of securities directly from the issuer thereof in accordance with the Fund’s investment objective. This restriction shall not limit the Fund’s ability to invest in securities issued by other registered investment companies. |
F2 – | The Fund will not underwrite any issue of securities issued by other persons within the meaning of the 1933 Act except when it might be deemed to be an underwriter either: (i) in connection with the disposition of a portfolio security; or (ii) in connection with the purchase of securities directly from the issuer where the Fund later resells such securities. This restriction shall not limit the Fund’s ability to invest in securities issued by other registered investment companies. |
G. | Lending |
G1 – | The Fund may not make loans, except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
G2 – | The Fund will not make loans, except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief, as interpreted or modified by regulatory authority having jurisdiction, from time to time. |
G3 – | The Fund will not make loans, except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
H. | Borrowing |
H1 – | The Fund may not borrow money except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
H2 – | The Fund will not borrow money except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief, as interpreted or modified by regulatory authority having jurisdiction, from time to time. |
H3 – | The Fund will not borrow money except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
I. | Issue senior securities |
I1 – | The Fund may not issue senior securities, except as permitted under the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
I2 – | The Fund will not issue senior securities, except as permitted under the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief, as interpreted or modified by regulatory authority having jurisdiction, from time to time. |
I3 – | The Fund will not issue senior securities, except as permitted under the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
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■ | Bond Fund may invest up to 25% of its assets in dollar-denominated debt securities issued by foreign governments, companies or other entities. |
■ | Balanced Fund, Contrarian Core Fund and Dividend Income Fund each may invest up to 20% of its net assets in foreign securities. |
■ | Disciplined Small Core Fund, Large Cap Growth Fund, Mid Cap Growth Fund, Small Cap Growth Fund I and Small Cap Value Fund I each may invest up to 20% of its total assets in foreign securities. |
■ | Up to 25% of the net assets of MM Total Return Bond Strategies Fund may be invested in foreign investments, which may include investments in non-U.S. dollar denominated securities, as well as investments in emerging markets securities. |
■ | MM Small Cap Equity Strategies Fund may invest up to 25% of its net assets in foreign investments. |
■ | Ultra Short Term Bond Fund may invest up to 20% of its total assets in dollar-denominated foreign debt securities. |
■ | Each Fund (other than those Funds listed below) may not sell securities short, except as permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
■ | The following Funds may not sell securities short: AMT-Free OR Intermediate Muni Bond Fund, Balanced Fund, Bond Fund, Emerging Markets Fund, Global Dividend Opportunity Fund, Global Energy and Natural Resources Fund, Global Technology Growth Fund, Mid Cap Growth Fund, MM Growth Strategies Fund, MM Total Return Bond Strategies Fund Pacific/Asia Fund, Real Estate Equity Fund, Select Large Cap Growth Fund and Small Cap Growth Fund I. |
■ | Tax-Exempt Fund may not have a short position, unless the Fund owns, or owns rights (exercisable without payment) to acquire, an equal amount of such securities. |
■ | Tax-Exempt Fund may not purchase securities on margin, but may receive short-term credit to clear securities transactions and may make initial or maintenance margin deposits in connection with futures transactions. |
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Type of Investment | Alternative and Fund-of-Funds – Alternative |
Equity
and Flexible |
Funds-of-Funds
– Equity and Fixed Income |
Taxable
Fixed Income (a) |
Tax-Exempt
Fixed Income |
Asset-Backed Securities | • | • | • | • | • |
Bank Obligations (Domestic and Foreign) | • | • | • | • | • |
Collateralized Bond Obligations | • | • | • | • | • |
Commercial Paper | • | • | • | • | • |
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Type of Investment | Alternative and Fund-of-Funds – Alternative |
Equity
and Flexible |
Funds-of-Funds
– Equity and Fixed Income |
Taxable
Fixed Income (a) |
Tax-Exempt
Fixed Income |
Common Stock | • | • | • | • | — |
Convertible Securities | • | • | • | • | • |
Corporate Debt Securities | • | • | • | • | • |
Custody Receipts and Trust Certificates | • | • | • | • | • |
Debt Obligations | • | • | • | • | • |
Depositary Receipts | • | • | • | • | — |
Derivatives | • | • | • | • | • |
Dollar Rolls | • | • | • | • | • |
Exchange-Traded Notes | • | • | • | • | • |
Foreign Currency Transactions | • | • | • | • | • |
Foreign Securities | • | • | • | • | • |
Guaranteed Investment Contracts (Funding Agreements) | • | • | • | • | • |
High-Yield Securities | • | • | • | • | • |
Illiquid Securities | • | • | • | • | • |
Inflation Protected Securities | • | • | • | • | • |
Initial Public Offerings | • | • | • | • | • |
Inverse Floaters | • | • | • | • | • |
Investments in Other Investment Companies (Including ETFs) | • | • | • | • | • |
Listed Private Equity Funds | • | • | • | • | • |
Money Market Instruments | • | • | • | • | • |
Mortgage-Backed Securities | • | • | • | • | • |
Municipal Securities | • | • | • | • | • |
Participation Interests | • | • | • | • | • |
Partnership Securities | • | • | • | • | • |
Preferred Stock | • | • | • | • | • |
Private Placement and Other Restricted Securities | • | • | • | • | • |
Real Estate Investment Trusts | • | • | • | • | • |
Repurchase Agreements | • | • | • | • | • |
Reverse Repurchase Agreements | • | • | • | • | • |
Short Sales (b) | • | • | • | • | • |
Sovereign Debt | • | • | • | • | • |
Standby Commitments | • | • | • | • | • |
U.S. Government and Related Obligations | • | • | • | • | • |
Variable and Floating Rate Obligations | • | • | • | • | • |
Warrants and Rights | • | • | • | • | • |
(a) | Total Return Bond Fund is not authorized to purchase common stock or bank obligations. U.S. Treasury Index Fund is not authorized to purchase asset-backed securities, bank obligations, convertible securities, corporate debt obligations (other than money market instruments), depositary receipts, dollar rolls, foreign currency transactions, foreign securities, guaranteed investment contracts, inverse floaters, high-yield securities, mortgage-backed securities, municipal securities, participation interests, partnership securities, REITs, reverse repurchase agreements, short sales, sovereign debt and standby commitments. Ultra Short Term Bond is not authorized to purchase common stock, foreign currency transactions and short sales. |
(b) | See Fundamental and Non-Fundamental Investment Policies for Funds that are not permitted to sell securities short. |
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■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). The effectiveness of any currency hedging strategy by a Fund may be reduced by the Fund’s inability to precisely match forward contract amounts and the value of securities involved. Forward foreign currency contracts used for hedging may also limit any potential gain that might result from an increase or decrease in the value of the currency. The Fund may use these instruments to gain leveraged exposure to currencies, which is a speculative investment practice that increases the Fund's risk exposure and the possibility of losses. Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
■ | A forward interest rate agreement is a derivative whereby the buyer locks in an interest rate at a future settlement date. If the interest rate on the settlement date exceeds the lock rate, the buyer pays the seller the difference between the two rates (based on the notional value of the agreement). If the lock rate exceeds the interest rate on the settlement date, the seller pays the buyer the difference between the two rates (based on the notional value of the agreement). The Fund may act as a buyer or a seller. |
Statement of Additional Information – [____, 2018] | 61 |
■ | A bond (or debt instrument) future is a derivative that is an agreement for the contract holder to buy or sell a bond or other debt instrument, a basket of bonds or other debt instrument, or the bonds or other debt instruments in an index on a specified date at a predetermined price. The buyer (long position) of a bond future is obliged to buy the underlying reference at the agreed price on expiry of the future. |
■ | A commodity-linked future is a derivative that is an agreement to buy or sell one or more commodities (such as crude oil, gasoline and natural gas), basket of commodities or indices of commodity futures at a specific date in the future at a specific price. |
■ | A currency future , also an FX future or foreign exchange future, is a derivative that is an agreement to exchange one currency for another at a specified date in the future at a price (exchange rate) that is fixed on the purchase date. |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
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■ | A commodity-linked structured note is a derivative (structured investment) that has principal and/or interest payments based on the market price of one or more particular commodities (such as crude oil, gasoline and natural gas), a basket of commodities, indices of commodity futures or other economic variable. If payment of interest on a commodity-linked structured note is linked to the value of a particular commodity, basket of commodities, commodity index or other economic variable, the Fund might receive lower interest payments (or not receive any of the interest due) on its investments if there is a loss of value in the underlying reference. Further, to the extent that the amount of principal to be repaid upon maturity is linked to the value of a particular commodity, basket of commodities, commodity index or other economic variable, the Fund might not receive a portion (or any) of the principal at maturity of the investment or upon earlier exchange. At any time, the risk of loss associated with a particular structured note in the Fund’s portfolio may be significantly higher than the value of the note. A liquid secondary market may not exist for the commodity-linked structured notes held in the Fund’s portfolio, which may make it difficult for the notes to be sold at a price acceptable to the portfolio manager(s) or for the Fund to accurately value them. |
■ | Structured investments include collateralized debt obligations which are debt instruments that are collateralized by the underlying cash flows of a pool of financial assets or receivables. |
■ | An equity-linked note (ELN) is a derivative (structured investment) that has principal and/or interest payments based on the value of a single equity security, a basket of equity securities or an index of equity securities, and generally has risks similar to these underlying equity securities. ELNs may be leveraged or unleveraged. An ELN typically provides interest income, thereby offering a yield advantage over investing directly in an underlying equity. The Fund may purchase ELNs that trade on a securities exchange or those that trade on the over-the-counter markets, as well as in privately negotiated transactions with the issuer of the ELN. Investments in ELNs are also subject to liquidity risk, which may make ELNs difficult to sell and value. The liquidity of unlisted ELNs is normally determined by the willingness of the issuer to make a market in the ELN. While the Fund will seek to purchase ELNs only from issuers that it believes to be willing and able to repurchase the ELN at a reasonable price, there can be no assurance that the Fund will be able to sell at such a price. Furthermore, such inability to sell may impair the Fund’s ability to enter into other transactions at a time when doing so might be advantageous. The Fund’s investments in ELNs have the potential to lead to significant losses, including the amount the Fund invested in the ELN, because ELNs are subject to the market and volatility risks associated with their underlying equity. In addition, because ELNs often take the form of unsecured notes of the issuer, the Fund would be subject to the risk that the issuer may default on its obligations under the ELN, thereby subjecting the Fund to the further risk of being too concentrated in the securities (including ELNs) of that issuer. However, the Fund typically considers ELNs alongside other securities of the issuer in its assessment of issuer concentration risk. In addition, ELNs may exhibit price behavior that does not correlate with the underlying securities. ELNs may also be subject to leverage risk (the risk that losses may be greater than the amount invested). The Fund may or may not hold an ELN until its maturity. ELNs also include participation notes. |
■ | A commodity-linked swap is a derivative (swap) that is an agreement where the underlying reference is the market price of one or more particular commodities (such as crude oil, gasoline and natural gas), basket of commodities or indices of commodity futures. |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as |
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credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a credit default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
■ | An inflation rate swap is a derivative typically used to transfer inflation risk from one party to another through an exchange of cash flows. In an inflation rate swap, one party pays a fixed rate on a notional principal amount, while the other party pays a floating rate linked to an inflation index, such as the Consumer Price Index (CPI). |
■ | An interest rate swap is a derivative in which two parties agree to exchange interest rate cash flows, based on a specified notional amount from a fixed rate to a floating rate (or vice versa) or from one floating rate to another. Interest rate swaps can be based on various measures of interest rates, including LIBOR, swap rates, treasury rates and foreign interest rates. |
■ | Total return swaps are derivative swap transactions in which one party agrees to pay the other party an amount equal to the total return of a defined underlying reference during a specified period of time. In return, the other party would make periodic payments based on a fixed or variable interest rate or on the total return of a different underlying reference. |
■ | Contracts for differences are swap arrangements in which the parties agree that their return (or loss) will be based on the relative performance of two different groups or baskets of securities or other instruments. Often, one or both baskets will be an established securities index. The Fund’s return will be based on changes in value of theoretical long futures positions in the securities comprising one basket (with an aggregate face value equal to the notional amount of the contract for differences) and theoretical short futures positions in the securities comprising the other basket. The Fund also may use actual long and short futures positions and achieve similar market exposure by netting the payment obligations of the two contracts. If the short basket outperforms the long basket, the Fund will realize a loss – even in circumstances when the securities in both the long and short baskets appreciate in value. |
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Fund |
Assets
(millions) |
Annual
rate at
each asset level |
Management
Agreement
Effective Date |
Alternative Beta Fund (a) | $0 - $500 | 0.960% | 10/1/2016 |
>$500 - $1,000 | 0.955% | ||
>$1,000 - $3,000 | 0.950% | ||
>$3,000 - $12,000 | 0.940% | ||
>$12,000 | 0.930% | ||
AMT-Free Intermediate Muni Bond Fund | $0 - $500 | 0.480% | 3/1/2016 |
Tax-Exempt Fund | >$500 - $1,000 | 0.475% | 12/1/2015 |
U.S. Social Bond Fund (b) | >$1,000 - $2,000 | 0.445% | 12/1/2015 |
>$2,000 - $3,000 | 0.420% | ||
>$3,000 - $6,000 | 0.385% | ||
>$6,000 - $9,000 | 0.360% | ||
>$9,000 - $10,000 | 0.350% | ||
>$10,000 - $12,000 | 0.340% | ||
>$12,000 - $15,000 | 0.330% | ||
>$15,000 - $24,000 | 0.320% | ||
>$24,000 - $50,000 | 0.300% | ||
>$50,000 | 0.290% | ||
AMT-Free OR Intermediate Muni Bond Fund | $0 - $250 | 0.470% | 12/1/2015 |
AMT-Free CT Intermediate Muni Bond Fund | >$250 - $500 | 0.465% | 3/1/2016 |
AMT-Free MA Intermediate Muni Bond Fund | >$500 - $1,000 | 0.415% | 3/1/2016 |
AMT-Free NY Intermediate Muni Bond Fund | >$1,000 - $3,000 | 0.380% | 3/1/2016 |
CA Tax-Exempt Fund | >$3,000 - $6,000 | 0.340% | 3/1/2016 |
NY Tax-Exempt Fund | >$6,000 - $7,500 | 0.330% | 3/1/2016 |
>$7,500 - $12,000 | 0.320% | ||
>$12,000 | 0.310% | ||
Balanced Fund | $0 - $500 | 0.720% | 1/1/2016 |
Dividend Income Fund | >$500 - $1,000 | 0.670% | 10/1/2015 |
>$1,000 - $1,500 | 0.620% | ||
>$1,500 - $3,000 | 0.570% | ||
>$3,000 - $6,000 | 0.550% | ||
>$6,000 - $12,000 | 0.530% | ||
>$12,000 | 0.520% | ||
Bond Fund | $0 - $500 | 0.500% | 9/1/2015 |
Corporate Income Fund | >$500 - $1,000 | 0.495% | 9/1/2015 |
MM Total Return Bond Strategies Fund | >$1,000 - $2,000 | 0.480% | 9/1/2015 |
Total Return Bond Fund | >$2,000 - $3,000 | 0.460% | 9/1/2015 |
>$3,000 - $6,000 | 0.450% | ||
>$6,000 - $7,500 | 0.430% | ||
>$7,500 - $9,000 | 0.415% | ||
>$9,000 - $12,000 | 0.410% | ||
>$12,000 - $20,000 | 0.390% | ||
>$20,000 - $24,000 | 0.380% | ||
>$24,000 - $50,000 | 0.360% | ||
>$50,000 | 0.340% | ||
Contrarian Core Fund | $0 - $500 | 0.770% | 1/1/2016 |
Global Dividend Opportunity Fund | >$500 - $1,000 | 0.720% | 1/1/2016 |
Large Cap Growth Fund | >$1,000 - $1,500 | 0.670% | 12/1/2015 |
MM Growth Strategies Fund | >$1,500 - $3,000 | 0.620% | 12/1/2015 |
Select Large Cap Growth Fund | >$3,000 - $6,000 | 0.600% | 8/1/2015 |
>$6,000 - $12,000 | 0.580% | ||
>$12,000 | 0.570% |
Statement of Additional Information – [____, 2018] | 87 |
Fund |
Assets
(millions) |
Annual
rate at
each asset level |
Management
Agreement
Effective Date |
Disciplined Small Core Fund (c) | $0 - $500 | 0.850% | 7/1/2017 |
>$500 - $1,000 | 0.800% | ||
>$1,000 - $3,000 | 0.750% | ||
>$3,000 - $12,000 | 0.740% | ||
>$12,000 | 0.730% | ||
Diversified Absolute Return Fund (a) | $0 - $500 | 1.180% | 10/1/2015 |
>$500 - $1,000 | 1.130% | ||
>$1,000 - $3,000 | 1.100% | ||
>$3,000 - $6,000 | 1.070% | ||
>$6,000 - $12,000 | 1.040% | ||
>$12,000 | 1.030% | ||
Emerging Markets Fund (c) | $0 - $500 | 1.100% | 7/1/2017 |
>$500 - $1,000 | 1.060% | ||
>$1,000 - $1,500 | 0.870% | ||
>$1,500 - $3,000 | 0.820% | ||
>$3,000 - $6,000 | 0.770% | ||
>$6,000 - $12,000 | 0.720% | ||
>$12,000 | 0.700% | ||
Global Energy and Natural Resources Fund | $0 - $1,000 | 0.750% | 1/1/2016 |
>$1,000 - $1,500 | 0.670% | ||
>$1,500 - $3,000 | 0.620% | ||
>$3,000 - $6,000 | 0.600% | ||
>$6,000 | 0.580% | ||
Global Technology Growth Fund | $0 - $500 | 0.870% | 1/1/2016 |
>$500 - $1,000 | 0.820% | ||
>$1,000 | 0.770% | ||
Greater China Fund | $0 - $1,000 | 0.950% | 1/1/2016 |
Pacific/Asia Fund | >$1,000 - $1,500 | 0.870% | 8/1/2015 |
>$1,500 - $3,000 | 0.820% | ||
>$3,000 - $6,000 | 0.770% | ||
>$6,000 | 0.720% | ||
HY Municipal Fund | $0 - $500 | 0.540% | 10/1/2015 |
>$500 - $1,000 | 0.535% | ||
>$1,000 - $2,000 | 0.505% | ||
>$2,000 - $3,000 | 0.480% | ||
>$3,000 - $6,000 | 0.445% | ||
>$6,000 - $7,500 | 0.420% | ||
>$7,500 - $10,000 | 0.410% | ||
>$10,000 - $12,000 | 0.400% | ||
>$12,000 - $15,000 | 0.390% | ||
>$15,000 - $24,000 | 0.380% | ||
>$24,000 - $50,000 | 0.360% | ||
>$50,000 | 0.340% | ||
Mid Cap Growth Fund | $0 - $500 | 0.820% | 1/1/2016 |
>$500 - $1,000 | 0.770% | ||
>$1,000 - $1,500 | 0.720% | ||
>$1,500 - $3,000 | 0.670% | ||
>$3,000 - $12,000 | 0.660% | ||
>$12,000 | 0.650% | ||
MM Alternative Strategies Fund (a) | $0 - $500 | 1.100% | 1/1/2016 |
>$500 - $1,000 | 1.050% | ||
>$1,000 - $3,000 | 1.020% | ||
>$3,000 - $6,000 | 0.990% | ||
>$6,000 - $12,000 | 0.960% | ||
> $12,000 | 0.950% | ||
MM Directional Alternative Strategies Fund | All assets | 1.60% | 8/17/2016 |
MM International Equity Strategies Fund | [______] | [_______] | [______] |
Statement of Additional Information – [____, 2018] | 88 |
Fund |
Assets
(millions) |
Annual
rate at
each asset level |
Management
Agreement
Effective Date |
MM Small Cap Equity Strategies Fund (c) | $0 - $500 | 0.870% | 7/1/2017 |
Small Cap Growth Fund I | >$500 - $1,000 | 0.820% | 1/1/2016 |
Small Cap Value Fund I | >$1,000 - $3,000 | 0.770% | 9/1/2015 |
>$3,000 - $12,000 | 0.760% | ||
>$12,000 | 0.750% | ||
Multi-Asset Income Fund | $0 - $500 | 0.660% | 9/1/2015 |
>$500 - $1,000 | 0.625% | ||
>$1,000 - $1,500 | 0.610% | ||
>$1,500 - $3,000 | 0.600% | ||
>$3,000 - $6,000 | 0.570% | ||
>$6,000 - $12,000 | 0.545% | ||
>$12,000 | 0.510% | ||
Real Estate Equity Fund | $0 - $500 | 0.750% | 5/1/2016 |
>$500 - $1,000 | 0.745% | ||
>$1,000 - $1,500 | 0.720% | ||
>$1,500 - $3,000 | 0.670% | ||
>$3,000 | 0.660% | ||
Solutions Aggressive Portfolio | All assets | 0.00% | 8/16/2017 |
Solutions Conservative Portfolio | |||
Strategic Income Fund | $0 - $500 | 0.600% | 3/1/2016 |
>$500 - $1,000 | 0.590% | ||
>$1,000 - $2,000 | 0.575% | ||
>$2,000 - $3,000 | 0.555% | ||
>$3,000 - $6,000 | 0.530% | ||
>$6,000 - $7,500 | 0.505% | ||
>$7,500 - $9,000 | 0.490% | ||
>$9,000 - $10,000 | 0.481% | ||
>$10,000 - $12,000 | 0.469% | ||
>$12,000 - $15,000 | 0.459% | ||
>$15,000 - $20,000 | 0.449% | ||
>$20,000 - $24,000 | 0.433% | ||
>$24,000 - $50,000 | 0.414% | ||
>$50,000 | 0.393% | ||
U.S. Treasury Index Fund (d) | All assets | 0.400% | 9/1/2015 |
Ultra Short Term Bond Fund (e) | All assets | 0.250% | 12/1/2015 |
Statement of Additional Information – [____, 2018] | 89 |
Asset Category |
Assets
(millions) |
Annual
rate at
each asset level |
Management
Agreement
Effective Date |
Category 1 : Assets invested in affiliated mutual funds, exchange- traded funds and closed-end funds that pay a management services fee (or an investment management services fee, as applicable) to the Investment Manager. | $0 - $500 | 0.060% | 10/1/2015 |
>$500 - $1,000 | 0.055% | ||
>$1,000 - $3,000 | 0.050% | ||
>$3,000 - $12,000 | 0.040% | ||
>$12,000 | 0.030% | ||
Category 2 : Assets invested in exchange-traded funds and mutual funds that are not managed by the Investment Manager or its affiliates. | $0 - $500 | 0.160% | |
>$500 - $1,000 | 0.155% | ||
>$1,000 - $3,000 | 0.150% | ||
>$3,000 - $12,000 | 0.140% | ||
>$12,000 | 0.130% | ||
Category 3 : Securities, instruments and other assets not described above, including without limitation affiliated mutual funds, exchange-traded funds and closed-end funds that do not pay a management services fee (or an investment management services fee, as applicable) to the Investment Manager, third party closed-end funds, derivatives and individual securities. | $0 - $500 | 0.760% | |
>$500 - $1,000 | 0.745% | ||
>$1,000 - $1,500 | 0.730% | ||
>$1,500 - $3,000 | 0.720% | ||
>$3,000 - $6,000 | 0.690% | ||
>$6,000 - $12,000 | 0.665% | ||
>$12,000 | 0.630% |
Statement of Additional Information – [____, 2018] | 90 |
Management Services Fees | |||
2017 | 2016 | 2015 | |
For Funds with fiscal period ending January 31 | |||
Diversified Real Return Fund | $1,750 | N/A | N/A |
For Funds with fiscal period ending March 31 | |||
Adaptive Retirement 2020 Fund (a) | N/A | N/A | N/A |
Adaptive Retirement 2030 Fund (a) | N/A | N/A | N/A |
Adaptive Retirement 2040 Fund (a) | N/A | N/A | N/A |
Adaptive Retirement 2050 Fund (a) | N/A | N/A | N/A |
Adaptive Retirement 2060 Fund (a) | N/A | N/A | N/A |
MM Growth Strategies Fund | 15,336,414 | $10,774,541 | N/A |
Pacific/Asia Fund | 2,101,261 | 1,466,562 | N/A |
Select Large Cap Growth Fund | 32,224,821 | 27,503,236 | N/A |
Solutions Aggressive Portfolio (b) | N/A | N/A | N/A |
Solutions Conservative Portfolio (b) | N/A | N/A | N/A |
For Funds with fiscal period ending April 30 | |||
Bond Fund | 2,601,726 | 1,850,973 | N/A |
Corporate Income Fund | 5,913,133 | 4,120,977 | N/A |
MM Directional Alternative Strategies Fund | 8,637,630 (c) | N/A | N/A |
Multi-Asset Income Fund | 767,760 | 387,936 | N/A |
Small Cap Value Fund I | 5,104,454 | 4,030,575 | N/A |
Total Return Bond Fund | 13,987,904 | 10,476,193 | N/A |
U.S. Treasury Index Fund | 3,182,138 | 1,480,882 | N/A |
For Funds with fiscal period ending May 31 | |||
Adaptive Risk Allocation Fund | 8,000,497 | 2,017,753 | N/A |
Alternative Beta Fund | 2,938,737 | 1,360,397 | N/A |
Diversified Absolute Return Fund | 1,158,838 | 1,189,076 | N/A |
Dividend Income Fund | 54,720,306 | 31,592,477 | N/A |
HY Municipal Fund | 4,668,440 | 3,193,770 | N/A |
For Funds with fiscal period ending July 31 | |||
AMT-Free OR Intermediate Muni Bond Fund | 2,152,358 | 1,434,255 | N/A |
Large Cap Growth Fund | 22,327,952 | 14,487,605 | N/A |
Tax-Exempt Fund | 17,289,123 | 11,938,008 | N/A |
U.S. Social Bond Fund | 177,410 | 98,416 | N/A |
Ultra Short Term Bond Fund | 4,331,299 | 2,387,448 | N/A |
For Funds with fiscal period ending August 31 | |||
Balanced Fund | 37,000,407 | 18,729,563 | N/A |
Contrarian Core Fund | 62,449,221 | 32,688,864 | N/A |
Disciplined Small Core Fund | 2,120,260 | 1,772,071 | N/A |
Emerging Markets Fund | 13,852,430 | 8,354,982 | N/A |
Global Dividend Opportunity Fund | 4,563,064 | 3,221,310 | N/A |
Global Energy and Natural Resources Fund | 1,792,602 | 1,170,361 | N/A |
Global Technology Growth Fund | 5,448,440 | 2,823,794 | N/A |
Greater China Fund | 1,044,824 | 727,251 | N/A |
Statement of Additional Information – [____, 2018] | 91 |
(a) | The Fund commenced operations on October 24, 2017, and therefore has no reporting information for periods prior to such date. |
(b) | The Fund commenced operations on October 24, 2017. The Solutions Series Funds do not pay a management services fee. |
(c) | For the period from October 17, 2016 (commencement of operations) to April 30, 2017. |
(d) | The Fund changed its fiscal year end in 2017 from October 31 to August 31. For the fiscal year ended in 2017, the information shown is for the period from November 1, 2016 to August 31, 2017. |
Statement of Additional Information – [____, 2018] | 92 |
Investment Advisory Services Fees | |||||
Fund | |||||
For Funds with fiscal period ending January 31 | 2017 | 2016 | 2015 | ||
Diversified Real Return Fund | $2,260 | $6,504 | $6,813 (a) | ||
For Funds with fiscal period ending March 31 | 2017 | 2016 | 2015 | ||
MM Growth Strategies Fund | N/A | $4,662,175 | $11,264,268 | ||
Pacific/Asia Fund | N/A | $772,948 | $2,337,343 | ||
Select Large Cap Growth Fund | N/A | $14,071,760 | $40,020,937 | ||
For Funds with fiscal period ending April 30 | 2017 | 2016 | 2015 | ||
Bond Fund | N/A | $890,053 | $3,091,167 | ||
Corporate Income Fund | N/A | $2,057,083 | $6,174,639 | ||
Multi-Asset Income Fund | N/A | $184,801 | $47,483 (b) | ||
Small Cap Value Fund I | N/A | $2,410,692 | $9,230,465 | ||
Total Return Bond Fund | N/A | $4,803,822 | $15,122,287 | ||
U.S. Treasury Index Fund | N/A | $134,417 | $325,652 | ||
For Funds with fiscal period ending May 31 | 2017 | 2016 | 2015 | ||
Adaptive Risk Allocation Fund | N/A | $869,670 | $1,474,567 | ||
Alternative Beta Fund | N/A | $674,446 | $642,780 (c) | ||
Diversified Absolute Return Fund | N/A | $402,600 | $320,186 (d) | ||
Dividend Income Fund | N/A | $15,277,338 | $47,320,865 | ||
HY Municipal Fund | N/A | $1,326,979 | $3,742,648 | ||
For Funds with fiscal period ending July 31 | 2017 | 2016 | 2015 | ||
AMT-Free OR Intermediate Muni Bond Fund | N/A | $599,072 | $1,802,859 | ||
Large Cap Growth Fund | N/A | $6,999,213 | $20,114,401 | ||
Tax-Exempt Fund | N/A | $5,125,319 | $15,029,336 | ||
U.S. Social Bond Fund | N/A | $33,567 | $26,951 (e) | ||
Ultra Short Term Bond Fund | N/A | $1,224,265 | $4,102,773 | ||
For Funds with fiscal period ending August 31 | 2017 | 2016 | 2015 | ||
Balanced Fund | N/A | $6,697,690 | $15,376,747 | ||
Contrarian Core Fund | N/A | $12,844,105 | $33,944,896 | ||
Disciplined Small Core Fund | N/A | $1,296,456 | $7,204,789 | ||
Emerging Markets Fund | N/A | $3,910,352 | $14,725,495 | ||
Global Dividend Opportunity Fund | N/A | $1,654,873 | $5,854,673 | ||
Global Energy and Natural Resources Fund | N/A | $555,215 | $2,082,111 | ||
Global Technology Growth Fund | N/A | $1,315,278 | $2,604,481 | ||
Greater China Fund | N/A | $405,805 | $1,277,028 | ||
Mid Cap Growth Fund | N/A | $4,700,583 | $15,395,981 | ||
MM Alternative Strategies Fund | N/A | $2,594,022 | $7,820,583 | ||
MM Small Cap Equity Strategies Fund | N/A | $3,830,983 | $6,947,679 | ||
MM Total Return Bond Strategies Fund | N/A | $7,029,420 | $19,958,476 |
Statement of Additional Information – [____, 2018] | 93 |
Investment Advisory Services Fees | |||||
Fund | |||||
Small Cap Growth Fund I | N/A | $1,248,693 | $5,347,823 | ||
Strategic Income Fund (f) | N/A | $4,071,702 | $10,818,719 | ||
For Funds with fiscal period ending October 31 | 2016 | 2015 | 2014 | ||
AMT-Free CT Intermediate Muni Bond Fund | $211,065 | $634,771 | $688,737 | ||
AMT-Free Intermediate Muni Bond Fund | $2,934,748 | $8,483,272 | $8,262,651 | ||
AMT-Free MA Intermediate Muni Bond Fund | $391,155 | $1,171,729 | $1,203,390 | ||
AMT-Free NY Intermediate Muni Bond Fund | $370,479 | $1,072,538 | $1,014,210 | ||
CA Tax-Exempt Fund | $701,751 | $1,959,863 | $1,870,343 | ||
NY Tax-Exempt Fund | $256,900 | $709,903 | $682,302 | ||
For Funds with fiscal period ending December 31 | 2016 | 2015 | 2014 | ||
Real Estate Equity Fund | $1,126,073 | $3,776,529 | $3,762,944 |
(a) | For the period from March 11, 2014 (commencement of operations) to January 31, 2015. |
(b) | For the period from March 27, 2015 (commencement of operations) to April 30, 2015. |
(c) | For the period from January 27, 2015 (commencement of operations) to May 31, 2015. |
(d) | For the period from February 19, 2015 (commencement of operations) to May 31, 2015. |
(e) | For the period from March 26, 2015 (commencement of operations) to July 31, 2015. |
(f) | The Fund changed its fiscal year end in 2017 from October 31 to August 31. |
Statement of Additional Information – [____, 2018] | 94 |
Statement of Additional Information – [____, 2018] | 95 |
Fund | Subadviser |
Parent
Company/Other Information |
Fee Schedule |
For Funds with fiscal period ending August 31 | |||
MM Alternative Strategies Fund |
AQR
(since commencement of operations) |
C | 0.65% on the first $500 million declining to 0.50% as assets increase (b) |
Manulife (effective September 13, 2017) | N | 0.35% on the first $20 million declining to 0.25% as assets increase | |
TCW
(effective March 29, 2017) |
E | 0.30% on the first $500 million declining to 0.15% as assets increase | |
Water
Island
(since commencement of operations) |
D | 0.70% on the first $50 million declining to 0.60% as assets increase | |
MM Small Cap Equity Strategies Fund |
BMO
(c)
(effective May 1, 2017) |
I | 0.30% on the first $200 million, declining to 0.20% as assets increase (b) |
Conestoga
(effective October 1, 2012) |
F | 0.48% on all assets | |
DGHM
(since commencement of operations) |
G | 0.65% of the first $50 million declining to 0.35% as assets increase up to $200 million, thereafter 0.45% | |
EAM
(since commencement of operations) |
H | 0.50% of the first $100 million declining to 0.40% as assets increase | |
MM Total Return Bond Strategies Fund |
Loomis
Sayles
(effective April 11, 2016) |
B | 0.15% on the first $500 million and 0.08% as assets increase |
PGIM
Fixed Income
(effective May 16, 2016) |
J | 0.20% on the first $300 million declining to 0.09% as assets increase | |
TCW
(since commencement of operations) |
E | 0.18% on the first $500 million declining to 0.05% as assets increase (b) |
(a) | The Fund invests substantially all of its assets in affiliated underlying funds, for which the Investment Manager is not paid management services fees and, therefore, the subadvisory fee rate is 0.00%. |
(b) | The fee is calculated based on the combined net assets of certain Columbia Funds subject to the subadviser’s investment management. |
Statement of Additional Information – [____, 2018] | 96 |
Statement of Additional Information – [____, 2018] | 97 |
Subadvisory Fees Paid | ||||
Fund | Subadviser | 2017 | 2016 | 2015 |
For Funds with fiscal period ending August 31 | ||||
MM Alternative Strategies Fund | AQR | $1,645,635 | $1,935,948 | $1,855,699 |
TCW (c) | 186,845 | N/A | N/A | |
Wasatch | 194,138 | 1,433,722 | 1,546,847 | |
Water Island | 1,672,157 | 1,558,201 | 1,549,211 | |
MM Small Cap Equity Strategies Fund | BMO | 557,267 | 601,312 | N/A |
Conestoga | 878,850 | 1,210,731 | 894,675 | |
DGHM | 857,735 | 1,156,275 | 907,318 | |
EAM | 854,606 | 1,022,250 | 875,997 | |
MM Total Return Bond Strategies Fund |
Former
subadviser:
Federated (through May 13, 2016) |
N/A | 972,639 | 1,321,671 |
Loomis Sayles | 1,413,796 | 506,365 (d) | N/A | |
PGIM | 2,193,440 | 613,465 (e) | N/A | |
TCW | 1,419,650 | 1,540,587 | 1,577,344 |
(a) | For the period from February 7, 2017 to March 31, 2017. |
(b) | For the period from October 17, 2016 (commencement of operations) to April 30, 2017. |
(c) | The subadviser began managing the Fund after its last fiscal year end; therefore there are no fees to report. |
(d) | For the period from April 11, 2016 to August 31, 2016. |
(e) | For the period from May 16, 2016 to August 31, 2016. |
Statement of Additional Information – [____, 2018] | 98 |
Other
accounts Managed (excluding the Fund) |
Ownership
of Fund Shares |
Potential
Conflicts of Interest |
Structure
of Compensation |
||||
Fund |
Portfolio
Manager |
Number
and Type of Account* |
Approximate
Total Net Assets |
Performance-
Based Accounts** |
|||
Adaptive Retirement 2030 Fund | Jeffrey Knight (e) |
26
RICs
1 PIV 9 other accounts |
$72.43
billion
$10.98 million $4.87 million |
None | None |
Columbia
Management |
Columbia
Management |
Joshua Kutin (e) |
14
RICs
1 PIV 8 other accounts |
$9.50
billion
$10.98 million $40.68 million |
None | None | |||
Alex Wilkinson (e) |
2
RICs
1 other account |
$351.82
million
$4,316.14 |
None | None | |||
Adaptive Retirement 2040 Fund | Jeffrey Knight (e) |
26
RICs
1 PIV 9 other accounts |
$72.43
billion
$10.98 million $4.87 million |
None | None |
Columbia
Management |
Columbia
Management |
Joshua Kutin (e) |
14
RICs
1 PIV 8 other accounts |
$9.50
billion
$10.98 million $40.68 million |
None | None | |||
Alex Wilkinson (e) |
2
RICs
1 other account |
$351.82
million
$4,316.14 |
None | None | |||
Adaptive Retirement 2050 Fund | Jeffrey Knight (e) |
26
RICs
1 PIV 9 other accounts |
$72.43
billion
$10.98 million $4.87 million |
None | None |
Columbia
Management |
Columbia
Management |
Joshua Kutin (e) |
14
RICs
1 PIV 8 other accounts |
$9.50
billion
$10.98 million $40.68 million |
None | None | |||
Alex Wilkinson (e) |
2
RICs
1 other account |
$351.82
million
$4,316.14 |
None | None | |||
Adaptive Retirement 2060 Fund | Jeffrey Knight (e) |
26
RICs
1 PIV 9 other accounts |
$72.43
billion
$10.98 million $4.87 million |
None | None |
Columbia
Management |
Columbia
Management |
Joshua Kutin (e) |
14
RICs
1 PIV 8 other accounts |
$9.50
billion
$10.98 million $40.68 million |
None | None | |||
Alex Wilkinson (e) |
2
RICs
1 other account |
$351.82
million
$4,316.14 |
None | None |
Statement of Additional Information – [____, 2018] | 99 |
Other
accounts Managed (excluding the Fund) |
Ownership
of Fund Shares |
Potential
Conflicts of Interest |
Structure
of Compensation |
||||
Fund |
Portfolio
Manager |
Number
and Type of Account* |
Approximate
Total Net Assets |
Performance-
Based Accounts** |
|||
MM
Growth Strategies
Fund |
Columbia
Management:
Thomas M. Galvin |
6 RICs 3 PIVs 1332 other accounts |
$5.05 billion $494.09 million $4.34 billion |
3 other accounts ($0.89 B) |
None |
Columbia Management |
Columbia Management |
Richard A. Carter |
6
RICs
3 PIVs 1333 other accounts |
$5.05
billion
$494.09 million $4.33 billion |
3
other
accounts ($0.89 B) |
None | |||
Todd D. Herget |
6
RICs
3 PIVs 1336 other accounts |
$5.05
billion
$494.09 million $4.33 billion |
3
other
accounts ($0.89 B) |
None | |||
Loomis
Sayles:
Aziz Hamzaogullari |
16 RICs 13 PIVs 95 other accounts |
$17.05 billion $2.66 billion $12.29 billion |
1 PIV ($543 M) |
None |
Loomis Sayles |
Loomis Sayles |
|
Los
Angeles Capital:
Thomas Stevens |
14 RICs 12 PIVs 38 other accounts |
$4.95 billion $4.88 billion $14.47 billion |
1 RIC ($2.38 B) 4 PIVs ($2.87 B) 5 other accounts ($8.31 B) |
None |
Los Angeles Capital |
Los Angeles Capital |
|
Hal Reynolds |
13
RICs
12 PIVs 38 other accounts |
$4.87
billion
$4.88 billion $14.47 billion |
1
RIC ($2.38 B)
4 PIVs ($2.87 B) 5 other accounts ($8.31 B) |
None | |||
Daniel Allen |
10
RICs
12 PIVs 38 other accounts |
$1.77
billion
$4.88 billion $14.47 billion |
4
PIVs ($2.87 B)
5 other accounts ($8.31 B) |
None | |||
Daniel Arche |
1
RIC
5 PIVs 14 other accounts |
$536.24
million
$3.1 billion $1.86 billion |
2 PIVs ($2.21 B) | None | |||
Pacific/
Asia Fund |
Jasmine
(Weili)
Huang |
4
RICs
1 PIV 12 other accounts |
$2.05
billion
$608.28 million $103.09 million |
None |
$10,001
–
$50,000 (b) |
Columbia
Management |
Columbia
Management |
Daisuke Nomoto |
2
RICs
1 PIV 3 other accounts |
$763.19
million
$114.68 million $0.89 million |
None |
$100,001
–
$500,000 (b) $50,001 – $100,000 (a) |
|||
Christine Seng |
1
PIV
1 other account |
$46.94
million
$25.46 million |
None | None (c) | Threadneedle | Threadneedle |
Statement of Additional Information – [____, 2018] | 100 |
Other
accounts Managed (excluding the Fund) |
Ownership
of Fund Shares |
Potential
Conflicts of Interest |
Structure
of Compensation |
||||
Fund |
Portfolio
Manager |
Number
and Type of Account* |
Approximate
Total Net Assets |
Performance-
Based Accounts** |
|||
Select
Large
Cap Growth Fund |
Thomas M. Galvin |
6
RICs
3 PIVs 1332 other accounts |
$1.26
billion
$494.09 million $4.34 billion |
3
other
accounts ($0.89 B) |
Over
$1,000,000 (a) $100,001 – $500,000 (b) |
Columbia
Management |
Columbia
Management |
Richard A. Carter |
6
RICs
3 PIVs 1333 other accounts |
$1.26
billion
$494.09 million $4.33 billion |
3
other
accounts ($0.89 B) |
$100,001
–
$500,000 (a) $100,001 – $500,000 (b) |
|||
Todd D. Herget |
6
RICs
3 PIVs 1336 other accounts |
$1.26
billion
$494.09 million $4.33 billion |
3
other
accounts ($0.89 B) |
$500,001
–
$1,000,000 (b) |
|||
Solutions Aggressive Portfolio | Jeffrey Knight (e) |
26
RICs
1 PIV 9 other accounts |
$72.43
billion
$10.98 million $4.87 million |
None | None | Columbia Management | Columbia Management |
Joshua Kutin (e) |
14
RICs
1 PIV 8 other accounts |
$9.50
billion
$10.98 million $40.68 million |
None | None | |||
Alex Wilkinson (e) |
2
RICs
1 other account |
$351.82
million
$4,316.14 |
None | None | |||
Solutions Conservative Portfolio | Jeffrey Knight (e) |
26
RICs
1 PIV 9 other accounts |
$72.43
billion
$10.98 million $4.87 million |
None | None | Columbia Management | Columbia Management |
Joshua Kutin (e) |
14
RICs
1 PIV 8 other accounts |
$9.50
billion
$10.98 million $40.68 million |
None | None | |||
Alex Wilkinson (e) |
2
RICs
1 other account |
$351.82
million
$4,316.14 |
None | None | |||
For Funds with fiscal year ending April 30 – Information is as of April 30, 2017, unless otherwise noted | |||||||
Bond Fund | Gene Tannuzzo (f) |
7
RICs
74 other accounts |
$5.37
billion
$1.24 billion |
None | None |
Columbia
Management |
Columbia
Management |
Jason Callan |
9
RICs
7 PIVs 4 other accounts |
$14.39
billion
$15.42 billion $0.95 million |
None | None | |||
Corporate
Income Fund |
Tom Murphy |
12
RICs
29 PIVs 35 other accounts |
$1.92
billion
$34.67 billion $5.18 billion |
None | None |
Columbia
Management |
Columbia
Management |
Tim Doubek |
10
RICs
1 PIV 34 other accounts |
$1.89
billion
$0.62 million $4.85 billion |
None |
$10,001
–
$50,000 (b) |
Statement of Additional Information – [____, 2018] | 101 |
Other
accounts Managed (excluding the Fund) |
Ownership
of Fund Shares |
Potential
Conflicts of Interest |
Structure
of Compensation |
||||
Fund |
Portfolio
Manager |
Number
and Type of Account* |
Approximate
Total Net Assets |
Performance-
Based Accounts** |
|||
MM
Directional
Alternative Strategies Fund |
Boston
Partners:
Joseph Feeney |
5 RICs 2 other accounts |
$8.49 billion $57.29 million |
None |
None |
Boston Partners |
Boston Partners |
Eric Connerly |
2
RICs
|
$6.62 billion | None | None | |||
AQR:
Michele Aghassi |
21 RICs 22 PIVs 18 other accounts |
$9.51 billion $12.19 billion $6.12 billion |
16 PIVs ($7.84 B) 6 other accounts ($2.04 B) |
None |
AQR |
AQR |
|
Andrea Frazzini |
39
RICs
34 PIVs 40 other accounts |
$19.69
billion
$18.95 billion $18.18 billion |
26
PIVs
($15.27 B) 12 other accounts ($2.84 B) |
None | |||
Jacques Friedman |
48
RICs
51 PIVs 121 other accounts |
$29.51
billion
$26.37 billion $62.5 billion |
39
PIVs
($20.62 B) 40 other accounts ($17.52 B) |
None | |||
Hoon Kim |
12
RICs
15 PIVs 21 other accounts |
$6.86
billion
$6.81 billion $9.6 billion |
11
PIVs
($4.08 B) 4 other accounts ($661.84 M) |
None | |||
Analytic
Investors:
Harindra de Silva |
15 RICs 18 PIVs 31 other accounts |
$7.11 billion $2.18 billion $7.58 billion |
3 PIVs ($244.30 M) 2 other accounts ($293.80 M) |
None |
Analytic Investors |
Analytic Investors |
|
Dennis Bein |
12
RICs
17 PIVs 30 other accounts |
$3.23
billion
$2.18 billion $7.25 billion |
3
PIVs
($244.30 M) 2 other accounts ($293.80 M) |
None | |||
David Krider |
3
RICs
11 PIVs 11 other accounts |
$1.21
billion
$1.73 billion $2.15 billion |
1
PIV
($169.30 M) 1 other account ($32.70 M) |
None |
Statement of Additional Information – [____, 2018] | 102 |
Other
accounts Managed (excluding the Fund) |
Ownership
of Fund Shares |
Potential
Conflicts of Interest |
Structure
of Compensation |
||||
Fund |
Portfolio
Manager |
Number
and Type of Account* |
Approximate
Total Net Assets |
Performance-
Based Accounts** |
|||
Multi-Asset
Income Fund |
Jeffrey Knight |
25
RICs
2 PIVs 7 other accounts |
$70.35
billion
$16.85 million $4.21 million |
None |
$500,001
–
$1,000,000 (b) |
Columbia
Management |
Columbia
Management |
Anwiti Bahuguna |
20
RICs
22 PIVs 16 other accounts |
$67.57
billion
$2.59 billion $100 million |
None | None | |||
Dan Boncarosky |
8
RICs
7 other accounts |
$5.93
billion
$3.06 million |
None |
$1
–
$10,000 (b) |
|||
Joshua Kutin |
13
RICs
2 PIVs 8 other accounts |
$8.71
billion
$16.85 million $37.82 million |
None | None | |||
Small
Cap
Value Fund I |
Jeremy Javidi |
1
RIC
1 PIV 9 other accounts |
$372.42
million
$163.46 million $42.51 million |
None |
$500,001
–
$1,000,000 (a) $50,001 – $100,000 (b) |
Columbia
Management |
Columbia
Management |
Total
Return
Bond Fund |
Gene Tannuzzo (f) |
7
RICs
74 other accounts |
$5.37
billion
$1.24 billion |
None |
$1
–
$10,000 (a) |
Columbia
Management |
Columbia
Management |
Jason Callan |
9
RICs
7 PIVs 4 other accounts |
$12.41
billion
$15.42 billion $0.95 million |
None | None | |||
U.S.
Treasury
Index Fund |
Alan Erickson | 38 other accounts | $942.60 million | None | $1–$10,000 (b) |
Columbia
Management |
Columbia
Management |
For Funds with fiscal year ending May 31 – Information is as of May 31, 2017, unless otherwise noted | |||||||
Adaptive
Risk
Allocation Fund |
Jeffrey L. Knight |
25
RICs
1 PIV 7 other accounts |
$69.30
billion
$13.86 million $4.30 million |
None |
$500,001
–
$1,000,000 (b) |
Columbia
Management; Columbia Management – FoF |
Columbia
Management |
Joshua Kutin |
13
RICS
1 PIV 8 other accounts |
$7.02
billion
$13.86 million $38.99 million |
None |
$50,001
–
$100,000 (b) |
|||
Alternative
Beta Fund |
Jeffrey L. Knight |
25
RICs
1 PIV 7 other accounts |
$70.78
billion
$13.86 million $4.30 million |
None | None |
Columbia
Management |
Columbia
Management |
William Landes |
4
other
accounts |
$42.75 million | None |
over
$1,000,000 (a) |
|||
Marc Khalamayzer |
6
RICs
4 other accounts |
$40.33
million
$38.41 million |
None | $1-$10,000 (b) | |||
Joshua Kutin |
13
RICs
1 PIV 8 other accounts |
$8.50
billion
$13.86 million $38.99 million |
None |
$50,001
–
$100,000 (b) |
Statement of Additional Information – [____, 2018] | 103 |
Other
accounts Managed (excluding the Fund) |
Ownership
of Fund Shares |
Potential
Conflicts of Interest |
Structure
of Compensation |
||||
Fund |
Portfolio
Manager |
Number
and Type of Account* |
Approximate
Total Net Assets |
Performance-
Based Accounts** |
|||
Diversified
Absolute Return Fund |
Jeffrey L. Knight |
25
RICs
1 PIV 7 other accounts |
$71.25
billion
$13.86 million $4.30 million |
None |
$100,001
–
$500,000 (a) $100,001 – $500,000 (b) |
Columbia
Management |
Columbia
Management |
Brian Virginia |
13
RICs
8 other accounts |
$62.55
billion
$2.41 million |
None |
$10,001
–
$50,000 (b) |
|||
Joshua Kutin |
13
RICs
1 PIV 8 other accounts |
$8.97
billion
$13.86 million $38.99 million |
None | None | |||
Alex Wilkinson |
1
RIC
2 other accounts |
$272.95
million
$4,163.00 |
None | None | |||
Dividend
Income Fund |
Michael
S.
Barclay |
2
RICs
2 PIVs 65 other accounts |
$776.48
million
$741.75 million $1.31 billion |
None |
$100,001
–
$500,000 (a) $50,001 – $100,000 (b) |
Columbia
Management |
Columbia
Management |
Scott L. Davis |
2
RICs
2 PIVs 68 other accounts |
$776.48
million
$741.75 million $1.38 billion |
None |
$100,001
–
$500,000 (a) $100,001 – $500,000 (b) |
|||
Peter Santoro |
6
RICs
2 PIVs 61 other accounts |
$2.62
billion
$741.75 million $1.78 billion |
None |
$10,001
–
$50,000 (a) $10,001 – $50,000 (b) |
|||
High
Yield
Municipal Fund |
Chad
H.
Farrington |
2
RICs
10 other accounts |
$994.64
million
$185.19 million |
None |
$10,001
–
$50,000 (a) $10,001 – $50,000 (b) |
Columbia
Management |
Columbia
Management |
Catherine Stienstra |
5
RICs
2 PIVs 3 other accounts |
$3.77
billion
$1.76 billion $0.72 million |
None |
$10,001
–
$50,000 (b) |
|||
For Funds with fiscal year ending July 31 – Information is as of July 31, 2017, unless otherwise noted | |||||||
AMT-Free
OR
Intermediate Muni Bond Fund |
Paul Fuchs |
10
RICs
6 other accounts |
$3.67
billion
$1.69 million |
None | None | Columbia Management | Columbia Management |
Deborah Vargo (f) | 126 other accounts | $1.66 billion | None | None | |||
Large
Cap
Growth Fund |
Peter
R.
Deininger |
2
RICs
8 other accounts |
$3.51
billion
$285.09 million |
None |
$100,001
–
$500,000 (b) |
Columbia
Management |
Columbia
Management |
John T. Wilson |
2
RICs
10 other accounts |
$3.51
billion
$299.46 million |
None |
over
$1,000,000 (a) $100,001 – $500,000 (b) |
|||
Tchintcia S. Barros |
2
RICs
7 other accounts |
$3.51
billion
$284.66 million |
None |
$10,001
–
$50,000 (b) |
Statement of Additional Information – [____, 2018] | 104 |
Other
accounts Managed (excluding the Fund) |
Ownership
of Fund Shares |
Potential
Conflicts of Interest |
Structure
of Compensation |
||||
Fund |
Portfolio
Manager |
Number
and Type of Account* |
Approximate
Total Net Assets |
Performance-
Based Accounts** |
|||
Tax-Exempt
Fund |
Kimberly
A.
Campbell |
19
other
accounts |
$31.28
million
|
None |
$10,001
–
$50,000 (a) $10,001 – $50,000 (b) |
Columbia
Management |
Columbia
Management |
James Dearborn |
1
RIC
5 other accounts |
$41.75
million
$1.27 million |
None |
$100,001
–
$500,000 (a) $10,001 – $50,000 (b) |
|||
U.S.
Social
Bond Fund |
James Dearborn |
1
RIC
5 other accounts |
$3.80
billion
$1.27 million |
None |
$100,001
–
$500,000 (a) $50,001 – $100,000 (b) |
Columbia
Management |
Columbia
Management |
Chad Farrington |
2
RICs
10 other accounts |
$1.78
billion
$175.43 million |
None |
$10,001
–
$50,000 (b) |
|||
Tom Murphy |
12
RICs
28 PIVs 37 other accounts |
$3.12
billion
$34.94 billion $5.32 billion |
None | None | |||
Ultra
Short
Term Bond Fund |
Leonard A. Aplet |
6
RICs
14 PIVs 64 other accounts |
$18.98
billion
$2.10 billion $6.24 billion |
None | None |
Columbia
Management |
Columbia
Management |
Ronald Stahl |
3
RICs
14 PIVs 48 other accounts |
$4.53
billion
$2.10 billion $5.11 billion |
None | None | |||
Greg Liechty |
3
RICs
14 PIVs 45 other accounts |
$4.53
billion
$2.10 billion $5.15 billion |
None | None | |||
For Funds with fiscal year ending August 31 – Information is as of August 31, 2017, unless otherwise noted | |||||||
Balanced Fund | Leonard A. Aplet |
6
RICs
14 PIVs 64 other accounts |
$17.98
billion
$2.13 billion $6.26 billion |
None |
$100,001
–
$500,000 (a) $10,001 – $50,000 (b) |
Columbia
Management |
Columbia
Management |
Brian Lavin |
13
RICs
1 PIV 10 other accounts |
$19.22
billion
$63.28 million $638.38 million |
None | None | |||
Gregory
S.
Liechty |
3
RICs
14 PIVs 46 other accounts |
$3.59
billion
$2.13 billion $5.16 billion |
None |
$50,001
–
$100,000 (b) |
|||
Guy W. Pope |
8
RICs
7 PIVs 65 other accounts |
$15.00
billion
$1.77 billion $5.59 billion |
None |
$100,001
–
$500,000 (a) $50,001 - $100,000 (b) |
|||
Ronald B. Stahl |
3
RICs
14 PIVs 48 other accounts |
$3.59
billion
$2.13 billion $5.13 billion |
None |
$100,001
–
$500,000 (a) $10,001 – $50,000 (b) |
Statement of Additional Information – [____, 2018] | 105 |
Other
accounts Managed (excluding the Fund) |
Ownership
of Fund Shares |
Potential
Conflicts of Interest |
Structure
of Compensation |
||||
Fund |
Portfolio
Manager |
Number
and Type of Account* |
Approximate
Total Net Assets |
Performance-
Based Accounts** |
|||
Contrarian
Core Fund |
Guy W. Pope |
8
RICs
7 PIVs 65 other accounts |
$8.56
billion
$1.77 billion $5.59 billion |
None |
Over
$1,000,000 (a) $100,001 – $500,000 (b) |
Columbia
Management |
Columbia
Management |
Disciplined
Small Core Fund |
Brian Condon |
24
RICs
4 PIVs 55 other accounts |
$13.51
billion
$131.92 million $6.30 billion |
None |
$10,001
–
$50,000 (a) $100,001 – $500,000 (b) |
Columbia
Management |
Columbia
Management |
Peter Albanese |
18
RICs
4 PIVs 50 other accounts |
$13.45
billion
$131.92 million $6.29 billion |
None | $10,001-$50,000 (b) | |||
Emerging
Markets Fund |
Robert
B.
Cameron |
2
RICs
1 PIV 9 other accounts |
$828.09
million
$652.61 million $127.51 million |
None |
$100,001
–
$500,000 (b) |
Columbia
Management |
Columbia
Management |
Jasmine
(Weili)
Huang |
4
RICs
1 PIV 12 other accounts |
$1.17
billion
$652.61 million $127.02 million |
None |
$10,001
–
$50,000 (b) |
|||
Dara J. White |
2
RICs
1 PIV 7 other accounts |
$828.09
million
$652.61 million $130.07 million |
None |
$500,001
–
$1,000,000 (a) $100,001 – $500,000 (b) |
|||
Young Kim |
2
RICs
1 PIV 8 other accounts |
$828.09
million
$652.61 million $126.69 million |
None | $50,001-$100,000 (b) | |||
Perry Vickery |
2
RICs
1 PIV 11 other accounts |
$828.09
million
$652.61 million $128.13 million |
None |
$100,001
–
$500,000 (a) $10,001 – $50,000 (b) |
|||
Global
Dividend Opportunity Fund |
Jonathan Crown |
1
PIV
5 other accounts |
$2.32
billion
$2.70 billion |
None | None | Threadneedle | Threadneedle |
Georgina Hellyer (g) | 1 other account | $55.00 million | None | None (c) | |||
Global
Energy
and Natural Resources Fund |
Josh Kapp |
1
PIV
5 other accounts |
$18.53
million
$1.82 million |
None | None |
Columbia
Management |
Columbia
Management |
Global
Technology Growth Fund |
Rahul Narang |
3
RICs
7 other accounts |
$1.23
billion
$6.16 million |
None |
$100,001
–
$500,000 (b) |
Columbia
Management |
Columbia
Management |
Greater
China
Fund |
Jasmine
(Weili)
Huang |
4
RICs
1 PIV 12 other accounts |
$2.41
billion
$652.61 million $127.02 million |
None |
$10,001
–
$50,000 (b) |
Columbia
Management |
Columbia
Management |
Statement of Additional Information – [____, 2018] | 106 |
Other
accounts Managed (excluding the Fund) |
Ownership
of Fund Shares |
Potential
Conflicts of Interest |
Structure
of Compensation |
||||
Fund |
Portfolio
Manager |
Number
and Type of Account* |
Approximate
Total Net Assets |
Performance-
Based Accounts** |
|||
Mid
Cap
Growth Fund |
George J. Myers |
1
RIC
2 PIVs 7 other accounts |
$459.01
million
$234.61 million $16.64 million |
None |
$50,001
–
$100,000 (a) $50,001-$100,000 (b) |
Columbia
Management |
Columbia
Management |
Brian D. Neigut |
1
RIC
2 PIVs 9 other accounts |
$459.01
million
$234.61 million $16.05 million |
None |
$1,001
–
$10,000 (b) |
|||
William
Chamberlain |
1
RIC
1 PIV 6 other accounts |
$459.01
million
$230.01 million $15.36 million |
None |
$10,001
–
$50,000 (b) |
|||
MM
Alternative Strategies
Fund |
AQR:
Clifford S. Asness |
39 RICs 52 PIVs 77 other accounts |
$26.57 billion $30.99 billion $40.14 billion |
43 PIVs ($25.05 B) 28 other accounts ($11.69B) |
None |
AQR |
AQR |
Brian K. Hurst |
13
RICs
60 PIVs 22 other accounts |
$18.49
billion
$36.15 billion $13.86 billion |
52
PIVs
($29.98 B) 6 other accounts ($5.23 B) |
None | |||
John M. Liew |
21
RICs
40 PIVs 32 other accounts |
$21.99
billion
$24.54 billion $17.07 billion |
34
PIVs
($18.4 B) 11 other accounts ($6.22 B) |
None | |||
Yao Hua Ooi |
12
RICs
49 PIVs 3 other accounts |
$18.29
billion
$27.95 billion $1.29 billion |
44
PIVs
($24.36 B) 2 other accounts ($1.01 B) |
None | |||
Ari Levine |
7
RICs
42 PIVs 9 other accounts |
$13.62
billion
$28.08 billion $4.97 billion |
39
PIVs
($23.88 B) 3 other accounts ($1.5 B) |
None |
Statement of Additional Information – [____, 2018] | 107 |
Statement of Additional Information – [____, 2018] | 108 |
Statement of Additional Information – [____, 2018] | 109 |
Other
accounts Managed (excluding the Fund) |
Ownership
of Fund Shares |
Potential
Conflicts of Interest |
Structure
of Compensation |
||||
Fund |
Portfolio
Manager |
Number
and Type of Account* |
Approximate
Total Net Assets |
Performance-
Based Accounts** |
|||
MM
Total
Return Bond Strategies Fund |
Columbia
Management:
Gene Tannuzzo (f) |
7 RICs 74 other accounts |
$5.37 billion $1.24 billion |
None |
None |
Columbia Management |
Columbia Management |
Jason Callan |
8
RICs
7 PIVs 4 other accounts |
$12.82
billion
$15.53 billion $0.84 million |
None | None | |||
Loomis
Sayles:
Christopher Harms |
3 RICs 4 PIVs 151 other accounts |
$1.25 billion $1.68 billion $13.18 billion |
None |
None |
Loomis Sayles |
Loomis Sayles |
|
Clifton Rowe |
3
RICs
5 PIVs 145 other accounts |
$1.25
billion
$1.71 billion $13.41 billion |
None | None | |||
Kurt Wagner |
3
RICs
9 PIVs 165 other accounts |
$1.25
billion
$11.24 billion $17.57 billion |
2
other
accounts ($4.72 B) |
None | |||
PGIM:
Michael Collins |
29 RICs 13 PIVs 76 other accounts |
$61.88 billion $10.54 billion $23 billion |
None |
None |
PGIM |
PGIM |
|
Robert Tipp |
24
RICs
19 PIVs 89 other accounts |
$34.75
billion
$8.23 billion $22.21 billion |
1
PIV
|
None | |||
Richard Piccirillo |
38
RICs
27 PIVs 132 other accounts |
$53.26
billion
$12.68 billion $53.51 billion |
2 PIVs | None | |||
Gregory Peters |
14
RICs
11 PIVs 40 other accounts |
$46.76
billion
$4.77 billion $22.06 billion |
None | None |
Statement of Additional Information – [____, 2018] | 110 |
Statement of Additional Information – [____, 2018] | 111 |
Other
accounts Managed (excluding the Fund) |
Ownership
of Fund Shares |
Potential
Conflicts of Interest |
Structure
of Compensation |
||||
Fund |
Portfolio
Manager |
Number
and Type of Account* |
Approximate
Total Net Assets |
Performance-
Based Accounts** |
|||
AMT-Free
MA
Intermediate Muni Bond Fund |
Paul F. Fuchs |
11
RICs
6 other accounts |
$4.64
billion
$1.42 million |
None | None |
Columbia
Management |
Columbia
Management |
Deborah Vargo (f) | 126 other accounts | $1.66 billion | None | $1-$10,000 (a) | |||
AMT-Free
NY
Intermediate Muni Bond Fund |
Paul F. Fuchs |
11
RICs
6 other accounts |
$4.64
billion
$1.42 million |
None | None |
Columbia
Management |
Columbia
Management |
Deborah Vargo (f) | 126 other accounts | $1.66 billion | None | None | |||
CA
Tax-Exempt
Fund |
Catherine
Stienstra |
5
RICs
2 PIVs 4 other accounts |
$4.35
billion
$1.78 billion $13.87 million |
None | None |
Columbia
Management |
Columbia
Management |
Anders Myhran |
3
RICs
1 PIV 2 other accounts |
$2.52
billion
$1.73 billion $1.32 million |
None | None | |||
NY
Tax-Exempt
Fund |
Catherine
Stienstra |
5
RICs
2 PIVs 4 other accounts |
$4.67
billion
$1.78 billion $13.87 million |
None | None |
Columbia
Management |
Columbia
Management |
Anders Myhran |
3
RICs
1 PIV 2 other accounts |
$2.84
billion
$1.73 billion $1.32 million |
None | None | |||
For Funds with fiscal year ending December 31 – Information is as of December 31, 2016, unless otherwise noted | |||||||
Real
Estate
Equity Fund |
Arthur J. Hurley |
1
RIC
9 other accounts |
$4.16
million
$1.62 million |
None |
$1
–
$10,000 (a) $10,001 – $50,000 (b) |
Columbia
Management |
Columbia
Management |
* | RIC refers to a Registered Investment Company; PIV refers to a Pooled Investment Vehicle. |
** | Number and type of accounts for which the advisory fee paid is based in part or wholly on performance and the aggregate net assets in those accounts. |
(a) | Excludes any notional investments. |
(b) | Notional investments through a deferred compensation account. |
(c) | The Fund is available for sale only in the U.S. The portfolio managers do not reside in the U.S. and therefore do not hold any shares of the Fund. |
(d) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of September 30, 2017. |
(e) | The portfolio manager began managing the Fund on October 24, 2017 (commencement of operations); reporting information is provided as of August 31, 2017. |
(f) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of September 30, 2017. |
(g) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of October 31, 2017. |
(h) | Reporting information is provided as of October 31, 2017. |
Statement of Additional Information – [____, 2018] | 112 |
Analytic Investors : Analytic Investors and its officers, employees and beneficial owners shall be free from time to time to acquire, possess, manage, and dispose of securities or other investment assets for their own accounts, for the accounts of their families, for the account of any entity in which they have a beneficial interest or for the accounts of others for whom they may provide investment advisory, brokerage or other services (collectively, “Managed Accounts”), in transactions which may or may not correspond with transactions effected or positions held in the fund. It is understood that when Analytic Investors determines that it would be appropriate for the fund and one or more Managed Accounts to participate in an investment opportunity, Analytic Investors will seek to execute orders for the fund and for such Managed Accounts on a basis which it considers equitable, but that equality of treatment of the fund and other Managed Accounts is not assured. In such situations, Analytic Investors may (but is not be required to) place orders for the fund and each other Managed Account simultaneously and if all such orders are not filled at the same price, Analytic Investors may cause the fund and each Managed Account to pay or receive the average of the prices at which the orders were filled. If all such orders cannot be fully executed under prevailing market conditions, Analytic Investors may allocate the securities traded among the fund and other Managed Accounts in a manner which it considers equitable, taking into account the size of the order placed for the fund and each other Managed Account as well as any other factors which it deems relevant. |
Certain of the Managed Accounts that Analytic Investors advises may sell securities short, including securities with respect to which other Managed Accounts hold long positions. The portfolio managers and traders for these Managed Accounts are not separated from the rest of Analytic Investors’ investment personnel and therefore have access to full information about Analytic Investors’ investment research and the investment decisions and strategies being employed for the Managed Accounts. These Managed Accounts pay Analytic Investors management fees at rates comparable to and in some cases lower than those paid by the fund and other Managed Accounts. Analytic Investors also receives a significant share of any profits earned by certain of the Managed Accounts as incentive compensation. As a result, Analytic Investors may have a conflict between its own interests and the interests of other Analytic Investors investment advisory clients in managing the portfolios of certain of these Managed Accounts. |
AQR: Each of the portfolio managers is also responsible for managing other accounts in addition to each Fund, including other accounts of AQR, or its affiliates. Other accounts may include, without limitation, separately managed accounts for foundations, endowments, pension plans, and high net-worth families; registered investment companies; unregistered investment companies relying on either Section 3(c)(1) or Section 3(c)(7) of the 1940 Act (such companies are commonly referred to as “hedge funds”); foreign investment companies; and may also include accounts or investments managed or made by the portfolio managers in a personal or other capacity (“Proprietary Accounts”). Management of other accounts in addition to a Fund can present certain conflicts of interest, as described below. From time to time, potential conflicts of interest may arise between a portfolio manager’s management of the investments of a Fund, on the one hand, and the management of other accounts (including, for purposes of this discussion, other Funds and Proprietary Accounts), on the other. The other accounts might have similar investment objectives or strategies as the Fund, or otherwise hold, purchase, or sell securities that are eligible to be held, purchased or sold by the Fund. Because of their positions with the Fund, the portfolio managers know the size, timing and possible market impact of the Fund’s trades. A potential conflict of interest exists where portfolio managers could use this information to the advantage of other accounts they manage and to the possible detriment of the Fund. |
A number of potential conflict of interest may arise as a result of AQR’s or the portfolio manager’s management of a number of accounts with similar investment strategies. Often, an investment opportunity may be suitable for both the Fund and other accounts, but may not be available in sufficient quantities for both the Fund and the other accounts to participate fully. Similarly, there may be limited opportunity to sell an investment held by the Fund and another account. In circumstances where the amount of total exposure to a strategy or investment type across accounts is, in the opinion of AQR, capacity constrained, the availability of the strategy or investment type for the Fund and other accounts will be reduced regardless of the AQR’s trade allocation policies. A Fund may therefore have reduced exposure to a capacity constrained strategy or investment type, which could adversely affect the Fund’s return. AQR is not obligated to allocate capacity pro rata and may take its financial interests into account when allocating capacity among the Fund and other accounts. Among other things, capacity constraints in a particular strategy or investment type could cause the Fund to close to all or certain new investors. |
Another conflict could arise where different account guidelines and/or differences within particular investment strategies lead to the use of different investment practices for portfolios with a similar investment strategy. AQR will not necessarily purchase or sell the same instruments at the same time or in the same direction (particularly if different accounts have different strategies), or in the same proportionate amounts for all eligible accounts (particularly if different accounts have materially different amounts of capital under management, different amounts of investable cash available, different investment restrictions, or different risk tolerances). As a result, although AQR manages numerous accounts and/or portfolios with similar or identical investment objectives, or may manage accounts with different objectives that trade in the |
Statement of Additional Information – [____, 2018] | 113 |
same instruments, the portfolio decisions relating to these accounts, and the performance resulting from such decisions, may differ from account to account. AQR may, from time to time, implement new trading strategies or participate in new trading strategies for some but not all accounts, including the Fund. Strategies may not be implemented in the same manner among accounts where they are employed, even if the strategy is consistent with the objectives of such accounts. |
Whenever decisions are made to buy or sell investments by the Fund and one or more other accounts simultaneously, AQR or the portfolio managers may aggregate the purchases and sales of the investments and will allocate the transactions in a manner that it believes to be equitable under the circumstances. To this end, AQR has adopted policies and procedures that are intended to assure that investment opportunities are allocated equitably among accounts over time. As a result of the allocations, there may be instances where the Fund will not participate in a transaction that is allocated among other accounts or the Fund may not be allocated the full amount of the investments sought to be traded. These aggregation and allocation policies could have a detrimental effect on the price or amount of the investments available to the Fund from time to time. Subject to applicable laws and/or account restrictions, AQR may buy, sell or hold securities for other accounts while entering into a different or opposite investment decision for the Fund. |
To the extent that a Fund holds interests in an issue that are different (or more senior or junior) than those held by other accounts, AQR may be presented with investment decisions where the outcome would benefit one account and would not benefit or would harm the other account. Furthermore, it is possible that a Fund’s interest may be subordinated or otherwise adversely impacted by virtue of such other accounts’ involvement and actions relating to their investment. In addition, when a Fund and other accounts hold investments in the same issuer (including at the same place in the capital structure), the Fund may be prohibited by applicable law from participating in restructurings, work-outs or other activities related to its investment in the issuer. As a result, a Fund may not be permitted by law to make the same investment decisions as other accounts in the same or similar situations even if AQR believes it would be in the Fund’s best economic interests to do so. A Fund may be prohibited by applicable law from investing in an issuer (or an affiliate) that other accounts are also investing in or currently invest in even if AQR believes it would be in the best economic interests of the Fund to do so. Furthermore, entering into certain transactions that are not deemed prohibited by law when made may potentially lead to a condition that raises regulatory or legal concerns in the future. This may be the case, for example, with issuers that AQR consider to be at risk of default and restructuring or work-outs with debt holders, which may include a Fund and other accounts. In some cases, to avoid the potential of future prohibited transactions, AQR may avoid allocating an investment opportunity to a Fund that it would otherwise recommend, subject to AQR’s then-current allocation policy and any applicable exemptions. |
AQR and the Fund’s portfolio managers may also face a conflict of interest where some accounts pay higher fees to AQR than others, as they may have an incentive to favor accounts with the potential for greater fees. For instance, the entitlement to a performance fee in managing one or more accounts may create an incentive for AQR to take risks in managing assets that it would not otherwise take in the absence of such arrangements. Additionally, since performance fees reward AQR for performance in accounts which are subject to such fees, AQR may have an incentive to favor these accounts over those that have only fixed asset-based fees, such as the Fund, with respect to areas such as trading opportunities, trade allocation, and allocation of new investment opportunities. |
AQR has implemented specific policies and procedures (e.g., a code of ethics and trade allocation policies) that seek to address potential conflicts of interest that may arise in connection with the management of the Fund and other accounts and that are designed to ensure that all client accounts are treated fairly and equitably over time. |
BMO: A conflict of interest may arise as a result of a portfolio manager being responsible for multiple accounts, including the Fund, which may have different investment guidelines and objectives. In addition to the Fund, these accounts may include other mutual funds managed on an advisory or subadvisory basis, separate accounts, and collective trust accounts. An investment opportunity may be suitable for a Fund as well as for any of the other managed accounts. However, the investment may not be available in sufficient quantity for all of the accounts to participate fully. In addition, there may be limited opportunity to sell an investment held by a Fund and the other accounts. The other accounts may have similar investment objectives or strategies as the Fund, they may track the same benchmarks or indexes as the Fund tracks, and they may sell securities that are eligible to be held, sold or purchased by the Fund. A portfolio manager may be responsible for accounts that have different advisory fee schedules, which may create the incentive for the portfolio manager to favor one account over another in terms of access to investment opportunities. A portfolio manager also may manage accounts whose investment objectives and policies differ from those of the Fund, which may cause the portfolio manager to effect trading in one account that may have an adverse effect on the value of the holdings within another account, including a Fund. |
To address and manage these potential conflicts of interest, BMO has adopted compliance policies and procedures to allocate investment opportunities and to ensure that each of its clients is treated on a fair and equitable basis. Such policies and procedures include, but are not limited to, trade allocation and trade aggregation policies, cross trading policies, portfolio manager assignment practices, and oversight by investment management, and/or compliance departments. |
Statement of Additional Information – [____, 2018] | 114 |
Boston Partners: Boston Partners owes its clients a duty of loyalty and monitors situations in which the interests of its advisory clients may be in conflict with its own interests. Boston Partners identifies business practices that may cause a conflict of interest between it and its clients, discloses such conflicts of interest to clients and develops reasonable procedures to mitigate such conflicts. |
Boston Partners has identified the following potential conflicts of interest and the measures it uses to address these matters: |
Equitable
Treatment of Accounts
Boston Partners recognizes that potential conflicts may arise from the side-by-side management of registered investment companies and “investment accounts,” which include privately offered funds and separately managed accounts of individuals and institutional investors. Where Boston Partners’ separately managed accounts are charged performance fees, portfolio managers may be inclined to take investment risks that are outside the scope of such client’s investment objectives and strategy. In addition, since Boston Partners’ private investment funds charge performance fees and share those fees with portfolio managers, such portfolio managers may also be inclined to take additional investment risks. Boston Partners maintains a Trade Allocation and Aggregation Policy as well as a Simultaneous Management Policy to ensure that client accounts are treated equitably. The Compliance Department (“CD”) reviews allocations and dispersion regularly, and accounts within the same strategy are precluded from simultaneously holding a security long and short. There are certain circumstances that would permit a long/short portfolio to take a contra position in a security that is held in another strategy. This happens very infrequently and the contra position is generally not related to the fundamental views of the security (i.e. – initiating a long position in a security at year-end to take advantage of tax-loss selling as a short term investment, or initiating a position based solely on its relative weight in the benchmark to manage investment risk). However in certain situations, the investment constraints of a strategy, including but not limited to country, region, industry or benchmark, may result in a different investment thesis for the same security. Each situation is fully vetted and approved by the firm’s Chief Investment Officer or his designee. Risk Management performs periodic reviews to ensure the product complies with the investment strategy and defined risk parameters. |
Furthermore, since Boston Partners charges a performance fee on certain accounts, and in particular these accounts may receive “new issues” allocations, Boston Partners has a conflict of interest in allocating new issues to these accounts. Boston Partners maintains an IPO Allocation Policy and the CD assists in, and/or reviews, the allocation of new issues to ensure that IPOS are being allocated among all eligible accounts in an equitable manner. |
Utilizing
Brokerage to Advantage Boston Partners
Boston Partners does not place trades through affiliated brokers. Securities trades are executed through brokerage firms with which Boston Partners maintains other advantageous relationships, such as soft dollars. In these cases, the broker may expect commission business in return. Boston Partners has established a Trade Management Oversight Committee to evaluate brokerage services and to review commissions paid to brokers. In addition, Boston Partners maintains a Best Execution Policy and a Soft Dollar Policy to assist in its monitoring efforts. Boston Partners also identifies affiliates of the investment companies for which it acts as investment adviser or sub adviser to ensure it is trading in accordance with applicable rules and regulations. |
Directed
Brokerage
Boston Partners faces an inherent conflict since it is in a position to direct client transactions to a broker or dealer in exchange for distribution capacity. Boston Partners maintains policies which prohibit its traders from considering a broker-dealer’s distribution capacity for promoting or selling Boston Partners’ separate account services, mutual funds, or proprietary funds (collectively “Boston Partners’ Services”) during the broker selection process. Nor will Boston Partners compensate any broker either directly or indirectly by directing brokerage transactions to that broker for consideration in selling Boston Partners’ Services. |
Mixed Use
Allocations and Use of Soft Dollars to Benefit Adviser
Soft dollar services which have a “mixed use” allocation present a conflict of interest when determining the allocation between those services that primarily benefit Boston Partners’ clients and those that primarily benefit Boston Partners. In addition, a conflict of interest exists when Boston Partners uses soft dollars to pay expenses that would normally be paid by Boston Partners. Boston Partners has developed soft dollar policies which require it to make a good faith allocation of “mixed use” services and to document its analysis. In addition, the CD reviews all requests for soft dollars to ensure inclusion under the safe harbor of Section 28 (e) of the Securities Exchange Act of 1934 (the “Exchange Act”). |
Trade Errors
A conflict arises when an investment adviser requests a broker/dealer to absorb the cost of a trade error in return for increased trading and/or commissions. Boston Partners prohibits correcting a trade error for any quid pro quo with a broker and has procedures for the proper correction of trade errors. |
Statement of Additional Information – [____, 2018] | 115 |
Principal
Transactions
A principal transaction occurs when an investment adviser, acting for the account of itself or an affiliate buys a security from, or sells a security to a client. An inherent conflict of interest exists since an adviser has an opportunity to transfer unwanted securities from its account to a client's account, sell securities to a client’s account at prices above the market, or transfer more favorably priced securities from a client account to its account. Boston Partners generally does not permit the selling of a security from one client account and the purchasing of the same security in another client account if Boston Partners has a principal interest in one of the accounts at the time of the transaction. Additionally, Boston Partners requires that clients give consent by signing subscription agreements to purchase a pooled investment vehicle in which Boston Partners or a related entity has an interest. |
Cross Trades
Cross transactions between clients create an inherent conflict of interest because Boston Partners has a duty to obtain the most favorable price for both the selling client and the purchasing client. Boston Partners generally does not engage in cross trading, however Boston Partners has procedures to ensure that any cross trade is in the best interests of all clients. |
Affiliated
Investments
Potential conflicts exist if Boston Partners directs client investments into affiliated vehicles in order to increase the size of these vehicles and thereby increase its compensation by (a) lowering overall expenses of the vehicle, some of which Boston Partners may have responsibility for; (b) permitting greater marketing of the vehicle which will generate greater fee revenue for Boston Partners; or (c) allowing Boston Partners or an affiliate to redeem its investment capital in such vehicle. To mitigate any detriment to the client, Boston Partners has product suitability procedures and will obtain a client’s consent prior to investing client assets in an affiliated vehicle. |
Proprietary
Trading Opportunities
Employees are in a position to take investment opportunities for themselves or Boston Partners before such opportunities are executed on behalf of clients. Employees have a duty to advance Boston Partners’ client interests before Boston Partners interests or their personal interests. Boston Partners must assure that employees do not favor their own or Boston Partners’ accounts. The Code of Ethics (“the Code”) includes procedures on ethical conduct and personal trading, including preclearance and blackout procedures, to which all employees are subject. |
Insider
Trading/Non-Public Information
Employees are in a position to learn material nonpublic information. Such employees are in a position to trade in their personal accounts on such information, to the potential disadvantage of client accounts. The Code addresses insider trading including permissible activities. Employees certify, at least annually, that they are in compliance with the Code. |
Boston Partners periodically discusses securities which may be held in client accounts with external investment professionals when sourcing and analyzing investment ideas. These discussions may include but are not limited to economic factors, market outlook, sector and industry views, and general and/or specific information regarding securities. Discussion of specific securities creates a conflict which could disadvantage Boston Partners’ clients if the external parties were to act upon this information, including but not limited to front-running and scalping either particular securities or numerous securities in a similar sector to the extent such information is known about Boston Partners’ holdings. Boston Partners has policies prohibiting discussion of client investments for non-business purposes and has outlined permissible activities as well as certain other prohibitions when sourcing investment ideas for business purposes. |
Value-Added
Investors
A senior executive from a public company or a private company that is a hedge fund, broker-dealer, investment adviser, or investment bank, (collectively “VAIs”), may invest in Boston Partners’ private funds. A conflict exists if Boston Partners invests in companies affiliated with a VAI or if a VAI who works at a private company provide material non-public information to Boston Partners or vice versa. Both of these conflicts raise issues with respect to information sharing. Boston Partners has procedures to: i) identify these individuals through its annual outside businesses questionnaire, its annual compliance questionnaire, review of new account start-up documents, and its 5130 and 5131 questionnaires, and ii) monitor conflicts these persons present through its pre-trade compliance system and/or email surveillance. |
Selective
Disclosure
Selective disclosure occurs when material information is given to a single investor, or a limited group of investors, and not to all investors at the same time. This practice may allow one set of investors to profit on undisclosed information prior to giving others the same opportunity. In order to prevent this conflict of interest, Boston Partners has procedures regarding the dissemination of account holdings. |
Valuation of
Client Accounts
Because Boston Partners calculates its own advisory fees, it has an incentive to over-value such accounts to either increase the fees payable by the client, or to conceal poor performance for an incentive fee. Boston Partners has several safeguards in |
Statement of Additional Information – [____, 2018] | 116 |
place to mitigate this conflict. Boston Partners has a policy for the valuation of securities. Boston Partners’ Operations Department reconciles cash, assets, and prices for all client accounts with the client’s custodian bank’s records on a monthly basis. Finally the CD, periodically reviews client fee invoices. |
Representing Clients \t times, clients may request Boston Partners represent their interests in class action litigation, bankruptcies or other matters. Boston Partners’ expertise lies in investment management and has an inherent conflict of interest if cast in any other role. When possible, Boston Partners’ investment management agreements include provisions that Boston Partners will not act on behalf of the client in class actions, bankruptcies or matters of litigation. |
Outside Business
Activities
An employee’s outside business activities may conflict with the employee’s duties to Boston Partners and its clients. Boston Partners requires all employees to disclose any outside employment to the CD, who, in conjunction with the employee’s supervisor and the Director of HR, will identify any potential conflicts. In the event that a resolution to the conflict cannot be reached, the employee may be asked to terminate either his outside employment or his position with Boston Partners. |
Business Gifts and
Entertainment
Boston Partners employees periodically give or receive gifts from clients. Boston Partners employees host clients or receive entertainment provided by a client. Such gifts or entertainment may be considered efforts to gain unfair advantage. Boston Partners maintains a gifts and entertainment policy and has developed a “Q&A” guide for employees regarding certain types of gifts and entertainment. Generally, employees are not permitted to give or receive gifts of more than $100 in value, per person, per year. Entertainment that is normal or customary in the industry is considered appropriate. Employees should consult the CD if they are unsure about a particular gift or value of entertainment. |
Illegal or
Unethical Behavior
Unethical or illegal conduct by employees damages Boston Partners’ ability to meet its fiduciary duties to clients. Employees are required to report to management any actual or suspected illegal or unethical conduct on the part of other employees of which they become aware or any situations in which they are concerned about the “best course of action.” In addition, employees are required to certify annually that they are in compliance with this Manual. Regardless of whether a government inquiry occurs, Boston Partners views seriously any violation of this Manual. Disciplinary sanctions may be imposed on any employee committing a violation of this Manual. |
Proxy Voting
Boston Partners’ proxy voting authority for its clients, puts it in a position where its interests may conflict with the best interests of its clients when determining how to vote. Boston Partners has a proxy voting policy and has engaged an outside vendor to execute proxies according to this policy. Boston Partners has a procedure to handle conflicts of interest which may arise in voting client securities. |
Consulting
Relationships
Boston Partners may purchase software, educational programs and peer group information from consulting firms that represent Boston Partners clients. Due to the lack of payment transparency, these relationships could give rise to improper activity on the part of the investment adviser or the consultant. Products purchased from consultants must serve a legitimate need for Boston Partners’ business and may not be acquired to influence a consultant’s recommendation of Boston Partners. |
Columbia Management: Like other investment professionals with multiple clients, a Fund’s portfolio manager(s) may face certain potential conflicts of interest in connection with managing both the Fund and other accounts at the same time. The Investment Manager and the Funds have adopted compliance policies and procedures that attempt to address certain of the potential conflicts that portfolio managers face in this regard. Certain of these conflicts of interest are summarized below. | |
The management of accounts with different advisory fee rates and/or fee structures, including accounts that pay advisory fees based on account performance (performance fee accounts), may raise potential conflicts of interest for a portfolio manager by creating an incentive to favor higher fee accounts. | |
Potential conflicts of interest also may arise when a portfolio manager has personal investments in other accounts that may create an incentive to favor those accounts. As a general matter and subject to the Investment Manager’s Code of Ethics and certain limited exceptions, the Investment Manager’s investment professionals do not have the opportunity to invest in client accounts, other than the funds. | |
A portfolio manager who is responsible for managing multiple funds and/or accounts may devote unequal time and attention to the management of those Funds and/or accounts. The effects of this potential conflict may be more pronounced where Funds and/or accounts managed by a particular portfolio manager have different investment strategies. | |
A portfolio manager may be able to select or influence the selection of the broker/dealers that are used to execute securities transactions for the Funds. A portfolio manager’s decision as to the selection of broker/dealers could produce disproportionate costs and benefits among the Funds and the other accounts the portfolio manager manages. |
Statement of Additional Information – [____, 2018] | 117 |
A potential conflict of interest may arise when a portfolio manager buys or sells the same securities for a Fund and other accounts. On occasions when a portfolio manager considers the purchase or sale of a security to be in the best interests of a Fund as well as other accounts, the Investment Manager’s trading desk may, to the extent consistent with applicable laws and regulations, aggregate the securities to be sold or bought in order to obtain the best execution and lower brokerage commissions, if any. Aggregation of trades may create the potential for unfairness to a Fund or another account if a portfolio manager favors one account over another in allocating the securities bought or sold. The Investment Manager and its Participating Affiliates (including Threadneedle) may coordinate their trading operations for certain types of securities and transactions pursuant to personnel-sharing agreements or similar intercompany arrangements. However, typically the Investment Manager does not coordinate trading activities with a Participating Affiliate with respect to accounts of that Participating Affiliate unless such Participating Affiliate is also providing trading services for accounts managed by the Investment Manager. Similarly, a Participating Affiliate typically does not coordinate trading activities with the Investment Manager with respect to accounts of the Investment Manager unless the Investment Manager is also providing trading services for accounts managed by such Participating Affiliate. As a result, it is possible that the Investment Manager and its Participating Affiliates may trade in the same instruments at the same time, in the same or opposite direction or in different sequence, which could negatively impact the prices paid by the Fund on such instruments. Additionally, in circumstances where trading services are being provided on a coordinated basis for the Investment Manager’s accounts (including the Funds) and the accounts of one or more Participating Affiliates in accordance with applicable law, it is possible that the allocation opportunities available to the Funds may be decreased, especially for less actively traded securities, or orders may take longer to execute, which may negatively impact Fund performance. | |
“Cross trades,” in which a portfolio manager sells a particular security held by a Fund to another account (potentially saving transaction costs for both accounts), could involve a potential conflict of interest if, for example, a portfolio manager is permitted to sell a security from one account to another account at a higher price than an independent third party would pay. The Investment Manager and the Funds have adopted compliance procedures that provide that any transactions between a Fund and another account managed by the Investment Manager are to be made at a current market price, consistent with applicable laws and regulations. | |
Another potential conflict of interest may arise based on the different investment objectives and strategies of a Fund and other accounts managed by its portfolio manager(s). Depending on another account’s objectives and other factors, a portfolio manager may give advice to and make decisions for a Fund that may differ from advice given, or the timing or nature of decisions made, with respect to another account. A portfolio manager’s investment decisions are the product of many factors in addition to basic suitability for the particular account involved. Thus, a portfolio manager may buy or sell a particular security for certain accounts, and not for a Fund, even though it could have been bought or sold for the Fund at the same time. A portfolio manager also may buy a particular security for one or more accounts when one or more other accounts are selling the security (including short sales). There may be circumstances when a portfolio manager’s purchases or sales of portfolio securities for one or more accounts may have an adverse effect on other accounts, including the Funds. | |
To the extent a Fund invests in underlying funds, a portfolio manager will be subject to the potential conflicts of interest described in Potential Conflicts of Interest – Columbia Management – FOF (Fund-of-Funds) below. | |
A Fund’s portfolio manager(s) also may have other potential conflicts of interest in managing the Fund, and the description above is not a complete description of every conflict that could exist in managing the Fund and other accounts. Many of the potential conflicts of interest to which the Investment Manager’s portfolio managers are subject are essentially the same or similar to the potential conflicts of interest related to the investment management activities of the Investment Manager and its affiliates. |
Columbia Management – FoF (Fund-of-Funds): Management of funds-of-funds differs from that of the other Funds. The portfolio management process is set forth generally below and in more detail in the Funds’ prospectus. | |
Portfolio managers of the fund-of-funds may be involved in determining each funds-of-fund’s allocation among the three main asset classes (equity, fixed income and cash) and the allocation among investment categories within each asset class, as well as each funds-of-fund’s allocation among the underlying funds. |
■ | Because of the structure of the funds-of-funds, the potential conflicts of interest for the portfolio managers may be different than the potential conflicts of interest for portfolio managers who manage other Funds. |
■ | The Investment Manager and its affiliates may receive higher compensation as a result of allocations to underlying funds with higher fees. |
Statement of Additional Information – [____, 2018] | 118 |
Conestoga: Like other investment professionals with multiple clients, portfolio managers may face certain potential conflicts of interest in connection with managing both the portion of the Fund’s assets allocated to Conestoga (Conestoga’s Sleeve) and other accounts at the same time. Conestoga has adopted compliance policies and procedures that attempt to address certain of the potential conflicts that Conestoga’s portfolio managers face in this regard. Certain of those conflicts of interest are summarized below. | |
The management of accounts with different advisory or sub-advisory fee rates and/or fee and expense structures may raise certain potential conflicts of interest for a portfolio manager by creating an incentive to favor higher fee, or higher profit margin accounts. | |
Potential conflicts of interest also may arise when a portfolio manager has personal investments in other accounts that may create an incentive to favor those accounts. A portfolio manager who is responsible for managing multiple funds and/or accounts may devote unequal time and attention to the management of those funds and/or accounts. The effects of this potential conflict may be more pronounced where funds and/or accounts managed by a particular portfolio manager have different investment strategies. | |
A portfolio manager may be able to select or influence the selection of the broker-dealers that are used to execute securities transactions for a fund. A portfolio manager’s decision as to the selection of broker-dealers could produce disproportionate costs and benefits among Conestoga’s Sleeve and the other accounts the portfolio manager manages. | |
A potential conflict of interest may arise when a portfolio manager buys or sells the same securities for the Conestoga’s Sleeve and other accounts. On occasions when a portfolio manager considers the purchase or sale of a security to be in the best interests of Conestoga’s Sleeve as well as other accounts, the Conestoga’s trading desk may, to the extent consistent with applicable laws and regulations, aggregate the securities to be sold or bought in order to obtain the best execution and lower brokerage commissions, if any. Aggregation of trades may create the potential for unfairness to Conestoga’s Sleeve or the Fund or another account if a portfolio manager favors one account over another in allocating the securities bought or sold. | |
“Cross trades,” in which a portfolio manager sells a particular security held by Conestoga’s Sleeve to another account (potentially saving transaction costs for both accounts), could involve a potential conflict of interest if, for example, a portfolio manager is permitted to sell a security from one account to another account at a higher price than an independent third party would pay. The Investment Manager has adopted compliance procedures that provide that any transactions between the Fund and another account managed by Conestoga are to be made at a current market price, consistent with applicable laws and regulations. | |
Another potential conflict of interest may arise based on the different investment objectives and strategies of Conestoga’s Sleeve and other accounts managed by its portfolio manager(s). Depending on another account’s objectives and other factors, a portfolio manager may give advice to and make decisions for Conestoga’s Sleeve that may differ from advice given, or the timing or nature of decisions made, with respect to another account. A portfolio manager’s investment decisions are the product of many factors in addition to basic suitability for the particular account involved. Thus, a portfolio manager may buy or sell a particular security for certain accounts, and not for Conestoga’s Sleeve, even though it could have been bought or sold for Conestoga’s Sleeve at the same time. A portfolio manager also may buy a particular security for one or more accounts when one or more other accounts are selling the security. There may be circumstances when a portfolio manager’s purchases or sales of portfolio securities for one or more accounts may have an adverse effect on other accounts, including the Fund. |
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The portfolio manager(s) also may have other potential conflicts of interest in managing Conestoga’s Sleeve, and the description above is not a complete description of every conflict that could exist in managing Conestoga’s Sleeve and other accounts. Many of the potential conflicts of interest to which the Conestoga’s portfolio managers are subject are essentially the same or similar to the potential conflicts of interest related to the investment management activities of the Investment Manager or other subadvisers of the Fund. |
DGHM: The portfolio managers’ management of “other accounts” may give rise to potential conflicts of interest in connection with their management of the investments of the portion of the Fund’s assets allocated to DGHM (DGHM’s Sleeve), on the one hand, and the investments of the other accounts, on the other. The other accounts include hedge funds, separately managed private clients and discretionary 401(k) accounts (“Other Accounts”). The Other Accounts might have similar investment objectives as the Fund, be compared to the same index as the Fund, or otherwise hold, purchase, or sell securities that are eligible to be held, purchased, or sold by DGHM’s Sleeve. | |
Knowledge of the Timing and Size of Fund Trades . A potential conflict of interest may arise as a result of the portfolio managers’ day-to-day management of DGHM’s Sleeve. The portfolio managers know the size and timing of trades for DGHM’s Sleeve and the Other Accounts, and may be able to predict the market impact of the DGHM’s Sleeve trades. It is theoretically possible that the portfolio managers could use this information to the advantage of Other Accounts they manage and to the possible detriment of DGHM’s Sleeve, or vice versa. | |
Investment Opportunities. DGHM provides investment supervisory services for a number of investment products that have varying investment guidelines. The same portfolio management team works across all investment products. Differences in the compensation structures of DGHM’s investment products may give rise to a conflict of interest by creating an incentive for DGHM to allocate the investment opportunities it believes might be the most profitable to the client accounts where it might benefit the most from the investment gains. |
EAM: The portfolio manager is responsible for managing other accounts invested in the same strategy as the portion of the Fund’s assets allocated to EAM (EAM’s Sleeve). These other accounts include separately managed accounts for pension funds. In addition, other EAM portfolio managers manage accounts which have similar investment strategies and may invest in some of the same securities as EAM’s Sleeve or the Fund. | |
From time to time, potential conflicts of interest may arise between the portfolio manager’s management of the investments of EAM’s Sleeve, on the one hand, and the management of other accounts, on the other. For example, an investment opportunity may be suitable for both EAM’s Sleeve and other accounts, but may not be available in sufficient quantities for both EAM’s Sleeve and the other accounts to participate fully. Similarly, there may be limited opportunity to sell an investment held by EAM’s Sleeve and another account. Whenever decisions are made to buy or sell securities by EAM’s Sleeve and one or more of the other accounts simultaneously, EAM or the portfolio managers may aggregate the purchases and sales of the securities and will allocate the securities transactions in a manner that it believes to be equitable under the circumstances. As a result of the allocations, there may be instances when EAM’s Sleeve will not participate in a transaction that is allocated among other accounts or that may not be allocated the full amount of the securities sought to be traded. Another potential conflict may arise when a portfolio manager may have an incentive to allocate opportunities to an account where EAM and the portfolio manager have a greater financial incentive, such as a performance fee account. | |
EAM has implemented specific policies and procedures ( e.g. , a code of ethics and trade allocation policies) that seek to address these potential conflicts. | |
Loomis Sayles: Conflicts of interest may arise in the allocation of investment opportunities and the allocation of aggregated orders among the Funds and other accounts managed by the portfolio managers. A portfolio manager potentially could give favorable treatment to some accounts for a variety of reasons, including favoring larger accounts, accounts that pay higher fees, accounts that pay performance-based fees, accounts of affiliated companies and accounts in which the portfolio manager has an interest. Such favorable treatment could lead to more favorable investment opportunities or allocations for some accounts. Loomis Sayles makes investment decisions for all accounts (including institutional accounts, mutual funds, hedge funds and affiliated accounts) based on each account’s availability of other comparable investment opportunities and Loomis Sayles’ desire to treat all accounts fairly and equitably over time. Loomis Sayles maintains trade allocation and aggregation policies and procedures to address these potential conflicts. Conflicts of interest also may arise to the extent a portfolio manager short sells a stock in one client account but holds that stock long in other accounts, including the Funds, or sells a stock for some accounts while buying the stock for others, and through the use of “soft dollar arrangements,” which are discussed in Loomis Sayles’ Brokerage Allocation Policies and Procedures and Loomis Sayles’ Trade Aggregation and Allocation Policies and Procedures. |
Los Angeles Capital : Los Angeles Capital has implemented policies and procedures, including brokerage and trade allocation policies and procedures, which Los Angeles Capital believes address the potential for conflicts of interest |
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associated with managing portfolios for multiple clients to ensure that all clients are treated equitably and fairly. While each client account is managed individually, Los Angeles Capital will, at any given time, purchase and/or sell the same securities for a number of accounts. |
When appropriate, Los Angeles Capital will aggregate trades in the same securities for many accounts. In these situations, client accounts will receive the same execution price per share, which will reflect the average of multiple prices if the order was executed in multiple trades. Accounts participating in an aggregated trade will be charged a pro-rata share of the total commission charges. However, where a client has specified directed brokerage or a specific order strategy (e.g., market on-close), such transactions may not be aggregated with other orders and may result in commission rates and execution prices that differ from those obtained in an aggregated transaction. In addition, aggregated trades that are partially filled will generally be allocated on a pro-rata basis, subject to adjustments for factors such as available cash and maintenance of guideline weightings. |
Los Angeles Capital’s portfolio managers may manage accounts that are charged a performance-based fee alongside accounts with standard asset-based fee schedules. While performance-based fee arrangements may be viewed as creating an incentive to favor certain accounts over others in the allocation of investment opportunities, Los Angeles Capital has designed and implemented procedures to ensure that all clients are treated fairly and equally, and to prevent conflicts from influencing the allocation of investment opportunities. |
Los Angeles Capital regularly rotates the order for the trading of U.S. strategy accounts and non-U.S. strategy accounts. Given the number of different strategies, the customization of guidelines and turnover in accounts, the weekly trade lists for accounts vary from one account to the next. In a typical week, Los Angeles Capital will begin trading its U.S. strategy accounts followed shortly thereafter by its non-U.S. strategy accounts. While most accounts are traded weekly, some strategies are traded less frequently. Los Angeles Capital endeavors to complete the rebalancing of accounts to be traded within a trading week using alphas generated at the start of the trading week. Los Angeles Capital’s proprietary accounts may be traded in rotation with client accounts, after the trading of most client accounts, or on a particular day of the week depending on liquidity, size, model constraints and resource constraints. Los Angeles Capital’s proprietary accounts are invested in liquid securities. Investment personnel of Los Angeles Capital or its affiliates may be permitted to be commercially or professionally involved with an issuer of securities. Any potential conflicts of interest from such involvement would be monitored for compliance with the firm's Code of Ethics. |
Manulife : When a portfolio manager is responsible for the management of more than one account, the potential arises for the portfolio manager to favor one account over another. The principal types of potential conflicts of interest that may arise are discussed below. For the reasons outlined below, the Fund does not believe that any material conflicts are likely to arise out of a portfolio manager‘s responsibility for the management of the Fund as well as one or more other accounts. Manulife has adopted procedures that are intended to monitor compliance with the policies referred to in the following paragraphs. Generally, the risks of such conflicts of interests are increased to the extent that a portfolio manager has a financial incentive to favor one account over another. Manulife has structured their compensation arrangements in a manner that is intended to limit such potential for conflicts of interests. See ―Compensation of Portfolio Managers below. | |
A portfolio manager could favor one account over another in allocating new investment opportunities that have limited supply, such as initial public offerings and private placements. If, for example, an initial public offering that was expected to appreciate in value significantly shortly after the offering was allocated to a single account, that account may be expected to have better investment performance than other accounts that did not receive an allocation on the initial public offering. Manulife has policies that require a portfolio manager to allocate such investment opportunities in an equitable manner and generally to allocate such investments proportionately among all accounts with similar investment objectives. | |
A portfolio manager could favor one account over another in the order in which trades for the accounts are placed. If a portfolio manager determines to purchase a security for more than one account in an aggregate amount that may influence the market price of the security, accounts that purchased or sold the security first may receive a more favorable price than accounts that made subsequent transactions. The less liquid the market for the security or the greater the percentage that the proposed aggregate purchases or sales represent of average daily trading volume, the greater the potential for accounts that make subsequent purchases or sales to receive a less favorable price. When a portfolio manager intends to trade the same security for more than one account, the policies of Manulife generally require that such trades be “bunched”, which means that the trades for the individual accounts are aggregated and each account receives the same price. There are some types of accounts as to which bunching may not be possible for contractual reasons (such as directed brokerage arrangements). Circumstances may also arise where the trader believes that bunching the orders may not result in the best possible price. Where those accounts or circumstances are involved, Manulife will place the order in a manner intended to result in as favorable a price as possible for such client. |
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A portfolio manager could favor an account if the portfolio manager‘s compensation is tied to the performance of that account rather than all accounts managed by the portfolio manager. If, for example, the portfolio manager receives a bonus based upon the performance of certain accounts relative to a benchmark while other accounts are disregarded for this purpose, the portfolio manager will have a financial incentive to seek to have the accounts that determine the portfolio manager‘s bonus achieve the best possible performance to the possible detriment of other accounts. Similarly, if Manulife receives a performance-based advisory fee, the portfolio manager may favor that account, whether or not the performance of that account directly determines the portfolio manager‘s compensation. The investment performance on specific accounts is not a factor in determining the portfolio manager‘s compensation. Neither the Advisor nor Manulife receives a performance-based fee with respect to any of the accounts managed by the portfolio managers. | |
A portfolio manager could favor an account if the portfolio manager has a beneficial interest in the account, in order to benefit a large client or to compensate a client that had poor returns. For example, if the portfolio manager held an interest in an investment partnership that was one of the accounts managed by the portfolio manager, the portfolio manager would have an economic incentive to favor the account in which the portfolio manager held an interest. Manulife imposes certain trading restrictions and reporting requirements for accounts in which a portfolio manager or certain family members have a personal interest in order to confirm that such accounts are not favored over other accounts. | |
If the different accounts have materially and potentially conflicting investment objectives or strategies, a conflict of interest may arise. For example, if a portfolio manager purchases a security for one account and sells the same security short for another account, such trading pattern could disadvantage either the account that is long or short. In making portfolio manager assignments, Manulife seeks to avoid such potentially conflicting situations. However, where a portfolio manager is responsible for accounts with differing investment objectives and policies, it is possible that the portfolio manager will conclude that it is in the best interest of one account to sell a portfolio security while another account continues to hold or increase the holding in such security. |
PGIM : Like other investment advisers, PGIM Fixed Income is subject to various conflicts of interest in the ordinary course of its business. PGIM Fixed Income strives to identify potential risks, including conflicts of interest, that are inherent in its business, and conducts annual conflict of interest reviews. When actual or potential conflicts of interest are identified, PGIM Fixed Income seeks to address such conflicts through one or more of the following methods: | |
elimination of the conflict; | |
disclosure of the conflict; or | |
management of the conflict through the adoption of appropriate policies, procedures or other mitigants. | |
PGIM Fixed Income follows the policies of Prudential Financial on business ethics, personal securities trading by investment personnel, and information barriers. PGIM Fixed Income has adopted a code of ethics, allocation policies and conflicts of interest policies, among others, and has adopted supervisory procedures to monitor compliance with its policies. PGIM Fixed Income cannot guarantee, however, that its policies and procedures will detect and prevent, or result in the disclosure of, each and every situation in which a conflict may arise. | |
Side-by-Side Management of Accounts and Related Conflicts of Interest. PGIM Fixed Income’s side-by-side management of multiple accounts can create conflicts of interest. Examples are detailed below, followed by a discussion of how PGIM Fixed Income addresses these conflicts. | |
Performance Fees - PGIM Fixed Income manages accounts with asset-based fees alongside accounts with performance-based fees. | |
This side-by-side management may be deemed to create an incentive for PGIM Fixed Income and its investment professionals to favor one account over another. Specifically, PGIM Fixed Income or its affiliates could be considered to have the incentive to favor accounts for which PGIM Fixed Income or an affiliate receives performance fees, and possibly take greater investment risks in those accounts, in order to bolster performance and increase its fees. | |
Affiliated accounts - PGIM Fixed Income manages accounts on behalf of its affiliates as well as unaffiliated accounts. PGIM Fixed Income could be considered to have an incentive to favor accounts of affiliates over others. | |
Large accounts - large accounts typically generate more revenue than do smaller accounts and certain of PGIM Fixed Income’s strategies have higher fees than others. As a result, a portfolio manager could be considered to have an incentive when allocating scarce investment opportunities to favor accounts that pay a higher fee or generate more income for PGIM Fixed Income. | |
Long only and long/short accounts - PGIM Fixed Income manages accounts that only allow it to hold securities long as well as accounts that permit short selling. PGIM Fixed Income may, therefore, sell a security short in some client accounts while holding the same security long in other client accounts. These short sales could reduce the value of the securities held in the long only accounts. In addition, purchases for long only accounts could have a negative impact on the short positions. |
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Securities of the same kind or class - PGIM Fixed Income sometimes buys or sells for one client account securities of the same kind or class that are purchased or sold for another client at prices that may be different. PGIM Fixed Income may also, at any time, execute trades of securities of the same kind or class in one direction for an account and in the opposite direction for another account due to differences in investment strategy or client direction. Different strategies trading in the same securities or types of securities may appear as inconsistencies in PGIM Fixed Income’s management of multiple accounts side-by-side. | |
Financial interests of investment professionals - PGIM Fixed Income investment professionals may invest in certain investment vehicles that it manages, including mutual funds and private funds. Also, certain of these investment vehicles are options under the 401(k) and deferred compensation plans offered by Prudential Financial, Inc. In addition, the value of grants under PGIM Fixed Income’s long-term incentive plan and targeted long-term incentive plan is affected by the performance of certain client accounts. As a result, PGIM Fixed Income investment professionals may have financial interests in accounts managed by PGIM Fixed Income or that are related to the performance of certain client accounts. | |
Non-discretionary accounts - PGIM Fixed Income provides non-discretionary investment advice to some clients and manages others on a discretionary basis. Trades in non-discretionary accounts could occur before, in concert with, or after PGIM Fixed Income executes similar trades in its discretionary accounts. The non-discretionary clients may be disadvantaged if PGIM Fixed Income delivers investment advice to them after it initiates trading for the discretionary clients, or vice versa. | |
How PGIM Fixed Income Addresses These Conflicts of Interest. PGIM Fixed Income has developed policies and procedures designed to address the conflicts of interest with respect to its different types of side-by-side management described above. | |
The chief investment officer/head of PGIM Fixed Income periodically reviews and compares performance and performance attribution for each client account within its various strategies during meetings typically attended by members of PGIM Fixed Income’s senior leadership team, chief compliance officer or his designee, and senior portfolio managers. | |
In keeping with PGIM Fixed Income’s fiduciary obligations, its policy with respect to trade aggregation and allocation is to treat all of its accounts fairly and equitably over time. PGIM Fixed Income’s trade management oversight committee, which generally meets quarterly, is responsible for providing oversight with respect to trade aggregation and allocation. Its compliance group periodically reviews a sampling of new issue allocations and related documentation to confirm compliance with the trade aggregation and allocation procedures. In addition, the compliance and investment risk management groups review forensic reports regarding new issue and secondary trade activity on a quarterly basis. This forensic analysis includes such data as the: (i) number of new issues allocated in the strategy; (ii) size of new issue allocations to each portfolio in the strategy;(iii) profitability of new issue transactions; and (iv) portfolio turnover. The results of these analyses are reviewed and discussed at PGIM Fixed Income’s trade management oversight committee meetings. The procedures above are designed to detect patterns and anomalies in PGIM Fixed Income’s side-by-side management and trading so that it may assess and improve its processes. | |
PGIM Fixed Income has procedures that specifically address its side-by-side management of long/short and long only portfolios. These procedures address potential conflicts that could arise from differing positions between long/short and long only portfolios. In addition, lending opportunities with respect to securities for which the market is demanding a slight premium rate over normal market rates are allocated to long only accounts prior to allocating the opportunities to long/short accounts. | |
Conflicts Related to PGIM Fixed Income’s Affiliations. As an indirect wholly-owned subsidiary of Prudential Financial, Inc., PGIM Fixed Income is part of a diversified, global financial services organization. PGIM Fixed Income is affiliated with many types of U.S. and non-U.S. financial service providers, including insurance companies, broker-dealers, commodity trading advisors, commodity pool operators and other investment advisers. Some of its employees are officers of some of these affiliates. | |
Conflicts Arising Out of Legal Restrictions. PGIM Fixed Income may be restricted by law, regulation, contract or other constraints as to how much, if any, of a particular security it may purchase or sell on behalf of a client, and as to the timing of such purchase or sale. Sometimes these restrictions apply as a result of its relationship with Prudential Financial, Inc. and its other affiliates. For example, PGIM Fixed Income does not purchase securities issued by Prudential Financial, Inc. for client accounts. In addition, PGIM Fixed Income’s holdings of a security on behalf of its clients are required, under some SEC rules, to be aggregated with the holdings of that security by other Prudential Financial, Inc. affiliates. These holdings could, on an aggregate basis, exceed certain reporting or ownership thresholds . Prudential Financial, Inc. tracks these aggregated holdings and may restrict purchases to avoid exceeding these thresholds because of the potential consequences to Prudential Financial, Inc. if such thresholds are exceeded. In addition, PGIM Fixed Income could receive material, non-public information with respect to a particular issuer and, as a result, be unable to execute transactions in securities of that |
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issuer for its clients. For example, PGIM Fixed Income’s bank loan team often invests in private bank loans in connection with which the borrower provides material, non-public information, resulting in restrictions on trading securities issued by those borrowers. PGIM Fixed Income has procedures in place to carefully consider whether to intentionally accept material, non-public information with respect to certain issuers. PGIM Fixed Income is generally able to avoid receiving material, non-public information from its affiliates and other units within PGIM by maintaining information barriers. In some instances, it may create an isolated information barrier around a small number of its employees so that material, non-public information received by such employees is not attributed to the rest of PGIM Fixed Income. | |
Conflicts Related to Outside Business Activity. From time to time, certain of PGIM Fixed Income employees or officers may engage in outside business activity, including outside directorships. Any outside business activity is subject to prior approval pursuant to PGIM Fixed Income’s personal conflicts of interest and outside business activities policy. Actual and potential conflicts of interest are analyzed during such approval process. PGIM Fixed Income could be restricted in trading the securities of certain issuers in client portfolios in the unlikely event that an employee or officer, as a result of outside business activity, obtains material, non-public information regarding an issuer. | |
Conflicts Related to Investment of Client Assets in Affiliated Funds. PGIM Fixed Income may invest client assets in funds that it manages or subadvises for an affiliate. PGIM Fixed Income may also invest cash collateral from securities lending transactions in these funds. These investments benefit both PGIM Fixed Income and its affiliate. | |
PICA General Account. Because of the substantial size of the general account of The Prudential Insurance Company of America (PICA), trading by PICA’s general account, including PGIM Fixed Income’s trades on behalf of the account, may affect market prices. Although PGIM Fixed Income does not expect that PICA’s general account will execute transactions that will move a market frequently, and generally only in response to unusual market or issuer events, the execution of these transactions could have an adverse effect on transactions for or positions held by other clients. | |
Conflicts Related to Co-investment by Affiliates. PGIM Fixed Income affiliates may provide initial funding or otherwise invest in vehicles it manages. When an affiliate provides “seed capital” or other capital for a fund, it may do so with the intention of redeeming all or part of its interest at a future point in time or when it deems that sufficient additional capital has been invested in that fund. | |
The timing of a redemption by an affiliate could benefit the affiliate. For example, the fund may be more liquid at the time of the affiliate’s redemption than it is at times when other investors may wish to withdraw all or part of their interests. | |
In addition, a consequence of any withdrawal of a significant amount, including by an affiliate, is that investors remaining in the fund will bear a proportionately higher share of fund expenses following the redemption. | |
PGIM Fixed Income could also face a conflict if the interests of an affiliated investor in a fund it manages diverge from those of the fund or other investors. For example, PGIM Fixed Income affiliates, from time to time, hedge some or all of the risks associated with their investments in certain funds PGIM Fixed Income manages. PGIM Fixed Income may provide assistance in connection with this hedging activity. | |
PGIM Fixed Income believes that these conflicts are mitigated by its allocation policies and procedures, its supervisory review of accounts and its procedures with respect to side-by-side management of long only and long-short accounts. | |
Conflicts Arising Out of Industry Activities. PGIM Fixed Income and its affiliates have service agreements with various vendors that are also investment consultants. Under these agreements, PGIM Fixed Income or its affiliates compensate the vendors for certain services, including software, market data and technology services. PGIM Fixed Income’s clients may also retain these vendors as investment consultants. The existence of these service agreements may provide an incentive for the investment consultants to favor PGIM Fixed Income when they advise their clients. PGIM Fixed Income does not, however, condition its purchase of services from consultants upon their recommending PGIM Fixed Income to their clients. PGIM Fixed Income will provide clients with information about services that it obtains from these consultants upon request. | |
PGIM Fixed Income retains third party advisors and other service providers to provide various services for PGIM Fixed Income as well as for funds that PGIM Fixed Income manages or subadvises. A service provider may provide services to PGIM Fixed Income or one of PGIM Fixed Income’s funds while also providing services to other PGIM units, other PGIM-advised funds, or affiliates of PGIM, and may negotiate rates in the context of the overall relationship. PGIM Fixed Income may benefit from negotiated fee rates offered to its funds and vice versa. There is no assurance, however, that PGIM Fixed Income will be able to obtain advantageous fee rates from a given service provider negotiated by its affiliates based on their relationship with the service provider, or that PGIM Fixed Income will know of such negotiated fee rates. | |
Conflicts Related to Securities Holdings and Other Financial Interests. |
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Securities Holdings. Prudential Financial, Inc., PICA, PGIM Fixed Income and other affiliates of PGIM at times have financial interests in, or relationships with, companies whose securities PGIM Fixed Income holds, purchases or sells in its client accounts. Certain of these interests and relationships are material to PGIM Fixed Income or to the Prudential enterprise. At any time, these interests and relationships could be inconsistent or in potential or actual conflict with positions held or actions taken by us on behalf of PGIM Fixed Income’s client accounts. For example: | |
PGIM Fixed Income invests in the securities of one or more clients for the accounts of other clients. | |
PGIM Fixed Income’s affiliates sell various products and/or services to certain companies whose securities we purchase and sell for PGIM Fixed Income clients. | |
PGIM Fixed Income invests in the debt securities of companies whose equity is held by its affiliates. | |
PGIM Fixed Income’s affiliates hold public and private debt and equity securities of a large number of issuers and may invest in some of the same companies as other client accounts but at different levels in the capital structure. For example: | |
Affiliated accounts can hold the senior debt of an issuer whose subordinated debt is held by PGIM Fixed Income’s clients or hold secured debt of an issuer whose public unsecured debt is held in client accounts. In the event of restructuring or insolvency, the affiliated accounts as holders of senior debt may exercise remedies and take other actions that are not in the interest of, or are adverse to, other clients that are the holders of junior debt. | |
To the extent permitted by applicable law, PGIM Fixed Income may also invest client assets in offerings of securities the proceeds of which are used to repay debt obligations held in affiliated accounts or other client accounts. PGIM Fixed Income’s interest in having the debt repaid creates a conflict of interest. PGIM Fixed Income has adopted a refinancing policy to address this conflict. | |
Certain of PGIM Fixed Income’s affiliates (as well as directors or officers of its affiliates) are officers or directors of issuers in which PGIM Fixed Income invests from time to time. These issuers may also be service providers to PGIM Fixed Income or its affiliates. | |
In addition, PGIM Fixed Income may invest client assets in securities backed by commercial mortgage loans that were originated or are serviced by an affiliate. | |
In general, conflicts related to the financial interests described above are addressed by the fact that PGIM Fixed Income makes investment decisions for each client independently considering the best economic interests of such client. | |
Conflicts Related to the Offer and Sale of Securities. Certain of PGIM Fixed Income’s employees may offer and sell securities of, and interests in, commingled funds that it manages or subadvises. There is an incentive for PGIM Fixed Income’s employees to offer these securities to investors regardless of whether the investment is appropriate for such investor since increased assets in these vehicles will result in increased advisory fees to it. In addition, such sales could result in increased compensation to the employee. | |
Conflicts Related to Long-Term Compensation. The performance of many client accounts is not reflected in the calculation of changes in the value of participation interests under PGIM Fixed Income’s long-term incentive plan. This may be because the composite representing the strategy in which the account is managed is not one of the composites included in the calculation or because the account is excluded from a specified composite due to guideline restrictions or other factors. In addition, the performance of only a small number of our investment strategies is covered under PGIM Fixed Income’s targeted long-term incentive plan. As a result of the long-term incentive plan and targeted long-term incentive plan, PGIM Fixed Income’s portfolio managers from time to time have financial interests related to the investment performance of some, but not all, of the accounts they manage. To address potential conflicts related to these financial interests, PGIM Fixed Income has procedures, including trade allocation and supervisory review procedures, designed to confirm that each of its client accounts is managed in a manner that is consistent with PGIM Fixed Income’s fiduciary obligations, as well as with the account’s investment objectives, investment strategies and restrictions. For example, PGIM Fixed Income’s chief investment officer/head reviews performance among similarly managed accounts on a quarterly basis during meetings typically attended by members of PGIM Fixed Income’s senior leadership team, chief compliance officer or his designee, and senior portfolio managers. | |
Conflicts Related to Trading – Personal Trading by Employees. Personal trading by PGIM Fixed Income employees creates a conflict when they are trading the same securities or types of securities as PGIM Fixed Income trades on behalf of its clients. This conflict is mitigated by PGIM Fixed Income’s personal trading standards and procedures. | |
In general, conflicts related to the securities holdings and financial interests described above are addressed by the fact that PGIM Fixed Income makes investment decisions for each client independently considering the best economic interests of such client. | |
Conflicts Related to Valuation and Fees. |
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When client accounts hold illiquid or difficult to value investments, PGIM Fixed Income faces a conflict of interest when making recommendations regarding the value of such investments since its management fees are generally based on the value of assets under management. PGIM Fixed Income believes that its valuation policies and procedures mitigate this conflict effectively and enable it to value client assets fairly and in a manner that is consistent with the client’s best interests. In addition, single client account clients often calculate fees based on the valuation of assets provided by their custodian or administrator. | |
Conflicts Related to Securities Lending Fees | |
When PGIM Fixed Income manages a client account and also serves as securities lending agent for the account, it could be considered to have the incentive to invest in securities that would yield higher securities lending rates. | |
TCW: TCW has policies and controls to avoid and/or mitigate conflicts of interest across its businesses. The policies and procedures in TCW’s Code of Ethics (the “Code”) serve to address or mitigate both conflicts of interest and the appearance of any conflict of interest. The Code contains several restrictions and procedures designed to eliminate conflicts of interest relating to personal investment transactions, including (i) reporting account openings, changes, or closings (including accounts in which an Access Person has a "beneficial interest"), (ii) pre-clearance of non-exempt personal investment transactions (make a personal trade request for Securities) and (iii) the completion of timely required reporting (Initial Holdings Report, Quarterly Transactions Report, Annual Holdings Report and Annual Certificate of Compliance). | |
In addition, the Code addresses potential conflicts of interest through its policies on insider trading, anti-corruption, an employee’s outside business activities, political activities and contributions, confidentiality and whistleblower provisions. | |
Conflicts of interest may also arise in the management of accounts and investment vehicles. These conflicts may raise questions that would allow TCW to allocate investment opportunities in a way that favors certain accounts or investment vehicles over other accounts or investment vehicles, or incentivize a TCW portfolio manager to receive greater compensation with regard to the management of certain account or investment vehicles. TCW may give advice or take action with certain accounts or investment vehicles that could differ from the advice given or action taken on other accounts or investment vehicles. When an investment opportunity is suitable for more than one account or investment vehicle, such investments will be allocated in a manner that is fair and equitable under the circumstances to all TCW clients. As such, TCW has adopted compliance policies and procedures in its Portfolio Management Policy that helps to identify a conflict of interest and then specifies how a conflict of interest is managed. TCW’s Trading and Brokerage Policy also discusses the process of timing and method of allocations, and addresses how the firm handles affiliate transactions. | |
The respective Equity and Fixed Income Trading and Allocation Committees review trading activities on behalf of client accounts, including the allocation of investment opportunities and address any issues with regard to side-by-side management in order to ensure that all of TCW’s clients are treated on a fair and equitable basis. Further, the Portfolio Analytics Committee reviews TCW’s investment strategies, evaluates various analytics to facilitate risk assessment, changes to performance composites and benchmarks and monitors the implementation and maintenance of the Global Investment Performance Standards or GIPS® compliance. | |
TCW’s approach to handling conflicts of interest is multi-layered starting with its policies and procedures, reporting and pre-clearance processes and oversight by various committees. |
Threadneedle: Threadneedle portfolio managers may manage one or more mutual funds as well as other types of accounts, including proprietary accounts, separate accounts for institutions, and other pooled investment vehicles. Portfolio managers make investment decisions for an account or portfolio based on its investment objectives and policies, and other relevant investment considerations. A portfolio manager may manage a separate account or other pooled investment vehicle whose fees may be materially greater than the management fees paid by the Fund and may include a performance-based fee. Management of multiple funds and accounts may create potential conflicts of interest relating to the allocation of investment opportunities, and the aggregation and allocation of trades. In addition, a portfolio manager’s responsibilities at Threadneedle include working as a securities analyst. This dual role may give rise to conflicts with respect to making investment decisions for accounts that he/she manages versus communicating his/her analyses to other portfolio managers concerning securities that he/she follows as an analyst. | |
Threadneedle has a fiduciary responsibility to all of the clients for which it manages accounts. Threadneedle seeks to provide best execution of all securities transactions and to aggregate securities transactions and then allocate securities to client accounts in a fair and timely manner. Threadneedle has developed policies and procedures, including brokerage and trade allocation policies and procedures, designed to mitigate and manage the potential conflicts of interest that may arise from the management of multiple types of accounts for multiple clients. |
Water Island: Water Island’s portfolio managers may face certain potential conflicts of interest in connection with their responsibility for managing multiple similar accounts. Other accounts may include, without limitation: separately managed accounts, registered investment companies, unregistered investment companies such as pooled investment vehicles and |
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hedge funds, and
proprietary accounts. Management of multiple accounts can present certain conflicts of interest, including variation in compensation across accounts, conflicts that may arise from the purchase or sale of similar securities for more than one account,
conflicts arising from transactions between accounts, conflicts arising from transactions involving ‘pilot’ funds, and conflicts arising from the selection of brokers and dealers to effect transactions. Water Island’s compliance
team has implemented trading and allocation policies and oversight procedures in order to closely monitor and ensure equitable treatment of all accounts to address these conflicts.
Variation in Compensation - A potential conflict of interest related to variation in compensation may arise where the financial or other benefits available to the portfolio manager differ among the accounts that they manage. A portfolio manager might be motivated to help certain accounts over others if the structure of the investment adviser’s management fee and/or the portfolio manager’s compensation differs among accounts (such as where certain accounts pay higher management fees or performance-based management fees), or if the portfolio manager or Water Island has a greater financial interest in one or more of the accounts. Similarly, the desire to maintain or raise assets under management or to enhance the portfolio manager’s performance record or to derive other rewards, financial or otherwise, could influence the portfolio manager to lend preferential treatment to those accounts that could most significantly benefit the portfolio manager. Purchase or Sale of Securities for More Than One Account - To address these and other potential conflicts of interest, Water Island has implemented policies and procedures designed to allocate securities among the various accounts it advises in a fair and equitable manner over time. In addition, Water Island has implemented processes for monitoring the effectiveness of these policies and procedures, including periodic reviews of allocations by its compliance department so as to help ensure equitable treatment. Water Island has also adopted policies and procedures to address certain additional conflicts specifically, as further described below. Cross Trades - “Cross trades,” in which one account sells a particular security to another account (saving transaction costs for both accounts), may also pose a potential conflict of interest. Conflicts may arise if, for example, one account is permitted to sell a security to another account at a higher price than an independent third party would pay, or if such trades result in more attractive investments being allocated to higher-fee accounts. In an effort to address this potential conflict of interest, Water Island has adopted compliance procedures that, consistent with applicable law, include Rule 17a-7 under the 1940 Act, provide that any transactions between the advised accounts are to be made for cash without payment of any commission, spread, or other type of brokerage costs and at an independent current market price. Proposed cross trade must be reviewed and approved by Water Island’s compliance department prior to execution. Pilot Funds - Water Island may from time to time establish “pilot” or “incubator” funds for the purpose of testing proposed investment strategies or products prior to accepting assets from outside investors. These pilot accounts may be in the form of registered investment companies, private funds such as partnerships, or separate accounts. Typically, Water Island or an affiliate supplies the funding for these accounts. Employees of Water Island, including the portfolio manager(s), may also invest in certain pilot accounts. Pilot funds and accounts may, and frequently do, invest in the same securities as the other accounts managed by Water Island. In an effort to address this potential conflict of interest, Water Island has adopted a policy to treat pilot accounts in the same manner as client accounts for purposes of trading allocation – neither favoring nor disfavoring them. For example, pilot accounts would be included in the daily block trade aggregation procedures alongside client accounts (except that pilot accounts do not participate in initial public offerings). Selection of Brokers/Dealers - A portfolio manager may be able to select or influence the selection of the broker/dealers that are used to execute securities transactions. In addition to executing trades, some brokers and dealers provide Water Island with brokerage and research services (as those terms are defined in Section 28(e) of the Securities Exchange Act of 1934 (the “Exchange Act”)), which may result in the payment of higher brokerage fees than might have otherwise be available. These services may be more beneficial to certain accounts than to others. In order to be assured of continuing to receive services considered of value to its clients, Water Island has adopted a brokerage allocation policy embodying the concepts of Section 28(e) of the Exchange Act. A portfolio manager’s decision as to the selection of brokers and dealers could yield disproportionate costs and benefits among the accounts that they manage, although the payment of brokerage commissions is always subject to the requirement that Water Island determine in good faith that the commissions are reasonable in relation to the value of the brokerage and research services provided. |
The portfolio managers may also face other potential conflicts of interest in the management of multiple similar accounts, and the examples above are not intended to provide an exhaustive list or complete description of every conflict that may arise. |
Analytic Investors: The compensation structure for WellsCap’s portfolio managers includes a competitive fixed base salary plus variable incentives, payable annually and over a longer term period. WellsCap participates in third party investment management compensation surveys in order to provide WellsCap with market-based compensation information to help |
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support individual pay decisions.Incentive bonuses are typically tied to relative, pre-tax investment performance of all accounts under his or her management within acceptable risk parameters. Relative investment performance is generally evaluated for 1- 3- and 5- year performance results, with a predominant weighting on the 3- and 5- year time periods, versus the relevant benchmarks and/or peer groups consistent with the investment style. This evaluation takes into account relative performance of the accounts to each account’s individual benchmark and/or the relative composite performance of all accounts to one or more relevant benchmarks consistent with the overall investment style. Research analysts are evaluated on the overall team's relative investment performance as well as the performance and quality of their individual research. |
AQR : The compensation for each of the portfolio managers that is a Principal of AQR is in the form of distributions based on the net income generated by AQR and each Principal’s relative ownership in AQR. Net income distributions are a function of assets under management and performance of the funds and accounts managed by AQR. A Principal’s relative ownership in AQR is based on cumulative research, leadership and other contributions to AQR. There is no direct linkage between assets under management, performance and compensation. However, there is an indirect linkage in that superior performance tends to attract assets and thus increase revenues. Each portfolio manager is also eligible to participate in AQR’s 401(k) retirement plan which is offered to all employees of AQR. |
BMO: Compensation for BMO’s portfolio managers consists of base salary, which is monitored to ensure competitiveness in the external marketplace. In addition to base salary, portfolio managers have a portion of their compensation tied to the investment performance of client accounts. The formula for each professional varies according to their level of portfolio responsibility and seniority. Investment professionals also may receive bonuses of restricted share units or other units linked to the performance of the Bank of Montreal, the indirect owner of BMO Asset Management Corp. |
Boston Partners : All investment professionals receive a compensation package comprised of an industry competitive base salary and a discretionary bonus and long-term incentives. Through our bonus program, key investment professionals are rewarded primarily for strong investment performance. |
Typically, bonuses are based upon a combination of one or more of the following four criteria: |
1. Individual Contribution: an evaluation of the professional’s individual contribution based on the expectations established at the beginning of each year; |
2. Product Investment Performance: performance of the investment product(s) with which the individual is involved versus the pre-designed index, based on the excess return; |
3. Investment Team Performance: the financial results of the investment group; and |
4. Firm-wide Performance: the overall financial performance of Boston Partners. |
Boston Partners professional compensation consultants with asset management expertise to annually review our practices to ensure that they remain highly competitive. | |
Columbia Management : Portfolio manager direct compensation is typically comprised of a base salary, and an annual incentive award that is paid either in the form of a cash bonus if the size of the award is under a specified threshold, or, if the size of the award is over a specified threshold, the award is paid in a combination of a cash bonus, an equity incentive award, and deferred compensation. Equity incentive awards are made in the form of Ameriprise Financial restricted stock, or for more senior employees both Ameriprise Financial restricted stock and stock options. The investment return credited on deferred compensation is based on the performance of specified Columbia Funds, in most cases including the Columbia Funds the portfolio manager manages. | |
Base salary is typically determined based on market data relevant to the employee’s position, as well as other factors including internal equity. Base salaries are reviewed annually, and increases are typically given as promotional increases, internal equity adjustments, or market adjustments. | |
Annual incentive awards are variable and are based on (1) an evaluation of the employee’s investment performance and (2) the results of a peer and/or management review of the employee, which takes into account skills and attributes such as team participation, investment process, communication, and professionalism. Scorecards are used to measure performance of Columbia Funds and other accounts managed by the employee versus benchmarks and/or peer groups. Performance versus benchmark and peer group is generally weighted for the rolling one, three, and five year periods. One year performance is weighted 10%, three year performance is weighted 60%, and five year performance is weighted 30%. Relative asset size is a key determinant for fund weighting on a scorecard. Typically, weighting would be proportional to actual assets. Consideration may also be given to performance in managing client assets in sectors and industries assigned to the employee as part of his/her investment team responsibilities, where applicable. For leaders who also have group management responsibilities, another factor in their evaluation is an assessment of the group’s overall investment performance. |
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Equity incentive awards are designed to align participants’ interests with those of the shareholders of Ameriprise Financial. Equity incentive awards vest over multiple years, so they help retain employees. | |
Deferred compensation awards are designed to align participants’ interests with the investors in the Columbia Funds and other accounts they manage. The value of the deferral account is based on the performance of Columbia Funds. Employees have the option of selecting from various Columbia Funds for their deferral account, however portfolio managers must allocate a minimum of 25% of their incentive awarded through the deferral program to the Columbia Fund(s) they manage. Deferrals vest over multiple years, so they help retain employees. | |
Exceptions to this general approach to bonuses exist for certain teams and individuals. Funding for the bonus pool is determined by management and depends on, among other factors, the levels of compensation generally in the investment management industry taking into account investment performance (based on market compensation data) and both Ameriprise Financial and Columbia Management profitability for the year, which is largely determined by assets under management. | |
For all employees the benefit programs generally are the same, and are competitive within the financial services industry. Employees participate in a wide variety of plans, including options in Medical, Dental, Vision, Health Care and Dependent Spending Accounts, Life Insurance, Long Term Disability Insurance, 401(k), and a cash balance pension plan. |
Conestoga: Each of the Fund’s portfolio managers is a partner of Conestoga. As such, each portfolio manager receives a share of Conestoga’s annual profits, as specified in the manager’s partnership agreement with Conestoga, from Conestoga’s management of the Fund and all other accounts. | |
DGHM: The portfolio managers’ compensation varies with the general success of the firm. Each portfolio manager’s compensation consists of a fixed annual salary, plus additional remuneration based on assets under management. The portfolio managers’ compensation is not directly linked to the performance of the Fund or other accounts managed by the firm, although positive performance and growth in managed assets are factors that may contribute to distributable profits and assets under management. |
EAM: The portfolio manager’s compensation is comprised of a base salary, a revenue allocation and firm profit allocation. The salary is in-line with industry specific benchmarks. The revenue allocation is based on firm-wide revenue while the profit allocation is based on firm-wide profitability. There is no direct linkage between performance and compensation, however, there is an indirect linkage as superior performance tends to attract and retain assets and consequently increase revenues and profitability. |
Loomis Sayles: Loomis Sayles believes that portfolio manager compensation should be driven primarily by the delivery of consistent and superior long-term performance for its clients. Portfolio manager compensation is made up primarily of three main components: base salary, variable compensation and a long-term incentive program. Although portfolio manager compensation is not directly tied to assets under management, a portfolio manager’s base salary and/or variable compensation potential may reflect the amount of assets for which the manager is responsible relative to other portfolio managers. Loomis Sayles also offers a profit sharing plan. Base salary is a fixed amount based on a combination of factors, including industry experience, firm experience, job performance and market considerations. Variable compensation is an incentive-based component and generally represents a significant multiple of base salary. Variable compensation is based on four factors: investment performance, profit growth of the firm, profit growth of the manager’s business unit and personal conduct. Investment performance is the primary component of total variable compensation and generally represents at least 60% of the total for fixed-income managers and 70% for equity managers. The other three factors are used to determine the remainder of variable compensation, subject to the discretion of the Chief Investment Officer (“CIO”) and senior management. The CIO and senior management evaluate these other factors annually. | |
Equity Managers . While mutual fund performance and asset size do not directly contribute to the compensation calculation, investment performance for equity managers is measured by comparing the performance of Loomis Sayles’ institutional composites to the performance of the applicable Morningstar peer group and/or the Lipper universe. Generally speaking the performance of the respective product’s fund is compared against the applicable Morningstar peer group and/or the Lipper universe. To the extent the majority of assets managed in the fund strategy are for institutional separate accounts, the Evestment Alliance institutional peer group will also be used as an additional comparison. In situations where substantially all of the assets for the strategy are institutional, the institutional peer group will be used as the primary method of comparison. A manager’s performance relative to the peer group for the 1, 3 and 5 year periods, (3 and 5 or 10 years for large cap growth, all cap growth and global growth), or since the start of the manager’s tenure, if shorter, is used to calculate the amount of variable compensation payable due to performance. Longer-term performance is typically weighted more than shorter-term performance (1 year or 3 years for large cap growth, all cap growth and global growth). In addition, the performance measurement for equity compensation usually incorporates a consistency metric using longer term (3, 5, etc.) rolling return compared to the peer group over a sustained measurement period (5, 7, etc. years). However, the exact method |
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may be adjusted to a product’s particular style. If a manager is responsible for more than one product, the rankings of each product are weighted based on relative revenue of accounts represented in each product. An external benchmark is used as a secondary comparison. The external benchmark used for the MM Growth Strategies Fund is the Russell 1000 Growth Index. Certain portfolio managers also receive additional compensation based on revenue and performance hurdles for their strategies, and performance fee based compensation as portfolio managers for private investment funds. | |
In cases where the institutional peer groups are used, Loomis Sayles believes they represent the most competitive product universe while closely matching the investment styles offered by the Loomis Sayles fund. | |
Fixed-Income Managers. While mutual fund performance and asset size do not directly contribute to the compensation calculation, investment performance for fixed-income managers is measured by comparing the performance of Loomis Sayles’ institutional composite (pre-tax and net of fees) in the manager’s style to the performance of an external benchmark and a customized peer group. The external benchmark used for the investment style utilized by each fund is noted below. The customized peer group is created by Loomis Sayles and is made up of institutional managers in the particular investment style. A manager’s relative performance for the past five years, or seven years for some products, is used to calculate the amount of variable compensation payable due to performance. To ensure consistency, Loomis Sayles analyzes the five or seven year performance on a rolling three year basis. If a manager is responsible for more than one product, the rankings of each product are weighted based on relative revenue size of accounts represented in each product. Loomis Sayles uses both an external benchmark and a customized peer group as a point of comparison for fixed-income manager performance because it believes they represent an appropriate combination of the competitive fixed-income product universe and the investment styles offered by Loomis Sayles. The external benchmark used for the MM Total Return Bond Strategies Fund is the Barclays U.S. Aggregate Index. | |
In addition to the compensation described above, portfolio managers may receive additional compensation based on the overall growth of their strategies. | |
General. Most mutual funds do not directly contribute to a portfolio manager’s overall compensation because Loomis Sayles’ uses the performance of the portfolio manager’s institutional accounts compared to an institutional peer group. However, each fund managed by Loomis Sayles employs strategies endorsed by Loomis Sayles and fits into the product category for the relevant investment style. Loomis Sayles may adjust compensation if there is significant dispersion among the returns of the composite and accounts not included in the composite. | |
Loomis Sayles has developed and implemented two distinct long-term incentive plans to attract and retain investment talent. The plans supplement existing compensation. The first plan has several important components distinguishing it from traditional equity ownership plans: |
■ | the plan grants units that entitle participants to an annual payment based on a percentage of company earnings above an established threshold; |
■ | upon retirement, a participant will receive a multi-year payout for his or her vested units; and |
■ | participation is contingent upon signing an award agreement, which includes a non-compete covenant. |
Los Angeles Capital: Los Angeles Capital’s portfolio managers participate in a competitive compensation program that is aimed at attracting and retaining talented employees with an emphasis on disciplined risk management, ethics and compliance-centered behavior. No component of Los Angeles Capital’s compensation policy or payment scheme is tied directly to the performance of one or more client portfolios or funds. |
Each of Los Angeles Capital’s portfolio managers receives a base salary fixed from year to year. In addition, the portfolio managers participate in Los Angeles Capital’s profit sharing plan. The aggregate amount of the contribution to Los Angeles |
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Capital’s profit sharing plan is based on overall firm profitability with amounts paid to individual employees based on their relative overall compensation. Each of the portfolio managers also are shareholders of Los Angeles Capital and receive compensation based upon the firm’s overall profits. Certain portfolio managers are also eligible to receive a discretionary bonus from Los Angeles Capital. |
Manulife : Manulife Asset Management has designed its compensation plan to effectively attract, retain and reward top investment talent. The incentive plan is designed to align and reward investment teams that deliver consistent value added performance for the company’s client and partners through world-class investment strategies and solutions. | |
Investment professionals are compensated with a combination of base salary and incentives as detailed below. | |
Base salaries | |
Base salaries are market-based and salary ranges are periodically reviewed. Individual salary adjustments are based on individual performance against mutually-agreed-upon objectives and development of technical skills. | |
Incentives — Short- and Long-Term | |
All investment professionals (including portfolio managers, analysts and traders) are eligible for participation in a short and long term investment incentive plan. These incentives are tied to performance against various objective and subjective measures, including: | |
Investment Performance — Performance of portfolios managed by the investment team. This is the most heavily weighted factor and it is measured relative to an appropriate benchmark or universe over established time periods. | |
Financial Performance — Performance of Manulife Asset Management and its parent corporation. | |
Non-Investment Performance — Derived from the contributions an investment professional brings to Manulife Asset Management. | |
Awards under this plan include: | |
Annual Cash Awards | |
Deferred Incentives — One hundred percent of this portion of the award is invested in strategies managed by the team/individual as well as other Manulife Asset Management strategies. | |
Manulife equity awards — Investment professionals that are considered officers of Manulife receive a portion of their award in Manulife Restricted Share Units (RSUs) or stock options. This plan is based on the value of the underlying common shares of Manulife. |
PGIM : The base salary of an investment professional in the PGIM Fixed Income unit of PGIM is based on market data relative to similar positions as well as the past performance, years of experience and scope of responsibility of the individual. Incentive compensation, including the annual cash bonus, the long-term equity grant and grants under PGIM Fixed Income’s long-term incentive plans, is primarily based on such person’s contribution to PGIM Fixed Income’s goal of providing investment performance to clients consistent with portfolio objectives, guidelines and risk parameters and market-based data such as compensation trends and levels of overall compensation for similar positions in the asset management industry. In addition, an investment professional’s qualitative contributions to the organization and its commercial success are considered in determining incentive compensation. Incentive compensation is not solely based on the performance of, or value of assets in, any single account or group of client accounts. | |
An investment professional’s annual cash bonus is paid from an annual incentive pool. The pool is developed as a percentage of PGIM Fixed Income’s operating income and the percentage used to calculate the pool may be refined by factors such as: | |
- business initiatives; | |
- the number of investment professionals receiving a related peer group compensation; and | |
- investment performance of portfolios: (i) relative to appropriate peer groups and/or (ii) as measured against relevant investment indices. | |
Long-term compensation consists of Prudential Financial restricted stock and grants under the long-term incentive plan and targeted long-term incentive plan. Grants under the long-term incentive plan and targeted long-term incentive plan are participation interests in notional accounts with a beginning value of a specified dollar amount. For the long-term incentive plan, the value attributed to these notional accounts increases or decreases over a defined period of time based, in part, on the performance of investment composites representing a number of PGIM Fixed Income’s investment strategies. With respect to targeted long-term incentive awards, the value attributed to the notional accounts increases or decreases over a defined period of time based on the performance of either (i) a long-short investment composite or (ii) a commingled |
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investment vehicle. An investment composite is an aggregation of accounts with similar investment strategies. The long-term incentive plan is designed to more closely align compensation with investment performance and the growth of PGIM Fixed Income’s business. In addition, the targeted long-term incentive plan is designed to align the interests of certain of PGIM Fixed Income’s investment professionals with the performance of a particular long-short composite or commingled investment vehicle. The chief investment officer/head of PGIM Fixed Income also receives (i) performance shares which represent the right to receive shares of Prudential Financial, Inc. common stock conditioned upon, and subject to, the achievement of specified financial performance goals by Prudential Financial, Inc.; (ii) book value units which track the book value per share of Prudential Financial, Inc.; and (iii) Prudential Financial, Inc. stock options. Each of the restricted stock, long-term incentive plan grants, performance shares and book value units and stock options is subject to vesting requirements. | |
TCW: The overall objective of TCW’s compensation program for portfolio managers is to attract experienced and expert investment professionals and to retain them over the long-term. Compensation is comprised of several components which, in the aggregate, are designed to achieve these objectives and to reward the portfolio managers for their contributions to the successful performance of the accounts they manage. Portfolio managers are compensated through a combination of base salary, fee sharing based compensation (“fee sharing”), bonus and equity incentive participation in the TCW’s parent company (“equity incentives”). Fee sharing and equity incentives generally represent most of the portfolio managers’ compensation. In some cases, portfolio managers are eligible for discretionary bonuses. | |
Salary. Salary is agreed to with managers at time of employment and is reviewed from time to time. It does not change significantly and generally does not constitute a significant part of the portfolio manager’s compensation. | |
Fee Sharing. Fee sharing for investment professionals is based on revenues generated by accounts in the investment strategy area for which the investment professionals are responsible. In most cases, revenues are allocated to a pool and fee sharing compensation is allocated among members of the investment team after the deduction of certain expenses (including compensation over a threshold level) related to the strategy group. The allocations are based on the investment professionals’ contributions to TCW and its clients, including qualitative and quantitative contributions. | |
In general, the same fee sharing percentage is used to compensate investment professionals for investment services related to the Funds is generally the same as that used to compensate investment professionals for other client accounts in the same strategy managed by MetWest or one of the other TCW-affiliated advisers (together, “the TCW Group”). In some cases, the fee sharing pool includes revenues related to more than one product, in which case each participant in the pool is entitled to fee sharing derived from his or her contributions to all the included products. | |
Investment professionals are not directly compensated for generating performance fees. In some cases, the fee sharing pool is subject to fluctuation based on the relative pre-tax performance of the investment strategy composite returns, net of fees and expenses, to that of the benchmark. The measurement of performance relative to the benchmark can be based on single year or multiple year metrics, or a combination thereof. The benchmark used is the one associated with the Fund managed by the portfolio manager as disclosed in the prospectus. Benchmarks vary from strategy to strategy but, within a given strategy, the same benchmark applies to all accounts, including the Funds. | |
Discretionary Bonus/Guaranteed Minimums. Discretionary bonuses may be paid out of an investment team’s fee sharing pool, as determined by the supervisor(s) in the department. Investment professionals do not receive fee sharing or the company has determined the combination of salary and fee sharing does not adequately compensate an investment professional, discretionary bonuses may be paid by the TCW Group. Also, pursuant to contractual arrangements, some investment professionals received minimum bonuses. | |
Equity Incentives. Management believes that equity ownership aligns the interest of investment professionals with the interests of the firm and its clients. Accordingly, TCW’s key investment professionals participate in equity incentives through ownership or participation in restricted unit plans that vest over time or unit appreciation plans of TCW’s parent company. The plans include the Fixed Income Retention Plan, Restricted Unit Plan and 2013 Equity Unit Incentive Plan. | |
Under the Fixed Income Retention Plan, certain investment professionals in the fixed income area were awarded cash and/or partnership units in TCW’s parent company, either on a contractually-determined basis or on a discretionary basis. Awards under this plan were made in or after 2010 vested over a period of time. | |
Under the Restricted Unit Plan, certain investment professionals in the fixed income and equity areas were awarded partnership units in TCW’s parent company. Awards under this plan vest over time. Vesting is in part dependent on satisfaction of performance criteria. | |
Under the 2013 Equity Unit Incentive Plan, certain investment professionals in the fixed income and equity areas are awarded options to acquire partnership units in TCW’s parent company with a strike price equal to the fair market value of the option at the date of grant. The options granted under the plan are subject to vesting and other conditions. |
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Other Plans and Compensation Vehicles. Investment professionals may also elect to participate in the TCW Group’s 401(k) plan, to which they may contribute a portion of their pre—and post-tax compensation to the plan for investment on a tax-deferred basis. |
Threadneedle: Direct compensation is typically comprised of a base salary, and an annual incentive award that is paid either in the form of a cash bonus if the size of the award is under a specified threshold, or, if the size of the award is over a specified threshold, the award is paid in a combination of a cash bonus, an equity incentive award, and deferred compensation. Equity incentive awards are made in the form of Ameriprise Financial restricted stock, or for more senior employees both Ameriprise Financial restricted stock and stock options. The investment return credited on deferred compensation is based on the performance of specified Threadneedle funds, in most cases including the funds the portfolio manager manages. | |
Base salary is typically determined based on market data relevant to the employee’s position, as well as other factors including internal equity. Base salaries are reviewed annually, and increases are typically given as promotional increases, internal equity adjustments, or market adjustments. | |
Annual incentive awards and pool funding are variable and are designed to reward: |
■ | Investment performance, both at the individual and team levels |
■ | Client requirements, in particular the alignment with clients through a mandatory deferral into the company’s own products |
■ | Team cooperation and Values |
Water Island: Investment professionals are compensated with salary and a bonus based on individual performance, both relative and absolute fund performance, and profitability of Water Island. Profit sharing in Water Island may also be included as potential compensation. In addition, Water Island believes employee ownership and the opportunity for all employees to hold ownership interests in Water Island fosters teamwork and encourages longevity in tenure. Ownership shares may be issued to employees based on tenure, position, and contribution to Water Island. Water Island’s policies help ensure that the financial interests of its key investment personnel are aligned with its clients’ financial interests. Water Island also expends efforts to help ensure it attracts and retains key investment talent. Its goal is to focus its employees on long-term rather than short-term performance and to encourage employee retention. |
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Administrative Services Fees | |||
2017 | 2016 | 2015 | |
AMT-Free OR Intermediate Muni Bond Fund | N/A | $101,527 | $305,465 |
Large Cap Growth Fund | N/A | 584,102 | 1,688,311 |
Tax-Exempt Fund | N/A | 815,484 | 2,394,304 |
U.S. Social Bond Fund | N/A | 4,699 | 3,773 (e) |
Ultra Short Term Bond Fund (f) | N/A | 0 | 0 |
For Funds with fiscal period ending August 31 | |||
Balanced Fund | N/A | 605,430 | 1,412,144 |
Contrarian Core Fund | N/A | 1,004,339 | 2,679,269 |
Disciplined Small Core Fund | N/A | 131,266 | 727,538 |
Emerging Markets Fund | N/A | 292,437 | 1,140,095 |
Global Dividend Opportunity Fund | N/A | 139,005 | 490,647 |
Global Energy and Natural Resources Fund | N/A | 48,280 | 181,053 |
Global Technology Growth Fund | N/A | 0 | 0 |
Greater China Fund | N/A | 37,315 | 117,428 |
Mid Cap Growth Fund | N/A | 365,736 | 1,201,473 |
MM Alternative Strategies Fund | N/A | 202,111 | 609,318 |
MM Small Cap Equity Strategies Fund | N/A | 349,312 | 638,594 |
MM Total Return Bond Strategies Fund | N/A | 985,615 | 2,809,022 |
Small Cap Growth Fund I | N/A | 126,449 | 540,729 |
Strategic Income Fund (g) | N/A | 497,333 | 1,322,802 |
2016 | 2015 | 2014 | |
For Funds with fiscal period ending October 31 | |||
AMT-Free CT Intermediate Muni Bond Fund | $36,936 | 111,085 | 120,529 |
AMT-Free Intermediate Muni Bond Fund | 472,435 | 1,364,016 | 1,327,108 |
AMT-Free MA Intermediate Muni Bond Fund | 67,735 | 202,872 | 208,051 |
AMT-Free NY Intermediate Muni Bond Fund | 64,375 | 186,753 | 177,279 |
CA Tax-Exempt Fund | 119,000 | 331,278 | 316,431 |
NY Tax-Exempt Fund | 44,957 | 124,233 | 119,403 |
For Funds with fiscal period ending December 31 | |||
Real Estate Equity Fund | 97,784 | 325,962 | 324,853 |
(a) | For the period from March 11, 2014 (commencement of operations) to January 31, 2015. |
(b) | For the period from March 27, 2015 (commencement of operations) to April 30, 2015. |
(c) | For the period from January 27, 2015 (commencement of operations) to May 31, 2015. |
(d) | For the period from February 19, 2015 (commencement of operations) to May 31, 2015. |
(e) | For the period from March 26, 2015 (commencement of operations) to July 31, 2015. |
(f) | The Fund did not pay an administrative services fee under the Administrative Services Agreement because payment for such services was included in its Unitary Fee. |
(g) | The Fund changed its fiscal year end in 2017 from October 31 to August 31. |
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(a) | For the period from March 11, 2014 (commencement of operations) to January 31, 2015. |
(b) | The Fund commenced operations on October 24, 2017, and therefore has no reporting information for periods prior to such date. |
(c) | For the period from October 17, 2016 (commencement of operations) to April 30, 2017. |
(d) | For the period from March 27, 2015 (commencement of operations) to April 30, 2015. |
(e) | For the period from January 27, 2015 (commencement of operations) to May 31, 2015. |
(f) | For the period from February 19, 2015 (commencement of operations) to May 31, 2015. |
(g) | For the period from March 26, 2015 (commencement of operations) to July 31, 2015. |
(h) | The Fund changed its fiscal year end in 2017 from October 31 to August 31. For the fiscal year ended in 2017, the information shown is for the period from November 1, 2016 to August 31, 2017. |
Statement of Additional Information – [____, 2018] | 137 |
Distribution Fee | Service Fee | Combined Total | |
Class A | up to 0.10% | 0.25% | Up to 0.25% (a)(b) |
Class A for Multi-Manager Strategies Funds | up to 0.25% | up to 0.25% | 0.25% (c) |
Class Adv | None | None | None |
Class C | 0.75% | 0.25% | 1.00% (b)(d) |
Class Inst | None | None | None |
Class Inst2 | None | None | None |
Class Inst3 | None | None | None |
Class E | 0.10% | 0.25% | 0.35% |
Class K | None | None (e) | None (e) |
Class R | 0.50% | — (f) | 0.50% |
Class T | up to 0.25% | up to 0.25% | 0.25% |
Class V | None | 0.50% (g) | 0.50% (g) |
Shares of Ultra Short Term Bond Fund | None | None | None |
(a) | As shown in the table below, the maximum distribution and service fees of Class A shares varies among the Funds. |
Funds |
Class
A
Distribution Fee |
Class
A
Service Fee |
Class
A
Combined Total |
Adaptive Risk Allocation Fund, Alternative Beta Fund, AMT-Free CT Intermediate Muni Bond Fund, AMT-Free MA Intermediate Muni Bond Fund, AMT-Free NY Intermediate Muni Bond Fund, Bond Fund, CA Tax-Exempt Fund, Corporate Income Fund, Diversified Absolute Return Fund, Diversified Real Return Fund; Emerging Markets Fund, Global Dividend Opportunity Fund, Global Energy and Natural Resources Fund, Greater China Fund, Multi-Asset Income Fund, NY Tax-Exempt Fund, Pacific/Asia Fund, Select Large Cap Growth Fund, Small Cap Value Fund I, Strategic Income Fund, U.S. Social Bond Fund and U.S. Treasury Index Fund | — | 0.25% | 0.25% |
AMT-Free Intermediate Muni Bond Fund, HY Municipal Fund and Tax-Exempt Fund | — | 0.20% | 0.20% |
AMT-Free OR Intermediate Muni Bond Fund, Balanced Fund, Contrarian Core Fund, Disciplined Small Core Fund, Dividend Income Fund, Global Technology Growth Fund, Large Cap Growth Fund, Mid Cap Growth Fund, Real Estate Equity Fund, Small Cap Growth Fund I and Total Return Bond Fund | up to 0.10% | up to 0.25% | Up to 0.35%; these Funds may pay distribution and service fees up to a maximum of 0.35% of their average daily net assets attributable to Class A shares but currently limit such fees to an aggregate fee of not more than 0.25% |
Statement of Additional Information – [____, 2018] | 138 |
(b) | The annual service fee for Class A and Class C shares of HY Municipal Fund, AMT-Free Intermediate Muni Bond Fund and Tax-Exempt Fund may equal up to 0.20% of the average daily net asset value of all shares of such Fund class. The annual distribution fee for Class C shares for AMT-Free Intermediate Muni Bond Fund shall be 0.65% of the average daily net assets of the Fund’s Class C shares. The Distributor has voluntarily agreed to waive the Service Fee for Class A and Class C shares of U.S. Treasury Index Fund so that the Service Fee does not exceed 0.15% annually. This arrangement may be modified by the Distributor at any time. |
(c) | Class A shares of Multi-Manager Strategies Funds may pay distribution and service fees up to a maximum of 0.25% of the Fund’s average daily net assets attributable to Class A shares (comprised of up to 0.25% for distribution services and up to 0.25% for shareholder liaison services). |
(d) | The Distributor has voluntarily agreed to waive a portion of the distribution fee for Class C shares of the following Funds so that the distribution fee does not exceed the specified percentage annually: 0.45% for AMT-Free CT Intermediate Muni Bond Fund, AMT-Free MA Intermediate Muni Bond Fund, AMT-Free NY Intermediate Muni Bond Fund, AMT-Free OR Intermediate Muni Bond Fund, CA Tax-Exempt Fund and NY Tax-Exempt Fund; 0.60% for Corporate Income Fund; 0.65% for HY Municipal Fund and Tax-Exempt Fund; and 0.70% for U.S. Treasury Index Fund. These arrangements may be modified or terminated by the Distributor at any time. |
(e) | Under a Plan Administration Services Agreement, the Funds’ Class K shares pay for plan administration services. These fees for Class K shares are not paid pursuant to a Rule 12b-1 plan. See Investment Management and Other Services – Other Services Provided – Plan Administration Services for more information. |
(f) | Class R shares pay a distribution fee pursuant to a Fund’s distribution (Rule 12b-1) plan for Class R shares. The Funds do not have a shareholder service plan for Class R shares. |
(g) | The shareholder servicing fees for Class V shares are up to 0.50% of average daily net assets attributable to Class V shares for equity Funds and 0.40% for fixed income Funds. In general, the Funds currently limit such fees to a maximum of 0.25% for equity Funds and 0.15% for fixed income Funds. These fees for Class V shares are not paid pursuant to a Rule 12b-1 plan. See Class V Shares Shareholder Service Fees below for more information. |
Statement of Additional Information – [____, 2018] | 139 |
Statement of Additional Information – [____, 2018] | 140 |
Fund | Class A | Class C | Class R | Class T | Class V |
For Funds with fiscal period ending January 31 | |||||
Diversified Real Return Fund | $162 | $415 | N/A | $22 | N/A |
For Funds with fiscal period ending March 31 | |||||
MM Growth Strategies Fund | 5,395,143 | N/A | N/A | N/A | N/A |
Pacific/Asia Fund | 6,673 | 9,235 | N/A | 7 | N/A |
Select Large Cap Growth Fund | 2,523,309 | 1,948,597 | $79,817 | 23,784 | N/A |
For Funds with fiscal period ending April 30 | |||||
Bond Fund | 140,756 | 108,524 | 6,978 | 25 | $15,813 |
Corporate Income Fund | 237,708 | 99,430 | N/A | 61,475 | N/A |
MM Directional Alternative Strategies Fund | 1,061,513 (a) | N/A (a) | N/A (a) | N/A (a) | N/A (a) |
Multi-Asset Income Fund | 1,062 | 2,641 | N/A | 24 | N/A |
Small Cap Value Fund I | 615,253 | 272,557 | 14,605 | N/A | N/A |
Total Return Bond Fund | 2,323,070 | 541,007 | 10,627 | 1,046,345 | N/A |
U.S. Treasury Index Fund | 72,439 | 80,331 | N/A | 358,943 | N/A |
For Funds with fiscal period ending May 31 | |||||
Adaptive Risk Allocation Fund | 384,411 | 780,436 | 15,933 | 1,550,105 | N/A |
Alternative Beta Fund | 34,800 | 16,453 | 46 | 489,200 | N/A |
Diversified Absolute Return Fund | 357 | 142 | N/A | 27,871 | N/A |
Dividend Income Fund | 5,750,410 | 7,385,509 | 463,216 | 224 | 190,638 |
HY Municipal Fund | 340,902 | 502,733 | N/A | N/A | N/A |
For Funds with fiscal period ending July 31 | |||||
AMT-Free OR Intermediate Muni Bond Fund | 125,634 | 184,831 | N/A | N/A | N/A |
Large Cap Growth Fund (b) | 4,419,525 | 1,024,524 | 137,651 | 154,824 | 456,438 |
Tax-Exempt Fund | 6,155,287 | 974,695 | N/A | N/A | N/A |
U.S. Social Bond Fund | 9,416 | 7,169 | N/A | N/A | N/A |
Ultra Short Term Bond Fund | N/A | N/A | N/A | N/A | N/A |
For Funds with fiscal period ending August 31 | |||||
Balanced Fund | 7,569,839 | 14,108,132 | 490,083 | 2 | N/A |
Contrarian Core Fund | 6,061,118 | 7,086,541 | 569,474 | 165,466 | 371,584 |
Disciplined Small Core Fund | 154,484 | 130,463 | N/A | 459 | 146,821 |
Emerging Markets Fund | 615,340 | 193,689 | 50,187 | 90,096 | N/A |
Global Dividend Opportunity Fund | 259,598 | 90,701 | 8,339 | 5 | N/A |
Global Energy and Natural Resources Fund | 221,768 | 145,380 | 45,637 | N/A | N/A |
Global Technology Growth Fund | 469,830 | 753,103 | N/A | N/A | N/A |
Greater China Fund | 143,698 | 95,013 | N/A | 5 | N/A |
Mid Cap Growth Fund | 2,117,819 | 437,457 | 77,454 | 340 | 54,239 |
MM Alternative Strategies Fund | 891,194 | N/A | N/A | N/A | N/A |
MM Small Cap Equity Strategies Fund | 1,303,432 | N/A | N/A | N/A | N/A |
MM Total Return Bond Strategies Fund | 8,847,864 | N/A | N/A | N/A | N/A |
Small Cap Growth Fund I | 444,679 | 129,421 | 7,051 | N/A | N/A |
Statement of Additional Information – [____, 2018] | 141 |
Fund | Class A | Class C | Class R | Class T | Class V |
Strategic Income Fund (c) | $2,848,122 | $2,719,573 | $24,995 | $21 | N/A |
For Funds with fiscal period ending October 31 | |||||
AMT-Free CT Intermediate Muni Bond Fund | 24,212 | 43,420 | N/A | N/A | $17,726 |
AMT-Free Intermediate Muni Bond Fund | 490,408 | 501,956 | N/A | N/A | 21,573 |
AMT-Free MA Intermediate Muni Bond Fund | 64,976 | 69,750 | N/A | N/A | 28,882 |
AMT-Free NY Intermediate Muni Bond Fund | 72,795 | 156,578 | N/A | N/A | 10,847 |
CA Tax-Exempt Fund | 966,458 | 348,326 | N/A | N/A | N/A |
NY Tax-Exempt Fund | 420,524 | 177,674 | N/A | N/A | N/A |
For Funds with fiscal period ending December 31 | |||||
Real Estate Equity Fund | 304,416 | 180,603 | 44,163 | 64 | N/A |
(a) | For the period from October 17, 2016 (commencement of operations) to April 30, 2017. |
(b) | The Fund paid distribution and/or service fees of $51,598 for Class E shares and $8,388 for Class F shares for the fiscal year ended 2017. |
(c) | The Fund changed its fiscal year end in 2017 from October 31 to August 31. For the fiscal year ended in 2017, the information shown is for the period from November 1, 2016 to August 31, 2017. |
Statement of Additional Information – [____, 2018] | 142 |
Statement of Additional Information – [____, 2018] | 143 |
Statement of Additional Information – [____, 2018] | 144 |
Amounts Reimbursed | |||
2017 | 2016 | 2015 | |
Contrarian Core Fund | $0 | $0 | $0 |
Disciplined Small Core Fund | 104,936 | 38,331 | 0 |
Emerging Markets Fund | 277,910 | 0 | 0 |
Global Dividend Opportunity Fund | 803,209 | 767,205 | 446,626 |
Global Energy and Natural Resources Fund | 0 | 0 | 0 |
Global Technology Growth Fund | 0 | 0 | 0 |
Greater China Fund | 0 | 0 | 0 |
Mid Cap Growth Fund | 0 | 0 | 0 |
MM Alternative Strategies Fund | 0 | 0 | 0 |
MM Small Cap Equity Strategies Fund | 2,192,588 | 1,786,978 | 1,694,733 |
MM Total Return Bond Strategies Fund | 0 | 0 | 0 |
Small Cap Growth Fund I | 186,196 | 135,594 | 0 |
Strategic Income Fund | 0 (h) | 97,786 | 627,722 |
2016 | 2015 | 2014 | |
For Funds with fiscal period ending October 31 | |||
AMT-Free CT Intermediate Muni Bond Fund | 277,658 | 288,981 | 301,578 |
AMT-Free Intermediate Muni Bond Fund | 2,078,361 | 2,569,822 | 2,332,871 |
AMT-Free MA Intermediate Muni Bond Fund | 446,678 | 462,338 | 453,509 |
AMT-Free NY Intermediate Muni Bond Fund | 591,994 | 576,794 | 536,026 |
CA Tax-Exempt Fund | 348,734 | 457,819 | 422,557 |
NY Tax-Exempt Fund | 226,407 | 244,644 | 230,452 |
For Funds with fiscal period ending December 31 | |||
Real Estate Equity Fund | 0 | 0 | 0 |
(a) | For the period from March 11, 2014 (commencement of operations) to January 31, 2015. |
(b) | The Fund commenced operations on October 24, 2017, and therefore has no reporting information for periods prior to such date. |
(c) | For the period from October 17, 2016 (commencement of operations) to April 30, 2017. |
(d) | For the period from March 27, 2015 (commencement of operations) to April 30, 2015. |
(e) | For the period from January 27, 2015 (commencement of operations) to May 31, 2015. |
(f) | For the period from February 19, 2015 (commencement of operations) to May 31, 2015. |
(g) | For the period from March 26, 2015 (commencement of operations) to July 31, 2015. |
(h) | The Fund changed its fiscal year end in 2017 from October 31 to August 31. For the fiscal year ended in 2017, the information shown is for the period from November 1, 2016 to August 31, 2017. |
Statement of Additional Information – [____, 2018] | 145 |
(a) | For the period from January 27, 2015 (commencement of operations) to May 31, 2015. |
(b) | The Fund changed its fiscal year end in 2017 from October 31 to August 31. For the fiscal year ended in 2017, the information shown is for the period from November 1, 2016 to August 31, 2017. |
Statement of Additional Information – [____, 2018] | 146 |
Statement of Additional Information – [____, 2018] | 147 |
Statement of Additional Information – [____, 2018] | 148 |
Statement of Additional Information – [____, 2018] | 149 |
Statement of Additional Information – [____, 2018] | 150 |
Statement of Additional Information – [____, 2018] | 151 |
Name, address, year of birth |
Position
held with Subsidiary
and length of service |
Principal occupation during past five years |
Anthony
P. Haugen
807 Ameriprise Financial Center, Minneapolis, MN 55474-2405 Born 1964 |
Director
since
November 2013 |
Vice
President – Finance, Ameriprise Financial, Inc.
since June 2004 |
Amy
K. Johnson
5228 Ameriprise Financial Center Minneapolis, MN 55474-2405 Born 1965 |
Director
since
November 2013 |
See Fund Governance – Fund Officers . |
Christopher
O. Petersen
5228 Ameriprise Financial Center Minneapolis, MN 55474-2405 Born 1970 |
Director
since
January 2015 |
See Fund Governance – Fund Officers . |
Subsidiary |
Assets
(millions) |
Annual
rate at
each asset level (a) |
ASGM Offshore Fund, Ltd. | $0 - $500 | 1.100% |
ASMF Offshore Fund, Ltd. | >$500 - $1,000 | 1.050% |
(Subsidiaries of MM Alternative Strategies Fund) | >$1,000 - $3,000 | 1.020% |
>$3,000 - $6,000 | 0.990% | |
>$6,000 - $12,000 | 0.960% | |
>$12,000 | 0.950% | |
CAAF Offshore Fund, Ltd. | $0 - $500 | 0.960% |
(Subsidiary of Alternative Beta Fund) | >$500 - $1,000 | 0.955% |
>$1,000 - $3,000 | 0.950% | |
>$3,000 - $12,000 | 0.940% | |
>$12,000 | 0.930% | |
CDARF1 Offshore Fund, Ltd. | $0 - $500 | 1.180% |
CDARF2 Offshore Fund, Ltd. | >$500 - $1,000 | 1.130% |
CDARF3 Offshore Fund, Ltd. | >$1,000 - $3,000 | 1.100% |
(Subsidiaries of Diversified Absolute Return Fund) | >$3,000 - $6,000 | 1.070% |
>$6,000 - $12,000 | 1.040% | |
>$12,000 | 1.030% |
(a) | When calculating asset levels for purposes of determining fee rate breakpoints, asset levels are based on aggregate net assets of the Fund and the Parent Fund. When calculating the fee payable under this agreement, the annual rates are based on a percentage of the daily net assets of the Fund. |
Statement of Additional Information – [____, 2018] | 152 |
Statement of Additional Information – [____, 2018] | 153 |
Statement of Additional Information – [____, 2018] | 154 |
Name, Address, Year of Birth | Position Held with the Trust and Length of Service |
Principal
Occupation(s)
During the Past Five Years and Other Relevant Professional Experience |
Number
of Funds in the Columbia Funds Complex Overseen |
Other
Directorships
Held by Trustee During the Past Five Years |
Committee Assignments |
David
M. Moffett
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1952 |
Trustee
2011 |
Retired. Consultant to Bridgewater and Associates | 66 | Director, CSX Corporation (transportation suppliers); Genworth Financial, Inc. (financial and insurance products and services); Paypal Holdings Inc. (payment and data processing services); Trustee, University of Oklahoma Foundation; former Director, eBay Inc. (online trading community), 2007-2015; and former Director, CIT Bank, CIT Group Inc. (commercial and consumer finance), 2010-2016 | Compliance, Audit, Investment Oversight Committee #1 |
John
J. Neuhauser
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1943 |
Trustee
1984 |
President, Saint Michael’s College since August 2007; Director or Trustee of several non-profit organizations, including University of Vermont Medical Center; Academic Vice President and Dean of Faculties, Boston College from August 1999 to October 2005; University Professor, Boston College from November 2005 to August 2007 | 66 | Liberty All-Star Equity Fund and Liberty All-Star Growth Fund (closed-end funds) | Advisory Fees & Expenses, Product and Distribution, Investment Oversight Committee #2 |
Patrick
J. Simpson
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1944 |
Trustee
2000 |
Of Counsel, Perkins Coie LLP (law firm) since 2015; Partner, Perkins Coie LLP from 1988 to 2014 | 66 | None | Advisory Fees & Expenses, Audit, Governance, Investment Oversight Committee #1 |
Anne-Lee
Verville
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1945 |
Trustee
1998 |
Retired. General Manager, Global Education Industry from 1994 to 1997, President – Application Systems Division from 1991 to 1994, Chief Financial Officer – US Marketing & Services from 1988 to 1991, and Chief Information Officer from 1987 to 1988, IBM Corporation (computer and technology) | 66 | Enesco Group, Inc. (producer of giftware and home and garden decor products) from 2001 to 2006 | Audit, Compliance, Investment Oversight Committee #1 |
Statement of Additional Information – [____, 2018] | 155 |
Name, Address, Year of Birth | Position Held with the Funds and Length of Service |
Principal
Occupation(s)
During the Past Five Years and Other Relevant Professional Experience |
Number
of Funds in the Columbia Funds Complex Overseen |
Other
Directorships
Held by Trustee During the Past Five Years |
Committee Assignments |
J.
Kevin Connaughton
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1964 |
Independent
Trustee Consultant
2016 |
Independent Trustee Consultant, Columbia Funds since March 2016; Managing Director and General Manager of Mutual Fund Products, Columbia Management Investment Advisers, LLC from May 2010 to February 2015; President, Columbia Funds from 2009 to 2015; and senior officer of Columbia Funds and affiliated funds from 2003 to 2015 | 66 | Board of Governors, Gateway Healthcare since January 2016; Trustee, New Century Portfolios since March 2015; and Director, The Autism Project since March 2015 | Product and Distribution, Advisory Fees & Expenses, Audit, Investment Oversight Committees #1 & #2 |
Natalie
A. Trunow
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1967 |
Independent
Trustee Consultant
2016 |
Independent Trustee Consultant, Columbia Funds since September 2016; Chief Executive Officer, Millennial Partners (investment consulting services to institutions) since January 2016; Director of Investments, Casey Family Programs from April 2016 to September 2016; Senior Vice President and Chief Investment Officer, Calvert Investments from August 2008 to January 2016; Section Head and Portfolio Manager, General Motors Asset Management from June 1997 to August 2008 | 66 | Healthcare Services for Children with Special Needs | Product and Distribution, Advisory Fees & Expenses, Compliance, Investment Oversight Committees #1 & #2 |
* | J. Kevin Connaughton was appointed consultant to the Independent Trustees effective March 1, 2016. Natalie A. Trunow was appointed consultant to the Independent Trustees effective September 1, 2016. Shareholders of the Funds are expected to be asked to elect each of Mr. Connaughton and Ms. Trunow as a Trustee at a future shareholder meeting. |
Statement of Additional Information – [____, 2018] | 156 |
Name,
Address,
Year of Birth |
Position
Held
with the Trust and Length of Service |
Principal
Occupation(s)
During the Past Five Years and Other Relevant Professional Experience |
Number
of
Funds in the Columbia Funds Complex Overseen |
Other Directorships Held by Trustee During the Past Five Years |
Committee
Assignments |
William
F. Truscott
c/o Columbia Management Investment Advisers, LLC, 225 Franklin St. Boston, MA 02110 1960 |
Trustee
2012 |
Chairman of the Board and President, Columbia Management Investment Advisers, LLC since May 2010 and February 2012, respectively; Chief Executive Officer, Global Asset Management, Ameriprise Financial, Inc. since September 2012 (previously Chief Executive Officer, U.S. Asset Management & President, Annuities, May 2010 - September 2012); Director and Chief Executive Officer, Columbia Management Investment Distributors, Inc. since May 2010 and February 2012, respectively; Chairman of the Board and Chief Executive Officer, RiverSource Distributors, Inc. since 2006; Director, Threadneedle Asset Management Holdings, SARL since 2014; President and Chief Executive Officer, Ameriprise Certificate Company, 2006 - August 2012. | 190 | Chairman of the Board, Columbia Management Investment Advisers, LLC since May 2010; Director, Columbia Management Investment Distributors, Inc. since May 2010; Former Director, Ameriprise Certificate Company, 2006 - January 2013 | None |
* | Interested person (as defined under the 1940 Act) by reason of being an officer, director, security holder and/or employee of the Investment Manager or Ameriprise Financial. |
Statement of Additional Information – [____, 2018] | 157 |
Name,
Address
and Year of Birth |
Position
and Year
First Appointed to Position for any Fund in the Columbia Funds Complex or a Predecessor Thereof |
Principal Occupation(s) During Past Five Years |
Paul
B. Goucher
100 Park Avenue New York, NY 10017 Born 1968 |
Senior Vice President (2011) and Assistant Secretary (2008) | Senior Vice President and Assistant General Counsel, Ameriprise Financial, Inc. since January 2017 (previously Vice President and Lead Chief Counsel, November 2008 – January 2017 and January 2013 – January 2017, respectively; and Chief Counsel, January 2010 - January 2013); Vice President, Chief Legal Officer and Assistant Secretary, Columbia Management Investment Advisers, LLC since May 2010. |
Thomas
P. McGuire
225 Franklin Street Boston, MA 02110 Born 1972 |
Senior Vice President and Chief Compliance Officer (2012) | Vice President – Asset Management Compliance, Ameriprise Financial, Inc., since May 2010; Chief Compliance Officer, Ameriprise Certificate Company since September 2010. |
Colin
Moore
225 Franklin Street Boston, MA 02110 Born 1958 |
Senior Vice President (2010) | Executive Vice President and Global Chief Investment Officer, Ameriprise Financial, Inc., since July 2013; Executive Vice President and Global Chief Investment Officer, Columbia Management Investment Advisers, LLC since July 2013 (previously Director and Global Chief Investment Officer, 2010 – 2013). |
Ryan
C. Larrenaga
225 Franklin Street Boston, MA 02110 Born 1970 |
Senior Vice President (2017), Chief Legal Officer (2017) and Secretary (2015) | Vice President and Group Counsel, Ameriprise Financial, Inc. since August 2011; officer of Columbia Funds and affiliated funds since 2005. |
Michael
E. DeFao
225 Franklin Street Boston, MA 02110 Born 1968 |
Vice President (2011) and Assistant Secretary (2010) | Vice President and Chief Counsel, Ameriprise Financial, Inc. since May 2010. |
Amy
Johnson
5228 Ameriprise Financial Center Minneapolis, MN 55474 Born 1965 |
Vice President (2006) | Managing Director and Global Head of Operations, Columbia Management Investment Advisers, LLC since April 2016 (previously Managing Director and Chief Operating Officer, 2010 – 2016). |
Lyn
Kephart-Strong
5228 Ameriprise Financial Center Minneapolis, MN 55474 Born 1960 |
Vice President (2015) | President, Columbia Management Investment Services Corp. since October 2014; Vice President & Resolution Officer, Ameriprise Trust Company since August 2009. |
Statement of Additional Information – [____, 2018] | 158 |
Statement of Additional Information – [____, 2018] | 159 |
Statement of Additional Information – [____, 2018] | 160 |
Fiscal Period |
Audit
Committee |
Governance
Committee |
Advisory
Fees
& Expenses Committee |
Compliance
Committee |
Investment
Oversight Committee |
Product
&
Distribution Committee |
For
the fiscal year
ending January 31, 2017 |
6 | 5 | 6 | 5 | 8 | 4 |
For
the fiscal year
ending March 31, 2017 |
6 | 5 | 6 | 5 | 6 | 4 |
For
the fiscal year
ending April 30, 2017 |
7 | 6 | 8 | 6 | 10 | 5 |
For
the fiscal year
ending May 31, 2017 |
6 | 5 | 7 | 6 | 8 | 4 |
For
the fiscal year
ending July 31, 2017 |
7 | 7 | 8 | 6 | 10 | 5 |
For
the fiscal year
ending August 31, 2017 |
7 | 7 | 7 | 6 | 12 | 5 |
For
the fiscal year
ending October 31, 2016 |
5 | 4 | 4 | 4 | 8 | 5 |
For
the fiscal year
ending December 31, 2016 |
5 | 4 | 5 | 4 | 8 | 3 |
Fund | Carrig | Hacker | Lukitsh | Moffett | Neuhauser | Simpson | Verville |
Adaptive Retirement 2020 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2030 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2040 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2050 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2060 Fund | A | A | A | A | A | A | A |
Adaptive Risk Allocation Fund | A | E | A | A | A | A | A |
Statement of Additional Information – [____, 2018] | 161 |
Fund | Carrig | Hacker | Lukitsh | Moffett | Neuhauser | Simpson | Verville |
Alternative Beta Fund | A | A | A | A | A | A | A |
AMT-Free CT Intermediate Muni Bond Fund | A | A | A | A | A | A | A |
AMT-Free Intermediate Muni Bond Fund | A | A | A | A | A | A | A |
AMT-Free MA Intermediate Muni Bond Fund | A | A | A | A | A | A | A |
AMT-Free NY Intermediate Muni Bond Fund | A | A | A | A | A | A | A |
AMT-Free OR Intermediate Muni Bond Fund | A | A | A | A | A | A | A |
Balanced Fund | A | A | A | A | A | D | E (a) |
Bond Fund | A | A | A | A | A | A | C (a) |
CA Tax-Exempt Fund | A | A | A | A | A | A | A |
Contrarian Core Fund | E | A | A | A | A | A | A |
Corporate Income Fund | D (a) | A | A | A | A | A | A |
Disciplined Small Core Fund | A | A | A | A | A | A | A |
Diversified Absolute Return Fund | A | A | A | A | A | A | A |
Diversified Real Return Fund | A | A | A | A | A | A | A |
Dividend Income Fund | E (a) | A | A | A | A | E (a) | D (a) |
Emerging Markets Fund | A | E | A | A | A | E (a) | A |
Global Dividend Opportunity Fund | A | A | A | A | A | A | A |
Global Energy and Natural Resources Fund | A | A | A | A | A | D (a) | A |
Global Technology Growth Fund | A | A | E | E (a) | A | A | A |
Greater China Fund | A | E | A | A | A | A | A |
High Yield Municipal Fund | A | A | A | A | A | A | A |
Large Cap Growth Fund | D | A | A | A | A | E (a) | D (a) |
Mid Cap Growth Fund | A | A | A | A | A | B | A |
MM Alternative Strategies Fund | A | A | A | A | A | A | A |
MM Directional Alternative Strategies Fund | A | A | A | A | A | A | A |
MM Growth Strategies Fund | A | A | A | A | A | A | A |
MM Small Cap Equity Strategies Fund | A | A | A | A | A | A | A |
MM Total Return Bond Strategies Fund | A | A | A | A | A | A | A |
Multi-Asset Income Fund | A | A | A | A | A | A | A |
NY Tax-Exempt Fund | A | A | A | A | A | A | A |
Pacific/Asia Fund | A | A | A | A | A | A | A |
Real Estate Equity Fund | A | A | A | A | A | E (a) | A |
Select Large Cap Growth Fund | D | E | A | A | A | A | A |
Small Cap Growth Fund I | A | A | A | A | A | E (a) | A |
Small Cap Value Fund I | A | A | A | A | E | E (a) | A |
Solutions Aggressive Portfolio | A | A | A | A | A | A | A |
Solutions Conservative Portfolio | A | A | A | A | A | A | A |
Strategic Income Fund | A | A | A | A | A | A | D (a) |
Tax-Exempt Fund | A | A | A | A | E | A | A |
Total Return Bond Fund | A | A | A | A | A | E (a) | A |
U.S. Social Bond Fund | A | A | A | A | A | A | A |
U.S. Treasury Index Fund | A | A | A | A | A | A | A |
Ultra Short Term Bond Fund | A | A | A | A | A | A | A |
Aggregate Dollar Range of Equity Securities in all Funds in the Columbia Funds Complex Overseen by the Trustee | E (a) | E | E | E (a) | E | E (a) | E (a) |
Statement of Additional Information – [____, 2018] | 162 |
(a) | Includes the value of compensation payable under a Deferred Compensation Plan that is determined as if the amounts deferred had been invested, as of the date of deferral, in shares of one or more funds in the Columbia Funds Complex overseen by the Trustee as specified by the Trustee. |
Fund | Connaughton | Trunow |
Adaptive Retirement 2020 Fund | A | A |
Adaptive Retirement 2030 Fund | A | A |
Adaptive Retirement 2040 Fund | A | A |
Adaptive Retirement 2050 Fund | A | A |
Adaptive Retirement 2060 Fund | A | A |
Adaptive Risk Allocation Fund | A | A |
Alternative Beta Fund | A | A |
AMT-Free CT Intermediate Muni Bond Fund | A | A |
AMT-Free Intermediate Muni Bond Fund | A | A |
AMT-Free MA Intermediate Muni Bond Fund | A | A |
AMT-Free NY Intermediate Muni Bond Fund | A | A |
AMT-Free OR Intermediate Muni Bond Fund | A | A |
Balanced Fund | C | A |
Bond Fund | A | A |
CA Tax-Exempt Fund | A | A |
Contrarian Core Fund | E | A |
Corporate Income Fund | A | A |
Disciplined Small Core Fund | A | A |
Diversified Absolute Return Fund | A | A |
Diversified Real Return Fund | A | A |
Dividend Income Fund | A | A |
Emerging Markets Fund | D | A |
Global Dividend Opportunity Fund | A | A |
Global Energy and Natural Resources Fund | A | A |
Global Technology Growth Fund | A | A |
Greater China Fund | A | A |
High Yield Municipal Fund | A | A |
Large Cap Growth Fund | A | A |
Mid Cap Growth Fund | A | A |
MM Alternative Strategies Fund | A | A |
MM Directional Alternative Strategies Fund | A | A |
MM Growth Strategies Fund | A | A |
MM Small Cap Equity Strategies Fund | A | A |
MM Total Return Bond Strategies Fund | A | A |
Multi-Asset Income Fund | A | A |
NY Tax-Exempt Fund | A | A |
Pacific/Asia Fund | A | A |
Real Estate Equity Fund | A | A |
Select Large Cap Growth Fund | E | A |
Small Cap Growth Fund I | A | A |
Small Cap Value Fund I | A | A |
Statement of Additional Information – [____, 2018] | 163 |
Fund | Connaughton | Trunow |
Solutions Aggressive Portfolio | A | A |
Solutions Conservative Portfolio | A | A |
Strategic Income Fund | E | A |
Tax-Exempt Fund | A | A |
Total Return Bond Fund | A | A |
U.S. Social Bond Fund | A | A |
U.S. Treasury Index Fund | A | A |
Ultra Short Term Bond Fund | A | A |
Aggregate
Dollar Range of Equity Securities in all Funds in the
Columbia Funds Complex Overseen by the Consultant |
E | A |
Fund | Truscott |
Adaptive Retirement 2020 Fund | A |
Adaptive Retirement 2030 Fund | A |
Adaptive Retirement 2040 Fund | A |
Adaptive Retirement 2050 Fund | A |
Adaptive Retirement 2060 Fund | A |
Adaptive Risk Allocation Fund | E |
Alternative Beta Fund | E |
AMT-Free CT Intermediate Muni Bond Fund | A |
AMT-Free Intermediate Muni Bond Fund | A |
AMT-Free MA Intermediate Muni Bond Fund | A |
AMT-Free NY Intermediate Muni Bond Fund | A |
AMT-Free OR Intermediate Muni Bond Fund | A |
Balanced Fund | A |
Bond Fund | A |
CA Tax-Exempt Fund | A |
Contrarian Core Fund | E (a) |
Corporate Income Fund | B |
Disciplined Small Core Fund | A |
Diversified Absolute Return Fund | A |
Diversified Real Return Fund | A |
Dividend Income Fund | A |
Emerging Markets Fund | D |
Global Dividend Opportunity Fund | A |
Global Energy and Natural Resources Fund | A |
Global Technology Growth Fund | A |
Greater China Fund | A |
High Yield Municipal Fund | E |
Large Cap Growth Fund | D |
Mid Cap Growth Fund | A |
MM Alternative Strategies Fund | A |
MM Directional Alternative Strategies Fund | A |
MM Growth Strategies Fund | A |
Statement of Additional Information – [____, 2018] | 164 |
Fund | Truscott |
MM Small Cap Equity Strategies Fund | A |
MM Total Return Bond Strategies Fund | A |
Multi-Asset Income Fund | A |
NY Tax-Exempt Fund | A |
Pacific/Asia Fund | A |
Real Estate Equity Fund | A |
Select Large Cap Growth Fund | E |
Small Cap Growth Fund I | A |
Small Cap Value Fund I | A |
Solutions Aggressive Portfolio | A |
Solutions Conservative Portfolio | A |
Strategic Income Fund | E |
Tax-Exempt Fund | A |
Total Return Bond Fund | C |
U.S. Social Bond Fund | A |
U.S. Treasury Index Fund | B |
Ultra Short Term Bond Fund | A |
Aggregate
Dollar Range of Equity Securities in all Funds in the
Columbia Funds Complex Overseen by the Trustee |
E (a) |
(a) | Includes notional investments through a deferred compensation account. Mr. Truscott’s deferred compensation plan is separate from that of the Independent Trustees (for these purposes, including Mr. Connaughton and Ms. Trunow, as Consultants to the Independent Trustees). |
Trustee Name |
Total
Cash Compensation
from the Columbia Funds Complex Paid to Trustee (a) |
Amount
Deferred
from Total Compensation (b) |
Trustee | ||
Janet L. Carrig | $281,250 | $281,250 |
Douglas A. Hacker | $408,250 | $0 |
Nancy T. Lukitsh | $271,750 | $0 |
William E.Mayer (c) | $58,250 | $0 |
David M. Moffett | $286,750 | $59,750 |
Charles R. Nelson (d) | $259,250 | $0 |
John J. Neuhauser | $278,250 | $0 |
Patrick J. Simpson | $300,250 | $144,000 |
Anne-Lee Verville | $269,250 | $0 |
Consultant | ||
J. Kevin Connaughton | $257,250 | $0 |
Natalie A. Trunow (e) | $248,250 | $112,500 |
Statement of Additional Information – [____, 2018] | 165 |
(a) | Includes any portion of cash compensation Trustees elected to defer during the fiscal period. |
(b) | The Trustees may elect to defer a portion of the total cash compensation payable. Additional information regarding the Deferred Compensation Plan is described below. |
(c) | Mr. Mayer served as Trustee until December 31, 2016, and stopped receiving compensation from the Funds and the Columbia Funds Complex as of such date. |
(d) | Mr. Nelson served as Trustee until December 31, 2017, and stopped receiving compensation from the Funds and the Columbia Funds Complex as of such date. |
(e) | For the period from September 1, 2016 (when Ms. Trunow was appointed consultant to the Independent Trustees) through the applicable fiscal year end. Ms. Trunow receives compensation from the Funds for serving as a consultant to the Independent Trustees at an annual rate of $255,000. |
Fund | Aggregate Compensation from Fund | |||||||||||
Independent Trustees | Consultant to Independent Trustees | |||||||||||
Janet
L.
Carrig (a) |
Douglas
A.
Hacker |
Nancy
T.
Lukitsh |
William
E.
Mayer (b) |
David
M.
Moffett (c) |
Charles
R.
Nelson (d) |
John
J.
Neuhauser |
Patrick
J.
Simpson (e) |
Anne-Lee
Verville (f) |
J.
Kevin
Connaughton (g) |
Natalie
A.
Trunow (h) |
||
For Funds with fiscal period ending January 31 | ||||||||||||
Diversified Real Return Fund | $1,362 | $2,105 | $1,387 | $1,098 | $1,393 | $1,299 | $1,434 | $1,467 | $1,367 | $1,417 | $814 | |
Amount Deferred | $1,362 | $0 | $0 | $0 | $1,153 | $0 | $0 | $601 | $0 | $0 | $212 | |
For Funds with fiscal period ending March 31 | ||||||||||||
Adaptive Retirement 2020 Fund (i) | $521 | $655 | $515 | $0 | $526 | $496 | $521 | $534 | $515 | $324 | $324 | |
Amount Deferred | $521 | $0 | $0 | $0 | $0 | $0 | $0 | $331 | $0 | $0 | $191 | |
Adaptive Retirement 2030 Fund (i) | $525 | $659 | $518 | $0 | $530 | $499 | $525 | $538 | $518 | $326 | $326 | |
Amount Deferred | $525 | $0 | $0 | $0 | $0 | $0 | $0 | $333 | $0 | $0 | $192 | |
Adaptive Retirement 2040 Fund (i) | $518 | $651 | $512 | $0 | $523 | $493 | $518 | $531 | $512 | $322 | $322 | |
Amount Deferred | $518 | $0 | $0 | $0 | $0 | $0 | $0 | $329 | $0 | $0 | $190 | |
Adaptive Retirement 2050 Fund (i) | $518 | $651 | $512 | $0 | $523 | $493 | $518 | $531 | $512 | $322 | $322 | |
Amount Deferred | $518 | $0 | $0 | $0 | $0 | $0 | $0 | $329 | $0 | $0 | $190 |
Statement of Additional Information – [____, 2018] | 166 |
Statement of Additional Information – [____, 2018] | 167 |
Fund | Aggregate Compensation from Fund | |||||||||||
Independent Trustees | Consultant to Independent Trustees | |||||||||||
Janet
L.
Carrig (a) |
Douglas
A.
Hacker |
Nancy
T.
Lukitsh |
William
E.
Mayer (b) |
David
M.
Moffett (c) |
Charles
R.
Nelson (d) |
John
J.
Neuhauser |
Patrick
J.
Simpson (e) |
Anne-Lee
Verville (f) |
J.
Kevin
Connaughton (g) |
Natalie
A.
Trunow (h) |
||
Amount Deferred | $2,561 | $0 | $0 | $0 | $705 | $0 | $0 | $1,252 | $0 | $0 | $1,025 | |
Large Cap Growth Fund | $8,481 | $12,274 | $8,188 | $2,449 | $8,472 | $7,804 | $8,386 | $8,907 | $8,035 | $7,822 | $7,549 | |
Amount Deferred | $8,481 | $0 | $0 | $0 | $2,336 | $0 | $0 | $4,155 | $0 | $0 | $3,388 | |
Tax-Exempt Fund | $9,862 | $14,294 | $9,540 | $2,988 | $9,837 | $9,086 | $9,774 | $10,368 | $9,361 | $9,121 | $8,793 | |
Amount Deferred | $9,862 | $0 | $0 | $0 | $2,849 | $0 | $0 | $4,832 | $0 | $0 | $3,892 | |
U.S. Social Bond Fund | $1,688 | $2,446 | $1,630 | $482 | $1,688 | $1,554 | $1,670 | $1,773 | $1,599 | $1,560 | $1,507 | |
Amount Deferred | $1,688 | $0 | $0 | $0 | $460 | $0 | $0 | $825 | $0 | $0 | $679 | |
Ultra Short Term Bond Fund | $5,095 | $7,376 | $4,930 | $1,352 | $5,109 | $4,704 | $5,049 | $5,352 | $4,839 | $4,726 | $4,561 | |
Amount Deferred | $5,095 | $0 | $0 | $0 | $1,297 | $0 | $0 | $2,482 | $0 | $0 | $2,104 | |
For Funds with fiscal period ending August 31 | ||||||||||||
AP - Alternatives Fund | $2,922 | $4,277 | $2,829 | $670 | $2,981 | $2,692 | $2,898 | $3,125 | $2,804 | $2,713 | $2,619 | |
Amount Deferred | $2,922 | $0 | $0 | $0 | $685 | $0 | $0 | $1,477 | $0 | $0 | $1,152 | |
AP - Small Cap Equity Fund | $3,612 | $5,257 | $3,482 | $788 | $3,675 | $3,319 | $3,566 | $3,860 | $3,454 | $3,316 | $3,201 | |
Amount Deferred | $3,612 | $0 | $0 | $0 | $800 | $0 | $0 | $1,845 | $0 | $0 | $1,429 | |
AP - Total Return Bond Fund | $15,482 | $22,475 | $14,965 | $3,195 | $15,786 | $14,272 | $15,321 | $16,527 | $14,818 | $14,147 | $13,669 | |
Amount Deferred | $15,482 | $0 | $0 | $0 | $3,277 | $0 | $0 | $7,924 | $0 | $0 | $6,196 | |
Balanced Fund | $14,434 | $20,825 | $13,930 | $2,758 | $14,714 | $13,311 | $14,256 | $15,385 | $13,795 | $13,049 | $12,601 | |
Amount Deferred | $14,434 | $0 | $0 | $0 | $2,837 | $0 | $0 | $7,456 | $0 | $0 | $5,834 | |
Contrarian Core Fund | $22,425 | $32,543 | $21,679 | $4,611 | $22,870 | $20,681 | $22,196 | $23,933 | $21,478 | $20,521 | $19,799 | |
Amount Deferred | $22,425 | $0 | $0 | $0 | $4,735 | $0 | $0 | $11,472 | $0 | $0 | $8,991 | |
Disciplined Small Core Fund | $2,148 | $3,131 | $2,077 | $466 | $2,190 | $1,979 | $2,128 | $2,295 | $2,059 | $1,980 | $1,912 | |
Amount Deferred | $2,148 | $0 | $0 | $0 | $477 | $0 | $0 | $1,092 | $0 | $0 | $856 | |
Emerging Markets Fund | $4,260 | $6,208 | $4,123 | $919 | $4,348 | $3,930 | $4,223 | $4,551 | $4,086 | $3,929 | $3,791 | |
Amount Deferred | $4,260 | $0 | $0 | $0 | $945 | $0 | $0 | $2,165 | $0 | $0 | $1,700 | |
Global Dividend Opportunity Fund | $2,873 | $4,181 | $2,776 | $616 | $2,929 | $2,646 | $2,843 | $3,069 | $2,751 | $2,638 | $2,547 | |
Amount Deferred | $2,873 | $0 | $0 | $0 | $630 | $0 | $0 | $1,466 | $0 | $0 | $1,143 | |
Global Energy and Natural Resources Fund | $2,129 | $3,099 | $2,058 | $454 | $2,171 | $1,962 | $2,108 | $2,274 | $2,039 | $1,957 | $1,890 | |
Amount Deferred | $2,129 | $0 | $0 | $0 | $465 | $0 | $0 | $1,084 | $0 | $0 | $849 | |
Global Technology Growth Fund | $2,890 | $4,173 | $2,784 | $571 | $2,945 | $2,660 | $2,850 | $3,082 | $2,758 | $2,609 | $2,521 | |
Amount Deferred | $2,890 | $0 | $0 | $0 | $586 | $0 | $0 | $1,495 | $0 | $0 | $1,155 | |
Greater China Fund | $1,857 | $2,700 | $1,793 | $396 | $1,893 | $1,710 | $1,837 | $1,983 | $1,777 | $1,701 | $1,643 | |
Amount Deferred | $1,857 | $0 | $0 | $0 | $405 | $0 | $0 | $949 | $0 | $0 | $739 | |
Mid Cap Growth Fund | $5,374 | $7,823 | $5,195 | $1,153 | $5,479 | $4,951 | $5,320 | $5,740 | $5,148 | $4,942 | $4,770 | |
Amount Deferred | $5,374 | $0 | $0 | $0 | $1,180 | $0 | $0 | $2,737 | $0 | $0 | $2,140 | |
Small Cap Growth Fund I | $2,470 | $3,590 | $2,386 | $522 | $2,518 | $2,275 | $2,443 | $2,637 | $2,364 | $2,262 | $2,185 | |
Amount Deferred | $2,470 | $0 | $0 | $0 | $534 | $0 | $0 | $1,262 | $0 | $0 | $984 | |
Strategic Income Fund (k) | $8,220 | $11,911 | $7,943 | $1,652 | $8,384 | $7,584 | $8,132 | $8,771 | $7,869 | $7,502 | $7,237 | |
Amount Deferred | $8,220 | $0 | $0 | $0 | $1,699 | $0 | $0 | $4,216 | $0 | $0 | $3,311 | |
For Funds with fiscal period ending October 31 | ||||||||||||
AMT-Free CT Intermediate Muni Bond Fund | $1,668 | $2,528 | $1,686 | $1,581 | $1,680 | $1,548 | $1,732 | $1,768 | $1,658 | $1,351 | $546 | |
Amount Deferred | $1,668 | $0 | $0 | $0 | $1,680 | $0 | $0 | $739 | $0 | $0 | $0 |
Statement of Additional Information – [____, 2018] | 168 |
Fund | Aggregate Compensation from Fund | |||||||||||
Independent Trustees | Consultant to Independent Trustees | |||||||||||
Janet
L.
Carrig (a) |
Douglas
A.
Hacker |
Nancy
T.
Lukitsh |
William
E.
Mayer (b) |
David
M.
Moffett (c) |
Charles
R.
Nelson (d) |
John
J.
Neuhauser |
Patrick
J.
Simpson (e) |
Anne-Lee
Verville (f) |
J.
Kevin
Connaughton (g) |
Natalie
A.
Trunow (h) |
||
AMT-Free Intermediate Muni Bond Fund | $5,751 | $8,706 | $5,813 | $5,450 | $5,792 | $5,339 | $5,972 | $6,095 | $5,717 | $4,680 | $1,861 | |
Amount Deferred | $5,751 | $0 | $0 | $0 | $5,792 | $0 | $0 | $2,556 | $0 | $0 | $0 | |
AMT-Free MA Intermediate Muni Bond Fund | $1,924 | $2,915 | $1,945 | $1,823 | $1,937 | $1,785 | $1,998 | $2,038 | $1,912 | $1,557 | $625 | |
Amount Deferred | $1,924 | $0 | $0 | $0 | $1,937 | $0 | $0 | $852 | $0 | $0 | $0 | |
AMT-Free NY Intermediate Muni Bond Fund | $1,907 | $2,889 | $1,927 | $1,807 | $1,920 | $1,769 | $1,980 | $2,020 | $1,895 | $1,545 | $624 | |
Amount Deferred | $1,907 | $0 | $0 | $0 | $1,920 | $0 | $0 | $845 | $0 | $0 | $0 | |
CA Tax-Exempt Fund | $2,395 | $3,627 | $2,421 | $2,269 | $2,411 | $2,222 | $2,487 | $2,538 | $2,380 | $1,941 | $779 | |
Amount Deferred | $2,395 | $0 | $0 | $0 | $2,411 | $0 | $0 | $1,062 | $0 | $0 | $0 | |
NY Tax-Exempt Fund | $1,764 | $2,673 | $1,782 | $1,672 | $1,775 | $1,636 | $1,831 | $1,869 | $1,752 | $1,435 | $587 | |
Amount Deferred | $1,764 | $0 | $0 | $0 | $1,775 | $0 | $0 | $782 | $0 | $0 | $0 | |
For Funds with fiscal period ending December 31 | ||||||||||||
Real Estate Equity Fund | $2,307 | $3,586 | $2,350 | $2,218 | $2,360 | $2,198 | $2,430 | $2,486 | $2,315 | $1,910 | $778 | |
Amount Deferred | $2,307 | $0 | $0 | $0 | $2,360 | $0 | $0 | $1,032 | $0 | $0 | $0 |
(a) | As of December 31, 2016, the value of Ms. Carrig’s account under the deferred compensation plan was $1,254,843. |
(b) | Mr. Mayer served as Trustee until December 31, 2016, and stopped receiving compensation from the Funds and the Columbia Funds Complex as of such date. |
(c) | As of December 31, 2016, the value of Mr. Moffett's account under the deferred compensation plan was $468,310. |
(d) | Mr. Nelson served as Trustee until December 31, 2017, and stopped receiving compensation from the Funds and the Columbia Funds Complex as of such date. |
(e) | As of December 31, 2016, the value of Mr. Simpson’s account under the deferred compensation plan was $2,146,984. |
(f) | As of December 31, 2016, the value of Ms. Verville’s account under the deferred compensation plan was $558,310. |
(g) | Beginning with the fiscal year ended March 31, 2017, Mr. Connaughton was a consultant to the Independent Trustees for the full period shown in the table above. For fiscal years ended prior to March 31, 2017, payments to Mr. Connaughton are for the period from March 1, 2016 (when he was first appointed consultant to the Independent Trustees) through the applicable fiscal year end. Mr. Connaughton receives compensation from the Funds for serving as a consultant to the Independent Trustees at an annual rate of $255,000. |
(h) | Payments to Ms. Trunow are for the period from September 1, 2016 (when she was first appointed consultant to the Independent Trustees) through the applicable fiscal year end. Ms. Trunow receives compensation from the Funds for serving as a consultant to the Independent Trustees at an annual rate of $255,000. |
(i) | The Fund commenced operations on October 24, 2017. The compensation shown for the Fund is the estimated amount that will be paid from October 23, 2017 to March 31, 2018. |
(j) | For the period from October 17, 2016 (commencement of operations) to April 30, 2017. |
(k) | The Fund changed its fiscal year end in 2017 from October 31 to August 31. For the fiscal year ended in 2017, the information shown is for the period from November 1, 2016 to August 31, 2017. |
Statement of Additional Information – [____, 2018] | 169 |
Statement of Additional Information – [____, 2018] | 170 |
Statement of Additional Information – [____, 2018] | 171 |
Statement of Additional Information – [____, 2018] | 172 |
Total Brokerage Commissions | |||
Fund | 2017 | 2016 | 2015 |
For Funds with fiscal period ending January 31 | |||
Diversified Real Return Fund | $260 | $530 | $932 (a) |
For Funds with fiscal period ending March 31 | |||
Adaptive Retirement 2020 Fund (b) | N/A | N/A | N/A |
Adaptive Retirement 2030 Fund (b) | N/A | N/A | N/A |
Adaptive Retirement 2040 Fund (b) | N/A | N/A | N/A |
Adaptive Retirement 2050 Fund (b) | N/A | N/A | N/A |
Adaptive Retirement 2060 Fund (b) | N/A | N/A | N/A |
MM Growth Strategies Fund | 1,170,504 | 1,540,259 | 1,048,675 |
Pacific/Asia Fund | 483,636 | 456,905 | 510,601 |
Select Large Cap Growth Fund | 1,601,142 | 2,716,236 | 2,312,302 |
Solutions Aggressive Portfolio (b) | N/A | N/A | N/A |
Solutions Conservative Portfolio (b) | N/A | N/A | N/A |
For Funds with fiscal period ending April 30 | |||
Bond Fund | 18,287 | 23,846 | 15,224 |
Corporate Income Fund | 69,484 | 54,070 | 59,212 |
MM Directional Alternative Strategies Fund | 930,710 (c) | N/A | N/A |
Multi-Asset Income Fund | 21,643 | 22,078 | 42,481 (d) |
Small Cap Value Fund I | 1,212,265 | 1,960,857 | 2,305,255 |
Total Return Bond Fund | 225,810 | 167,980 | 72,702 |
U.S. Treasury Index Fund | 0 | 0 | 0 |
For Funds with fiscal period ending May 31 | |||
Adaptive Risk Allocation Fund | 627,857 | 239,119 | 210,129 |
Statement of Additional Information – [____, 2018] | 173 |
Total Brokerage Commissions | |||
Fund | 2017 | 2016 | 2015 |
Alternative Beta Fund | $17,770 | $46,588 | $23,795 (e) |
Diversified Absolute Return Fund | 104,102 | 2,293,997 | 618,976 (f) |
Dividend Income Fund | 1,356,544 | 1,853,862 | 2,285,197 |
HY Municipal Fund | 0 | 0 | 0 |
For Funds with fiscal period ending July 31 | |||
AMT-Free OR Intermediate Muni Bond Fund | 0 | 0 | 0 |
Large Cap Growth Fund | 926,115 | 1,107,524 | 1,344,066 |
Tax-Exempt Fund | 4,550 | 0 | 0 |
U.S. Social Bond Fund | 332 | 13 | 0 (g) |
Ultra Short Term Bond Fund | 0 | 0 | 0 |
For Funds with fiscal period ending August 31 | |||
Balanced Fund | 1,764,194 | 1,567,482 | 827,182 |
Contrarian Core Fund | 4,479,950 | 3,952,735 | 2,566,680 |
Disciplined Small Core Fund | 382,628 | 1,236,808 | 821,155 |
Emerging Markets Fund | 2,969,418 | 3,765,444 | 4,498,397 |
Global Dividend Opportunity Fund | 459,504 | 853,746 | 1,119,280 |
Global Energy and Natural Resources Fund | 103,062 | 112,438 | 265,939 |
Global Technology Growth Fund | 379,605 | 328,663 | 333,197 |
Greater China Fund | 139,256 | 136,815 | 268,667 |
Mid Cap Growth Fund | 2,081,806 | 2,710,169 | 2,311,420 |
MM Alternative Strategies Fund | 1,110,334 | 1,059,559 | 1,427,187 |
MM Small Cap Equity Strategies Fund | 1,730,634 | 3,051,542 | 1,967,401 |
MM Total Return Bond Strategies Fund | 420,658 | 489,671 | 210,419 |
Small Cap Growth Fund I | 1,207,610 | 1,065,842 | 1,711,624 |
Strategic Income Fund | 262,921 (h) | 178,818 | 129,182 |
Fund | 2016 | 2015 | 2014 |
For Funds with fiscal period ending October 31 | |||
AMT-Free CT Intermediate Muni Bond Fund | 0 | 0 | 0 |
AMT-Free Intermediate Muni Bond Fund | 0 | 0 | 0 |
AMT-Free MA Intermediate Muni Bond Fund | 0 | 0 | 0 |
AMT-Free NY Intermediate Muni Bond Fund | 0 | 0 | 0 |
CA Tax-Exempt Fund | 1,232 | 0 | 0 |
NY Tax-Exempt Fund | 809 | 0 | 0 |
For Funds with fiscal period ending December 31 | |||
Real Estate Equity Fund | 245,905 | 284,239 | 354,039 |
(a) | For the period from March 11, 2014 (commencement of operations) to January 31, 2015. |
(b) | The Fund commenced operations on October 24, 2017, and therefore has no reporting information for periods prior to such date. |
(c) | For the period from October 17, 2016 (commencement of operations) to April 30, 2017. |
(d) | For the period from March 27, 2015 (commencement of operations) to April 30, 2015. |
(e) | For the period from January 27, 2015 (commencement of operations) to May 31, 2015. |
(f) | For the period from February 19, 2015 (commencement of operations) to May 31, 2015. |
(g) | For the period from March 26, 2015 (commencement of operations) to July 31, 2015. |
(h) | The Fund changed its fiscal year end in 2017 from October 31 to August 31. For the fiscal year ended in 2017, the information shown is for the period from November 1, 2016 to August 31, 2017. |
Statement of Additional Information – [____, 2018] | 174 |
Brokerage directed for research | ||
Fund | Amount of Transactions | Amount of Commissions Imputed or Paid |
For Funds with fiscal period ending January 31 | ||
Diversified Real Return Fund | $0 | $0 |
For Funds with fiscal period ending March 31 | ||
Adaptive Retirement 2020 Fund | N/A (b) | N/A (b) |
Adaptive Retirement 2030 Fund | N/A (b) | N/A (b) |
Adaptive Retirement 2040 Fund | N/A (b) | N/A (b) |
Adaptive Retirement 2050 Fund | N/A (b) | N/A (b) |
Adaptive Retirement 2060 Fund | N/A (b) | N/A (b) |
MM Growth Strategies Fund | 1,983,862,874 | 362,061 |
Pacific/Asia Fund | 48,694,488 | 55,573 |
Select Large Cap Growth Fund | 2,713,958,498 | 695,008 |
Solutions Aggressive Portfolio | N/A (b) | N/A (b) |
Solutions Conservative Portfolio | N/A (b) | N/A (b) |
For Funds with fiscal period ending April 30 | ||
Bond Fund | 0 | 0 |
Corporate Income Fund | 0 | 0 |
MM Directional Alternative Strategies Fund | 748,476,870 (c) | 221,469 (c) |
Multi-Asset Income Fund | 3,038,917 | 2,268 |
Small Cap Value Fund I | 319,153,574 | 542,616 |
Total Return Bond Fund | 0 | 0 |
U.S. Treasury Index Fund | 0 | 0 |
For Funds with fiscal period ending May 31 | ||
Adaptive Risk Allocation Fund | 0 | 0 |
Statement of Additional Information – [____, 2018] | 175 |
Brokerage directed for research | ||
Fund | Amount of Transactions | Amount of Commissions Imputed or Paid |
Alternative Beta Fund | $0 | $0 |
Diversified Absolute Return Fund | 18,981,941 | 6,358 |
Dividend Income Fund | 2,058,851,738 | 873,880 |
HY Municipal Fund | 0 | 0 |
For Funds with fiscal period ending July 31 | ||
AMT-Free OR Intermediate Muni Bond Fund | 0 | 0 |
Large Cap Growth Fund | 1,006,812,328 | 356,717 |
Tax-Exempt Fund | 0 | 0 |
U.S. Social Bond Fund | 0 | 0 |
Ultra Short Term Bond Fund | 0 | 0 |
For Funds with fiscal period ending August 31 | ||
Balanced Fund | 1,762,235,353 | 721,726 |
Contrarian Core Fund | 4,525,483,379 | 1,864,970 |
Disciplined Small Core Fund | 127,145,134 | 123,710 |
Emerging Markets Fund | 289,983,785 | 467,673 |
Global Dividend Opportunity Fund | 220,480,966 | 136,298 |
Global Energy and Natural Resources Fund | 38,278,873 | 30,887 |
Global Technology Growth Fund | 122,882,265 | 76,386 |
Greater China Fund | 18,766,331 | 24,877 |
Mid Cap Growth Fund | 1,193,894,857 | 639,990 |
MM Alternative Strategies Fund | 1,740,450,417 | 368,432 |
MM Small Cap Equity Strategies Fund | 338,013,806 | 165,451 |
MM Total Return Bond Strategies Fund | 0 | 0 |
Small Cap Growth Fund I | 540,188,659 | 389,932 |
Strategic Income Fund (d) | 0 | 0 |
For Funds with fiscal period ending October 31 | ||
AMT-Free CT Intermediate Muni Bond Fund | 0 | 0 |
AMT-Free Intermediate Muni Bond Fund | 0 | 0 |
AMT-Free MA Intermediate Muni Bond Fund | 0 | 0 |
AMT-Free NY Intermediate Muni Bond Fund | 0 | 0 |
CA Tax-Exempt Fund | 0 | 0 |
NY Tax-Exempt Fund | 0 | 0 |
For Funds with fiscal period ending December 31 | ||
Real Estate Equity Fund | 109,816,330 | 57,313 |
(a) | For the period from March 11, 2014 (commencement of operations) to January 31, 2015. |
(b) | The Fund commenced operations on October 24, 2017, and therefore has no reporting information for periods prior to such date. |
(c) | For the period from October 17, 2016 (commencement of operations) to April 30, 2017. |
(d) | The Fund changed its fiscal year end in 2017 from October 31 to August 31. For the fiscal year ended in 2017, the information shown is for the period from November 1, 2016 to August 31, 2017. |
Statement of Additional Information – [____, 2018] | 176 |
Statement of Additional Information – [____, 2018] | 177 |
Fund | Issuer |
Value
of securities owned
at end of fiscal period |
Total Return Bond Fund | Chase Issuance Trust | $10,291,844 |
Citigroup, Inc. | $15,060,248 | |
Citigroup Commercial Mortgage Trust | $2,201,702 | |
Citigroup Mortgage Loan Trust, Inc. | $15,893,745 | |
Credit Suisse Mortgage Capital Certificates | $22,813,634 | |
Credit Suisse Securities (USA) LLC | $7,358,096 | |
JPMorgan Chase & Co. | $28,475,081 | |
JPMorgan Chase Capital XXI | $20,108,070 | |
JPMorgan Chase Capital XXIII | $387,541 | |
JPMorgan Commercial Mortgage-Backed Securities Trust | $1,731,403 | |
JPMorgan Resecuritization Trust | $6,096,818 | |
Merrill Lynch Mortgage Investors Trust | $5,078 | |
Morgan Stanley Capital I Trust | $4,307,542 | |
Morgan Stanley Re-Remic Trust | $4,067,487 | |
PNC Bank NA | $3,442,740 | |
U.S. Treasury Index Fund | None | N/A |
For Funds with fiscal period ending May 31, 2017 | ||
Adaptive Risk Allocation Fund | None | N/A |
Alternative Beta Fund | None | N/A |
Diversified Absolute Return Fund | Affiliated Managers Group, Inc. | $(87,848) |
Citigroup, Inc. | $829,402 | |
Franklin Resources, Inc. | $(52,279) | |
The Goldman Sachs Group, Inc. | $112,179 | |
JPMorgan Chase & Co. | $998,576 | |
JPMorgan Chase Capital XXI | $297,905 | |
JPMorgan Chase Capital XXIII | $395,973 | |
Legg Mason, Inc. (subsidiary) | $(49,148) | |
Morgan Stanley | $98,840 | |
Dividend Income Fund | JPMorgan Chase & Co. | $330,243,000 |
PNC Financial Services Group, Inc.(The) | $155,832,327 | |
High Yield Municipal Fund | None | N/A |
For Funds with fiscal period ending July 31, 2017 | ||
AMT-Free OR Intermediate Muni Bond Fund | None | N/A |
Large Cap Growth Fund | The Goldman Sachs Group, Inc. | $40,104,459 |
Tax-Exempt Fund | None | N/A |
U.S. Social Bond Fund | None | N/A |
Ultra Short Term Bond Fund | Citigroup, Inc. | $14,112,420 |
Credit Suisse AG | $6,001,596 | |
The Goldman Sachs Group, Inc. | $13,218,790 | |
JPMorgan Chase & Co. | $16,140,000 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $5,568,485 | |
JPMBB Commercial Mortgage Securities Trust | $3,487,250 | |
Morgan Stanley | $12,093,300 | |
Morgan Stanley Bank of America Merrill Lynch Trust | $844,680 | |
PNC Bank NA | $10,438,324 |
Statement of Additional Information – [____, 2018] | 178 |
Statement of Additional Information – [____, 2018] | 179 |
Fund | Issuer |
Value
of securities owned
at end of fiscal period |
MM Total Return Bond Strategies Fund | The Bear Stearns Companies LLC | $7,531,037 |
Chase Issuance Trust | $20,858,408 | |
Citigroup, Inc. | $67,483,868 | |
Citigroup Commercial Mortgage Trust | $24,318,679 | |
Citigroup Mortgage Loan Trust, Inc. | $4,185,120 | |
Credit Suisse Mortgage Capital Certificates | $16,611,611 | |
Credit Suisse Group Funding | $7,054,442 | |
Credit Suisse Mortgage Capital Trust | $14,283,501 | |
E*TRADE Financial Corp. | $3,426,983 | |
GS Mortgage Securities Trust | $36,331,604 | |
The Goldman Sachs Group, Inc. | $64,765,439 | |
Jefferies Group LLC | $3,793,086 | |
JPMorgan Chase & Co. | $87,329,783 | |
JPMorgan Chase Bank NA | $2,614,364 | |
JPMorgan Chase Capital XXI | $17,190,288 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $20,566,156 | |
JPMorgan Commercial Mortgage-Backed Securities Trust | $44,577 | |
JPMorgan Mortgage Trust | $1,247,320 | |
JPMorgan Resecuritization Trust | $4,675,762 | |
Lehman XS Trust | $5,379,190 | |
Merrill Lynch & Co., Inc. | $2,118,154 | |
Banc of America Merrill Lynch Commercial Mortgage, Inc. | $1,734,164 | |
Morgan Stanley | $55,077,027 | |
Morgan Stanley Bank of America Merrill Lynch Trust | $3,635,832 | |
Morgan Stanley Capital I Trust | $13,742,600 | |
Morgan Stanley Mortgage Loan Trust | $4,363,742 | |
Morgan Stanley Re-Remic Trust | $1,072,558 | |
Morgan Stanley Resecuritization Trust | $492,732 | |
PNC Bank NA | $10,192,742 | |
Stifel Financial Corp. | $1,780,987 | |
Small Cap Growth Fund I | None | N/A |
Strategic Income Fund | Citigroup, Inc. | $7,039,145 |
Citigroup Mortgage Loan Trust, Inc. | $15,369,616 | |
Credit Suisse Mortgage Capital Certificates | $90,317,642 | |
Jefferies Resecuritization Trust | $513,679 | |
Banc of America Merrill Lynch Commercial Mortgage, Inc. | $11,687,429 | |
For Funds with fiscal period ending October 31, 2016 | ||
AMT-Free CT Intermediate Muni Bond Fund | None | N/A |
AMT-Free Intermediate Muni Bond Fund | None | N/A |
AMT-Free MA Intermediate Muni Bond Fund | None | N/A |
AMT-Free NY Intermediate Muni Bond Fund | None | N/A |
CA Tax-Exempt Fund | None | N/A |
NY Tax-Exempt Fund | None | N/A |
For Funds with fiscal period ending December 31, 2016 | ||
Real Estate Equity Fund | None | N/A |
(a) | The Fund commenced operations on October 24, 2017, and therefore has no reporting information for periods prior to such date. |
Statement of Additional Information – [____, 2018] | 180 |
Fund | Predecessor Fund | For periods prior to: | ||
Bond Fund | Excelsior Core Bond Fund, a series of Excelsior Funds, Inc. | March 31, 2008 | ||
Emerging Markets Fund | Excelsior Emerging Markets Fund, a series of Excelsior Funds, Inc. | March 31, 2008 | ||
Global Energy and Natural Resources Fund | Excelsior Energy and Natural Resources Fund, a series of Excelsior Funds, Inc. | March 31, 2008 | ||
Pacific/Asia Fund | Excelsior Pacific/Asia Fund, a series of Excelsior Funds, Inc. | March 31, 2008 | ||
Select Large Cap Growth Fund | Excelsior Large Cap Growth Fund, a series of Excelsior Funds, Inc. | March 31, 2008 |
Statement of Additional Information – [____, 2018] | 181 |
■ | For equity, alternative and flexible funds (other than the equity funds identified below) and funds-of-funds (equity and fixed income), a complete list of Fund portfolio holdings as of month-end is posted approximately, but no earlier than, 15 calendar days after such month-end. |
■ | For Columbia Small Cap Growth Fund I and Columbia Variable Portfolio – Small Company Growth Fund, a complete list of Fund portfolio holdings as of month-end is posted approximately, but no earlier than, 30 calendar days after such month-end. |
■ | For fixed-income Funds (other than money market funds), a complete list of Fund portfolio holdings as of calendar quarter-end is posted approximately, but no earlier than, 30 calendar days after such quarter-end. |
■ | For money market Funds, a complete list of Fund portfolio holdings as of month-end is posted no later than five business days after such month-end. Such month-end holdings are continuously available on the website for at least six months, together with a link to an SEC webpage where a user of the website may obtain access to the Fund’s most recent 12 months of publicly available filings on Form N-MFP. Money market Fund portfolio holdings information posted on the website, at minimum, includes with respect to each holding, the name of the issuer, the category of investment ( e.g. , Treasury debt, government agency debt, asset backed commercial paper, structured investment vehicle note), the CUSIP number (if any), the principal amount, the maturity date (as determined under Rule 2a-7 for purposes of calculating weighted average maturity), the final maturity date (if different from the maturity date previously described), coupon or yield and the value. The money market Funds will also disclose on the website its overall weighted average maturity, weighted average life maturity, percentage of daily liquid assets, percentage of weekly liquid assets and daily inflows and outflows. |
Statement of Additional Information – [____, 2018] | 182 |
Statement of Additional Information – [____, 2018] | 183 |
Statement of Additional Information – [____, 2018] | 184 |
Identity of Recipient | Conditions/restrictions on use of information |
Frequency
of
Disclosure |
||
FactSet Research Systems, Inc. | Used for provision of quantitative analytics, charting and fundamental data and for portfolio analytics. Used to cover product and marketing developments related to index funds, ETFs, index derivatives, and other sophisticated investment strategies. | Daily or Monthly | ||
Fidelity National Information Services, Inc. | Used as portfolio accounting system. | Daily | ||
Harte-Hanks | Used for printing of prospectuses, factsheets, annual and semi-annual reports. | As Needed | ||
Imagine Print Solutions | Used for commercial printing. | Daily, Monthly and Quarterly | ||
Institutional Shareholder Services Inc. (ISS) | Used for proxy voting administration and research on proxy matters. | Daily | ||
Intex Solutions Inc. | Used to provide mortgage analytics. | Periodic | ||
Investment Technology Group, Inc. | Used to evaluate and assess trading activity, execution and practices. | Quarterly | ||
Investor Tools | Used for municipal bond analytics, research and decision support. | As Needed | ||
JDP Marketing Services | Used to write or edit Columbia Fund shareholder reports, quarterly fund commentaries, and communications, including shareholder letters and management’s discussion of Columbia Fund performance. | Monthly, as needed | ||
John Roberts, Inc. | Used for commercial printing. | Daily, Monthly and Quarterly | ||
Kendall Press | Used for commercial printing. | As Needed | ||
Kynex | Used to provide portfolio attribution reports for the Columbia Convertible Securities Fund. Used also for portfolio analytics. | Daily | ||
Malaspina Communications | Used to facilitate writing management’s discussion of Columbia Fund performance for Columbia Fund shareholder reports and periodic marketing communications. | Monthly | ||
Markit | Used for an asset database for analytics and investor reporting. Used to reconcile client commission trades with broker-dealers. | As Needed and Monthly | ||
Merrill Corporation | Used for printing of prospectuses, factsheets, annual and semi-annual reports. | As Needed | ||
MoneyMate, Inc. | Used to report returns and analytics to client facing materials. | Monthly | ||
Morningstar, Inc. | Used for independent research and ranking of funds. Used also for statistical analysis. | Monthly, Quarterly or As Needed | ||
MSCI, Inc. | Used as a hosted portfolio management platform designed for research, reporting, strategy development, portfolio construction and performance and risk attribution, and used for risk analysis and reporting. | Daily |
Statement of Additional Information – [____, 2018] | 185 |
Identity of Recipient | Conditions/restrictions on use of information |
Frequency
of
Disclosure |
||
Print Craft | Used to assemble kits and mailing that include the fact sheets. | As Needed | ||
RegEd, Inc. | Used to review external and certain internal communications prior to dissemination. | Daily | ||
SEI Investments Company | Used for trading wrap accounts and to reconcile wrap accounts. | Daily | ||
SS&C Technologies, Inc. | Used to translate account positions for reconciliations. | Daily | ||
Sustainalytics US Inc. | Used to affirm and validate social scoring methodology of Columbia U.S. Social Bond Fund’s investment strategy. | Quarterly | ||
S.W.I.F.T. Scrl. | Used to send trade messages via SWIFT to custodians. | Daily | ||
Thomson Reuters | Used for statistical analysis. | Monthly | ||
Threadneedle Investments | Used by portfolio managers and research analysts in supporting certain management strategies, and by shared support partners (legal, operations, compliance, risk, etc.) to provide Fund maintenance and development. | As Needed | ||
Universal Wilde | Used to provide printing and mailing services for prospectuses, annual and semi-annual reports, and supplements. | As Needed | ||
Visions, Inc. | Used for commercial printing. | Daily, Monthly and Quarterly | ||
Wilshire Associates, Inc. | Used to provide daily performance attribution reporting based on daily holdings to the investment and investment analytics teams. | Daily | ||
Wolters Kluwer | Used to perform tax calculations specific to wash sales and used to analyze tax straddles (diminution of risk). | Monthly |
Statement of Additional Information – [____, 2018] | 186 |
Identity of Recipient | Conditions/restrictions on use of information |
Frequency
of
Disclosure |
||
Brown Brothers Harriman & Co. | Used by certain subadvisers for FX trade execution for non-US trades. Used by certain subadvisers for trade matching and SWIFT messaging. | Daily | ||
Charles River Development, Ltd. | Used by certain subadvisers for order management, for order management and compliance, and for OMS trading system and compliance. | Daily | ||
Client Service Specialists, Inc. | Used by certain subadvisers for operational and reconciliation services. | Monthly | ||
DDM Marketing & Communications | Used by certain subadvisers for marketing and reporting. | Quarterly | ||
Electra Information Systems, Inc. | Used by certain subadvisers for daily reconciliation of positions and transactions for outside custodians. Used by certain subadvisers for portfolio holdings reconciliation. Used by certain subadvisers for monthly audited client statements for market value reconciliations. | Daily | ||
Ernst & Young, LLP | Used by certain subadvisers to provide general audit services. | Semi-annually | ||
eVestment OMNI | Used by certain subadvisers for marketing and reporting. | Quarterly | ||
FactSet Research Systems, Inc. | Used by certain subadvisers for analytical and statistical information, for portfolio attribution and for portfolio and risk analytics. | Daily | ||
Fidelity ActionsXchange, Inc. | Used by certain subadvisers for corporate actions processing. | Daily | ||
Financial Recovery Technologies, LLC | Used by certain subadvisers for class action monitoring. | Quarterly | ||
Glass, Lewis & Company, LLC | Used by certain subadvisers for proxy voting services. | Daily | ||
IHS Markit, Ltd. | Used by certain subadvisers for confirming and settling bank loan trades. Used by certain subadvisers for matching Credit Default Swaps and Interest Rate Swaps. | Daily | ||
Infinit-O Global, Ltd. | Used by certain subadvisers for reconciling cash and positions. | Daily | ||
Institutional Shareholder Services Inc. | Used by certain subadvisers for proxy voting services. | Daily | ||
Investment Technology Group, Inc. | Used by certain subadvisers for transaction cost analysis. | Daily | ||
MSCI, Inc. | Used by certain subadvisers for portfolio analytics and analysis. | Daily | ||
Northern Trust Corporation | Used by certain subadvisers for settlement, accounting, reconciliation and performance. | Daily | ||
Omgeo, LLC | Used by certain subadvisers for trade settlement. Used by certain subadvisers for block trade confirmations. Used by certain subadvisers for electronically providing allocations to counterparties, and electronic trade matching and affirmation of confirms. | Daily |
Statement of Additional Information – [____, 2018] | 187 |
Identity of Recipient | Conditions/restrictions on use of information |
Frequency
of
Disclosure |
||
SS&C Technologies, Inc. | Used by certain subadvisers for SWIFT messaging and reconciliation, and for accounting. | Daily | ||
State Street Bank and Trust Company | Used by certain subadvisers for FX trading matching and SWIFT messaging. | Daily | ||
Trade Informatics, LLC | Used by certain subadvisers for equity trading transaction cost analysis. | Daily | ||
Tradeweb Markets, LLC | Used by certain subadvisers for confirmation of TBAs, Treasuries and Discount Notes. | Daily | ||
Traiana, Inc. | Used by certain subadvisers for block trade confirmation between Charles River and ISDA counterparty. | Daily | ||
TriOptima, AB | Used by certain subadvisers for back office reconciliation. Used by certain subadvisers for daily reconciliations on collateral management. | Daily | ||
William O’Neil & Co., Inc. | Used by certain subadvisers for analytical and statistical information. | Daily |
Statement of Additional Information – [____, 2018] | 188 |
■ | ADP Broker-Dealer, Inc. |
■ | American Enterprise Investment Services Inc.* |
■ | American United Life Insurance Co. |
■ | Ameriprise Financial Services, Inc.* |
■ | Ascensus, Inc. |
■ | AXA Advisors |
■ | AXA Equitable Life Insurance |
■ | Bank of America, N.A. |
■ | Benefit Plan Administrators |
■ | Benefit Trust |
■ | BMO Harris Bank (f/k/a Marshall & Illsley Trust Company) |
■ | BNY Mellon, N.A. |
■ | Charles Schwab & Co., Inc. |
■ | Charles Schwab Trust Co. |
■ | Davenport & Company |
■ | Daily Access Concepts, Inc. |
■ | Digital Retirement Solutions |
■ | Edward D. Jones & Co., LP |
■ | ExpertPlan |
■ | Fidelity Brokerage Services, Inc. |
■ | Fidelity Investments Institutional Operations Co. |
■ | First Mercantile Trust Co. |
■ | Guardian Insurance and Annuity Company Inc. |
■ | Genworth Life and Annuity Insurance Company |
■ | Genworth Life Insurance Co. of New York |
■ | Goldman Sachs & Co. |
■ | GWFS Equities, Inc. |
■ | Hartford Life Insurance Company |
■ | HD Vest |
■ | Hewitt Associates LLC |
■ | ICMA Retirement Corporation |
■ | Janney Montgomery Scott, Inc. |
■ | JJB Hilliard Lyons |
■ | JP Morgan Chase Bank |
■ | John Hancock Life Insurance Company (USA) |
Statement of Additional Information – [____, 2018] | 189 |
■ | John Hancock Life Insurance Company of New York |
■ | John Hancock Trust Company |
■ | Lincoln Life & Annuity Company of New York |
■ | Lincoln National Life Insurance Company |
■ | Lincoln Retirement Services |
■ | LPL Financial Corporation |
■ | Massachusetts Mutual Life Insurance Company |
■ | Mercer HR Services, LLC |
■ | Merrill Lynch, Pierce, Fenner & Smith Incorporated |
■ | Mid Atlantic Capital Corporation |
■ | Minnesota Life Insurance Co. |
■ | Morgan Stanley Smith Barney |
■ | MSCS Financial Services Division of Broadridge Business Process Outsourcing LLC |
■ | National Financial Services |
■ | Nationwide Investment Services |
■ | Newport Retirement Services, Inc. |
■ | New York State Deferred Compensation Plan |
■ | Oppenheimer & Co., Inc. |
■ | Plan Administrators, Inc. |
■ | PNC Bank |
■ | Principal Life Insurance Company of America |
■ | Prudential Insurance Company of America |
■ | Prudential Retirement Insurance & Annuity Company |
■ | Pershing LLC |
■ | Raymond James & Associates |
■ | RBC Capital Markets |
■ | Reliance Trust |
■ | Robert W. Baird & Co., Inc. |
■ | Sammons Retirement Solutions |
■ | SEI Private Trust Company |
■ | Standard Insurance Company |
■ | Stifel Nicolaus & Co. |
■ | TD Ameritrade Clearing, Inc. |
■ | TD Ameritrade Trust Company |
■ | The Retirement Plan Company |
■ | Teachers Insurance and Annuity Association of America |
■ | Transamerica Advisors Life Insurance Company |
■ | Transamerica Advisors Life Insurance Company of New York |
■ | Transamerica Financial Life Insurance Company |
■ | T. Rowe Price Group, Inc. |
■ | UBS Financial Services, Inc. |
■ | Unified Trust Company, N.A. |
■ | Upromise Investments, Inc. |
■ | US Bank NA |
■ | Vanguard Group, Inc. |
■ | VALIC Retirement Services Company |
■ | Voya Retirement Insurance and Annuity Company |
■ | Voya Institutional Plan Services, LLP |
■ | Voya Investments Distributors, LLC |
■ | Voya Financial Partners, LLC |
■ | Wells Fargo Clearing Services, LLC |
■ | Wells Fargo Advisors |
■ | Wells Fargo Bank, N.A. |
■ | Wilmington Trust Retirement & Institutional Services Company |
■ | Xerox HR Solutions |
* | Ameriprise Financial affiliate |
Statement of Additional Information – [____, 2018] | 190 |
■ | AIG Advisor Group |
■ | Ameriprise Financial Services, Inc.* |
■ | AXA Advisors, LLC |
■ | Bank of America, N.A. |
■ | Cetera Financial Group, Inc. |
■ | Citigroup Global Markets Inc./Citibank |
■ | Commonwealth Financial Network |
■ | J.J.B. Hilliard, W.L. Lyons, Inc. |
■ | Lincoln Financial Advisors Corp. |
■ | LPL Financial Corporation |
■ | Merrill Lynch, Pierce, Fenner & Smith Incorporated |
■ | Morgan Stanley Smith Barney |
■ | Northwestern Mutual Investment Services, LLC |
■ | Oppenheimer & Co., Inc. |
■ | PNC Investments |
■ | Raymond James & Associates, Inc. |
■ | Raymond James Financial Services, Inc. |
■ | RBC Capital Markets |
■ | UBS Financial Services Inc. |
■ | Unified Trust Company, N.A. |
■ | US Bancorp Investments, Inc. |
■ | Vanguard Marketing Corp. |
■ | Voya Financial Advisors, LLC |
■ | Wells Fargo Advisors |
■ | Wells Fargo Advisors Financial Network, LLC |
■ | Wells Fargo Clearing Services, LLC |
* | Ameriprise Financial affiliate |
Statement of Additional Information – [____, 2018] | 191 |
Statement of Additional Information – [____, 2018] | 192 |
Statement of Additional Information – [____, 2018] | 193 |
Statement of Additional Information – [____, 2018] | 194 |
Statement of Additional Information – [____, 2018] | 195 |
Statement of Additional Information – [____, 2018] | 196 |
Statement of Additional Information – [____, 2018] | 197 |
Statement of Additional Information – [____, 2018] | 198 |
Statement of Additional Information – [____, 2018] | 199 |
Statement of Additional Information – [____, 2018] | 200 |
Fund |
Total
Capital Loss Carryovers |
Amount Expiring in | Amount not Expiring | ||||
2017 | 2018 | 2019 | Short-term | Long-term | |||
For Funds with fiscal period ending January 31 | |||||||
Diversified Real Return Fund | $1,027,662 | N/A | $0 | $0 | $0 | $1,027,662 | |
For Funds with fiscal period ending March 31 | |||||||
Pacific/Asia Fund | $1,786,666 | N/A | $1,786,666 | $0 | $0 | $0 | |
For Funds with fiscal period ending April 30 | |||||||
Corporate Income Fund | $13,814,802 | N/A | $0 | $0 | $1,247,636 | $12,567,166 | |
Multi-Asset Income Fund | $3,308,467 | N/A | $0 | $0 | $3,308,467 | $0 | |
For Funds with fiscal period ending May 31 | |||||||
Alternative Beta Fund | $10,185,772 | N/A | $0 | $0 | $9,504,956 | $680,816 | |
Diversified Absolute Return Fund | $2,667,641 | N/A | $0 | $0 | $1,675,808 | $991,833 | |
HY Municipal Fund | $42,710,600 | N/A | $35,721,468 | $4,244,605 | $1,961,649 | $782,878 | |
For Funds with fiscal period ending July 31 | |||||||
AMT-Free OR Intermediate Muni Bond Fund | $947,711 | N/A | $0 | $0 | $947,711 | $0 | |
Tax-Exempt Fund | $23,446,035 | N/A | $0 | $7,286,973 | $8,117,805 | $8,041,257 | |
U.S. Social Bond Fund | $258,025 | N/A | $0 | $0 | $56,443 | $201,582 | |
Ultra Short Term Bond Fund | $24,288,560 | N/A | $1,023,617 | $11,369,928 | $4,055,173 | $7,839,842 |
Statement of Additional Information – [____, 2018] | 201 |
Fund |
Total
Capital Loss Carryovers |
Amount Expiring in | Amount not Expiring | ||||
2017 | 2018 | 2019 | Short-term | Long-term | |||
For Funds with fiscal period ending August 31 | |||||||
Emerging Markets Fund | $74,781,273 | N/A | $0 | $0 | $74,781,273 | $0 | |
Global Dividend Opportunity Fund | $17,051,810 | N/A | $0 | $0 | $17,051,810 | $0 | |
Global Energy and Natural Resources Fund | $33,763,919 | N/A | $0 | $0 | $3,003,362 | $30,760,557 | |
Greater China Fund | $1,802,252 | N/A | $0 | $0 | $1,802,252 | $0 | |
MM Alternative Strategies Fund | $45,740,767 | N/A | $0 | $0 | $10,816,699 | $34,924,068 | |
For Funds with fiscal period ending October 31 | |||||||
AMT-Free Intermediate Muni Bond Fund | $6,686,046 | $832,773 | $62,558 | $0 | $5,790,715 | $0 | |
For Funds with fiscal period ending December 31 | |||||||
Real Estate Equity Fund | $5,025,563 | $5,025,563 | $0 | $0 | $0 | $0 |
Statement of Additional Information – [____, 2018] | 202 |
Statement of Additional Information – [____, 2018] | 203 |
Statement of Additional Information – [____, 2018] | 204 |
Statement of Additional Information – [____, 2018] | 205 |
Statement of Additional Information – [____, 2018] | 206 |
Statement of Additional Information – [____, 2018] | 207 |
Statement of Additional Information – [____, 2018] | 208 |
Statement of Additional Information – [____, 2018] | 209 |
Statement of Additional Information – [____, 2018] | 210 |
Statement of Additional Information – [____, 2018] | 211 |
Statement of Additional Information – [____, 2018] | 212 |
Statement of Additional Information – [____, 2018] | 213 |
Statement of Additional Information – [____, 2018] | 214 |
Statement of Additional Information – [____, 2018] | 215 |
Fund | Class |
Percentage
of Class
Beneficially Owned |
Adaptive Risk Allocation Fund | Class Inst2 | 8.00% |
Alternative Beta Fund | Class Inst2 | 66.85% |
MM Directional Alternative Strategies Fund | Class A | 1.40% |
Multi-Asset Income Fund | Class Inst | 53.09% |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
Diversified Real Return Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class A
|
11.84% | 88.60% (a) |
Class C | 16.49% | |||
Class R4 | 100.00% | |||
Class R5 | 100.00% | |||
Class T | 100.00% | |||
Class Y | 100.00% | |||
Class Z | 99.24% | |||
LPL
FINANCIAL
9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class A
|
66.59% | N/A | |
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class A
|
7.16% | N/A | |
Class C | 83.51% | |||
WELDON
L WEBER III
6226 GEORGIA DR CORPUS CHRISTI TX 78414-3664 |
Class A
|
5.87% | N/A |
Statement of Additional Information – [____, 2018] | 216 |
Statement of Additional Information – [____, 2018] | 217 |
Statement of Additional Information – [____, 2018] | 218 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
MID
ATLANTIC TRUST COMPANY FBO
1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class R
|
10.27% | N/A | |
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class A
|
6.14% | N/A | |
Class C | 17.37% | |||
Class Z | 11.51% | |||
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class A
|
49.32% | N/A | |
Class C | 32.01% | |||
Class R4 | 33.28% | |||
Class R5 | 80.48% | |||
Class Y | 5.31% | |||
NATIONWIDE
TRUST COMPANY/FSB
C/O IPO PORTFOLIO ACCOUNTING PO BOX 182029 COLUMBUS OH 43218-2029 |
Class R5
|
8.67% | N/A | |
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class R4
|
33.64% | N/A | |
RELIANCE
TRUST CO CUST
FBO PO BOX 48529 ATLANTA GA 30362-1529 |
Class R
|
19.81% | N/A | |
UBS
WM USA
SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class C
|
5.38% | N/A | |
VANGUARD
FDUCIARY TRUST CO
PO BOX 2600 VM 613 ATTN: OUTSIDE FUNDS VALLEY FORGE PA 19482-2600 |
Class R4
|
15.76% | N/A | |
WELLS
FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C
|
6.17% | N/A | |
Class Z | 5.07% |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
Bond Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A
|
13.64% | N/A |
Class C | 23.89% | |||
ASCENSUS
TRUST COMPANY FBO
PO BOX 10758 FARGO ND 58106-0758 |
Class A
|
6.05% | N/A | |
Class C | 22.76% | |||
Class R | 61.36% | |||
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class B
|
100.00% | N/A (a) | |
Class T | 100.00% | |||
LPL
FINANCIAL
9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class A
|
7.75% | N/A | |
Class C | 5.10% | |||
MERRILL
LYNCH, PIERCE, FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A
|
29.64% | 74.74% | |
Class C | 6.76% | |||
Class V | 21.37% | |||
Class Y | 99.27% | |||
Class Z | 82.87% |
Statement of Additional Information – [____, 2018] | 219 |
Statement of Additional Information – [____, 2018] | 220 |
Statement of Additional Information – [____, 2018] | 221 |
Statement of Additional Information – [____, 2018] | 222 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
CAPITAL
BANK & TRUST CO TRUSTEE FBO
C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R
|
83.16% | N/A | |
CHARLES
SCHWAB & CO INC
SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A
|
6.62% | N/A | |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class B
|
100.00% | N/A (a) | |
FIIOC
FBO
100 MAGELLAN WAY (KW1C) COVINGTON KY 41015-1987 |
Class R5
|
5.06% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA INCOME BUILDER FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class Y
|
92.09% | N/A | |
LINCOLN
RETIREMENT SERVICES CO
FBO PO BOX 7876 FORT WAYNE IN 46801-7876 |
Class Z
|
7.90% | N/A | |
LPL
FINANCIAL
9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C
|
7.31% | N/A | |
MATRIX
TRUST COMPANY CUST FBO
717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class R
|
6.53% | N/A | |
Class R5 | 12.76% | |||
MERRILL
LYNCH, PIERCE, FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A
|
6.69% | N/A | |
Class Z | 42.57% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class C
|
15.77% | N/A | |
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class A
|
8.48% | N/A | |
Class C | 8.56% | |||
Class R4 | 43.26% | |||
Class R5 | 32.97% | |||
Class Z | 9.90% | |||
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class A
|
5.35% | N/A | |
Class C | 11.07% | |||
Class R4 | 47.02% | |||
PIMS/PRUDENTIAL
RETIREMENT
AS NOMINEE P O BOX 1979 835 N RUSH ST CHICAGO IL 60611-2030 |
Class Y
|
5.58% | N/A | |
RAYMOND
JAMES
FBO OMNIBUS FOR MUTUAL FUNDS HOUSE ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C
|
7.83% | N/A |
Statement of Additional Information – [____, 2018] | 223 |
Statement of Additional Information – [____, 2018] | 224 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
MATRIX
TRUST COMPANY CUST FBO
717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class R
|
20.60% | N/A | |
MERRILL
LYNCH, PIERCE, FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class C
|
5.46% | N/A | |
Class R | 11.91% | |||
Class Z | 37.07% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class C
|
21.75% | N/A | |
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class R
|
9.04% | N/A | |
Class R4 | 11.32% | |||
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class C
|
6.37% | N/A | |
Class R4 | 15.70% | |||
Class R5 | 32.75% | |||
RELIANCE
TRUST COMPANY FBO
PO BOX 28004 ATLANTA GA 30358-0004 |
Class R5
|
6.99% | N/A | |
WELLS
FARGO BANK FBO
1525 W W T HARRIS BLVD CHARLOTTE NC 28262-8522 |
Class K
|
98.37% | N/A | |
Class R5 | 16.38% | |||
U.S. Treasury Index Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A
|
6.75% | N/A |
Class C | 31.34% | |||
Class T | 99.19% | |||
Class Z | 8.22% | |||
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class B
|
100.00% | 53.82% (a) | |
COLUMBIA
THERMOSTAT FUND
ATTN STEVEN SWINHART 225 FRANKLIN ST FL 25 BOSTON MA 02110-2888 |
Class Y
|
32.11% | N/A | |
EDWARD
D JONES & CO
FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3729 |
Class C
|
6.20% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION CONSERVATIVE PORTFOLIO 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class Y
|
12.75% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION MODERATE AGGRESSIVE PORTFOLIO 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class Y
|
6.87% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION MODERATE CONSERVATIVE PORTFOLIO 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class Y
|
22.98% | N/A |
Statement of Additional Information – [____, 2018] | 225 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
Adaptive Risk Allocation Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A
|
65.94% | 89.76% |
Class C | 67.85% | |||
Class T | 99.83% | |||
Class Z | 93.69% | |||
CHARLES
SCHWAB & CO INC
CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class R4
|
29.57% | N/A | |
Class R5 | 25.01% |
Statement of Additional Information – [____, 2018] | 226 |
Statement of Additional Information – [____, 2018] | 227 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION MODERATE PORTFOLIO 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class Y
|
19.99% | N/A | |
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class C
|
7.63% | N/A | |
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class R4
|
95.48% | N/A | |
TD
AMERITRADE INC FOR THE
EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class R5
|
20.59% | N/A | |
Diversified Absolute Return Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A
|
89.09% | N/A |
Class T | 88.85% | |||
Class Z | 22.45% | |||
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class A
|
9.88% | 97.56% (a) | |
Class C | 70.11% | |||
Class R4 | 100.00% | |||
Class R5 | 100.00% | |||
Class T | 11.15% | |||
DONNA
C KNIGHT & JEFFREY L KNIGHT
TTEES DONNA C KNIGHT LIVING TRUST 15 SYLVAN LN WESTON MA 02493-1027 |
Class Z
|
39.59% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION AGGRESSIVE PORTFOLIO 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class Y
|
8.98% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION CONSERVATIVE PORTFOLIO 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class Y
|
5.09% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION MODERATE AGGRESSIVE PORTFOLIO 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class Y
|
32.01% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION MODERATE CONSERVATIVE PORTFOLIO 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class Y
|
11.76% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION MODERATE PORTFOLIO 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class Y
|
26.66% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA GLOBAL OPPORTUNITIES FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class Y
|
13.95% | N/A | |
LPL
FINANCIAL
9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Z
|
36.21% | N/A |
Statement of Additional Information – [____, 2018] | 228 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
STATE
STREET BK & TR IRA
JUSTIN D PITTMAN 1623 EUCLID AVE JOPLIN MO 64801-1308 |
Class C
|
29.89% | N/A | |
Dividend Income Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A
|
14.58% | N/A |
Class C | 16.42% | |||
Class T | 95.15% | |||
Class Z | 18.69% | |||
CHARLES
SCHWAB & CO INC
CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A
|
7.07% | N/A | |
Class R5 | 21.64% | |||
Class V | 8.17% | |||
Class Z | 7.88% | |||
DCGT
AS TTEE AND /OR CUST
FBO PLIC VARIOUS RETIREMENT PLANS OMNIBUS ATTN NPIO TRADE DESK 711 HIGH ST DES MOINES IA 50392-0001 |
Class R
|
6.34% | N/A | |
EQUITABLE
LIFE FOR SA NO65
ON BEHALF OF VARIOUS 401K EXPEDITER PLANS 1290 AVENUE OF THE AMERICAS NEW YORK NY 10104-0101 |
Class R
|
54.02% | N/A | |
GREAT
WEST TRUST CO
FBO RETIREMENT PLANS 8515 E ORCHARD RD 2T2 GREENWOOD VLG CO 80111-5002 |
Class R4
|
6.98% | N/A | |
LPL
FINANCIAL
9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C
|
5.30% | N/A | |
Class Z | 5.21% | |||
MERRILL
LYNCH PIERCE FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A
|
9.86% | N/A | |
Class C | 12.62% | |||
Class R | 10.34% | |||
Class R4 | 6.12% | |||
Class V | 17.40% | |||
Class Y | 73.28% | |||
Class Z | 7.46% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class C
|
11.73% | N/A | |
Class Z | 5.09% | |||
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class A
|
20.65% | N/A | |
Class C | 8.47% | |||
Class R4 | 40.58% | |||
Class R5 | 21.23% | |||
Class Y | 9.23% | |||
Class Z | 16.76% | |||
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class A
|
5.58% | N/A | |
Class C | 7.19% | |||
Class R4 | 22.92% | |||
PIMS/PRUDENTIAL
RETIREMENT
AS NOMINEE FOR THE TTEE/CUST ROBERT WOOD JOHNSON HOSPITAL 379 CAMPUS DRIVE SOMERSET NJ 08873-1161 |
Class R5
|
6.74% | N/A |
Statement of Additional Information – [____, 2018] | 229 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
RAYMOND
JAMES
FBO OMNIBUS FOR MUTUAL FUNDS HOUSE ACCT FIRM ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C
|
9.99% | N/A | |
Class Z | 15.30% | |||
RELIANCE
TRUST CO CUST
FBO MASSMUTUAL OMNIBUS PO BOX 48529 ATLANTA GA 30362-1529 |
Class R5
|
12.60% | N/A | |
TD
AMERITRADE INC FOR THE
EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class R5
|
7.02% | N/A | |
UBS
WM USA
SPEC CDY A/C EXCL BEN CUST 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class C
|
6.81% | N/A | |
WELLS
FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C
|
11.27% | N/A | |
HY Municipal Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A
|
28.06% | N/A |
Class C | 24.68% | |||
Class Z | 7.40% | |||
CHARLES
SCHWAB & CO INC
CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A
|
6.31% | N/A | |
Class R5 | 17.18% | |||
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class Y
|
43.18% | N/A (a) | |
MERRILL
LYNCH PIERCE FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A
|
8.59% | 48.02% | |
Class C | 6.72% | |||
Class Z | 61.31% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class A
|
14.76% | N/A | |
Class C | 12.36% | |||
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class A
|
6.43% | N/A | |
Class R4 | 47.76% | |||
Class R5 | 35.38% | |||
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class R4
|
51.34% | N/A | |
Class R5 | 45.58% | |||
Class Y | 56.74% | |||
RAYMOND
JAMES
FBO OMNIBUS FOR MUTUAL FUNDS HOUSE ACCT FIRM ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class A
|
9.49% | N/A | |
Class C | 18.59% |
Statement of Additional Information – [____, 2018] | 230 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
UBS
WM USA
SPEC CDY A/C EXCL BEN CUST 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class C
|
6.76% | N/A | |
WELLS
FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A
|
6.53% | N/A | |
Class C | 18.50% |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
AMT-Free OR Intermediate Muni Bond Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 8.10% | N/A |
Class C | 17.44% | |||
CHARLES
SCHWAB & CO INC
SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 10.69% | N/A | |
Class Inst2 | 70.69% | |||
Class Inst | 14.22% | |||
EDWARD
D JONES & CO
FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3729 |
Class A | 36.98% | N/A | |
Class C | 10.80% | |||
Class Inst3 | 99.66% | |||
MERRILL
LYNCH PIERCE FENNER &
SMITH INC FOR THE SOLE BENEFIT OF IT S CUSTOM 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class C | 7.62% | N/A | |
Class Inst | 8.55% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class C | 18.75% | N/A | |
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class A | 6.83% | N/A | |
Class Adv | 11.16% | |||
Class Inst2 | 5.73% | |||
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 87.25% | N/A | |
RAYMOND
JAMES
FBO OMNIBUS FOR MUTUAL FUNDS HOUSE ACCT FIRM ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class A | 6.23% | N/A | |
TD
AMERITRADE INC FOR THE
EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 23.44% | N/A | |
UBS
WM USA
SPEC CDY A/C EXCL BEN 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class A | 7.27% | N/A | |
WELLS
FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 12.78% | N/A | |
Class C | 29.49% |
Statement of Additional Information – [____, 2018] | 231 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
Large Cap Growth Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 63.58% | 37.84% |
Class C | 35.32% | |||
Class T | 99.67% | |||
Class Inst | 13.72% | |||
CHARLES
SCHWAB & CO INC
SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class K | 84.10% | N/A | |
Class Adv | 7.00% | |||
Class Inst2 | 81.98% | |||
Class Inst | 8.12% | |||
FIIOC
FBO
100 MAGELLAN WAY #KW1C COVINGTON KY 41015-1987 |
Class Inst2 | 5.97% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 5.13% | N/A (a) | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION MODERATE AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 15.47% | N/A (a) | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION MODERATE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 5.54% | N/A (a) | |
JPMCB
NA CUST FOR
COLUMBIA GLOBAL STRATEGIC EQUITY PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 5.70% | N/A (a) | |
MERRILL
LYNCH PIERCE FENNER &
SMITH INC FOR THE SOLE BENEFIT OF IT S CUSTOM 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class C | 6.26% | N/A | |
Class R | 84.28% | |||
Class Adv | 10.86% | |||
Class V | 24.37% | |||
Class Inst3 | 55.09% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class C | 6.64% | N/A | |
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class Adv | 56.93% | N/A | |
Class Inst | 7.58% | |||
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 7.68% | N/A | |
STATE
STREET BANK AND TRUST AS
TRUSTEE AND/OR CUSTODIAN FBO 1 LINCOLN ST BOSTON MA 02111-2901 |
Class Adv | 8.92% | N/A | |
UBS
WM USA
SPEC CDY A/C EXCL BEN 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class C | 8.60% | N/A | |
WELLS
FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 7.33% | N/A | |
Class K | 11.01% |
Statement of Additional Information – [____, 2018] | 232 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
Tax-Exempt Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 47.82% | 39.90% |
Class C | 45.04% | |||
Class Inst | 11.76% | |||
CATHAY
LIFE INSURANCE CO LTD
296 JEN-AI ROAD SEC. 4 TAIPEI, 106 TAIWAN R.O.C |
Class Inst | 15.19% | N/A | |
CHARLES
SCHWAB & CO INC
SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 26.88% | N/A | |
EDWARD
D JONES & CO
FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3729 |
Class A | 11.92% | N/A | |
Class Inst3 | 98.11% | |||
MERRILL
LYNCH PIERCE FENNER &
SMITH INC FOR THE SOLE BENEFIT OF IT S CUSTOM 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class C | 8.35% | N/A | |
Class Inst | 39.02% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class C | 6.60% | N/A | |
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class Adv | 46.20% | N/A | |
Class Inst2 | 22.30% | |||
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 50.42% | N/A | |
Class Inst2 | 30.79% | |||
RAYMOND
JAMES
FBO OMNIBUS FOR MUTUAL FUNDS HOUSE ACCT FIRM ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 7.46% | N/A | |
TD
AMERITRADE INC FOR THE
EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 19.59% | N/A | |
WELLS
FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 5.28% | N/A | |
Class C | 9.07% | |||
U.S. Social Bond Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 23.75% | N/A |
Class C | 46.93% | |||
Class Inst | 14.96% | |||
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class Adv | 100.00% | 54.89% (a) | |
Class Inst | 68.28% | |||
EDWARD
D JONES & CO
FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3729 |
Class C | 8.71% | N/A | |
Class Inst3 | 98.15% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class A | 45.10% | N/A | |
Class C | 19.58% |
Statement of Additional Information – [____, 2018] | 233 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
Balanced Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE MINNEAPOLIS MN 55402-2405 |
Class A | 47.92% | 36.64% |
Class C | 44.53% | |||
Class Inst | 33.88% | |||
CHARLES
SCHWAB & CO INC
SPECIAL CUSTODY ACCT FBO CUSTOMERS ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 6.79% | N/A | |
Class Inst2 | 12.26% | |||
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class T | 100.00% | N/A (a) | |
EDWARD
D JONES & CO
FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3729 |
Class Inst3 | 19.95% | N/A | |
FIIOC
FBO
100 MAGELLAN WAY (KW1C) COVINGTON KY 41015-1987 |
Class R | 5.60% | N/A | |
GREAT-WEST
TRUST COMPANY LLC TTEE F
EMPLOYEE BENEFITS CLIENTS 401K 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class K | 32.75% | N/A | |
LPL
FINANCIAL
9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Inst | 5.71% | N/A |
Statement of Additional Information – [____, 2018] | 234 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
MERRILL
LYNCH PIERCE FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class C | 5.42% | N/A | |
Class Inst | 15.36% | |||
Class Inst3 | 9.57% | |||
Class R | 30.61% | |||
MID
ATLANTIC TRUST COMPANY FBO
1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class Inst3 | 14.67% | N/A | |
Class R | 5.80% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class C | 8.03% | N/A | |
Class Inst | 7.59% | |||
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class A | 14.85% | N/A | |
Class Adv | 58.54% | |||
Class Inst2 | 39.36% | |||
Class Inst3 | 9.85% | |||
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 29.52% | N/A | |
Class C | 6.56% | |||
Class Inst2 | 8.53% | |||
RAYMOND
JAMES
FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 7.70% | N/A | |
Class Inst | 7.85% | |||
RELIANCE
TRUST COMPANY FBO
PO BOX 48529 ATLANTA GA 30362-1529 |
Class Inst3 | 11.48% | N/A | |
STATE
STREET BANK
FBO 1 LINCOLN ST BOSTON MA 02111-2901 |
Class Inst3 | 9.07% | N/A | |
Class R | 36.81% | |||
TD
AMERITRADE INC FOR THE
EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 13.13% | N/A | |
WELLS
FARGO BANK FBO
1525 W W T HARRIS BLVD CHARLOTTE NC 28262-8522 |
Class Inst2 | 11.39% | N/A | |
Class K | 66.44% | |||
WELLS
FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 13.70% | N/A | |
Class Inst | 7.84% | |||
Contrarian Core Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE MINNEAPOLIS MN 55402-2405 |
Class A | 43.31% | N/A |
Class C | 28.61% | |||
Class Inst | 18.61% | |||
Class T | 99.67% | |||
CHARLES
SCHWAB & CO INC
SPECIAL CUSTODY ACCT FBO CUSTOMERS ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst | 11.42% | N/A | |
Class Inst2 | 14.67% | |||
EDWARD
D JONES & CO
FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3729 |
Class Inst3 | 13.45% | N/A | |
JOHN
HANCOCK TRUST COMPANY LLC
690 CANTON ST STE 100 WESTWOOD MA 02090-2324 |
Class K | 97.58% | N/A |
Statement of Additional Information – [____, 2018] | 235 |
Statement of Additional Information – [____, 2018] | 236 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
Disciplined Small Core Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE MINNEAPOLIS MN 55402-2405 |
Class A | 18.07% | N/A |
Class C | 19.03% | |||
Class Inst | 12.38% | |||
Class T | 99.21% | |||
ASCENSUS
TRUST COMPANY FBO
PO BOX 10758 FARGO ND 58106-0758 |
Class Adv | 42.68% | N/A | |
Class Inst2 | 29.57% | |||
CHARLES
SCHWAB & CO INC
SPECIAL CUSTODY ACCT FBO CUSTOMERS ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst | 5.47% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 21.95% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION MODERATE AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 20.89% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION MODERATE CONSERVATIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 11.25% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION MODERATE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 41.49% | N/A | |
MATRIX
TRUST COMPANY FBO
PO BOX 52129 PHOENIX AZ 85072-2129 |
Class Inst | 15.94% | N/A | |
MERRILL
LYNCH PIERCE FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A | 20.43% | N/A | |
Class C | 11.42% | |||
Class Inst | 29.96% | |||
Class V | 26.83% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class C | 7.17% | N/A | |
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class A | 10.46% | N/A | |
Class Adv | 28.65% | |||
Class C | 10.97% | |||
Class Inst | 8.95% | |||
Class Inst2 | 6.90% | |||
Class V | 6.04% | |||
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class A | 6.44% | N/A | |
Class Adv | 23.68% | |||
Class C | 10.98% | |||
Class Inst2 | 44.90% | |||
TD
AMERITRADE INC FOR THE
EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 14.08% | N/A |
Statement of Additional Information – [____, 2018] | 237 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
UBS
WM USA
SPEC CDY A/C EXCL BEN CUST 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class Inst | 5.49% | N/A | |
WELLS
FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 19.09% | N/A | |
Emerging Markets Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE MINNEAPOLIS MN 55402-2405 |
Class A | 71.40% | N/A |
Class C | 42.73% | |||
Class Inst | 25.66% | |||
Class T | 98.38% | |||
ASCENSUS
TRUST COMPANY FBO
PO BOX 10758 FARGO ND 58106-0758 |
Class Inst2 | 16.51% | N/A | |
CHARLES
SCHWAB & CO INC
SPECIAL CUSTODY ACCT FBO CUSTOMERS ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Adv | 67.63% | N/A | |
Class Inst | 22.66% | |||
COMERICA
BANK FBO CALHOUN
PO BOX 75000 MSC 3446 DETROIT MI 48275-0001 |
Class Inst | 20.44% | N/A | |
JOHN
RITUCCI TTEE FBO
TRI STATE TRUCK CENTER 401K C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 5.66% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 7.03% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION MODERATE AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 15.02% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION MODERATE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 6.01% | N/A | |
MERRILL
LYNCH PIERCE FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class Adv | 12.59% | 32.48% | |
Class Inst | 6.32% | |||
Class Inst3 | 60.29% | |||
Class R | 65.56% | |||
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class Adv | 11.65% | N/A | |
Class Inst2 | 66.78% | |||
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class C | 5.34% | N/A | |
Class Inst2 | 5.49% | |||
Class K | 42.90% |
Statement of Additional Information – [____, 2018] | 238 |
Statement of Additional Information – [____, 2018] | 239 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
STATE
STREET BANK
FBO 1 LINCOLN ST BOSTON MA 02111-2901 |
Class Adv | 10.78% | N/A | |
TD
AMERITRADE INC FOR THE
EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 69.53% | N/A | |
UBS
WM USA
SPEC CDY A/C EXCL BEN CUST 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class C | 12.96% | N/A | |
WELLS
FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 5.68% | N/A | |
Global Energy and Natural Resources Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE MINNEAPOLIS MN 55402-2405 |
Class A | 65.46% | 28.23% |
Class C | 29.05% | |||
Class Inst | 10.59% | |||
ASCENSUS
TRUST COMPANY FBO
PO BOX 10758 FARGO ND 58106-0758 |
Class Inst2 | 15.08% | N/A | |
CAPITAL
BANK & TRUST COMPANY TTEE F
8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 6.38% | N/A | |
CHARLES
SCHWAB & CO INC
SPECIAL CUSTODY ACCT FBO CUSTOMERS ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst | 32.02% | N/A | |
Class Inst2 | 18.69% | |||
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class K | 41.33% | N/A (a) | |
HARTFORD
LIFE INS. CO.
SEPARATE ACCOUNT ATTN UIT OPERATIONS PO BOX 2999 HARTFORD CT 06104-2999 |
Class R | 14.22% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA GLOBAL STRATEGIC EQUITY PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 95.73% | N/A | |
MASSACHUSETTS
MUTUAL LIFE INS CO
1295 STATE ST MIP M200-INVST SPRINGFIELD MA 01111-0001 |
Class R | 34.77% | N/A | |
MERRILL
LYNCH PIERCE FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class Adv | 9.01% | N/A | |
Class C | 6.77% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class C | 8.53% | N/A | |
Class Inst | 5.98% |
Statement of Additional Information – [____, 2018] | 240 |
Statement of Additional Information – [____, 2018] | 241 |
Statement of Additional Information – [____, 2018] | 242 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
MERRILL
LYNCH PIERCE FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A | 11.09% | N/A | |
Class Inst | 8.20% | |||
Class Inst3 | 88.01% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class A | 6.71% | N/A | |
Class C | 15.51% | |||
Class Inst | 11.74% | |||
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class A | 12.46% | N/A | |
Class Adv | 12.57% | |||
Class C | 16.31% | |||
Class Inst | 15.08% | |||
Class Inst2 | 8.05% | |||
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class A | 5.67% | N/A | |
Class Adv | 81.99% | |||
Class C | 10.01% | |||
Class Inst2 | 63.81% | |||
RBC
CAPITAL MARKETS, LLC
MUTUAL FUND OMNIBUS PROCESSING OMNIBUS ATTN MUTUAL FUND OPS MANAGER 510 MARQUETTE AVE S MINNEAPOLIS MN 55402-1110 |
Class Inst | 10.07% | N/A | |
UBS
WM USA
SPEC CDY A/C EXCL BEN CUST 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class C | 5.13% | N/A | |
Class Inst | 6.48% | |||
WELLS
FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 9.20% | N/A | |
Class C | 20.40% | |||
Class Inst | 8.89% | |||
Mid Cap Growth Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE MINNEAPOLIS MN 55402-2405 |
Class A | 66.04% | 31.46% |
Class C | 22.41% | |||
Class T | 98.30% | |||
ASCENSUS
TRUST COMPANY FBO
PO BOX 10758 FARGO ND 58106-0758 |
Class R | 7.89% | N/A | |
CAPITAL
BANK & TRUST COMPANY TTEE F
8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class Inst2 | 18.35% | N/A | |
CHARLES
SCHWAB & CO INC
SPECIAL CUSTODY ACCT FBO CUSTOMERS ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class C | 5.25% | N/A | |
Class Inst | 11.37% | |||
CHRISTOPHER
J. HUYCK, MD FBO
ARTHRITIS CARE PC 401(K) PROFIT SHARING PLAN & TRUST 2414 15TH ST TROY NY 12180-1701 |
Class K | 8.67% | N/A | |
COUNSEL
TRUST DBA MATC FBO
EAGLE METALCRAFT INC 401K PSP & TRUST 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class K | 22.92% | N/A |
Statement of Additional Information – [____, 2018] | 243 |
Statement of Additional Information – [____, 2018] | 244 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
MM Total Return Bond Strategies Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE MINNEAPOLIS MN 55402-2405 |
Class A | 99.95% | 100.00% |
Class Inst | 100.00% | |||
Small Cap Growth Fund I |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE MINNEAPOLIS MN 55402-2405 |
Class A | 19.79% | N/A |
Class C | 14.56% | |||
ASCENSUS
TRUST COMPANY FBO
PO BOX 10758 FARGO ND 58106-0758 |
Class R | 5.80% | N/A | |
BAND
& CO C/O US BANK NA
1555 N RIVERCENTER DR STE 302 MILWAUKEE WI 53212-3958 |
Class Inst | 5.28% | N/A | |
CHARLES
SCHWAB & CO INC
SPECIAL CUSTODY ACCT FBO CUSTOMERS ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst | 14.35% | N/A | |
DCGT
AS TTEE AND/OR CUST
FBO PLIC VARIOUS RETIREMENT PLANS OMNIBUS ATTN NPIO TRADE DESK 711 HIGH ST DES MOINES IA 50392-0001 |
Class R | 6.41% | N/A | |
HEI
HOSPITALITY LLC
FBO EXEC EXCESS OF HEI HOSPITALITY ATTN ERNIE FREEDMAN 101 MERRITT 7 STE 1 NORWALK CT 06851-1060 |
Class R | 12.08% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 6.43% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA CAPITAL ALLOCATION MODERATE AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 18.16% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA GLOBAL STRATEGIC EQUITY PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 43.27% | N/A | |
MERRILL
LYNCH PIERCE FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A | 13.66% | N/A | |
Class R | 6.34% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class C | 7.41% | N/A | |
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class A | 6.02% | N/A | |
Class Adv | 79.97% | |||
Class C | 7.78% | |||
Class Inst | 5.69% | |||
Class Inst3 | 5.87% | |||
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 18.65% | N/A | |
Class C | 6.28% | |||
Class K | 85.16% |
Statement of Additional Information – [____, 2018] | 245 |
Statement of Additional Information – [____, 2018] | 246 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
MERRILL
LYNCH PIERCE FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A | 5.66% | N/A | |
Class C | 6.71% | |||
Class Inst | 10.03% | |||
Class Inst3 | 51.45% | |||
Class R | 23.61% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class C | 11.59% | N/A | |
Class Inst | 11.69% | |||
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class A | 6.96% | N/A | |
Class Adv | 37.98% | |||
Class Inst2 | 22.88% | |||
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class A | 5.08% | N/A | |
Class Adv | 57.45% | |||
Class C | 5.46% | |||
Class Inst2 | 16.61% | |||
Class K | 88.30% | |||
Class R | 5.44% | |||
RAYMOND
JAMES
FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 7.87% | N/A | |
Class Inst | 5.81% | |||
UBS
WM USA
SPEC CDY A/C EXCL BEN CUST 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class C | 5.60% | N/A | |
Class Inst | 9.10% | |||
WELLS
FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 11.73% | N/A | |
Class Inst | 7.46% |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
AMT-Free CT Intermediate Muni Bond Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A
|
30.50% | N/A |
Class C | 15.87% | |||
CHARLES
SCHWAB & CO INC
SPECIAL CUSTODY ACCT FBO CUSTOMERS ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A
|
9.71% | N/A | |
Class C | 10.21% | |||
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class B
|
100.00% | N/A (a) | |
KELLY
F SHACKELFORD
PO BOX 672 NEW CANAAN CT 06840-0672 |
Class V
|
14.77% | N/A | |
LPL
FINANCIAL
9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C
|
11.90% | N/A |
Statement of Additional Information – [____, 2018] | 247 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
MERRILL
LYNCH, PIERCE, FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DRIVE EAST 3RD FLOOR JACKSONVILLE FL 32246-6484 |
Class A
|
17.58% | 79.27% | |
Class C | 12.85% | |||
Class V | 17.15% | |||
Class Z | 93.17% | |||
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class A
|
8.51% | N/A | |
Class R4 | 35.47% | |||
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class A
|
10.35% | N/A | |
Class R4 | 62.94% | |||
RBC
CAPITAL MARKETS, LLC
MUTUAL FUND OMNIBUS PROCESSING OMNIBUS ATTN MUTUAL FUND OPS MANAGER 510 MARQUETTE AVE S MINNEAPOLIS MN 55402-1110 |
Class C
|
5.44% | N/A | |
UBS
WM USA
SPEC CDY A/C EXCL BEN CUST 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class C
|
5.56% | N/A | |
WELLS
FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A
|
6.55% | N/A | |
Class C | 24.32% | |||
AMT-Free Intermediate Muni Bond Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A
|
59.40% | N/A |
Class B | 40.46% | |||
Class C | 31.40% | |||
CHARLES
SCHWAB & CO INC
SPECIAL CUSTODY ACCT FBO CUSTOMERS ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class R5
|
19.22% | N/A | |
Class V | 6.28% | |||
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class B
|
9.43% | N/A (a) | |
JOHN
J ALMEIDA TR
JOHN J ALMEIDA REVOCABLE TRUST U/A DATED MAY 15 1997 27 TOPMAST CT JAMESTOWN RI 02835-2227 |
Class V
|
7.47% | N/A | |
MERRILL
LYNCH, PIERCE, FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DRIVE EAST 3RD FLOOR JACKSONVILLE FL 32246-6484 |
Class A
|
10.24% | 76.75% | |
Class B | 45.21% | |||
Class C | 22.39% | |||
Class V | 10.33% | |||
Class Z | 88.56% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class C
|
8.95% | N/A | |
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class R5
|
32.64% | N/A |
Statement of Additional Information – [____, 2018] | 248 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class R4
|
94.58% | N/A | |
Class R5 | 15.80% | |||
TD
AMERITRADE INC FOR THE
EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class R5
|
31.94% | N/A | |
UBS
WM USA
SPEC CDY A/C EXCL BEN CUST 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class C
|
5.13% | N/A | |
WELLS
FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A
|
5.18% | N/A | |
Class C | 12.88% | |||
AMT-Free MA Intermediate Muni Bond Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A
|
40.83% | N/A |
Class C | 30.30% | |||
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class B
|
99.82% | N/A (a) | |
Class R5 | 100.00% | |||
MERRILL
LYNCH, PIERCE, FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DRIVE EAST 3RD FLOOR JACKSONVILLE FL 32246-6484 |
Class A
|
10.48% | 77.55% | |
Class C | 13.50% | |||
Class V | 45.12% | |||
Class Z | 92.54% | |||
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class A
|
8.30% | N/A | |
Class C | 11.85% | |||
Class R4 | 83.73% | |||
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class R4
|
15.76% | N/A | |
RAYMOND
JAMES
FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class A
|
19.50% | N/A | |
Class C | 13.48% | |||
UBS
WM USA
SPEC CDY A/C EXCL BEN CUST 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class A
|
6.86% | N/A | |
Class C | 5.10% | |||
WELLS
FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C
|
14.19% | N/A | |
AMT-Free NY Intermediate Muni Bond Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A
|
49.20% | N/A |
Class C | 5.16% | |||
CHARLES
SCHWAB & CO INC
SPECIAL CUSTODY ACCT FBO CUSTOMERS ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A
|
6.94% | N/A |
Statement of Additional Information – [____, 2018] | 249 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class B
|
41.71% | N/A (a) | |
Class R5 | 5.67% | |||
MERRILL
LYNCH, PIERCE, FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DRIVE EAST 3RD FLOOR JACKSONVILLE FL 32246-6484 |
Class A
|
7.20% | 69.87% | |
Class C | 36.77% | |||
Class V | 24.16% | |||
Class Z | 81.65% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class A
|
5.04% | N/A | |
Class C | 16.07% | |||
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class A
|
5.32% | N/A | |
Class R4 | 83.13% | |||
Class R5 | 94.09% | |||
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class A
|
7.98% | N/A | |
Class B | 58.04% | |||
Class C | 7.29% | |||
Class R4 | 16.06% | |||
UBS
WM USA
SPEC CDY A/C EXCL BEN CUST 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class C
|
7.78% | N/A | |
WELLS
FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A
|
7.57% | N/A | |
Class C | 10.06% | |||
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 46.73% (a) | |
CA Tax-Exempt Fund |
AMERICAN
ENTERPRISE INVESTMENT SVC
707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A
|
36.12% | 26.60% |
Class C | 18.66% | |||
CHARLES
SCHWAB & CO INC
SPECIAL CUSTODY ACCT FBO CUSTOMERS ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A
|
5.50% | N/A | |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class B
|
8.99% | N/A (a) | |
LPL
FINANCIAL
9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Z
|
10.47% | N/A | |
MERRILL
LYNCH, PIERCE, FENNER
& SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DRIVE EAST 3RD FLOOR JACKSONVILLE FL 32246-6484 |
Class A
|
10.69% | N/A | |
Class B | 23.25% | |||
Class C | 35.48% | |||
Class Z | 65.64% | |||
MORGAN
STANLEY SMITH BARNEY
HARBORSIDE FINANCIAL CENTER PLAZA 2, 3RD FLOOR JERSEY CITY NJ 07311 |
Class A
|
5.43% | N/A | |
Class B | 15.73% | |||
Class C | 10.39% |
Statement of Additional Information – [____, 2018] | 250 |
Statement of Additional Information – [____, 2018] | 251 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
WELLS
FARGO CLEARING SERVICES LLC
SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A
|
6.05% | N/A | |
Class C | 13.00% | |||
Class Z | 6.33% |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
Real Estate Equity Fund |
AMERICAN
ENTERPRISE INVESTMENT SVCS
PO BOX 9446 MINNEAPOLIS MN 55440-9446 |
Class A
|
70.00% | N/A |
Class B | 62.97% | |||
Class C | 26.55% | |||
Class T | 83.78% | |||
CAPITAL
BANK & TRUST COMPANY TTEE
8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R
|
30.06% | N/A | |
CHARLES
SCHWAB & CO INC
CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class C
|
9.13% | N/A | |
Class K | 62.12% | |||
Class Z | 21.18% | |||
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class K
|
6.61% | 25.14% (a) | |
Class T | 16.22% | |||
FIRST
CLEARING LLC
2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class B
|
14.46% | N/A | |
Class C | 9.39% | |||
Class K | 31.27% | |||
JPMCB
NA CUST FOR
COLUMBIA ADAPTIVE RISK ALLOCATION 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class Y
|
90.00% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA INCOME BUILDER FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class Y
|
10.00% | N/A | |
MAC
& CO
ATTN: MUTUAL FUND OPS 500 GRANT STREET PITTSBURGH PA 15219-2502 |
Class R5
|
63.82% | N/A | |
MERRILL
LYNCH PIERCE FENNER & SMITH
FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTN FUND ADMINISTRATION 4800 DEER LAKE DR E FL 2 JACKSONVILLE FL 32246-6484 |
Class C
|
7.42% | N/A | |
Class R | 37.70% | |||
Class Z | 34.45% | |||
MID
ATLANTIC TRUST COMPANY FBO
1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class R
|
5.72% | N/A | |
NATIONAL
FINANCIAL SERVICES LLC
FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1003 |
Class R4
|
60.91% | N/A | |
PERSHING
LLC
1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class B
|
5.79% | N/A | |
Class R4 | 25.28% |
Statement of Additional Information – [____, 2018] | 252 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
RAYMOND
JAMES
FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C
|
12.26% | N/A | |
SEI
PRIVATE TRUST COMPANY
1 FREEDOM VALLEY DR OAKS PA 19456-9989 |
Class Z
|
6.41% | N/A | |
VOYA
INSTITUTIONAL TRUST COMPANY
TTE 30 BRAINTREE HILL OFFICE PARK BRAINTREE MA 02184-8747 |
Class R5
|
34.30% | N/A |
(a) | Combination of all share classes of Columbia Management initial capital and/or affiliated funds-of-funds’ investments. |
Statement of Additional Information – [____, 2018] | 253 |
Statement of Additional Information – [____, 2018] | 254 |
Statement of Additional Information – [____, 2018] | A-1 |
Statement of Additional Information – [____, 2018] | A-2 |
Statement of Additional Information – [____, 2018] | A-3 |
Statement of Additional Information – [____, 2018] | A-4 |
■ | Independence — A nominee who is deemed an affiliate of the company by virtue of a material business, familial or other relationship with the company but is otherwise not an employee, and who sits on a key committee (audit, compensation, nominating or governance). |
■ | Attendance — A nominee who failed to attend at least 75% of the board’s meetings. |
■ | Over Boarding — A nominee who serves on more than five total public company boards or an employee director nominee who serves on more than two total public company boards. |
■ | Committee Membership — A nominee who has been assigned to a key committee if that nominee is not independent of management, or if the nominee does not meet the specific independence and experience requirements for such committees. |
■ | Audit Committee Chair — A nominee who serves as audit committee chair where the committee failed to put forth shareholder proposals for ratification of auditors. |
■ | Board Independence — A nominee of a company whose board as proposed to be constituted would have more than one-third of its members from management. |
■ | Interlocking Directorship — A nominee who is an executive officer of another company on whose board one of the company’s executive officers sits. |
■ | Poor Governance — A nominee involved with, among other things, options backdating, financial restatements or material weakness in controls, approving egregious compensation, or who has consistently disregarded the interests of shareholders. |
Statement of Additional Information – [____, 2018] | B-1 |
Statement of Additional Information – [____, 2018] | B-2 |
Statement of Additional Information – [____, 2018] | B-3 |
Statement of Additional Information – [____, 2018] | B-4 |
Statement of Additional Information – [____, 2018] | B-5 |
Statement of Additional Information – [____, 2018] | B-6 |
Statement of Additional Information – [____, 2018] | B-7 |
Statement of Additional Information – [____, 2018] | B-8 |
Statement of Additional Information – [____, 2018] | B-9 |
Statement of Additional Information – [____, 2018] | B-10 |
■ | the inability or perceived inability of a government authority to collect sufficient tax or other revenues to meet its payment obligations; |
■ | natural disasters and ecological or environmental concerns; |
■ | the introduction of constitutional or statutory limits on a tax-exempt issuer’s ability to raise revenues or increase taxes; |
■ | the inability of an issuer to pay interest on or to repay principal or securities in which the funds invest during recessionary periods; and |
■ | economic or demographic factors that may cause a decrease in tax or other revenues for a government authority or for private operators of publicly financed facilities. |
Statement of Additional Information – [____, 2018] | C-1 |
Statement of Additional Information – [____, 2018] | C-2 |
Statement of Additional Information – [____, 2018] | C-3 |
Statement of Additional Information – [____, 2018] | C-4 |
Statement of Additional Information – [____, 2018] | C-5 |
Statement of Additional Information – [____, 2018] | C-6 |
Statement of Additional Information – [____, 2018] | C-7 |
Statement of Additional Information – [____, 2018] | C-8 |
Statement of Additional Information – [____, 2018] | D-1 |
Statement of Additional Information – [____, 2018] | D-2 |
■ | Current or retired fund Board members, officers or employees of the funds or Columbia Management or its affiliates (b) ; |
■ | Current or retired Ameriprise Financial Services, Inc. (Ameriprise Financial Services) financial advisors and employees of such financial advisors (b) ; |
■ | Registered representatives and other employees of affiliated or unaffiliated financial intermediaries (and their immediate family members and related trusts or other entities owned by the foregoing) having a selling agreement with the Distributor (b) ; |
■ | Registered broker-dealer firms that have entered into a dealer agreement with the Distributor may buy Class A shares without paying a front-end sales charge for their investment account only; |
■ | Portfolio managers employed by subadvisers of the funds (b) ; |
■ | Partners and employees of outside legal counsel to the funds or to the funds’ directors or trustees who regularly provide advice and services to the funds, or to their directors or trustees; |
■ | Direct rollovers ( i.e. , rollovers of fund shares and not reinvestments of redemption proceeds) from qualified employee benefit plans, provided that the rollover involves a transfer to Class A shares in the same fund; |
■ | Employees of Bank of America, its affiliates and subsidiaries (c) ; |
■ | Employees or partners of Columbia Wanger Asset Management, LLC (or their successors) (d) ; |
■ | For Class V shares only: Shareholders who (i) bought Galaxy fund Retail A shares at net asset value and received Class V shares (formerly known as Class T shares, as stated above, which have no relation to, or connection with, Class T shares in effect on March 10, 2017) in exchange for those shares during the Galaxy/Liberty fund reorganization; and (ii) continue to maintain the account in which the Retail A shares were originally bought; and Boston 1784 fund shareholders on the date that those funds were reorganized into Galaxy funds (c) ; |
■ | Separate accounts established and maintained by an insurance company which are exempt from registration under Section 3(c)(11); |
■ | At a fund’s discretion, front-end sales charges may be waived for shares issued in plans of reorganization, such as mergers, asset acquisitions and exchange offers, to which the fund is a party; |
Statement of Additional Information – [____, 2018] | S-1 |
■ | Purchases by registered representatives and employees (and their immediate family members and related trusts or other entities owned by the foregoing (referred to as “Related Persons”)) of Ameriprise Financial Services and its affiliates; provided that with respect to employees (and their Related Persons) of an affiliate of Ameriprise Financial, such persons must make purchases through an account held at Ameriprise Financial or its affiliates. |
■ | Through or under a wrap fee product or other investment product sponsored by a financial intermediary that charges an account management fee or other managed agency/asset allocation accounts or programs involving fee-based compensation arrangements that have or that clear trades through a financial intermediary that has a selling agreement with the Distributor; |
■ | Through state sponsored college savings plans established under Section 529 of the Internal Revenue Code; |
■ | Through banks, trust companies and thrift institutions, acting as fiduciaries; or |
■ | Through “employee benefit plans” created under Section 401(a), 401(k), 457 and 403(b), and qualified deferred compensation plans, that have a plan level or omnibus account maintained with the Fund or the Transfer Agent and transact directly with the Fund or the Transfer Agent through a third-party administrator or third-party recordkeeper. This waiver does not apply to accounts held through commissionable brokerage platforms. |
* | Any shareholder with a Direct-at-Fund account (i.e., shares held directly with the Fund through the Transfer Agent) that is eligible to purchase shares without a front-end sales charge by virtue of having qualified for a previous waiver may continue to purchase shares without a front-end sales charge if they no longer qualify under a category described in the prospectus or in this section. Otherwise, you must qualify for a front-end sales charge waiver described in the prospectus or in this section. |
(a) | The Funds no longer accept investments from new or existing investors in Class E shares, except by existing Class E and former Class F shareholders who opened and funded their account prior to September 22, 2006 that may continue to invest in Class E shares (Class F shares automatically converted to Class E shares on July 17, 2017). See the prospectus offering Class E shares of Large Cap Growth Fund (a series of CFST I) for details. |
(b) | Including their spouses or domestic partners, children or step-children, parents, step-parents or legal guardians, and their spouse’s or domestic partner’s parents, step-parents, or legal guardians. |
■ | Employees or partners of Columbia Wanger Asset Management, LLC; |
■ | In the event of the shareholder’s death; |
■ | For which no sales commission or transaction fee was paid to an authorized financial intermediary at the time of purchase; |
■ | Purchased through reinvestment of dividend and capital gain distributions; |
■ | That result from required minimum distributions taken from retirement accounts upon the shareholder’s attainment of age 70½; |
■ | That result from returns of excess contributions made to retirement plans or individual retirement accounts, so long as the financial intermediary returns the applicable portion of any commission paid by the Distributor; |
■ | Of Class A shares of a fund initially purchased by an employee benefit plan; |
■ | Other than Class A shares of a fund initially purchased by an employee benefit plan that are not connected with a plan level termination; |
■ | In connection with the fund’s Small Account Policy (as described in the prospectus); and |
■ | At a fund’s discretion, issued in connection with plans of reorganization, including but not limited to mergers, asset acquisitions and exchange offers, to which the fund is a party. |
Statement of Additional Information – [____, 2018] | S-2 |
■ | Any client of Bank of America or one of its subsidiaries buying shares through an asset management company, trust, fiduciary, retirement plan administration or similar arrangement with Bank of America or the subsidiary. |
■ | Any employee (or family member of an employee) of Bank of America or one of its subsidiaries. |
■ | Any investor buying shares through a Columbia Management state tuition plan organized under Section 529 of the Internal Revenue Code. |
■ | Any trustee or director (or family member of a trustee or director) of a fund distributed by the Distributor. |
■ | Other than for the Multi-Manager Strategies Funds, any shareholder (as well as any family member of a shareholder or person listed on an account registration for any account of the shareholder) who holds Class Inst shares of a fund distributed by the Distributor is eligible to purchase Class Inst shares of other funds distributed by the Distributor, subject to a minimum initial investment of $2,000 ($1,000 for IRAs). If the account in which the shareholder holds Class Inst shares is not eligible to purchase additional Class Inst shares, the shareholder may purchase Class Inst shares in an account maintained directly with the Transfer Agent, subject to a minimum initial investment of $2,000 ($1,000 for IRAs). |
Statement of Additional Information – [____, 2018] | S-3 |
PART C. OTHER INFORMATION
Item 28. Exhibits
(a)(1) | Second Amended and Restated Agreement and Declaration of Trust, dated August 10, 2005, is incorporated by reference to Post-Effective Amendment No. 40 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (a)(1)), filed on September 16, 2005. | |
(a)(2) | Amendment No. 1 to Second Amended and Restated Agreement and Declaration of Trust, effective September 19, 2005, is incorporated by reference to Post-Effective Amendment No. 40 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (a)(2)), filed on September 16, 2005. |
(a)(3) | Amendment No. 2 to Second Amended and Restated Agreement and Declaration of Trust, effective December 13, 2017, is incorporated by reference to Post-Effective Amendment No. 313 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (a)(3)), filed on January 16, 2018. |
(b) | Amended and Restated By-laws of the Registrant, effective October 20, 2015, are incorporated by reference to Post-Effective Amendment No. 248 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (b)), filed on December 22, 2015. | |
(c) | Not Applicable. | |
(d)(1) | Amended and Restated Management Agreement, as of April 25, 2016, between Columbia Management Investment Advisers, LLC, Columbia Funds Variable Insurance Trust and the Registrant, is incorporated by reference to Post-Effective Amendment No. 257 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(1)), filed on April 27, 2016. | |
(d)(1)(i) | Schedule A and Schedule B, as of July 1, 2017, to the Management Agreement between Columbia Management Investment Advisers, LLC, Columbia Funds Variable Insurance Trust and the Registrant, as of April 25, 2016, are incorporated by reference to Post-Effective Amendment No. 299 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(1)(i)), filed on July 28, 2017. | |
(d)(2) | Amended and Restated Management Agreement, as of October 25, 2016, between Columbia Management Investment Advisers, LLC, Columbia Funds Variable Insurance Trust and the Registrant, effective June 16, 2015, is incorporated by reference to Post-Effective Amendment No. 68 to Registration Statement No. 033-14954 of Columbia Funds Variable Insurance Trust on Form N-1A (Exhibit (d)(2)), filed on October 31, 2016. | |
(d)(2)(i) | Schedule A and Schedule B, as of August 16, 2017, to the Management Agreement between Columbia Management Investment Advisers, LLC, Columbia Funds Variable Insurance Trust and the Registrant, as of October 25, 2016, are incorporated by reference to Post-Effective Amendment No. 74 to Registration Statement No. 033-14954 of Columbia Funds Variable Insurance Trust on Form N-1A (Exhibit (d)(2)(i)), filed on September 11, 2017. | |
(d)(3) | Subadvisory Agreement between Columbia Management Investment Advisers, LLC and AQR Capital Management, LLC dated March 7, 2012, is incorporated by reference to Post-Effective Amendment No. 196 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(3)), filed on May 30, 2014. | |
(d)(3)(i) | Addendum dated March 7, 2012 to the Subadvisory Agreement dated March 7, 2012 between Columbia Management Investment Advisers, LLC and AQR Capital Management, LLC on behalf of Multi-Manager Alternative Strategies Fund, is incorporated by reference to Post-Effective Amendment No. 196 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(3)(1)), filed on May 30, 2014. |
(d)(3)(ii) | Amendment No. 1, dated August 18, 2016 to the Subadvisory Agreement dated March 7, 2012 between Columbia Management Investment Advisers, LLC and AQR Capital Management, LLC on behalf of Multi-Manager Directional Alternative Strategies Fund is incorporated by reference to Post-Effective Amendment No. 276 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(3)(ii)), filed on September 30, 2016. | |
(d)(4) | Subadvisory Agreement between Columbia Management Investment Advisers, LLC and Dalton, Greiner, Hartman, Maher & Co., LLC dated March 7, 2012, is incorporated by reference to Post-Effective Amendment No. 196 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(4)), filed on May 30, 2014. | |
(d)(4)(i) | Amendment No.1, dated June 10, 2015, to the Subadvisory Agreement between Columbia Management Investment Advisers, LLC and Dalton, Greiner, Hartman, Maher & Co., LLC dated March 7, 2012, is incorporated by reference to Post-Effective Amendment No. 231 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(6)(i)), filed on June 29, 2015. | |
(d)(5) | Subadvisory Agreement between Columbia Management Investment Advisers, LLC and EAM Investors, LLC dated March 7, 2012, is incorporated by reference to Post-Effective Amendment No. 196 to Registration Statement No. 99356 of the Registrant on Form N-1A (Exhibit (d)(5)), filed on May 30, 2014. | |
(d)(6) | Subadvisory Agreement between Columbia Management Investment Advisers, LLC and PGIM, Inc., the asset management arm of Prudential Financial, dated March 9, 2016, is incorporated by reference to Post-Effective Amendment No. 259 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(6)), filed on May 16, 2016. | |
(d)(7) | Subadvisory Agreement between Columbia Management Investment Advisers, LLC and TCW Investment Management Company LLC dated February 6, 2013, last amended January 25, 2017, is incorporated by reference to Post-Effective Amendment No. 293 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(7)), filed on March 29, 2017. | |
(d)(7)(i) | Addendum Authorization to Enter Into Over-The-Counter And/Or Exchange Traded Derivatives between Columbia Management Investment Advisers, LLC and TCW Investment Management Company LLC dated March 7, 2012, is incorporated by reference to Post-Effective Amendment No. 196 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(7)(1)), filed on May 30, 2014. | |
(d)(8) | Subadvisory Agreement among Columbia Management Investment Advisers, LLC and Threadneedle International Limited dated March 5, 2014, is incorporated by reference to Post-Effective Amendment No. 236 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(10)), filed on August 26, 2015. | |
(d)(8)(i) | Amendment No. 1, dated December 19, 2014, to the Subadvisory Agreement, between Columbia Management Investment Advisers, LLC and Threadneedle International Limited, is incorporated by reference to Post-Effective Amendment No. 236 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(10)(i)), filed on August 26, 2015. | |
(d)(8)(ii) | Amendment No. 2, dated March 4, 2015, to the Subadvisory Agreement between Columbia Management Investment Advisers, LLC and Threadneedle International Limited, is incorporated by reference to Post-Effective Amendment No. 236 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(10)(ii)), filed on August 26, 2015. | |
(d)(8)(iii) | Amendment No. 3, dated June 10, 2015, to the Subadvisory Agreement between Columbia Management Investment Advisers, LLC and Threadneedle International Limited, is incorporated by reference to Post-Effective Amendment No. 236 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(10)(iii)), filed on August 26, 2015. |
(d)(8)(iv) | Addendum, dated December 19, 2014, to the Subadvisory Agreement, dated March 5, 2014, between Columbia Management Investment Advisers, LLC and Threadneedle International Limited, pertaining to CDARF1 Offshore Fund Ltd., a subsidiary of Columbia Diversified Absolute Return Fund, is incorporated by reference to Post-Effective Amendment No. 236 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(10)(iv)), filed on August 26, 2015. | |
(d)(8)(v) | Addendum, dated December 19, 2014, to the Subadvisory Agreement, dated March 5, 2014, between Columbia Management Investment Advisers, LLC and Threadneedle International Limited, pertaining to CDARF2 Offshore Fund Ltd., a subsidiary of Columbia Diversified Absolute Return Fund, is incorporated by reference to Post-Effective Amendment No. 236 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(10)(v)), filed on August 26, 2015. | |
(d)(8)(vi) | Addendum, dated December 19, 2014, to the Subadvisory Agreement, dated March 5, 2014, between Columbia Management Investment Advisers, LLC and Threadneedle International Limited, pertaining to CDARF3 Offshore Fund Ltd., a subsidiary of Columbia Diversified Absolute Return Fund, is incorporated by reference to Post-Effective Amendment No. 236 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(10)(vi)), filed on August 26, 2015. | |
(d)(8)(vii) | Addendum, dated December 19, 2014, to the Subadvisory Agreement, dated March 5, 2014, between Columbia Management Investment Advisers, LLC and Threadneedle International Limited, pertaining to CAAF Offshore Fund Ltd., a subsidiary of Columbia Alternative Beta Fund, is incorporated by reference to Post-Effective Amendment No. 236 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(10)(vii)), filed on August 26, 2015. | |
(d)(9) | Subadvisory Agreement between Columbia Management Investment Advisers, LLC and Water Island Capital, LLC dated March 7, 2012, is incorporated by reference to Post-Effective Amendment No. 196 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(9)), filed on May 30, 2014. | |
(d)(10) | Delegation Agreement dated March 7, 2012 between Dalton, Greiner, Hartman, Maher & Co. LLC, and Real Estate Management Services Group, LLC, is incorporated by reference to Post-Effective Amendment No. 196 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(10)), filed on May 30, 2014. | |
(d)(11) | Subadvisory Agreement between Columbia Management Investment Advisers, LLC and Conestoga Capital Advisors, LLC dated June 11, 2014, is incorporated by reference to Post-Effective Amendment No. 205 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(11)), filed on August 28, 2014. | |
(d)(12) | Subadvisory Agreement between Columbia Management Investment Advisers, LLC and Loomis, Sayles and Company, L.P. dated December 4, 2013, is incorporated by reference to Post-Effective Amendment No. 196 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(12)), filed on May 30, 2014. | |
(d)(12)(i) | Amendment No.1, dated March 9, 2016, to the Subadvisory Agreement between Columbia Management Investment Advisers, LLC and Loomis, Sayles and Company, L.P., dated December 4, 2013, is incorporated by reference to Post-Effective Amendment No. 256 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(14)(i)), filed on April 11, 2016. | |
(d)(13) | Subadvisory Agreement between Columbia Management Investment Advisers, LLC and BMO Asset Management Corp., dated October 20, 2015, is incorporated by reference to Post-Effective Amendment No. 243 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(16)), filed on October 26, 2015. |
(d)(13)(i) | Amendment No.1, as of May 1, 2017, to the Subadvisory Agreement between Columbia Management Investment Advisers, LLC and BMO Asset Management Corp., dated October 20, 2015, is incorporated by reference to Post-Effective Amendment No. 295 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(13)(i)), filed on April 26, 2017. | |
(d)(14) | Subadvisory Agreement between Columbia Management Investment Advisers, LLC and Boston Partners Global Investors Inc., on behalf of Multi-Manager Directional Alternative Strategies Fund dated August 18, 2016, is incorporated by reference to Post-Effective Amendment No. 276 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(15)), filed on September 30, 2016. | |
(d)(15) | Subadvisory Agreement between Columbia Management Investment Advisers, LLC and Analytic Investors, LLC, on behalf of Multi-Manager Directional Alternative Strategies Fund dated October 3, 2016, is incorporated by reference to Post-Effective Amendment No. 277 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(16)), filed on October 3, 2016. | |
(d)(16) | Subadvisory Agreement between Columbia Management Investment Advisers, LLC and Los Angeles Capital Management and Equity Research, Inc., on behalf of Multi-Manager Growth Strategies Fund effective February 7, 2017, is incorporated by reference to Post-Effective Amendment No. 288 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(16)), filed on February 7, 2017. | |
(d)(17) | Subadvisory Agreement between Columbia Management Investment Advisers, LLC and Manulife Asset Management (US) LLC, on behalf of Multi-Manager Alternative Strategies Fund effective September 13, 2017, is incorporated by reference to Post-Effective Amendment No. 304 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(17)), filed on September 13, 2017. | |
(d)(18) | Management Agreement between Columbia Management Investment Advisers, LLC and CAAF Offshore Fund, Ltd., a subsidiary of Columbia Alternative Beta Fund, effective October 1, 2015, is incorporated by reference to Post-Effective Amendment No. 239 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(18)), filed on September 28, 2015. | |
(d)(19) | Management Agreement between Columbia Management Investment Advisers, LLC and CDARF1 Offshore Fund, Ltd., a subsidiary of Columbia Diversified Absolute Return Fund, effective October 1, 2015, is incorporated by reference to Post-Effective Amendment No. 239 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(19)), filed on September 28, 2015. | |
(d)(20) | Management Agreement between Columbia Management Investment Advisers, LLC and CDARF2 Offshore Fund, Ltd., a subsidiary of Columbia Diversified Absolute Return Fund, effective October 1, 2015, is incorporated by reference to Post-Effective Amendment No. 239 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(20)), filed on September 28, 2015. | |
(d)(21) | Management Agreement between Columbia Management Investment Advisers, LLC and CDARF3 Offshore Fund, Ltd., a subsidiary of Columbia Diversified Absolute Return Fund, effective October 1, 2015, is incorporated by reference to Post-Effective Amendment No. 239 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(21)), filed on September 28, 2015. | |
(d)(22) | Management Agreement between Columbia Management Investment Advisers, LLC and ASGM Offshore Fund, Ltd., a subsidiary of Multi-Manager Alternative Strategies Fund, effective January 1, 2016, is incorporated by reference to Post-Effective Amendment No. 248 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(22)), filed on December 22, 2015. | |
(d)(23)
|
Management Agreement between Columbia Management Investment Advisers, LLC and ASMF Offshore Fund, Ltd., a subsidiary of Multi-Manager Alternative Strategies Fund, effective January 1, 2016, is incorporated by reference to Post-Effective Amendment No. 248 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(23)), filed on December 22, 2015. |
(e)(1) | Amended and Restated Distribution Agreement by and between Registrant and Columbia Management Investment Distributors, Inc., dated March 1, 2016, is incorporated by reference to Post-Effective Amendment No. 256 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (e)(1)), filed on April 11, 2016. | |
(e)(1)(i) | Restated Schedule I, effective August 16, 2017 and Schedule II, to Amended and Restated Distribution Agreement by and between the Registrant and Columbia Management Investment Distributors, Inc., dated March 1, 2016, are incorporated by reference to Post-Effective Amendment No. 308 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (e)(1)(i)), filed on October 20, 2017. | |
(e)(2) | Form of Mutual Fund Sales Agreement is incorporated by reference to Post-Effective Amendment No. 293 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (e)(2)), filed on March 29, 2017. | |
(f) | Form of Deferred Compensation Agreement is incorporated by reference to Post-Effective Amendment No. 196 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (f)), filed on May 30, 2014. | |
(g)(1) | Second Amended and Restated Master Global Custody Agreement between certain Funds and JP Morgan Chase Bank, N.A., dated March 7, 2011, is incorporated by reference to Post-Effective Amendment No. 124 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(2)), filed on April 29, 2011. | |
(g)(2) | Addendum to Master Global Custody Agreement (related to Multi-Manager Alternative Strategies Fund, Multi-Manager Total Return Bond Strategies Fund, Multi-Manager Small Cap Equity Strategies Fund and Multi-Manager Growth Strategies Fund), dated March 9, 2012, Addendum to Master Global Custody Agreement (related to Columbia Adaptive Risk Allocation Fund), dated June 11, 2012, and Addendum to Master Global Custody Agreement (related to Columbia Diversified Real Return Fund), dated February 25, 2014, are incorporated by reference to Post-Effective Amendment No. 196 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(2)), filed on May 30, 2014. | |
(g)(3) | Addendum to Master Global Custody Agreement (related to Columbia Alternative Beta Fund and Columbia Diversified Absolute Return Fund), dated January 15, 2015, is incorporated by reference to Post-Effective Amendment No. 221 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(3)), filed on February 27, 2015. | |
(g)(4) | Addendum to Master Global Custody Agreement (related to Columbia Multi-Asset Income Fund and Columbia U.S. Social Bond Fund), dated March 18, 2015, is incorporated by reference to Post-Effective Amendment No. 223 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(4)), filed on March 24, 2015. | |
(g)(5) | Side letter (related to the China Connect Service on behalf of Columbia Emerging Markets Fund, Columbia Greater China Fund and Columbia Pacific/Asia Fund), dated December 19, 2014, to the Second Amended and Restated Master Global Custody Agreement with JP Morgan Chase Bank, N.A., dated March 7, 2011, is incorporated by reference to Post-Effective Amendment No. 221 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(4)), filed on February 27, 2015. | |
(g)(6) | Addendum to Master Global Custody Agreement (related to Multi-Manager Directional Alternative Strategies Fund), is incorporated by reference to Post-Effective Amendment No. 276 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(6)), filed on September 30, 2016. |
(g)(7) | Addendum to Master Global Custody Agreement (related to Columbia Adaptive Retirement 2020 Fund, Columbia Adaptive Retirement 2030 Fund, Columbia Adaptive Retirement 2040 Fund, Columbia Adaptive Retirement 2050 Fund, Columbia Adaptive Retirement 2060 Fund, Columbia Solutions Aggressive Portfolio and Columbia Solutions Conservative Portfolio), is incorporated by reference to Post-Effective Amendment No. 308 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(7)), filed on October 20, 2017. | |
(g)(8) | Addendum, effective April 4, 2016, to the Second Amended and Restated Master Global Custody Agreement with JP Morgan Chase Bank, N.A., dated March 7, 2011, is incorporated by reference to Post-Effective Amendment No. 297 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(7)), filed on May 30, 2017. | |
(h)(1) | Amended and Restated Transfer and Dividend Disbursing Agent Agreement by and between the Registrant and Columbia Management Investment Services Corp., dated March 1, 2016, is incorporated by reference to Post-Effective Amendment No. 295 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(1)), filed on April 26, 2017. | |
(h)(1)(i) | Schedule A and Schedule B, effective November 1, 2017, to the Amended and Restated Transfer and Dividend Disbursing Agent Agreement by and between the Registrant and Columbia Management Investment Services Corp., dated March 1, 2016, are incorporated by reference to Post-Effective Amendment No. 309 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(1)(i)), filed on October 30, 2017. | |
(h)(2) | Form of Indemnification Agreement is incorporated by reference to Post-Effective Amendment No. 46 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(6)), filed on March 24, 2006. | |
(h)(3) | Amended and Restated Plan Administration Services Agreement, dated as of September 7, 2010, amended and restated November 1, 2012, by and among the Registrant, Columbia Funds Series Trust and Columbia Management Investment Services Corp, is incorporated by reference to Post-Effective Amendment No. 165 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(13)), filed on November 7, 2012. | |
(h)(3)(i) | Exhibit A, Exhibit B and Exhibit C, effective July 1, 2017, to the Amended and Restated Plan Administration Services Agreement among Columbia Management Investment Services Corp., the Registrant and Columbia Funds Series Trust, dated as of September 7, 2010, are incorporated by reference to Registration Statement No. 333-89661 of Columbia Funds Series Trust on Form N-1A (Exhibit (h)(2)(i)), filed on July 28, 2017. | |
(h)(4) | Amended and Restated Fee Waiver and Expense Cap Agreement, effective July 1, 2016, by and among Columbia Management Investment Advisers, LLC, Columbia Management Investment Distributors, Inc., Columbia Management Investment Services Corp., the Registrant and Columbia Funds Variable Insurance Trust is incorporated by reference to Post-Effective Amendment No. 264 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(4)), filed on June 29, 2016. | |
(h)(4)(i) | Restated Schedule A, effective August 16, 2017, to the Amended and Restated Fee Waiver and Expense Cap Agreement, effective July 1, 2016, by and among Columbia Management Investment Advisers, LLC, Columbia Management Investment Distributors, Inc., Columbia Management Investment Services Corp., the Registrant and Columbia Funds Variable Insurance Trust is incorporated by reference to Post-Effective Amendment No. 74 to Registration Statement No. 033-14954 of Columbia Funds Variable Insurance Trust on Form N-1A (Exhibit (h)(3)(i)), filed on September 11, 2017. |
(h)(5) | Agreement and Plan of Reorganization, dated October 9, 2012, is incorporated by reference to Post-Effective Amendment No. 175 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(8)), filed on May 30, 2013. | |
(h)(6) | Agreement and Plan of Reorganization, dated December 20, 2010, is incorporated by reference to Post-Effective Amendment No. 15 to Registration Statement No. 333-146374 of Columbia Funds Variable Series Trust II on Form N-1A (Exhibit (h)(9)), filed on April 29, 2011. | |
(h)(7) | Agreement and Plan of Reorganization, dated December 17, 2015, is incorporated by reference to Registration Statement No. 333-208706 of Columbia Funds Series Trust on Form N-14 (Exhibit (4)), filed on December 22, 2015. | |
(h)(8) | Amended and Restated Credit Agreement, as of December 9, 2014, is incorporated by reference to Post-Effective Amendment No. 225 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(14)), filed on April 16, 2015. | |
(h)(8)(i) | Restated Credit Agreement, as of December 8, 2015, is incorporated by reference to Post-Effective Amendment No. 256 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(9)(i)), filed on April 11, 2016. | |
(h)(8)(ii) | Restated Credit Agreement, as of December 6, 2016, is incorporated by reference to Post-Effective Amendment No. 297 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(8)(ii)), filed on May 30, 2017. | |
(h)(8)(iii) | Amendment to the Credit Agreement, dated April 25, 2017, is incorporated by reference to Post-Effective Amendment No. 297 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(8)(iii)), filed on May 30, 2017. | |
(i)(1) | Opinion of Counsel of Ropes & Gray LLP is incorporated by reference to Post-Effective Amendment No. 40 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (i)), filed on September 16, 2005. | |
(i)(2) | Opinion of Counsel of Ropes & Gray LLP is incorporated by reference to Post-Effective Amendment No. 68 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (i)(2)), filed on January 16, 2008. | |
(i)(3) | Opinion of Counsel of Ropes & Gray LLP is incorporated by reference to Post-Effective Amendment No. 81 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (i)(3)), filed on November 25, 2008. | |
(i)(4) | Opinion of Counsel of Ropes & Gray LLP is incorporated by reference to Post-Effective Amendment No. 95 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (i)(4)), filed on November 20, 2009. | |
(i)(5) | Opinion of Counsel of Ropes & Gray LLP is incorporated by reference to Post-Effective Amendment No. 143 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (i)(5)), filed on March 14, 2012. | |
(i)(6) | Opinion of Counsel of Ropes & Gray LLP, with respect to Columbia Adaptive Risk Allocation Fund, is incorporated by reference to Post-Effective Amendment No. 153 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (I)(6)), filed on June 15, 2012. | |
(i)(7) | Opinion of Counsel of Ropes & Gray LLP, with respect to Columbia Diversified Real Return Fund, is incorporated by reference to Post-Effective Amendment No. 190 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (i)(7)), filed on March 10, 2014. |
(i)(8) | Opinion of Counsel of Ropes & Gray LLP, with respect to Columbia Alternative Beta Fund and Columbia Diversified Absolute Return Fund, is incorporated by reference to Post-Effective Amendment No. 219 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (j)(8)), filed on January 27, 2015. | |
(i)(9) | Opinion of Counsel of Ropes & Gray LLP, with respect to Columbia Multi-Asset Income Fund and Columbia U.S. Social Bond Fund is incorporated by reference to Post-Effective Amendment No. 223 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (i)(9)), filed on March 24, 2015. | |
(i)(10) | Opinion of Counsel of Ropes & Gray LLP, with respect to Multi-Manager Directional Alternative Strategies Fund, is incorporated by reference to Post-Effective Amendment No. 276 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (i)(10)), filed on September 30, 2016. | |
(i)(11) | Opinion of Counsel of Ropes & Gray LLP, with respect to Columbia Adaptive Retirement 2020 Fund, Columbia Adaptive Retirement 2030 Fund, Columbia Adaptive Retirement 2040 Fund, Columbia Adaptive Retirement 2050 Fund, Columbia Adaptive Retirement 2060 Fund, Columbia Solutions Aggressive Portfolio and Columbia Solutions Conservative Portfolio, is incorporated by reference to Post-Effective Amendment No. 308 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (i)(11)), filed on October 20, 2017. |
(i)(12) | Opinion of Counsel of Ropes & Gray LLP, with respect to Columbia Adaptive Retirement 2025 Fund, Columbia Adaptive Retirement 2035 Fund, Columbia Adaptive Retirement 2045 Fund and Columbia Adaptive Retirement 2055 Fund, is incorporated by reference to Post-Effective Amendment No. 313 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (i)(12)), filed on January 16, 2018. |
(j)(1) | Consent of Morningstar, Inc., is incorporated by reference to Post-Effective Amendment No. 21 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (11)(b)), filed on August 30, 1996. | |
(j)(2) | Consent of PricewaterhouseCoopers LLP: Not Applicable. | |
(k) | Omitted Financial Statements: Not Applicable. | |
(l) | Initial Capital Agreement: Not Applicable. | |
(m)(1) | Amended and Restated Distribution Plan, as of July 18, 2017, is incorporated by reference to Post-Effective Amendment No. 299 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (m)(1)), filed on July 28, 2017. | |
(m)(2) | Amended and Restated Shareholder Servicing Plan, as of July 18, 2017, for certain Fund share classes of the Registrant, is incorporated by reference to Post-Effective Amendment No. 299 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (m)(2)), filed on July 28, 2017. | |
(m)(3) | Amended and Restated Shareholder Services Plan, as of June 14, 2017, for Registrants Class V (formerly known as Class T) shares is incorporated by reference to Post-Effective Amendment No. 299 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (m)(3)), filed on July 28, 2017. | |
(m)(4) | Shareholder Servicing Plan Implementation Agreement, amended and restated as of June 14, 2017, for Registrants Class V (formerly known as Class T) shares between the Registrant and Columbia Management Investment Distributors, Inc., is incorporated by reference to Post-Effective Amendment No. 299 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (m)(4)), filed on July 28, 2017. |
(m)(4)(i) | Restated Schedule I, effective June 14, 2017, to Shareholder Servicing Plan Implementation Agreement for Registrants Class V (formerly known as Class T) shares between the Registrant and Columbia Management Investment Distributors, Inc., is incorporated by reference to Post-Effective Amendment No. 299 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (m)(4)(i)), filed on July 28, 2017. | |
(m)(5) | Shareholder Servicing Plan Implementation Agreement for certain Fund share classes of the Registrant between the Registrant, Columbia Funds Series Trust and Columbia Management Investment Distributors, Inc., is incorporated by reference to Post-Effective Amendment No. 113 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (m)(4)), filed on November 24, 2010. | |
(m)(5)(i) | Restated Schedule I, dated July 18, 2017, to Shareholder Servicing Plan Implementation Agreement, between the Registrant, Columbia Funds Series Trust and Columbia Management Investment Distributors, Inc. is incorporated by reference to Post-Effective Amendment No. 168 to Registration Statement No. 333-89661 of Columbia Funds Series Trust on Form N-1A (Exhibit (m)(4)(i)), filed on July 28, 2017. | |
(n) | Rule 18f 3 Multi-Class Plan, amended and restated as of November 1, 2017, is incorporated by reference to Post-Effective Amendment No. 309 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (n)), filed on October 30, 2017. | |
(o) | Reserved. | |
(p)(1) | Code of Ethics of Columbia Atlantic Board Funds, effective February 2016, is incorporated by reference to Post-Effective Amendment No. 256 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(1)), filed on April 11, 2016. |
(p)(2) | Ameriprise Global Asset Management Personal Trading Account Dealing and Code of Ethics Policy, effective December 17, 2017, is filed herewith as Exhibit (p)(2) to Post-Effective Amendment No. 315 to Registration Statement No. 2-99356 of the Registrant on Form N-1A. |
(p)(3) | Code of Ethics of AQR Capital Management, LLC (a subadviser of Multi-Manager Alternative Strategies Fund and Multi-Manager Directional Alternative Strategies Fund), effective February 2016, is incorporated by reference to Post-Effective Amendment No. 276 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(3)), filed on September 30, 2016. | |
(p)(4) | Code of Ethics of Dalton, Greiner, Hartman, Maher & Co., LLC (a subadviser of Multi-Manager Small Cap Equity Strategies Fund), dated May 20, 2016, is incorporated by reference to Post-Effective Amendment No. 295 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(4)), filed on April 26, 2017. | |
(p)(5) | Code of Ethics and Standards of Business Conduct of EAM Investors, LLC (a subadviser of Multi-Manager Small Cap Equity Strategies Fund), effective July 1, 2016, is incorporated by reference to Post-Effective Amendment No. 295 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(5)), filed on April 26, 2017. | |
(p)(6) | Code of Ethics of Prudential Financial (for PGIM, Inc., a subadviser of Multi-Manager Total Return Bond Strategies Fund), dated January 9, 2017, is incorporated by reference to Post-Effective Amendment No. 295 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(6)), filed on April 26, 2017. | |
(p)(7) | Code of Ethics of TCW Investment Management Company LLC (a subadviser of Multi-Manager Alternative Strategies Fund and Multi-Manager Total Return Bond Strategies Fund), dated March 13, 2017, is incorporated by reference to Post-Effective Amendment No. 295 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(7)), filed on April 26, 2017. |
(p)(8) | Code of Ethics of Water Island Capital, LLC (a subadviser of Multi-Manager Alternative Strategies Fund), dated April 2017, is incorporated by reference to Post-Effective Amendment No. 295 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(8)), filed on April 26, 2017. | |
(p)(9) | Code of Ethics of Real Estate Management Services Group, LLC (provides advisory services as delegated by Dalton, Greiner, Hartman, Maher & Co., LLC, a subadviser of Multi-Manager Small Cap Equity Strategies Fund), dated July 1, 2016, is incorporated by reference to Post-Effective Amendment No. 295 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(9)), filed on April 26, 2017. | |
(p)(10) | Code of Ethics of Conestoga Capital Advisors, LLC (a subadviser of Multi-Manager Small Cap Equity Strategies Fund), dated July 19, 2016, is incorporated by reference to Post-Effective Amendment No. 295 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(10)), filed on April 26, 2017. | |
(p)(11) | Code of Ethics of Loomis, Sayles and Company, L.P. (a subadviser of Multi-Manager Growth Strategies Fund and Multi-Manager Total Return Bond Strategies Fund), effective January 14, 2000, as amended August 11, 2016, is incorporated by reference to Post-Effective Amendment No. 295 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(11)), filed on April 26, 2017. | |
(p)(12) | Code of Ethics of BMO Asset Management Corp. (a subadviser of Multi-Manager Small Cap Equity Strategies Fund), dated December 2016, is incorporated by reference to Post-Effective Amendment No. 295 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(12)), filed on April 26, 2017. | |
(p)(13) | Code of Ethics of Boston Partners Global Investors Inc. (a subadviser of Multi-Manager Directional Alternative Strategies Fund), effective March 1, 2016, is incorporated by reference to Post-Effective Amendment No. 276 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(14)), filed on September 30, 2016. | |
(p)(14) | Code of Ethics of Wells Capital Management, Inc. (for Analytic Investors, LLC, a subadviser of Multi-Manager Directional Alternative Strategies Fund), effective September 30, 2016, is incorporated by reference to Post-Effective Amendment No. 278 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(15)), filed on October 5, 2016. | |
(p)(15) | Code of Ethics of Los Angeles Capital Management and Equity Research, Inc. (a subadviser of Multi-Manager Growth Strategies Fund), effective December 30, 2016, is incorporated by reference to Post-Effective Amendment No. 288 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(15)), filed on February 7, 2017. | |
(p)(16) | Code of Ethics of Manulife Asset Management (US) LLC (a subadviser of Multi-Manager Alternative Strategies Fund), effective September 1, 2015, is incorporated by reference to Post-Effective Amendment No. 304 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(16)), filed on September 13, 2017. |
(q)(1) | Trustees Power of Attorney, dated January 1, 2018, is filed herewith as Exhibit (q)(1) to Post-Effective Amendment No. 315 to Registration Statement No. 2-99356 of the Registrant on Form N-1A. |
(q)(2) | Power of Attorney for Christopher O. Petersen, dated February 16, 2015, is incorporated by reference to Post-Effective Amendment No. 221 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (q)(7)), filed on February 27, 2015. |
(q)(3) | Power of Attorney for Michael G. Clarke, dated May 23, 2016, is incorporated by reference to Post-Effective Amendment No. 261 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (q)(3)), filed on May 27, 2016. | |
(q)(4) | Power of Attorney for Amy K. Johnson, dated May 11, 2016, is incorporated by reference to Post-Effective Amendment No. 261 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (q)(4)), filed on May 27, 2016. | |
(q)(5) | Power of Attorney for Anthony P. Haugen, dated May 11, 2016, is incorporated by reference to Post-Effective Amendment No. 261 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (q)(5)), filed on May 27, 2016. |
Item 29. Persons Controlled by or under Common Control with the Registrant
Columbia Management Investment Advisers, LLC (the investment manager or Columbia Management), as sponsor of the Columbia funds, may make initial capital investments in Columbia funds (seed accounts). Columbia Management also serves as investment manager of certain Columbia funds-of-funds that invest primarily in shares of affiliated funds (the underlying funds). Columbia Management does not make initial capital investments or invest in underlying funds for the purpose of exercising control. However, since these ownership interests may be significant, in excess of 25%, such that Columbia Management may be deemed to control certain Columbia funds, procedures have been put in place to assure that public shareholders determine the outcome of all actions taken at shareholder meetings. Specifically, Columbia Management (which votes proxies for the seed accounts) and the Boards of Trustees of the affiliated funds-of-funds (which votes proxies for the affiliated funds-of-funds) vote on each proposal in the same proportion as the vote of the direct public shareholders vote; provided, however, that if there are no direct public shareholders of an underlying fund or if direct public shareholders represent only a minority interest in an underlying fund, the Fund may cast votes in accordance with instructions from the independent members of the Board.
Item 30. Indemnification
Article Five of the Bylaws of Registrant provides that Registrant shall indemnify each of its trustees and officers (including persons who serve at Registrants request as directors, officers or trustees of another organization in which Registrant has any interest as a shareholder, creditor or otherwise) who are not employees or officers of any investment adviser to Registrant or any affiliated person thereof and its chief compliance officer, regardless of whether such person is an employee or officer of any investment adviser to Registrant or any affiliated person thereof, and may indemnify each of its trustees and officers (including persons who serve at Registrants request as directors, officers or trustees of another organization in which Registrant has any interest as a shareholder, creditor or otherwise) (i.e., those who are employees or officers of any investment adviser to Registrant or any affiliated person thereof) (Covered Persons) under specified circumstances, all as more fully set forth in the Registrants Bylaws, which have been filed as an exhibit to this registration statement.
Section 17(h) of the Investment Company Act of 1940 (1940 Act) provides that no instrument pursuant to which Registrant is organized or administered shall contain any provision which protects or purports to protect any trustee or officer of Registrant against any liability to Registrant or its shareholders to which he or she would otherwise be subject by reason of willful misfeasance, bad faith, gross negligence, or reckless disregard of the duties involved in the conduct of his or her office. In accordance with Section 17(h) of the 1940 Act, no Covered Person is indemnified under the Bylaws against any liability to Registrant or its shareholders by reason of willful misfeasance, bad faith, gross negligence, or reckless disregard of the duties involved in the conduct of the Covered Persons office.
Pursuant to the Distribution Agreement, Columbia Management Investment Distributors, Inc. agrees to indemnify the Registrant, its officers and trustees against claims, demands, liabilities and expenses under specified circumstances, all as more fully set forth in the Registrants Distribution Agreement, which has been filed as an exhibit to the registration statement. The Registrant may be party to other contracts that include indemnification provisions for the benefit of the Registrants trustees and officers.
The trustees and officers of the Registrant and the personnel of the Registrants investment adviser and principal underwriter are insured under an errors and omissions liability insurance policy. Registrants investment adviser, Columbia Management Investment Advisers, LLC, maintains investment advisory professional liability insurance to insure it, for the benefit of Registrant and its non-interested trustees, against loss arising out of any effort, omission, or breach of any duty owed to Registrant or any series of Registrant by Columbia Management Investment Advisers, LLC.
Insofar as indemnification for liabilities arising under the Securities Act of 1933 may be permitted to trustees, officers and controlling persons of the Registrant by the Registrant pursuant to the Registrants organizational instruments or otherwise, the Registrant is aware that in the opinion of the Securities and Exchange Commission (SEC), such indemnification is against public policy as expressed in the Securities Act of 1933 and, therefore, is unenforceable.
Item 31. Business and Other Connections of the Investment Adviser
To the knowledge of the Registrant, none of the directors or officers of Columbia Management Investment Advisers, LLC (the Investment Manager), the Registrants investment adviser, or the subadviser to a series of the Registrant, except as set forth below, are or have been, at any time during the Registrants past two fiscal years, engaged in any other business, profession, vocation or employment of a substantial nature.
(a) | The Investment Manager, a wholly-owned subsidiary of Ameriprise Financial, Inc. performs investment advisory services for the Registrant and certain other clients. Information regarding the business of the Investment Manager and certain of its officers is set forth in the Prospectuses and Statements of Additional Information of the Registrants portfolios and is incorporated herein by reference. Information about the business of the Investment Manager and the directors and principal executive officers of the Investment Manager is also included in the Form ADV filed by the Investment Manager (formerly, RiverSource Investments, LLC) with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-25943), which is incorporated herein by reference. In addition to their position with the Investment Manager, certain directors and officers of the Investment Manager also hold various positions with, and engage in business for, Ameriprise Financial, Inc. or its other subsidiaries. |
(b) | Analytic Investors, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Analytic Investors, LLC and certain of its officers is set forth in the Prospectuses and Statement of Additional Information of the Registrants portfolio(s) subadvised by Analytic Investors, LLC and is incorporated herein by reference. Information about the business of Analytic Investors, LLC and the directors and principal executive officers of Analytic Investors, LLC is also included in the Form ADV filed by Analytic Investors, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-7082), which is incorporated herein by reference. |
(c) | AQR Capital Management, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of AQR Capital Management, LLC and certain of its officers is set forth in the Prospectuses and Statement of Additional Information of the Registrants portfolio(s) subadvised by AQR Capital Management, LLC and is incorporated herein by reference. Information about the business of AQR Capital Management, LLC and the directors and principal executive officers of AQR Capital Management, LLC is also included in the Form ADV filed by AQR Capital Management, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-55543), which is incorporated herein by reference. |
(d) | Boston Partners Global Investors, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of Boston Partners Global Investors, Inc. and certain of its officers is set forth in the Prospectuses and Statement of Additional Information of the Registrants portfolio(s) subadvised by Boston Partners Global Investors, Inc. and is incorporated herein by reference. Information about the business of Boston Partners Global Investors, Inc. and the directors and principal executive officers of Boston Partners Global Investors, Inc. is also included in the Form ADV filed by Boston Partners Global Investors, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-61786), which is incorporated herein by reference. |
(e) | BMO Asset Management Corp. performs investment management services for the Registrant and certain other clients. Information regarding the business of BMO Asset Management Corp. and certain of its officers is set forth in the Prospectuses and Statement of Additional Information of the Registrants portfolio(s) subadvised by BMO Asset Management Corp. and is incorporated herein by reference. Information about the business of BMO Asset Management Corp. and the directors and principal executive officers of BMO Asset Management Corp. is also included in the Form ADV filed by BMO Asset Management Corp. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-35533), which is incorporated herein by reference. |
(f) | Conestoga Capital Advisors, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Conestoga Capital Advisors, LLC and certain of its officers is set forth in the Prospectuses and Statement of Additional Information of the Registrants portfolio(s) subadvised by Conestoga Capital Advisors, LLC and is incorporated herein by reference. Information about the business of Conestoga Capital Advisors, LLC and the directors and principal executive officers of Conestoga Capital Advisors, LLC is also included in the Form ADV filed by Conestoga Capital Advisors, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-60133), which is incorporated herein by reference. |
(g) | Dalton, Greiner, Hartman, Maher & Co., LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Dalton, Greiner, Hartman, Maher & Co., LLC and certain of its officers is set forth in the Prospectuses and Statement of Additional Information of the Registrants portfolio(s) subadvised by Dalton, Greiner, Hartman, Maher & Co., LLC and is incorporated herein by reference. Information about the business of Dalton, Greiner, Hartman, Maher & Co., LLC and the directors and principal executive officers of Dalton, Greiner, Hartman, Maher & Co., LLC is also included in the Form ADV filed by Dalton, Greiner, Hartman, Maher & Co., LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-62895), which is incorporated herein by reference. |
(h) | EAM Investors, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of EAM Investors, LLC and certain of its officers is set forth in the Prospectuses and Statement of Additional Information of the Registrants portfolio(s) subadvised by EAM Investors, LLC and is incorporated herein by reference. Information about the business of EAM Investors, LLC and the directors and principal executive officers of EAM Investors, LLC is also included in the Form ADV filed by EAM Investors, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-70305), which is incorporated herein by reference. |
(i) | Loomis, Sayles and Company, L.P. performs investment management services for the Registrant and certain other clients. Information regarding the business of Loomis, Sayles and Company, L.P. and certain of its officers is set forth in the Prospectuses and Statement of Additional Information of the Registrants portfolio(s) subadvised by Loomis, Sayles and Company, L.P. and is incorporated herein by reference. Information about the business of Loomis, Sayles and Company, L.P. and the directors and principal executive officers of Loomis, Sayles and Company, L.P. is also included in the Form ADV filed by Loomis, Sayles and Company, L.P. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-170), which is incorporated herein by reference. |
(j) | Los Angeles Capital Management and Equity Research, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of Los Angeles Capital Management and Equity Research, Inc. and certain of its officers is set forth in the Prospectuses and Statement of Additional Information of the Registrants portfolio(s) subadvised by Los Angeles Capital Management and Equity Research, Inc. and is incorporated herein by reference. Information about the business of Los Angeles Capital Management and Equity Research, Inc. and the directors and principal executive officers of Los Angeles Capital Management and Equity Research, Inc. is also included in the Form ADV filed by Los Angeles Capital Management and Equity Research, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-60934), which is incorporated herein by reference. |
(k) | Manulife Asset Management (US) LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Manulife Asset Management (US) LLC and certain of its officers is set forth in the Prospectuses and Statement of Additional Information of the Registrants portfolio(s) subadvised by Manulife Asset Management (US) LLC and is incorporated herein by reference. Information about the business of Manulife Asset Management (US) LLC and the directors and principal executive officers of Manulife Asset Management (US) LLC is also included in the Form ADV filed by Manulife Asset Management (US) LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-42023), which is incorporated herein by reference. |
(l) | PGIM, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of PGIM, Inc. and certain of its officers is set forth in the Prospectuses and Statement of Additional Information of the Registrants portfolio(s) subadvised by PGIM, Inc. and is incorporated herein by reference. Information about the business of PGIM, Inc. and the directors and principal executive officers of PGIM, Inc. is also included in the Form ADV filed by PGIM, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-22808), which is incorporated herein by reference. |
(m) | TCW Investment Management Company LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of TCW Investment Management Company LLC and certain of its officers is set forth in the Prospectuses and Statement of Additional Information of the Registrants portfolio(s) subadvised by TCW Investment Management Company LLC and is incorporated herein by reference. Information about the business of TCW Investment Management Company LLC and the directors and principal executive officers of TCW Investment Management Company LLC is also included in the Form ADV filed by TCW Investment Management Company LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-29075), which is incorporated herein by reference. |
(n) | Threadneedle International Limited performs investment management services for the Registrant and certain other clients. Information regarding the business of Threadneedle International Limited and certain of its officers is set forth in the Prospectuses and Statement of Additional Information of the Registrants portfolio(s) subadvised by Threadneedle International Limited and is incorporated herein by reference. Information about the business of Threadneedle International Limited and the directors and principal executive officers of Threadneedle International Limited is also included in the Form ADV filed by Threadneedle International Limited with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-63196), which is incorporated herein by reference. |
(o) | Water Island Capital, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Water Island Capital, LLC and certain of its officers is set forth in the Prospectuses and Statement of Additional Information of the Registrants portfolio(s) subadvised by Water Island Capital, LLC and is incorporated herein by reference. Information about the business of Water Island Capital, LLC and the directors and principal executive officers of Water Island Capital, LLC is also included in the Form ADV filed by Water Island Capital, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-57341), which is incorporated herein by reference. |
Item 32. Principal Underwriter
(a) | Columbia Management Investment Distributors, Inc. acts as principal underwriter for the following investment companies, including the Registrant: |
Columbia Acorn Trust; Columbia Funds Series Trust; Columbia Funds Series Trust I; Columbia Funds Series Trust II; Columbia Funds Variable Series Trust II; Columbia Funds Variable Insurance Trust and Wanger Advisors Trust.
(b) | As to each director, principal officer or partner of Columbia Management Investment Distributors, Inc. |
Name and Principal Business Address* |
Position and Offices
|
Positions and Offices
|
||
William F. Truscott | Chief Executive Officer | Board Member, Senior Vice President | ||
Joseph Kringdon | President and Head of Intermediary Distribution | None | ||
Jeffrey J. Scherman | Chief Financial Officer | None | ||
Michael E. DeFao | Vice President, Chief Legal Officer and Assistant Secretary | Vice President and Assistant Secretary | ||
Stephen O. Buff | Vice President, Chief Compliance Officer | None | ||
James Bumpus | Vice President National Sales Manager | None | ||
Thomas A. Jones | Vice President and Head of Strategic Relations | None | ||
Gary Rawdon | Vice President Sales Governance and Administration | None | ||
Leslie A. Walstrom | Vice President and U.S. Head of Marketing | None | ||
Daniel J. Beckman | Vice President and Head of U.S. Retail Product | None | ||
Marc Zeitoun | Vice President, Head of Strategic Beta and Head of Private Client Accounts | None | ||
Thomas R. Moore | Secretary | None | ||
Paul B. Goucher | Vice President and Assistant Secretary | Senior Vice President and Assistant Secretary | ||
Tara W. Tilbury | Vice President and Assistant Secretary | Assistant Secretary | ||
Nancy W. LeDonne | Vice President and Assistant Secretary | None | ||
Ryan C. Larrenaga | Vice President and Assistant Secretary |
Senior Vice President, Chief Legal Officer and Secretary |
||
Joseph L. DAlessandro | Vice President and Assistant Secretary | Assistant Secretary | ||
Christopher O. Petersen | Vice President and Assistant Secretary | President and Principal Executive Officer | ||
James E. Brefeld, Jr. | Treasurer | None | ||
Michael Tempesta | Anti-Money Laundering Officer and Identity Theft Prevention Officer | None | ||
Kevin Wasp | Ombudsman | None | ||
Kristin Weisser | Conflicts Officer | None |
* | The principal business address of Columbia Management Investment Distributors, Inc. is 225 Franklin Street, Boston, MA 02110. |
(c) | Not Applicable. |
Item 33. Location of Accounts and Records
Persons maintaining physical possession of accounts, books and other documents required to be maintained by Section 31(a) of the 1940 Act and the Rules thereunder include:
| Registrant, 225 Franklin Street, Boston, MA 02110; |
| Registrants investment adviser and administrator, Columbia Management Investment Advisers, LLC, 225 Franklin Street, Boston, MA 02110; |
| Registrants subadviser, Analytic Investors, LLC, 555 West Fifth Street, 50th Floor, Los Angeles, CA 90013; |
| Registrants subadviser, AQR Capital Management, LLC, Two Greenwich Plaza, 3rd Floor, Greenwich, CT 06830; |
| Registrants subadviser, Boston Partners Global Investors, Inc., 909 Third Avenue, New York, NY 10022; |
| Registrants subadviser, BMO Asset Management, Corp., 115 South LaSalle Street, 11 th Floor, Chicago, IL, 60603; |
| Registrants subadviser, Conestoga Capital Advisors, LLC, 550 East Swedesford Road, Suite 120, Wayne, PA 19087; |
| Registrants subadviser, Dalton, Greiner, Hartman, Maher & Co., 565 Fifth Avenue, Suite 2101, New York, NY 10017; |
| Registrants subadviser, EAM Investors, LLC, 2533 South Coast Highway 101, Suite 240, Cardiff-by-the-Sea, CA 92007; |
| Registrants subadviser, Loomis, Sayles and Company, L.P., One Financial Center, Boston, MA 02111; |
| Registrants subadviser, Los Angeles Capital Management and Equity Research, Inc., 1150 Santa Monica Blvd., Suite 200, Los Angeles, CA 90025; |
| Registrants subadviser, Manulife Asset Management (US) LLC, 197 Clarendon St # 4, Boston, MA 02116; |
| Registrants subadviser, PGIM, Inc./Prudential Financial, Inc., 655 Broad Street, Newark, NJ 07102; |
| Registrants subadviser, TCW Investment Management Company LLC, 865 South Figueroa Street, Suite 1800, Los Angeles, CA 90017; |
| Registrants subadviser, Threadneedle International Limited, Cannon Place, 78 Cannon Street, London EC4N 6AG, United Kingdom; |
| Registrants subadviser, Water Island Capital, LLC, 41 Madison Avenue, 42nd floor, New York, NY 10010; |
| Registrants provider of advisory service as delegated by DGHM, Real Estate Management Services Group, LLC, 1100 Fifth Avenue South, Suite 305, Naples, FL 34102; |
| Registrants former subadviser, Eaton Vance Management, Two International Place, Boston, MA 02110; |
| Registrants former subadviser, Federated Investment Management Company, Federated Investors Tower, 1001 Liberty Avenue, Pittsburgh, PA 15222-3779; |
| Registrants former subadviser, Nordea Investment Management North America, Inc., 437 Madison Avenue, New York, NY 10022; |
| Registrants former subadviser, RS Investment Management Co. LLC, 388 Market Street, Suite 1700, San Francisco, CA 94111; |
| Registrants former subadviser, Wasatch Advisors Inc, 505 Wakara Way, 3 rd Floor, Salt Lake City, UT 84108; |
| Registrants principal underwriter, Columbia Management Investment Distributors, Inc., 225 Franklin Street, Boston, MA, 02110; |
| Registrants transfer agent, Columbia Management Investment Services Corp., 225 Franklin Street, Boston, MA, 02110; |
| Registrants custodian, JP Morgan Chase Bank, N.A., 1 Chase Manhattan Plaza 19 th Floor, New York, NY 10005; and |
| Registrants former custodian, State Street Bank and Trust Company, State Street Financial Center, One Lincoln Street, Boston, MA 02111. |
In addition, Iron Mountain Records Management is an off-site storage facility housing historical records that are no longer required to be maintained on-site. Records stored at this facility include various trading and accounting records, as well as other miscellaneous records. The address for Iron Mountain Records Management is 920 & 950 Apollo Road, Eagan, MN 55121.
Item 34. Management Services
Not Applicable.
Item 35. Undertakings
Not Applicable.
SIGNATURES
Pursuant to the requirements of the Securities Act of 1933 and the Investment Company Act of 1940, the Registrant, COLUMBIA FUNDS SERIES TRUST I, has duly caused this Amendment to its Registration Statement to be signed on its behalf by the undersigned, duly authorized, in the City of Minneapolis, and The State of Minnesota on the 1st day of February, 2018.
COLUMBIA FUNDS SERIES TRUST I | ||||
By: |
/s/ Christopher O. Petersen |
|||
Christopher O. Petersen | ||||
President |
Pursuant to the requirements of the Securities Act of 1933, this Amendment to the Registration Statement has been signed below by the following persons in the capacities indicated on the 1st day of February, 2018.
Signature | Capacity | Signature | Capacity | |||
/s/ Christopher O. Petersen |
President |
/s/ John J. Neuhauser* |
Trustee | |||
Christopher O. Petersen |
(Principal Executive Officer) | John J. Neuhauser | ||||
/s/ Michael G. Clarke* |
Chief Financial Officer |
/s/ Patrick J. Simpson* |
Trustee | |||
Michael G. Clarke |
(Principal Financial Officer) Chief Accounting Officer (Principal Accounting Officer) |
Patrick J. Simpson | ||||
/s/ Douglas A. Hacker* |
Chair of the Board |
/s/ William F. Truscott* |
Trustee | |||
Douglas A. Hacker | William F. Truscott | |||||
/s/ Janet L. Carrig* |
Trustee |
/s/ Anne-Lee Verville* |
Trustee | |||
Janet L. Carrig | Anne-Lee Verville | |||||
/s/ Nancy T. Lukitsh* |
Trustee | |||||
Nancy T. Lukitsh | ||||||
/s/ David M. Moffett* |
Trustee | |||||
David M. Moffett |
* | By: /s/ Joseph DAlessandro |
Name: Joseph DAlessandro** |
Attorney-in-fact
** | Executed by Joseph DAlessandro on behalf of Michael G. Clarke pursuant to a Power of Attorney, dated May 23, 2016 and incorporated by reference to Post-Effective Amendment No. 261 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (q)(3)), filed with the Commission on May 27, 2016, and on behalf of each of the Trustees pursuant to a Trustees Power of Attorney, dated January 1, 2018, filed herewith as Exhibit (q)(1) to Post-Effective Amendment No. 315 to Registration Statement No. 2-99356 of the Registrant on Form N-1A. |
Exhibit Index
(p)(2) | Ameriprise Global Asset Management Personal Trading Account Dealing and Code of Ethics Policy, effective December 17, 2017 | |
(q)(1)
|
Trustees Power of Attorney |
COLUMBIA THREADNEEDLE INVESTMENTS
GLOBAL PERSONAL ACCOUNT DEALING AND CODE OF ETHICS
Policy Type | Global Policy | |
Last Review Date | December 2017 | |
Applicable Global Regulatory Authorities |
SEC Rule 204A-1 of the Advisers Act
SEC Rule 17j-1 of the Investment Company Act
FCA Rule Conduct of Business Sourcebook (COBS) 11.7
Securities and Futures Act
MAS guidelines on Risk Management Practices-Internal Controls
Code of Conduct for Persons licensed by the Securities and Futures Commission
Guidelines on Compliance and Function for fund Managers |
|
Related Policies | See Appendix C-Other Policies Applicable to Covered Persons | |
Applicability and Scope | All Covered Persons and certain household members, trusteeships and executorships of Covered Persons. |
1
1. | POLICY STATEMENT |
1.1. | Keys Points |
Standard of Business Conduct: The conduct of personal dealings in investments by Covered Persons (See Appendix A - Definitions for Covered Persons definition) employed by or affiliated with the Ameriprise Global Asset Management Entities 1 (the Firms) is a matter of the utmost importance to the organization, its clients, its regulators and to employees themselves. It is essential that the Firms appropriately manage access to privileged information concerning clients portfolios, the Firms trading intentions and trading activities, and that the Firms discharge their duties in a way that does not harm the interests of clients, the Firms or breach any legal or regulatory requirements. It is important that the Firms are not seen to act on privileged information for personal gain.
Duty Owed to Clients: Various regulations applicable to the Firms impose a fiduciary duty to act in the exclusive best interest of their clients at all times recognizing their role as a Trusted Adviser. A number of specific obligations flow from the duty that is owed to clients, including:
| To act solely in the best interests of clients at all times. |
| To make full and fair disclosure of all material facts, particularly where the Firms interests may conflict with those of its clients. |
| To act in a manner which satisfies the fiduciary duty owed to clients. |
| To refrain from favoring the interest of a particular client over the interests of another client. |
| To keep all information about clients (including former clients) confidential, including the clients identity, clients securities holdings information, and other non-public information. |
| To exercise a high degree of care to ensure that adequate and accurate representations and other information is presented appropriately. |
In connection with providing investment management services to clients, this includes prohibiting any activity which directly or indirectly:
| Defrauds a client in any manner. |
| Misleads a client, including any statement that omits material facts. |
1 | See Appendix B-Entities That Have Adopted Policy |
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
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| Operates or would operate as a fraud or deceit on a client. |
| Functions as a manipulative practice with respect to a client. |
| Functions as a manipulative practice with respect to securities. |
Specifically, the fiduciary duty owed to clients means the following outcomes must be achieved:
| To have a reasonable, independent basis for investment advice. |
| To ensure that investment advice is suitable to the clients investment objectives, needs and circumstances. |
| To refrain from effecting Personal Securities Transactions inconsistent with clients interests. |
| To obtain best execution for clients securities transactions. |
Conflicts of Interest: All Covered Persons must be vigilant in terms of identifying circumstances that may present a conflict of interest. A conflict of interest is any situation that presents an incentive to act other than in the best interest of a client or without objectivity. A conflict of interest may arise, for example, when a Covered Person engages in a transaction that potentially favors:
| The Firms interests over a clients interest |
| The interest of a Covered Person over a clients interest |
| One clients interest over another clients interest |
In addition to this Ameriprise Global Asset Management Personal Account Dealing and Code of Ethics Policy (Policy), the Firms have adopted various policies designed to prevent, or otherwise manage, conflicts of interest in contexts outside of personal trading. To effectively manage conflicts of interest, all Covered Persons must seek to prevent conflicts of interest, including the appearance of a conflict.
The requirements set forth in this Policy do not identify all possible conflicts of interest that may arise in relation to personal transactions. Employees are encouraged to seek assistance from their local Compliance resources (see Appendix D-Resources ) whenever they have any questions concerning obligations under the Policy, including conflicts of interest situations or concerns .
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
3
Additional Standards of Conduct and Regulatory Requirements: Covered Persons must comply with other policies adopted by the individual Ameriprise Global Asset Management Entities that are intended to promote fair and ethical standards of business conduct and comply with related regulatory requirements (See Appendix C-Other Policies Applicable to Covered Persons ).
1.2. | Specific Policy Requirements |
This Policy applies to all Covered Persons and certain household members, Trusteeships and Executorships of Covered Persons. Covered Persons include:
| All Columbia Threadneedle employees and contractors. |
| Any other individual with a specific role (including working on a project) which compels Covered Person status due to access to proprietary information (e.g., holdings/transactions), such as the member of a staff group that provides ongoing audit, technology, finance, compliance, or legal support to Firms. |
| Any other persons that may be deemed appropriate by Compliance. |
Covered Securities Transactions/Accounts: This Policy governs a Covered Persons personal securities transactions as well as those securities transactions in which a Covered Person is deemed to have a direct or indirect Beneficial Ownership (see Appendix A-Definitions for Beneficial Ownership definition) and over which a Covered Person exercises direct or indirect influence or control (Affiliated Accounts). An account generally is covered by this Policy if it is:
| In the Covered Persons name |
| In the name of the Covered Persons spouse/partner and/or any financially dependent members of the Covered Persons household, |
| Of a partnership in which the Covered Person or a member of his/her immediate family is a partner with direct or indirect investment discretion |
| Of a trust in which the Covered Person (or a member of his/her immediate family) is a beneficiary and a trustee with direct or indirect investment discretion |
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
4
| Of a closely held corporation in which the Covered Person or a member of his/her immediate family holds shares and have direct or indirect investment discretion |
It is the responsibility of the Covered Person to seek advice in the event that it is not clear whether certain personal securities transactions are covered by this Policy.
Material Nonpublic Information: A Covered Person who is in possession of material nonpublic information (often referred to as Inside Information) about securities or financial instruments is prohibited from buying, selling, recommending or trading such securities or financial instruments. In addition, a Covered Person must not communicate or disclose such information to others who may misuse it. Material nonpublic information may include nonpublic information about a pooled investment vehicle (e.g., UCITS, open-end and closed-end mutual funds, and private funds) that are advised or sub-advised by the Firm. The Firms each have adopted specific policies that address these prohibitions, and set forth specific protocols for handling material nonpublic information(see Appendix C-Other Policies Applicable to Covered Persons )
Brokerage Accounts at Designated Broker-Dealers (Limited Choice): Covered Persons must promptly disclose their brokerage accounts to their Firms Compliance group, and ensure that each broker-dealer with which he/she maintains an account sends to the Compliance group, as soon as practicable, copies of all confirmations of his/her securities transactions and of all monthly, quarterly and annual account statements. North America employees must receive approval from Personal Trading Compliance prior to opening any new brokerage account outside of the Limited Choice Policy 2 in order to comply with new FINRA Rule 3210.
Personal Trading Restrictions
Prohibition on Front Running: Covered Persons are prohibited from engaging in a Personal Securities Transaction that involves the purchase or sale of a Reportable Security when such Covered Person has knowledge that such security (1) is being considered for purchase or sale by a client account or (2) is being purchased or sold by a client account.
2 | See Appendix H for details on the Limited Choice Policy |
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
5
Prior Approval (Pre-Clearance) of Personal Security Transactions: Covered Persons must obtain approval often referred to as pre-clearance-from Compliance prior to effecting a securities trade in most categories of investments. This pre-clearance requirement extends to securities transactions in all accounts for which the Covered Person has Beneficial Ownership (see Appendix A-Definitions ). If the Covered Person receives pre-clearance approval, it is valid only for the duration of the locally defined approval period; if a Covered Person does not effect the pre-cleared personal trade(s) within that locally approved time period, the Covered Person must request and obtain pre-clearance for the proposed personal trade(s) again before the trade(s) are effected. If the Covered Person does not receive pre-clearance approval, he/she must not effect the requested Personal Securities Transaction (but may request approval on a subsequent day).
Covered Persons are required to obtain such pre-clearance approval for the majority of investments. Please refer to Appendix E-Individual Security Requirements which identifies those categories of investments to which pre-clearance is or is not applicable.
Private Placements/Limited Offerings: Investments in private placement offerings require approval by the Compliance group (e.g., private placements, non-exchange traded REITs, hedge funds, fixed income new issues, unlisted structured products, non-charity crowdfunding, etc.).
Gifts and Charitable Donations: Approval is not necessary for a gift of securities to a Non-Profit Organization, but Compliance should be notified in advance and the Short-Term and 14-day Blackout rules do not apply. For gifting securities to a For-Profit Organization, individual, trust or other person or entity (other than a Non-Profit Organization), the pre-clearance requirement and 14-day Blackout rule do apply if you are purchasing the securities you intend to give.
Short-Term Trading Prohibition (30 Day Holding Period)
Individual Securities at a Profit: Covered Persons are prohibited from engaging in short-term trading of Reportable Securities. This means that Covered Persons may not buy (or add to their existing position), then sell the same securities (or equivalent) within 30 calendar days if the trade would result in a gain . Covered Persons must wait until calendar day 31 ( Trade Date + 30) to trade out of a position at a profit.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
6
When calculating the 30-day holding period, the average cost method must be used.
Covered Funds and other Pooled Investment Vehicles: A Covered Person is prohibited from short term trading in any Covered Fund (e.g., mutual fund, SICAV, OEIC, or other pooled investment vehicle, see Appendix F-Covered Funds List ) held for less than 30 calendar days, or a longer time if specified in the Covered Funds prospectus or similar disclosure document. Covered Persons are prohibited from engaging in market timing (short-term trading) in shares of any Mutual Fund or other pooled vehicles and must comply with the holding period policy established by any Mutual Fund held, even though the Mutual Fund may not be a Covered Fund. Please see the Mutual Funds prospectus for further information.
Transactions exempted from short-term trading prohibitions: Money market fund investments, automated investments and withdrawal programs, and Dividend Reinvestments are not subject to the 30 day holding period.
EMEA and APAC employees: Columbia Threadneedle provides discounts on investments to EMEA and APAC employees in certain of its products but operates a holding period of a minimum 60 working days in order to qualify for those discounts. Please refer to the Columbia Threadneedle EMEA and Asia Compensation & Benefits intranet site for information.
Initial Public Offerings (IPOs) and Limited Offerings: Covered Persons require pre-clearance approval to purchase Initial Public Offerings (IPOs) or Limited Offerings, including additions to existing holdings but excluding capital calls for previously approved commitments. Such approval will only be granted when it is established that there is no conflict or appearance of a conflict with any Client or other possible impropriety (such as where the Security in the Limited Offering is appropriate for purchase by a Client, or when his/her participation in the Limited Offering is suggested by a person who has a business relationship with any such Company or expects to establish such a relationship). The 30-day holding period also applies to IPOs.
Participation in Investment Clubs: No Covered Person may participate in private investment clubs or other similar groups.
Derivatives: Covered Persons are strongly discouraged from investing in any form of derivative that could give rise to an open ended, unlimited liability. Most derivative trading is subject to pre-clearance requirements, option trading guidelines and the Short Term Trading Prohibition. (See Appendix G-Options/Short Trading Guidelines ).
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
7
Frequent and Unusual Trading Activity: Compliance monitors patterns of personal trading activity and may require additional information from a Covered Person with respect to a specific trade or series of transactions. In addition, frequent trading activity is strongly discouraged. Although no set limit of trades during a period of time is expressly stated by the Firms, Covered Persons should understand that they may come under scrutiny for frequent trading activity, which could result in corrective measures if the activity is deemed especially excessive.
Additional Trading Restrictions for Investment Employees
Rules Applicable to Portfolio Managers and other Designated Covered Persons:
14 Day Blackout Period: Portfolio Managers (and other Covered Persons specifically identified by Compliance) are not permitted to transact in any security that is purchased or sold in a client account 7 calendar days before and 7 calendar days after a client account they manage trades in that same (or equivalent) security. This means a Portfolio Manager must wait until calendar day 8 to trade the security. Application of this rule may be applied broader based on team function and location.
Because it is a Portfolio Managers responsibility to put his/her clients interests ahead of his/her own, he/she may not delay taking appropriate action for a client account in order to avoid potential adverse consequences in his/her personal account. In certain limited instances, Compliance, at their discretion, may determine that a trade should be deemed to have not caused a black out violation (e.g., unexpected significant client redemption or inflow triggering a sale or purchase in all securities held in the client portfolio).
Rules Applicable to Research Analysts :
Centralised Research Analysts (those who publish research for the use by Columbia Threadneedle) are prohibited from engaging in a personal securities transaction that involves securities issued by issuers on their Coverage List at the security (not issuer) level. This restriction includes securities convertible into, options on, and derivatives of, such securities.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
8
Embedded Research Analysts- should the analyst have access to place an order within a fund they will be subject to the same blackout period as a Portfolio Manager (see above).
Rules Applicable to Trading Personnel:
3 Day Blackout Period: Traders are not permitted to transact in any security that is purchased or sold in a client account 3 calendar days after the client transaction. This means a Trader must wait until calendar day 4 to trade the security. Application of this rule may be adjusted based on team function and location.
1.3. | Reporting Requirements |
Initial Holdings Report and Certification: Upon becoming a Covered Person under this Policy , one must disclose all securities holdings (as indicated in Appendix E-Individual Securities Requirements ) in which they have Beneficial Ownership (as defined in Appendix A-Definitions ). All brokerage accounts must be disclosed.
All Covered Persons are notified of this requirement and are provided with a copy of this Policy when they first become subject to the Policy. This initial certification must be completed within 10 calendar days of becoming a Covered Person. This information must be current as of the date no more than 45 days prior to the date the person becomes a Covered Person.
Annual Certification: Covered Persons are also required to complete an annual accounts and holdings certification. This certification allows the Covered Person to validate the Brokerage Accounts and certain securities holdings in which they have Beneficial Ownership (as defined in Appendix A-Definitions ). Covered Persons also certify that they have received, read and understand the Policy. This information must be current as of a date no more than 45 days prior to the date the report was submitted.
Quarterly Certification: On a quarterly basis, Covered Persons must also certify to securities transactions outside of a previously reported and approved Brokerage Account. The quarterly certification must be completed within 30 calendar days of the last day of the quarter.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
9
1.4. | Confidentiality |
All reports and other documents and information supplied by or on behalf of any Covered Person in accordance with the requirements of this Policy will be treated as confidential, but are subject to review as provided herein and in the procedures by Legal, Compliance and other involved departments of the Firms, by Personal Trading, senior management, by representatives relevant regulatory authority of the asset management business regulatory or self-regulatory authority, or otherwise as required by law, regulation, or court order.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
10
2. | ADMINISTRATIVE REQUIREMENTS |
2.1. | Summary of Legal and Regulatory Requirements |
Regulatory rules require registered investment advisers and investment companies to adopt a code of ethics to; protect the firms clients, set forth standards of conduct, comply with applicable federal securities laws and address personal trading. SEC Rule 204A-1 under the Advisers Act (Rule 204A-1) requires each registered investment adviser to adopt a code of ethics that sets out standards of conduct expected of advisory personnel, safeguards material nonpublic information about client transactions and requires advisers access persons to report their personal securities transactions, including transactions in any mutual fund managed by the adviser.
Rule 17j-1 makes it unlawful for any affiliated person of a fund or any affiliated person of its investment adviser or principal underwriter to engage in certain enumerated types of misconduct in connection with the purchase or sale by such person of a security held or to be acquired by the fund. Each fund and its investment adviser and principal underwriter are required to adopt a written code of ethics containing provisions reasonably necessary to prevent the specified types of misconduct, and to use reasonable diligence and institute procedures reasonably necessary to prevent violations of the code.
FCA Rule COBS 11.7 requires a firm that conducts designated investment business to establish, implement and maintain adequate arrangements aimed at preventing certain activities (entering into certain personal transactions or advising anyone else to do so, or disclosing any non-public information) of any relevant person that may give rise to a conflict of interest, or who has access to inside information as defined in the Market Abuse Regulation3 or to other confidential information relating to clients or transactions with or for clients by virtue of an activity carried out by him on behalf of the firm.
MAS Guidelines on Risk Management Practices Internal Controls state that an institution should have adequate policies, procedures and controls to address conflict of interest situations. It should require employees to disclose such conflicts on a timely basis. These cases should be escalated to either the Board or senior management, and disclosed to customers where relevant.
SC Guidelines on Compliance Function for Fund Management Companies state a fund management company must take all reasonable steps to identify situations where conflicts of interest between the fund management company
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
11
and its clients arise in the course of the fund management company providing its services. A fund management company must ensure that it adopts measures to mitigate and manage, or avoid situations of conflict of interest.
2.2. | Roles and Responsibilities/Supervision |
At least annually, each Chief Compliance Officer/Compliance Executive of the Ameriprise Global Asset Management Entities must review the adequacy of this Policy and the policies and procedures herein referenced.
2.3. | Escalation for Non-Compliance |
The Firms have various resources for Covered Persons to raise compliance issues and concerns on a confidential basis (refer to Appendix D-Resources for a list of Compliance resources). In general, a Covered Person should first discuss a compliance issue with their supervisor, department head, Chief Compliance Officer, Compliance Executive, or other resource listed on Appendix D-Resources . In the event that a Covered Person does not feel comfortable discussing compliance issues through these channels, the employee may anonymously report suspected violations of law or company policy by contacting their local resources (refer to Appendix D-Resources ). Employees are encouraged to report these questionable practices so that the Firms have an opportunity to address and resolve these issues before they become more significant regulatory or legal issues.
Violations/Breaches of this Policy are taken seriously and may result in disciplinary actions and/or sanctions. Disciplinary actions could be up to and including termination of employment and sanctions will vary depending on local requirements or the circumstances (e.g., depending on the severity of the violation, if a record of previous violations exists, etc.).
2.4. | Monitoring/Oversight |
Compliance is responsible for the daily monitoring of employee personal trading and applicable accounts through the usage of personal trading assistant.
Escalation of matters are provided to appropriate local governance committee.
2.5. | Disclosure |
Columbia Threadneedle must provide information that is material about it business practices to clients and/or regulatory agencies, including information
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
12
about any conflicts of interests and the policies to address such conflicts. Practices related to this Policy are publicly disclosed in accordance to local rules and regulations.
2.6. | Recordkeeping |
Each respective Compliance group is primarily responsible for maintaining records created with respect to this Policy and the procedures adopted to implement it. All records must be maintained for five years after the end of the fiscal year in which the documents were later of creation or last use, the first two years in an easily accessible place.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
13
APPENDIX A-DEFINITIONS
Beneficial Owner of an account or a security includes any person who, directly or indirectly, has or shares voting or investment power. For the purposes of the Code of Ethics, a beneficial owner includes accounts held in the name of: you, your spouse/partner and/or any financially dependent members of your household (while this normally applies to dependent children, adult children living with older parents are also included)
In addition, you also have Beneficial Ownership if any of the individuals listed above:
| Is a trustee or custodian for an account (e.g., for a child or parent) |
| Exercises discretion over an account via a power of attorney arrangement or as an executor of an estate after death |
| Participates in an investment club |
| Has another arrangement where they give advice and also have a direct or indirect ownership (e.g. treasurer of an outside organization). |
Brokerage Account: A Brokerage Account is an account held at a licensed brokerage firm in which securities on the Securities Reporting List are bought and sold (e.g., stocks, bonds, futures, options, Covered Funds). This includes employer-sponsored incentive savings plans.
Closed-End Funds: A closed-end fund is a publicly traded investment company that raises a fixed amount of capital through an Initial Public Offering (IPO). The fund is then structured, listed and traded like a stock on a stock exchange.
Covered Funds: Closed-End Funds, ETFs and Mutual Funds for which Columbia Management Investment Advisers, LLC serves as an investment adviser or for which an affiliate of Columbia Management Investment Advisers, LLC serves as principal underwriter are considered Covered Funds.
Covered Persons includes all Columbia Threadneedle employees and contractors, any other individual with a specific role (including working on a project) which compels Covered Person status due to access to proprietary information (e.g., holdings/transactions), such as the member of a staff group that provides ongoing audit, technology, finance, compliance, or legal support to Firms, and any other persons that may be deemed appropriate by Compliance.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
14
Mutual Funds: U.S.-registered open-end investment companies, the shares of which are redeemable on any trading day at the net asset value, including those funds that are variable portfolios offered primarily as investment options to insurance companies.
Portfolio Managers: Individuals with direct responsibility and authority over investment decisions affecting any account owned or managed by Columbia Threadneedle and includes the person responsible for day-to-day investment decisions and other members of the Portfolio Managers investment team.
Private Funds: Private investment funds sponsored and managed by CMIA.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
15
APPENDIX B-ENTITIIES THAT HAVE ADOPTED POLICY
Columbia Management Investment Advisers, LLC
Columbia Management Investment Distributors, Inc.
Columbia Management Investment Services, Corp.
Threadneedle Asset Management Holdings SARL (TAMHS)
Threadneedle Asset Management Ltd.
Threadneedle Asset Management Limited (TAML)
Threadneedle Asset Management Malaysia Sdn Bhd (TAMM)
Threadneedle International Limited
Threadneedle International Investment GmbH
Threadneedle International Limited (TINTL)
Threadneedle Investment Services Limited (TISL)
Threadneedle Investments Singapore (Pte) Limited (TIS)
Threadneedle Investments Taiwan Limited (TITL)
Threadneedle Management Luxembourg SA. (TMLUX)
Threadneedle Management Services Limited
Threadneedle Navigator ISA Manager Limited (TNIML)
Threadneedle Pensions Limited (TPEN)
Threadneedle Portfolio Services Hong Kong Limited, Korea Representative Office
Threadneedle Portfolio Services Hong Kong Limited (TPSHKL)
Threadneedle Portfolio Services Limited (TPSL)
Threadneedle Unit Trust Manager Limited (TUTML)
It should be noted that Columbia Management includes Wanger Acorn trading data to also cover non- CWAM employees under one consolidated Code.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
16
APPENDIX C OTHER POLICIES APPLICABLE TO COVERED PERSONS
Ameriprise Financial Global Code of Conduct
Ameriprise Handling Whistleblower Claims Policy
Ameriprise Limited Choice Policy
Columbia Management Activities Involving Outside Entities or Family Relationships Policy
Columbia Management Gifts, Entertainment and Other Benefits Policy
Columbia Management Material Nonpublic Information Policy
Columbia Management Political Contributions Policy
Columbia Management Portfolio Holdings Disclosure Policy
Columbia Management Privacy Policy
Threadneedle Other Conflicts of Interest Policies Applicable to Covered Persons:
Threadneedle Market Abuse & Insider Dealing Policy
Threadneedle Conflicts of Interest Policy
Threadneedle Outside Activities & Family Relationships Policy
Columbia Threadneedle Investments EMEA and APAC Gifts, Entertainment and Other Benefits Policy
Threadneedle Treating Customers Fairly
Threadneedle Whistleblowing Policy
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
17
APPENDIX D RESOURCES
Compliance Resources
Personal Trading - 612-671-5196 or send email to Personal.Trading@ampf.com
Columbia Threadneedle EMEA and Asia Personal Trading personalaccountdealing@columbiathreadneedle.com
Contact the Compliance Team if you are ever at doubt as to your obligations under this Policy.
Whistleblowing
Ameriprise Financial provides a dedicated resource through NAVEX Global (formerly known as Ethicspoint) (800-963-6395) , a comprehensive and confidential reporting service for U.S. employees to report suspected fraud, abuse or other misconduct.
EMEA employees, in accordance with the EMEA/APAC Whistleblowing Policy, may contact the following for reporting, investigating and remedying any wrongdoing in the workplace.
Reporting Option |
Contact Email |
Contact Number (+44) |
||
Safecall | 0800 915 1571 | |||
FCA whistleblowing line | whistle@fca.gov.uk | 020 7066 9200 | ||
Public Concern at Work | helpline@pcaw.co.uk | 020 7404 6609 |
APAC employees, in accordance with the EMEA/APAC Whistleblowing Policy, may contact the Head of HR APAC, the Head of Legal or Compliance or Safecall (number noted above) for reporting, investigating and remedying any wrongdoing in the workplace.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
18
APPENDIX E-INDIVIDUAL SECURITIES REQUIREMENTS
Pre-clearance Requirements
All securities are subject to prior approval under the Global Asset Management Personal Account Dealing and Code of Ethics Policy (Policy) except those listed below:
| Ameriprise Financial Stock (other rules blackout, holding periods still apply, no speculative trading) |
| Annuities and Life Insurance (where there is no specific investment exposure) |
| Bank products (checking/savings, CDs, etc.) |
| Currencies |
| Debt securities issued by any government |
| Dividend Reinvestment Plans (DRIPS) |
| Futures |
| Money Market Funds |
| Non Investment derivatives sporting bets only |
| Open-End Mutual Funds |
| Columbia Threadneedle EMEA and Asia Products* |
| Unit Investment Trusts (UITs) |
*Pre-clearance | is required on Columbia Threadneedle EMEA and Asia OEICS/SICAVS by FPDC/SPC members (applicable to EMEA only). |
Ameriprise 401(K) Covered Persons must report Alight Financial self-directed brokerage accounts. ETF and Closed End Fund transactions within these self-directed accounts also require pre-clearance.
Holding Reporting Requirements*
All securities are subject to the reporting requirements under the Policy, including covered open-end funds ( Appendix F-Covered Funds List ), except those listed below:
| Annuities (report only Covered Funds listed in Appendix F ) |
| Bank products (checking/savings, CDs etc.) |
| Currencies |
| Debt securities issued by any government |
| 529 plans |
| Money Market Funds |
| Open-End Mutual Funds (Note: Holdings of Covered Open End Funds list on Appendix F-Covered Funds List are reportable in the quarterly and annual certifications) |
*All | brokerage accounts are reportable even if the holdings in those accounts are not. |
All other securities not listed above are subject to the Limited Choice Policy ( Appendix H ) and 30 Day Holding Period .
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
19
APPENDIX F-COVERED FUNDS LIST
The Global Asset Management Personal Account Dealing and Code of Ethics Policy (Policy) speaks to certain rules concerning activity within Covered Funds. Closed-End Funds, ETFs and Mutual Funds for which Columbia Management Investment Advisers, LLC serves as an investment adviser or for which an affiliate of Columbia Management Investment Advisers, LLC serves as principal underwriter are considered Covered Funds.
The following is the list of Covered Funds as of October 2017:
| All Columbia Mutual Funds (both retail and variable), including Columbia Acorn Funds, Wanger Funds, Active Portfolios ® and CMG Ultra Short Term Bond Fund |
| All Columbia Exchange-Traded Funds (ETFs) |
| All Columbia Threadneedle EMEA and Asia Funds |
| Columbia Seligman Premium Technology Growth Fund, Inc. |
| Tri-Continental Corporation |
Third-Party Funds Sub Advised by CMIA:
| AC Alternatives Long Short Fund |
| AST Columbia Adaptive Risk Allocation Portfolio |
| Bishop Street Dividend Value Fund |
| CGCM Large Cap Equity Fund |
| Destinations Large Cap Equity Fund |
| Destinations Equity Income Fund |
| Mercer US Large Cap Growth Equity Fund |
| SA Columbia Focused Growth Portfolio |
| SA Columbia Focused Value Portfolio |
| SunAmerica Series Trust Technology Portfolio |
| VALIC Company I Large Cap Core Fund |
| Voya Multi-Manager Large Cap Core Portfolio |
| VY Columbia Contrarian Core Portfolio |
| VY Columbia Small Cap Value II Portfolio |
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
20
APPENDIX G-OPTIONS/SHORT TRADING GUIDELINES
Short Trading-General Guidelines
Shorting individual securities is prohibited. Shorting broad-based market securities (ETFs) is permitted.
Options Trading-General Guidelines
All persons subject to the Global Asset Management Personal Account Dealing and Code of Ethics Policy (Policy) are strongly discouraged from dealing in any form of derivative that could give rise to an open ended, unlimited liability.
All Covered Persons must obtain pre-clearance via PTA prior to placing an options trade.
Short term trading at a profit is prohibited under the code. Covered Persons may not trade options that will result in a gain if held less than 30 days. Covered Persons must wait trade date plus 30 days before closing the position at a profit.
Acceptable Transactions
| Options that have an expiration greater than 30 days and |
| Out of the money option contracts |
| In the money option contracts only if there is an underlying position held greater than 30 days |
Prohibited Transactions
| Options that have an expiration less than 30 days |
| In the money option contracts unless there is an underlying position held greater than 30 days |
| Buying and selling options contracts at a profit held less than 30 days |
Key Reminders
Covered Persons are required to preclear the option ticker symbol (please use the new option symbology) and not the underlying ticker.
Covered Persons are responsible for calculating the 30 day holding period (Trade date + 30 days), you must use the average cost method (PTA does not calculate the 30 day holding period).
Receiving pre-clearance does not exclude you from other personal trading rules included in the Policy.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
21
APPENDIX H-LIMITED CHOICE POLICY
In order to comply with SEC expectations concerning the monitoring of trading activity within Covered Person accounts, Ameriprise Financial maintains a limited choice brokerage policy which dictates where certain types of securities must be held and traded.
Unless you have an exception approved by Personal Trade Compliance, your personal securities must be held and trading must be conducted through one of these brokers:
| Ameriprise/Columbia Threadneedle North America - Ameriprise Financial Brokerage, Charles Schwab, Merrill Lynch |
| Columbia Threadneedle EMEA and Asia Barclays, Hargreaves Lansdowne, Equiniti, Interactive Brokers, UOB Kay Hian, DBS Bank of Singapore, (Charles Schwab and Merrill Lynch restricted to U.S based accounts only) |
You must immediately* report any new accounts opened by completing the following steps:
| Add the account to the PTA system using the Add Brokerage Account functionality. |
| Notify your broker of your association with Ameriprise Financial or Columbia Threadneedle. You are responsible for notifying your broker that you are affiliated with or employed by a broker/dealer and ensuring that Personal Trade Compliance is provided with duplicate statements and confirmations for your account(s). |
* | North America employees must receive approval from Personal Trade Compliance prior to opening any new brokerage account outside of the Limited Choice Policy in order to comply with FINRA rule 3210. |
The types of securities that are subject to the Limited Choice Policy are specified in Appendix E- Individual Securities Requirements
If you maintain a Brokerage Account outside of the limited choice brokers that holds securities subject to the limited choice policy, you have the following options:
| You may transfer the subject holdings to a like-ownership account at one of the approved brokers. |
| You may liquidate the subject holdings (subject to the requirements in the Code) and either hold the proceeds as cash or reinvest in non-subject securities. |
| You may apply for an exception. |
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
22
Exceptions to the Limited Choice Policy are rare. If you believe your situation warrants an exception (e.g. managed discretionary accounts), contact Personal Trading for a Limited Choice Exception Request Form. An exception does not make you exempt from complying will all other requirements in Global Asset Management Personal Account Dealing and Code of Ethics Policy (Policy).
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
23
COLUMBIA FUNDS SERIES TRUST I
COLUMBIA FUNDS VARIABLE INSURANCE TRUST
(each a Registrant)
POWER OF ATTORNEY
Each of the undersigned constitutes and appoints Michael G. Clarke, Joseph DAlessandro, Paul B. Goucher, Michael E. DeFao, Ryan C. Larrenaga, John M. Loder, Brian D. McCabe, Christopher O. Petersen, and Megan E. Garcy, each individually, his or her true and lawful attorney-in-fact and agent (each an Attorney-in-Fact) with power of substitution or resubstitution, in any and all capacities, including without limitation in the undersigneds capacity as a trustee of each Registrant, in the furtherance of the business and affairs of each Registrant: (i) to execute any and all instruments which said Attorney-in-Fact may deem necessary or advisable or which may be required to comply with the Securities Act of 1933, the Investment Company Act of 1940, the Securities Exchange Act of 1934 (together the Acts) and any other applicable federal securities laws, or rules, regulations or requirements of the U.S. Securities and Exchange Commission (SEC) in respect thereof, in connection with the filing and effectiveness of each Registrants Registration Statement regarding the registration of each Registrant or its shares of beneficial interest, and any and all amendments thereto, including without limitation any reports, forms or other filings required by the Acts or any other applicable federal securities laws, or rules, regulations or requirements of the SEC; and (ii) to execute any and all federal, state or foreign regulatory or other required filings, including all applications with regulatory authorities, state charter or organizational documents and any amendments or supplements thereto, to be executed by, on behalf of, or for the benefit of, each Registrant. The undersigned hereby grants to each Attorney-in-Fact full power and authority to do and perform each and every act and thing contemplated above, as fully and to all intents and purposes as the undersigned might or could do in person, and hereby ratifies and confirms all that said Attorneys-in-Fact, individually or collectively, may lawfully do or cause to be done by virtue hereof.
This Power of Attorney shall not be revoked with respect to any undersigned trustee by any subsequent power of attorney the undersigned may execute unless such subsequent power of attorney specifically refers to this Power of Attorney or specifically states that the instrument is intended to revoke all prior general powers of attorney or all prior powers of attorney (and unless otherwise required by a provision of law that cannot be waived). This Power of Attorney shall terminate automatically with respect to a Registrant if the undersigned ceases to hold the above-referenced office of the Registrant.
Dated: January 1, 2018
[REMAINDER OF THIS PAGE IS LEFT BLANK INTENTIONALLY]
/s/ Janet L. Carrig |
Trustee | |
Janet L. Carrig | ||
/s/ Douglas A. Hacker |
Trustee | |
Douglas A. Hacker | ||
/s/ Nancy T. Lukitsh |
Trustee | |
Nancy T. Lukitsh | ||
/s/ David M. Moffett |
Trustee | |
David M. Moffett | ||
/s/ John J. Neuhauser |
Trustee | |
John J. Neuhauser | ||
/s/ Patrick J. Simpson |
Trustee | |
Patrick J. Simpson | ||
/s/ William F. Truscott |
Trustee | |
William F. Truscott | ||
/s/ Anne-Lee Verville |
Trustee | |
Anne-Lee Verville |