As filed with the Securities and Exchange Commission on February 21, 2018.
Registration Nos. 333-146374
811-22127
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. 61 | ☒ |
and/or
REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940 |
☒ | |
Amendment No. 62 | ☒ |
(Check Appropriate Box or Boxes)
COLUMBIA FUNDS VARIABLE SERIES TRUST II
(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 May 1, 2018 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 Columbia Variable Portfolio Select International Equity Fund (effective May 1, 2018, to be known as Columbia Variable Portfolio Overseas Core Fund) series. Information contained in the Registrants Registration Statement relating to any other series of the Registrant is neither amended nor superseded hereby.
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2 | Prospectus 2018 |
(a) | Other expenses have been restated to reflect current fees paid by the Fund. |
■ | you invest $10,000 in the applicable class of Fund shares 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 | 5 years | 10 years | |
Class 1 (whether or not shares are redeemed) | $[_____] | $[_____] | $[_____] | $[_____] |
Class 2 (whether or not shares are redeemed) | $[_____] | $[_____] | $[_____] | $[_____] |
Class 3 (whether or not shares are redeemed) | $[_____] | $[_____] | $[_____] | $[_____] |
Prospectus 2018 | 3 |
4 | Prospectus 2018 |
Prospectus 2018 | 5 |
6 | Prospectus 2018 |
Prospectus 2018 | 7 |
8 | Prospectus 2018 |
Prospectus 2018 | 9 |
Share
Class
Inception Date |
1 Year | 5 Years | 10 Years | |
Class 1 | 05/03/2010 | — | — | — |
Class 2 | 05/03/2010 | — | — | — |
Class 3 | 01/13/1992 | — | — | — |
MSCI EAFE Index (Net) (reflects reinvested dividends net of withholding taxes but reflects no deductions for fees, expenses or other taxes) | — | — | — |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Fred Copper, CFA | Senior Portfolio Manager | Co-Portfolio Manager | May 2018 | |||
Daisuke Nomoto, CMA (SAAJ) | Senior Portfolio Manager | Co-Portfolio Manager | May 2018 |
10 | Prospectus 2018 |
■ | businesses that are believed to be fundamentally sound and undervalued due to investor indifference, investor misperception of company prospects, or other factors; |
■ | various measures of valuation, including price-to-cash flow, price-to-earnings, price-to-sales, and price-to-book value. The Investment Manager believes that companies with lower valuations are generally more likely to provide opportunities for capital appreciation; |
■ | a company’s current operating margins relative to its historic range and future potential; and/or |
■ | potential indicators of stock price appreciation, such as anticipated earnings growth, company restructuring, changes in management, business model changes, new product opportunities or anticipated improvements in macroeconomic factors. |
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). 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. |
Prospectus 2018 | 13 |
■ | 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 |
22 | Prospectus 2018 |
Prospectus 2018 | 23 |
Portfolio Manager | Title | Role with Fund | Managed Fund Since | |||
Fred Copper, CFA | Senior Portfolio Manager | Co-Portfolio Manager | May 2018 | |||
Daisuke Nomoto, CMA (SAAJ) | Senior Portfolio Manager | Co-Portfolio Manager | May 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; |
24 | Prospectus 2018 |
■ | 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; |
■ | regulatory and other restrictions relating to the sharing of information between Ameriprise Financial and its affiliates, including the Investment Manager, and a Columbia Fund; and |
■ | insurance companies investing in the Fund may be affiliates of Ameriprise Financial; these affiliated insurance companies, individually and collectively, may hold through separate accounts a significant portion of the Fund's shares and may also invest in separate accounts managed by the Investment Manager that have the same or substantially similar investment objectives and strategies as the Fund. |
Prospectus 2018 | 25 |
Class 1 Shares | Class 2 Shares | Class 3 Shares | |
Eligible Investors | Shares of the Fund are available only to separate accounts of participating insurance companies as underlying investments for variable annuity contracts and/or variable life insurance policies (collectively, Contracts) or qualified pension and retirement plans (Qualified Plans) or other eligible investors authorized by the Distributor. | ||
Investment Limits | none | none | none |
Conversion Features | none | none | none |
Front-End Sales Charges | none | none | none |
Contingent Deferred Sales Charges (CDSCs) | none | none | none |
Maximum Distribution and/or Service Fees | none | 0.25% | 0.125% |
26 | Prospectus 2018 |
Prospectus 2018 | 27 |
28 | Prospectus 2018 |
Prospectus 2018 | 29 |
30 | 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; and |
Prospectus 2018 | 31 |
■ | increased brokerage and administrative costs. |
32 | Prospectus 2018 |
■ | 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 | Quarterly |
Distributions | Quarterly |
Prospectus 2018 | 33 |
34 | Prospectus 2018 |
Prospectus 2018 | 35 |
Columbia Funds Variable Series Trust II |
Columbia Variable Portfolio – Balanced Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Commodity Strategy Fund: Class 1 & Class 2 |
Columbia Variable Portfolio – Core Equity Fund*: single class of shares |
Columbia Variable Portfolio – Disciplined Core Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Dividend Opportunity Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Emerging Markets Bond Fund: Class 1 & Class 2 |
Columbia Variable Portfolio – Emerging Markets Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Global Bond Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Government Money Market Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – High Yield Bond Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Income Opportunities Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Intermediate Bond Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Large Cap Growth Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Large Cap Index Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Limited Duration Credit Fund: Class 1 & Class 2 |
Columbia Variable Portfolio – Managed Volatility Moderate Growth Fund: Class 2 |
Columbia Variable Portfolio – Mid Cap Growth Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Mid Cap Value Fund: Class 1, Class 2 & Class 3 |
[Columbia Variable Portfolio – Overseas Core Fund]: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Select Large Cap Equity Fund: Class 1 & Class 2 |
Columbia Variable Portfolio – Select Large-Cap Value Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Select Smaller-Cap Value Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Seligman Global Technology Fund: Class 1 & Class 2 |
Columbia Variable Portfolio – U.S. Equities Fund: Class 1 & Class 2 |
Columbia Variable Portfolio – U.S. Government Mortgage Fund: Class 1, Class 2 & Class 3 |
Variable Portfolio – Aggressive Portfolio: Class 2 & Class 4 |
Variable Portfolio – American Century Diversified Bond Fund: Class 1 & Class 2 |
Variable Portfolio – BlackRock Global Inflation-Protected Securities Fund: Class 1, Class 2 & Class 3 |
Variable Portfolio – CenterSquare Real Estate Fund: Class 1 & Class 2 |
Variable Portfolio – Columbia Wanger International Equities Fund: Class 1 & Class 2 |
Variable Portfolio – Conservative Portfolio: Class 2 & Class 4 |
Variable Portfolio – DFA International Value Fund: Class 1 & Class 2 |
Variable Portfolio – Eaton Vance Floating-Rate Income Fund: Class 1 & Class 2 |
Variable Portfolio – Loomis Sayles Growth Fund: Class 1 & Class 2 |
Variable Portfolio – Los Angeles Capital Large Cap Growth Fund: Class 1 & Class 2 |
Variable Portfolio – MFS ® Blended Research ® Core Equity Fund: Class 1, Class 2 & Class 3 |
Variable Portfolio – MFS ® Value Fund: Class 1 & Class 2 |
Variable Portfolio – Moderate Portfolio: Class 2 & Class 4 |
Variable Portfolio – Moderately Aggressive Portfolio: Class 2 & Class 4 |
Variable Portfolio – Moderately Conservative Portfolio: Class 2 & Class 4 |
Variable Portfolio – Morgan Stanley Advantage Fund: Class 1 & Class 2 |
Variable Portfolio – Oppenheimer International Growth Fund: Class 1 & Class 2 |
Variable Portfolio – Partners Core Bond Fund: Class 1 & Class 2 |
Variable Portfolio – Partners Small Cap Growth Fund: Class 1 & Class 2 |
Variable Portfolio – Partners Small Cap Value Fund: Class 1, Class 2 & Class 3 |
Variable Portfolio – Pyramis ® International Equity Fund: Class 1 & Class 2 |
Variable Portfolio – T. Rowe Price Large Cap Value Fund: Class 1 & Class 2 |
Variable Portfolio – TCW Core Plus Bond Fund: Class 1 & Class 2 |
Variable Portfolio – Victory Sycamore Established Value Fund: Class 1, Class 2 & Class 3 |
Variable Portfolio – Wells Fargo Short Duration Government Fund: Class 1 & Class 2 |
Variable Portfolio – Westfield Mid Cap Growth Fund: Class 1 & Class 2 |
* | This Fund is closed to new investors. |
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A-1 |
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B-1 |
Statement of Additional Information – [May 1, 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 |
Administrative Services Agreement | The Administrative Services Agreement, as amended, if applicable, between the Trust, on behalf of the Funds, and the Investment Manager |
American Century | American Century Investment Management Inc. |
Ameriprise Financial | Ameriprise Financial, Inc. |
BANA | Bank of America, National Association |
Bank of America | Bank of America Corporation |
Barrow Hanley | Barrow, Hanley, Mewhinney & Strauss, LLC |
BlackRock | BlackRock Financial Management, Inc. |
BMO | BMO Asset Management Corp. |
Board | The Trust’s Board of Trustees |
Board Services | Board Services Corporation |
Statement of Additional Information – [May 1, 2018] | 2 |
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 |
CenterSquare | CenterSquare Investment Management LLC |
CFTC | The United States Commodities Futures Trading Commission |
CFVST II | Columbia Funds Variable Series Trust II |
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 |
Columbia WAM | Columbia Wanger Asset Management, LLC |
Custodian | JPMorgan Chase Bank, N.A. |
Denver Investments | Denver Investment Advisors LLC |
DFA | Dimensional Fund Advisors LP |
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. |
Donald Smith | Donald Smith & Co., Inc. |
DST | DST Asset Manager Solutions, Inc. |
Eaton Vance | Eaton Vance Management |
FDIC | Federal Deposit Insurance Corporation |
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 |
Holland | Holland Capital Management LLC |
Independent Trustees | The Trustees of the Board who are not “interested persons” (as defined in the 1940 Act) of the Funds |
Statement of Additional Information – [May 1, 2018] | 3 |
Interested Trustees | The Trustees of the Board who are currently deemed to be “interested persons” (as defined in the 1940 Act) of the Funds |
Invesco | Invesco Advisers, Inc. |
Investment Management Services Agreement | The Investment Management Services Agreements, 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 |
Jacobs Levy | Jacobs Levy Equity Management, Inc. |
Jennison | Jennison Associates LLC |
JPMIM | J.P. Morgan Investment Management Inc. |
JPMorgan | JPMorgan Chase Bank, N.A., the Funds' custodian |
Kennedy | Kennedy Capital Management, Inc. |
LIBOR | London Interbank Offered Rate |
Loomis Sayles | Loomis, Sayles & Company, L.P. |
Los Angeles Capital | Los Angeles Capital Management and Equity Research, Inc. |
Marsico Capital | Marsico Capital Management, LLC |
MFS | Massachusetts Financial Services Company |
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. |
MSIM | Morgan Stanley Investment Management Inc. |
NASDAQ | National Association of Securities Dealers Automated Quotations system |
Nations Funds | The Funds within the Columbia Funds Complex that historically bore the Nations brand |
NAV | Net asset value per share of a Fund |
NFJ | NFJ Investment Group LLC |
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 |
Nuveen Asset Management | Nuveen Asset Management, LLC |
Oppenheimer | OppenheimerFunds Inc. |
Palisade | Palisade Capital Management LLC |
Participating Insurance Companies | Life insurance companies that issue the variable annuity contracts or variable life insurance policies through separate accounts for which the Funds serve as underlying investment vehicles |
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 is an indirect wholly-owned subsidiary of Bank of America. |
Pyramis | FIAM LLC (doing business as Pyramis Global Advisors) |
[___] | [______] |
REIT | Real estate investment trust |
REMIC | Real estate mortgage investment conduit |
Retirement Plan | A qualified plan or retirement arrangement or account through which shares of a Fund are made available. |
RIC | A “regulated investment company,” as such term is used in the Code |
River Road | River Road Asset Management, LLC |
Statement of Additional Information – [May 1, 2018] | 4 |
RiverSource Funds | The Funds within the Columbia Funds Complex that historically bore the RiverSource brand and includes series of CFVST II |
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 |
SBH | Segall Bryant & Hamill, LLC |
SEC | United States Securities and Exchange Commission |
Seligman Funds | The Funds within the Columbia Fund Complex that historically bore the Seligman brand and includes series of CFVST II |
Shareholder Services Agreement | The Shareholder Services Agreement between the Trust, on behalf of its Funds, and the Transfer Agent |
Shares | Shares of a Fund |
Sit Investment | Sit Investment Associates, Inc. |
Snow Capital | Snow Capital Management, L.P. |
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 |
T. Rowe Price | T. Rowe Price Associates, Inc. |
TCW | TCW Investment Management Company LLC |
The London Company | The London Company of Virginia, LLC |
Threadneedle | Threadneedle International Limited |
Transfer Agent | Columbia Management Investment Services Corp. |
Treasury Regulations | Regulations promulgated under the Code by the United States Treasury Department |
Trustee(s) | One or more members of the Board |
Trust | Columbia Funds Variable Series Trust II, the registered investment company in the Columbia Funds Complex to which this SAI relates |
Turner | Turner Investments, L.P. |
VA Contracts | Variable annuity contracts |
Victory Capital | Victory Capital Management Inc. |
VLI Policy(ies) | Variable life insurance policy(ies) |
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 |
VP – Portfolio Navigator Funds | VP – Aggressive Portfolio, VP – Conservative Portfolio, VP – Moderate Portfolio, VP – Moderately Aggressive Portfolio and VP – Moderately Conservative Portfolio |
WellsCap | Wells Capital Management Incorporated |
Westfield | Westfield Capital Management Company, L.P. |
Winslow Capital | Winslow Capital Management LLC |
Statement of Additional Information – [May 1, 2018] | 5 |
Fund Name: | Referred to as: | |
Columbia Variable Portfolio – Balanced Fund | VP – Balanced Fund | |
Columbia Variable Portfolio – Commodity Strategy Fund | VP – Commodity Strategy Fund | |
Columbia Variable Portfolio – Core Equity Fund | VP – Core Equity Fund | |
Columbia Variable Portfolio – Disciplined Core Fund | VP – Disciplined Core Fund | |
Columbia Variable Portfolio – Dividend Opportunity Fund | VP – Dividend Opportunity Fund | |
Columbia Variable Portfolio – Emerging Markets Bond Fund | VP – Emerging Markets Bond Fund | |
Columbia Variable Portfolio – Emerging Markets Fund | VP – Emerging Markets Fund | |
Columbia Variable Portfolio – Global Bond Fund | VP – Global Bond Fund | |
Columbia Variable Portfolio – Government Money Market Fund | VP – Government Money Market Fund | |
Columbia Variable Portfolio – High Yield Bond Fund | VP – High Yield Bond Fund | |
Columbia Variable Portfolio – Income Opportunities Fund | VP – Income Opportunities Fund | |
Columbia Variable Portfolio – Intermediate Bond Fund | VP – Intermediate Bond Fund | |
Columbia Variable Portfolio – Large Cap Growth Fund | VP – Large Cap Growth Fund | |
Columbia Variable Portfolio – Large Cap Index Fund | VP – Large Cap Index Fund | |
Columbia Variable Portfolio – Limited Duration Credit Fund | VP – Limited Duration Credit Fund | |
Columbia Variable Portfolio – Managed Volatility Moderate Growth Fund | VP – MV Moderate Growth Fund | |
Columbia Variable Portfolio – Mid Cap Growth Fund | VP – Mid Cap Growth Fund | |
Columbia Variable Portfolio – Mid Cap Value Fund | VP – Mid Cap Value Fund | |
[Columbia Variable Portfolio – Overseas Core Fund] | [VP – Overseas Core Fund] | |
Columbia Variable Portfolio – Select Large Cap Equity Fund | VP – Select Large Cap Equity Fund | |
Columbia Variable Portfolio – Select Large-Cap Value Fund | VP – Select Large-Cap Value Fund | |
Columbia Variable Portfolio – Select Smaller-Cap Value Fund | VP – Select Smaller-Cap Value Fund | |
Columbia Variable Portfolio – Seligman Global Technology Fund | VP – Seligman Global Technology Fund | |
Columbia Variable Portfolio – U.S. Equities Fund | VP – U.S. Equities Fund | |
Columbia Variable Portfolio – U.S. Government Mortgage Fund | VP – U.S. Government Mortgage Fund | |
Variable Portfolio – Aggressive Portfolio | VP – Aggressive Portfolio | |
Variable Portfolio – American Century Diversified Bond Fund | VP – American Century Diversified Bond Fund | |
Variable Portfolio – BlackRock Global Inflation-Protected Securities Fund |
VP
– BlackRock Global Inflation-Protected
Securities Fund |
|
Variable Portfolio – CenterSquare Real Estate Fund | VP – CenterSquare Real Estate Fund | |
Variable Portfolio – Columbia Wanger International Equities Fund | VP – Columbia Wanger International Equities Fund | |
Variable Portfolio – Conservative Portfolio | VP – Conservative Portfolio | |
Variable Portfolio – DFA International Value Fund | VP – DFA International Value Fund | |
Variable Portfolio – Eaton Vance Floating-Rate Income Fund | VP – Eaton Vance Floating-Rate Income Fund | |
Variable Portfolio – Loomis Sayles Growth Fund | VP – Loomis Sayles Growth Fund | |
Variable Portfolio – Los Angeles Large Cap Growth Fund | VP – Los Angeles Large Cap Growth Fund | |
Variable Portfolio – MFS ® Blended Research ® Core Equity Fund | VP – MFS Blended Research Core Equity Fund | |
Variable Portfolio – MFS ® Value Fund | VP – MFS Value Fund | |
Variable Portfolio – Moderate Portfolio | VP – Moderate Portfolio | |
Variable Portfolio – Moderately Aggressive Portfolio | VP – Moderately Aggressive Portfolio | |
Variable Portfolio – Moderately Conservative Portfolio | VP – Moderately Conservative Portfolio | |
Variable Portfolio – Morgan Stanley Advantage Fund | VP – Morgan Stanley Advantage Fund | |
Variable Portfolio – Oppenheimer International Growth Fund | VP – Oppenheimer International Growth Fund |
Statement of Additional Information – [May 1, 2018] | 6 |
Fund Name: | Referred to as: | |
Variable Portfolio – Partners Core Bond Fund | VP – Partners Core Bond Fund | |
Variable Portfolio – Partners Small Cap Growth Fund | VP – Partners Small Cap Growth Fund | |
Variable Portfolio – Partners Small Cap Value Fund | VP – Partners Small Cap Value Fund | |
Variable Portfolio – Pyramis ® International Equity Fund | VP – Pyramis International Equity Fund | |
Variable Portfolio – T. Rowe Price Large Cap Value Fund | VP – T. Rowe Price Large Cap Value Fund | |
Variable Portfolio – TCW Core Plus Bond Fund | VP – TCW Core Plus Bond Fund | |
Variable Portfolio – Victory Sycamore Established Value Fund | VP – Victory Sycamore Established Value Fund | |
Variable Portfolio – Wells Fargo Short Duration Government Fund | VP – Wells Fargo Short Duration Government Fund | |
Variable Portfolio – Westfield Mid Cap Growth Fund | VP – Westfield Mid Cap Growth Fund |
Statement of Additional Information – [May 1, 2018] | 7 |
Fund | Date Began Operations* | Diversified** | Fund Investment Category*** |
VP – Aggressive Portfolio | May 7, 2010 | Yes | Fund-of-funds – Equity |
VP – American Century Diversified Bond Fund | May 7, 2010 | Yes | Fixed Income |
VP – Balanced Fund | April 30, 1986 | Yes | Flexible |
VP – BlackRock Global Inflation-Protected Securities Fund | September 13, 2004 | No | Fixed Income |
VP – CenterSquare Real Estate Fund | May 7, 2010 | Yes | Equity |
VP – Columbia Wanger International Equities Fund | May 7, 2010 | Yes | Equity |
VP – Commodity Strategy Fund | April 30, 2013 | Yes | Equity |
VP – Conservative Portfolio | May 7, 2010 | Yes | Fund-of-funds – Fixed Income |
VP – Core Equity Fund | September 10, 2004 | Yes | Equity |
VP – DFA International Value Fund | May 7, 2010 | Yes | Equity |
VP – Disciplined Core Fund | October 13, 1981 | Yes | Equity |
VP – Dividend Opportunity Fund | September 15, 1999 | Yes | Equity |
VP – Eaton Vance Floating-Rate Income Fund | May 7, 2010 | Yes | Fixed Income |
VP – Emerging Markets Bond Fund | April 30, 2012 | No | Fixed Income |
VP – Emerging Markets Fund | May 1, 2000 | Yes | Equity |
VP – Global Bond Fund | May 1, 1996 | No | Fixed Income |
VP – Government Money Market Fund | October 31, 1981 | Yes | Money Market |
VP – High Yield Bond Fund | May 1, 1996 | Yes | Fixed Income |
VP – Income Opportunities Fund | June 1, 2004 | Yes | Fixed Income |
VP – Intermediate Bond Fund | October 13, 1981 | Yes | Fixed Income |
VP – Large Cap Growth Fund | September 15, 1999 | Yes | Equity |
VP – Large Cap Index Fund | May 1, 2000 | Yes | Equity |
VP – Limited Duration Credit Fund | May 7, 2010 | Yes | Fixed Income |
VP – Loomis Sayles Growth Fund | May 7, 2010 | Yes | Equity |
VP – Los Angeles Capital Large Cap Growth Fund | May 7, 2010 | Yes | Equity |
VP – MV Moderate Growth Fund | April 19, 2012 | Yes | Fund-of-funds – Equity |
VP – MFS Blended Research Core Equity Fund | May 1, 2006 | Yes | Equity |
VP – MFS Value Fund | May 7, 2010 | Yes | Equity |
VP – Mid Cap Growth Fund | May 1, 2001 | Yes | Equity |
VP – Mid Cap Value Fund | May 2, 2005 | Yes | Equity |
VP – Moderate Portfolio | May 7, 2010 | Yes | Fund-of-funds – Equity |
VP – Moderately Aggressive Portfolio | May 7, 2010 | Yes | Fund-of-funds – Equity |
Statement of Additional Information – [May 1, 2018] | 8 |
Fund | Date Began Operations* | Diversified** | Fund Investment Category*** |
VP – Moderately Conservative Portfolio | May 7, 2010 | Yes | Fund-of-funds – Fixed Income |
VP – Morgan Stanley Advantage Fund | May 7, 2010 | Yes | Equity |
VP – Oppenheimer International Growth Fund | May 7, 2010 | Yes | Equity |
[VP – Overseas Core Fund] | January 13, 1992 | Yes | Equity |
VP – Partners Core Bond Fund | May 7, 2010 | Yes | Fixed Income |
VP – Partners Small Cap Growth Fund | May 7, 2010 | Yes | Equity |
VP – Partners Small Cap Value Fund | August 14, 2001 | Yes | Equity |
VP – Pyramis International Equity Fund | May 7, 2010 | Yes | Equity |
VP – Select Large Cap Equity Fund | January 4, 2018 | Yes | Equity |
VP – Select Large-Cap Value Fund | February 4, 2004 | Yes | Equity |
VP – Select Smaller-Cap Value Fund | September 15, 1999 | Yes | Equity |
VP – Seligman Global Technology Fund | May 1, 1996 | No | Equity |
VP – T. Rowe Price Large Cap Value Fund | May 7, 2010 | Yes | Equity |
VP – TCW Core Plus Bond Fund | May 7, 2010 | Yes | Fixed Income |
VP – U.S. Equities Fund | May 7, 2010 | Yes | Equity |
VP – U.S. Government Mortgage Fund | September 15, 1999 | Yes | Fixed Income |
VP – Victory Sycamore Established Value Fund | February 4, 2004 | Yes | Equity |
VP – Wells Fargo Short Duration Government Fund | May 7, 2010 | Yes | Fixed Income |
VP – Westfield Mid Cap Growth Fund | May 7, 2010 | Yes | Equity |
* | 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 |
VP – CenterSquare Real Estate Fund | June 1, 2016 | Variable Portfolio - Morgan Stanley Global Real Estate Fund |
VP – Disciplined Core Fund |
May
1, 2016
|
Columbia Variable Portfolio – Large Core Quantitative Fund |
VP – Government Money Market Fund | May 1, 2016 | Columbia Variable Portfolio – Cash Management Fund |
VP – Intermediate Bond Fund | May 1, 2015 | Columbia Variable Portfolio – Diversified Bond Fund |
VP – Large Cap Index Fund | May 1, 2015 | Columbia Variable Portfolio – S&P 500 Index Fund |
Statement of Additional Information – [May 1, 2018] | 9 |
Fund |
Effective
Date of
Name Change |
Previous Fund Name |
VP – Loomis Sayles Growth Fund | March 21, 2014 | Variable Portfolio – American Century Growth Fund |
VP – Los Angeles Capital Large Cap Growth Fund | May 1, 2017 | Variable Portfolio – Nuveen Winslow Large Cap Growth Fund |
VP – MV Moderate Growth Fund | April 29, 2013 | Columbia Variable Portfolio – Managed Volatility Fund |
VP – MFS Blended Research Core Equity Fund | May 1, 2016 | Variable Portfolio – Sit Dividend Growth Fund |
VP – Mid Cap Growth Fund |
May
1, 2015
|
Columbia Variable Portfolio – Mid Cap Growth Opportunity Fund |
VP – Mid Cap Value Fund |
May
1, 2015
|
Columbia Variable Portfolio – Mid Cap Value Opportunity Fund |
VP – Morgan Stanley Advantage Fund |
May
1, 2016
March 25, 2013 |
Variable
Portfolio - Holland Large Cap Growth Fund
Variable Portfolio – Marsico Growth Fund |
VP – Oppenheimer International Growth Fund | May 1, 2016 | Variable Portfolio – Invesco International Growth Fund |
[VP – Overseas Core Fund] | May 1, 2018 | Columbia Variable Portfolio – Select International Equity Fund |
May 1, 2015 | Columbia Variable Portfolio – International Opportunity Fund | |
VP – Partners Core Bond Fund | May 1, 2017 | Variable Portfolio – J.P. Morgan Core Bond Fund |
VP – T. Rowe Price Large Cap Value Fund | November 14, 2016 | Variable Portfolio – NFJ Dividend Value Fund |
VP – TCW Core Plus Bond Fund | March 21, 2014 | Variable Portfolio – PIMCO Mortgage-Backed Securities Fund |
VP – U.S. Equities Fund | May 1, 2015 | Variable Portfolio – Columbia Wanger U.S. Equities Fund |
VP – U.S. Government Mortgage Fund | May 1, 2013 | Columbia Variable Portfolio – Short Duration U.S. Government Fund |
VP – Victory Sycamore Established Value Fund | May 1, 2016 | Variable Portfolio – Victory Established Value Fund |
VP – Westfield Mid Cap Growth Fund | September 18, 2017 | Variable Portfolio – Jennison Mid Cap Growth Fund |
Statement of Additional Information – [May 1, 2018] | 10 |
Statement of Additional Information – [May 1, 2018] | 11 |
A. | Buy or sell real estate |
A1 – | 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 securities or other instruments backed by real estate or securities of companies engaged in the real estate business or real estate investment trusts. For purposes of this policy, real estate includes real estate limited partnerships. |
A2 – | The Fund will not buy or sell real estate, commodities or commodity contracts. For purposes of this policy, real estate includes real estate limited partnerships. |
Statement of Additional Information – [May 1, 2018] | 12 |
A3 – | The Fund will not purchase or hold any real estate, except the Fund may invest in securities secured by real estate or interests therein or issued by persons (including real estate investment trusts) which deal in real estate or interests therein. |
A4 – | 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 will not buy or sell physical commodities unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the Fund from buying or selling options and futures contracts or from investing in securities or other instruments backed by, or whose value is derived from, physical commodities. |
B2 – | The Fund will not buy or sell physical commodities unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the Fund from buying or selling options, futures contracts and foreign currency or from investing in securities or other instruments backed by, or whose value is derived from, physical commodities. |
B3 – | The Fund will not purchase or sell commodities or commodity contracts, except to the extent permissible under applicable law and interpretations, as they may be amended from time to time. |
B4 – | The Fund will not buy or sell physical commodities unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the Fund from buying or selling options, futures contracts and foreign currency or from entering into forward currency contracts or from investing in securities or other instruments backed by, or whose value is derived from, physical commodities. |
B5 – | The Fund will not buy or sell commodities unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the fund from transacting in derivative instruments relating to commodities, including but not limited to, buying or selling options, swap contracts or futures contracts or from investing in securities or other instruments backed by, or whose value is derived from, commodities. |
B6 – | The Fund will not buy or sell commodities, except that the Fund may to the extent consistent with its investment objective(s), invest in securities of companies that purchase or sell commodities or which invest in such programs, and purchase and sell options, forward contracts, futures contracts, and options on futures contracts and enter into swap contracts and other financial transactions relating to commodities. This restriction does not apply to foreign currency transactions including without limitation forward currency contracts. This restriction also does not prevent the Fund from investing up to 25% of its total assets in one or more wholly-owned subsidiaries (as described further herein and referred to herein collectively as the “Subsidiary”), thereby gaining exposure to the investment returns of commodities markets within the limitations of the federal tax requirements.* |
B7 – | 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. |
* | 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 will not purchase more than 10% of the outstanding voting securities of an issuer, except that up to 25% of the Fund’s assets may be invested without regard to this 10% limitation. |
C2 – | The Fund will not make any investment inconsistent with its classification as a diversified company under the 1940 Act. |
C3 – | 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 |
Statement of Additional Information – [May 1, 2018] | 13 |
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. | |
C4 – | The Fund will not purchase more than 10% of the outstanding voting securities of an issuer, except that up to 25% of the Fund’s assets may be invested without regard to this 10% limitation. For tax-exempt Funds, for purposes of this policy, the terms of a municipal security determine the issuer. |
* | 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. | Lending |
D1 – | The Fund will not lend securities or participate in an interfund lending program if the total of all such loans would exceed 33 1 ⁄ 3 % of the Fund’s total assets, except this fundamental investment policy shall not prohibit the Fund from purchasing money market securities, loans, loan participation or other debt securities, or from entering into repurchase agreements. |
D2 – | The Fund will not make loans, except as permitted by the 1940 Act or any rule thereunder, any SEC or SEC staff interpretations thereof or any exemptions therefrom which may be granted by the SEC. |
D3 – | 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. |
E. | Act as an underwriter |
E1 – | The Fund will not act as an underwriter (sell securities for others). However, under the securities laws, the Fund may be deemed to be an underwriter when it purchases securities directly from the issuer and later resells them. |
E2 – | The Fund will not underwrite the securities of other issuers, except insofar as the Fund may be deemed an underwriter under the 1933 Act in disposing of a portfolio security or in connection with investments in other investment companies. |
E3 – | 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. |
F. | Borrowing |
F1 – | The Fund will not borrow money, except for temporary purposes (not for leveraging or investment) in an amount not exceeding 33 1 ⁄ 3 % of its total assets (including the amount borrowed) less liabilities (other than borrowings) immediately after the borrowings. |
F2 – | The Fund will not issue senior securities or borrow money, except as permitted by the 1940 Act or any rule thereunder, any SEC or SEC staff interpretations thereof or any exceptions therefrom which may be granted by the SEC. For borrowing, the 1940 Act permits a fund to borrow up to 33 1 ⁄ 3 % of its total assets (including the amounts borrowed) from banks, plus an additional 5% of its total assets for temporary purposes, which may be borrowed from banks or other sources. |
F3 – | 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. |
G. | Issue senior securities |
G1 – | The Fund will not issue senior securities, except as permitted under the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
H. | Concentration* |
H1 – | The Fund will not concentrate in any one industry. According to the present interpretation by the SEC, this means that up to 25% of the Fund’s total assets, based on current market value at time of purchase, can be invested in any one industry. |
H2 – | 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 |
Statement of Additional Information – [May 1, 2018] | 14 |
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. | |
H3 – | While the Fund may invest 25% or more of its total assets in the securities of foreign governmental and corporate entities located in the same country, it will not invest 25% or more of its total assets in any single foreign governmental issuer. |
H4 – | The Fund will not invest more than 25% of the market value of its total assets in the securities of issuers in any particular industry, except the Fund will invest more than 25% of the value of its total assets in securities of issuers principally engaged in the real estate industry and may invest without limit in securities issued or guaranteed by the U.S. government or any of its agencies or instrumentalities. |
H5 – | The Fund will not invest 25% or more of its total assets in securities of corporate issuers engaged in any one industry. The foregoing restriction does not apply to securities issued or guaranteed by the U.S. government or any of its agencies or instrumentalities, or repurchase agreements secured by them. In addition, the foregoing restriction shall not apply to or limit the Fund’s counterparties in commodities-related transactions. |
H6 – | 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 management investment companies to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
H7 – | 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. 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. |
■ | Buy on margin or sell short or deal in options to buy or sell securities. |
■ | Purchase common stocks, preferred stocks, warrants, other equity securities, corporate bonds or debentures, state bonds, municipal bonds, or industrial revenue bonds. |
■ | Intentionally invest more than 25% of the Fund’s assets taken at market value in any particular industry, except with respect to investing in U.S. government or agency securities and bank obligations. Investments are varied according to what is judged advantageous under different economic conditions. |
■ | Purchase securities on margin except as permitted by the 1940 Act or any rule thereunder, any Securities and Exchange Commission (the “SEC”) or SEC staff interpretations thereof or any exemptions therefrom which may be granted by the SEC. |
Statement of Additional Information – [May 1, 2018] | 15 |
■ | Up to 25% of the Fund’s net assets may be invested in foreign investments. |
■ | Up to 20% of the Fund’s net assets may be invested in foreign investments. |
■ | Up to 20% of the Fund’s total assets may be invested in foreign investments. |
■ | Up to 15% of the Fund’s net assets may be invested in foreign investments. |
■ | The Fund will not (subject to the succeeding sentence) 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 government securities, cash and/or repurchase agreements collateralized solely by government securities or cash; 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 to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. If, at a future date, the Fund ceases to be a government money market fund and becomes a money market fund that may invest significantly in Rule 2a-7 eligible securities issued by non-government entities, the Fund may invest more than 25% of its total assets in money market instruments issued by U.S. banks or U.S. branches of foreign banks (subject to the applicable requirements of Rule 2a-7) and U.S. Government securities. |
■ | The Fund will not invest in oil, gas or other mineral exploration or development programs; provided, however, that this investment restriction shall not prohibit the fund from purchasing publicly-traded securities of companies engaging in whole or in part in such activities. |
■ | The Fund will not purchase securities from or sell securities to any of its officers or Trustees, except with respect to its own shares and as permissible under applicable statutes, rule ad regulations. |
■ | The Fund will not invest more than 5% of the value of its net assets, valued at the lower of cost or market, in warrants, of which no more than 2% of net assets may be invested in warrants and rights not listed on the New York or American Stock Exchange. For this purpose, warrants acquired by the fund in units or attached to securities may be deemed to have been purchased without cost. |
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Type of Investment |
Equity
and Flexible |
Funds-of-Funds
– Equity and Fixed Income |
Taxable
Fixed Income |
Money
Market |
Asset-Backed Securities | • | • | • | • |
Bank Obligations (Domestic and Foreign) | • | • | • | • |
Collateralized Bond Obligations | • | • | • | • |
Commercial Paper | • | • | • | • |
Statement of Additional Information – [May 1, 2018] | 19 |
Type of Investment |
Equity
and Flexible |
Funds-of-Funds
– Equity and Fixed Income |
Taxable
Fixed Income |
Money
Market |
Common Stock | • | • | •A | — |
Convertible Securities | • | • | • | — |
Corporate Debt Securities | • | • | • | •B |
Custody Receipts and Trust Certificates | • | • | • | • |
Debt Obligations | • | • | • | • |
Depositary Receipts | • | • | •C | — |
Derivatives | • | • | • | — |
Dollar Rolls | •D | • | • | — |
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 | •E | • | • | — |
Investments in Other Investment Companies (Including ETFs) | • | • | • | • |
Listed Private Equity Funds | • | • | • | — |
Money Market Instruments | • | • | • | • |
Mortgage-Backed Securities | •F | • | • | • |
Municipal Securities | • | • | • | • |
Participation Interests | • | • | • | — |
Partnership Securities | • | • | • | — |
Preferred Stock | • | • | •G | — |
Private Placement and Other Restricted Securities | • | • | • | • |
Real Estate Investment Trusts | • | • | • | — |
Repurchase Agreements | • | • | • | • |
Reverse Repurchase Agreements | • | • | • | • |
Short Sales | • | • | • | — |
Sovereign Debt | • | • | • | • |
Standby Commitments | • | • | • | • |
U.S. Government and Related Obligations | • | • | • | • |
Variable- and Floating-Rate Obligations | •H | • | • | •I |
Warrants and Rights | • | • | • | — |
A. | The following Fund is not authorized to invest in Common Stock: VP - U.S. Government Mortgage Fund. |
B. | While the Fund is prohibited from investing in corporate bonds, it may invest in securities classified as corporate bonds if they meet the requirements of Rule 2a-7 of the 1940 Act. |
C. | The following Fund is not authorized to invest in Depository Receipts: VP - U.S. Government Mortgage Fund. |
D. | The following Funds are authorized to invest in Dollar Rolls: VP – Balanced Fund, VP – Commodity Strategy Fund, VP – Core Equity Fund, VP – Disciplined Core Fund and VP – Select Large Cap Equity Fund. |
E. | The following Funds are authorized to invest in Inverse Floaters: VP – Balanced Fund, VP – Commodity Strategy Fund, VP - Disciplined Core Fund and VP – Select Large Cap Equity Fund. |
F. | The following Funds are not authorized to invest in Mortgage-Backed Securities: VP – Large Cap Index Fund and VP - Select Smaller-Cap Value Fund. |
G. | The following Fund is not authorized to invest in Preferred Stock: VP - U.S. Government Mortgage Fund. |
Statement of Additional Information – [May 1, 2018] | 20 |
H. | The following Funds are authorized to invest in Floating-Rate Loans: VP – Balanced, VP - Commodity Strategy Fund and VP – Select Large Cap Equity Fund. |
I. | The Fund is not authorized to invest in floating rate loans. This restriction is not intended to prevent the Fund from investing in variable and floating rate instruments that are permissible investments for money market funds under Rule 2a-7. |
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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 |
Statement of Additional Information – [May 1, 2018] | 59 |
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. |
■ | 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. |
Statement of Additional Information – [May 1, 2018] | 60 |
■ | 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. |
Statement of Additional Information – [May 1, 2018] | 61 |
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 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) |
Statement of Additional Information – [May 1, 2018] | 62 |
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 |
VP – American Century Diversified Bond Fund (a) | $0-$500 | 0.500% |
>$500-$1,000 | 0.495% | |
>$1,000-$2,000 | 0.480% | |
>$2,000-$3,000 | 0.460% | |
>$3,000-$6,000 | 0.445% | |
>$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% | |
VP – Balanced Fund | $0-$500 | 0.720% |
>$500-$1,000 | 0.670% | |
>$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% | |
VP – BlackRock Global Inflation-Protected Securities Fund | $0-$500 | 0.510% |
>$500-$1,000 | 0.505% | |
>$1,000-$2,000 | 0.475% | |
>$2,000-$3,000 | 0.450% | |
>$3,000-$6,000 | 0.415% | |
>$6,000-$7,500 | 0.390% | |
>$7,500-$9,000 | 0.375% | |
>$9,000-$10,000 | 0.370% | |
>$10,000-$12,000 | 0.360% | |
>$12,000-$15,000 | 0.350% | |
>$15,000-$20,000 | 0.340% | |
>$20,000-$24,000 | 0.330% | |
>$24,000-$50,000 | 0.310% | |
>$50,000 | 0.290% | |
VP - CenterSquare Real Estate Fund | $0-$500 | 0.750% |
>$500-$1,000 | 0.745% | |
>$1,000-$1,500 | 0.720% | |
>$1,500-$3,000 | 0.670% | |
>$3,000 | 0.660% | |
VP – Columbia Wanger International Equities Fund | $0-$250 | 1.030% |
>$250-$500 | 0.980% | |
>$500-$1,000 | 0.925% | |
>$1,000-$3,000 | 0.820% | |
>$3,000-$12,000 | 0.780% | |
>$12,000 | 0.770% | |
VP – Commodity Strategy Fund (b) | $0-$500 | 0.630% |
>$500-$1,000 | 0.580% | |
>$1,000-$3,000 | 0.550% | |
>$3,000-$6,000 | 0.520% | |
>$6,000-$12,000 | 0.500% | |
>$12,000 | 0.490% | |
VP – Core Equity Fund | All | 0.400% |
Statement of Additional Information – [May 1, 2018] | 85 |
Fund |
Assets
(millions) |
Annual
rate at
each asset level |
VP – DFA International Value Fund | $0-$500 | 0.870% |
>$500-$1,000 | 0.820% | |
>$1,000-$1,500 | 0.770% | |
>$1,500-$3,000 | 0.720% | |
>$3,000-$6,000 | 0.700% | |
>$6,000-$12,000 | 0.680% | |
>$12,000 | 0.670% | |
VP
– Disciplined Core Fund
VP – Select Large-Cap Value Fund |
$0-$500 | 0.770% |
>$500-$1,000 | 0.715% | |
>$1,000-$3,000 | 0.615% | |
>$3,000-$6,000 | 0.600% | |
>$6,000-$12,000 | 0.580% | |
>$12,000 | 0.570% | |
VP – Dividend Opportunity Fund | $0-$500 | 0.720% |
>$500-$1,000 | 0.670% | |
>$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% | |
VP – Eaton Vance Floating-Rate Income Fund | $0-$500 | 0.700% |
>$500-$1,000 | 0.695% | |
>$1,000-$2,000 | 0.640% | |
>$2,000-$3,000 | 0.590% | |
>$3,000-$12,000 | 0.580% | |
>$12,000 | 0.570% | |
VP – Emerging Markets Bond Fund | $0-$500 | 0.600% |
>$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% | |
VP – Emerging Markets Fund (c) | $0-$500 | 1.100% |
>$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% | |
VP – Global Bond Fund | $0-$500 | 0.650% |
>$500-$1,000 | 0.645% | |
>$1,000-$2,000 | 0.595% | |
>$2,000-$3,000 | 0.590% | |
>$3,000-$6,000 | 0.575% | |
>$6,000-$7,500 | 0.570% | |
>$7,500-$12,000 | 0.560% | |
>$12,000-$20,000 | 0.540% | |
>$20,000-$50,000 | 0.530% | |
>$50,000 | 0.520% |
Statement of Additional Information – [May 1, 2018] | 86 |
Fund |
Assets
(millions) |
Annual
rate at
each asset level |
VP – Government Money Market Fund | $0-$500 | 0.390% |
>$500-$1,000 | 0.385% | |
>$1,000-$1,500 | 0.363% | |
>$1,500-$2,000 | 0.345% | |
>$2,000-$2,500 | 0.328% | |
>$2,500-$3,000 | 0.310% | |
>$3,000-$5,000 | 0.300% | |
>$5,000-$6,000 | 0.280% | |
>$6,000-$7,500 | 0.260% | |
>$7,500-$9,000 | 0.255% | |
>$9,000-$10,000 | 0.230% | |
>$10,000-$12,000 | 0.220% | |
>$12,000-$15,000 | 0.210% | |
>$15,000-$20,000 | 0.200% | |
>$20,000-$24,000 | 0.190% | |
>$24,000 | 0.180% | |
VP
– High Yield Bond Fund
VP – Income Opportunities Fund |
$0-$250 | 0.660% |
>$250-$500 | 0.645% | |
>$500-$750 | 0.635% | |
>$750-$1,000 | 0.625% | |
>$1,000-$2,000 | 0.610% | |
>$2,000-$3,000 | 0.600% | |
>$3,000-$6,000 | 0.565% | |
>$6,000-$7,500 | 0.540% | |
>$7,500-$9,000 | 0.525% | |
>$9,000-$10,000 | 0.500% | |
>$10,000-$12,000 | 0.485% | |
>$12,000-$15,000 | 0.475% | |
>$15,000-$20,000 | 0.465% | |
>$20,000-$24,000 | 0.440% | |
>$24,000-$50,000 | 0.425% | |
>$50,000 | 0.400% | |
VP – Intermediate Bond Fund | $0-$500 | 0.500% |
VP – TCW Core Plus Bond Fund (d) | >$500-$1,000 | 0.495% |
>$1,000-$2,000 | 0.480% | |
>$2,000-$3,000 | 0.460% | |
>$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% | |
VP – Large Cap Growth Fund | $0-$500 | 0.770% |
VP – MFS Blended Research Core Equity Fund | >$500-$1,000 | 0.720% |
VP – Victory Sycamore Established Value Fund (d) | >$1,000-$1,500 | 0.670% |
>$1,500-$3,000 | 0.620% | |
>$3,000-$6,000 | 0.600% | |
>$6,000-$12,000 | 0.580% | |
>$12,000 | 0.570% | |
VP – Large Cap Index Fund | All | 0.200% |
Statement of Additional Information – [May 1, 2018] | 87 |
Fund |
Assets
(millions) |
Annual
rate at
each asset level |
VP – Limited Duration Credit Fund | $0-$500 | 0.480% |
>$500-$1,000 | 0.475% | |
>$1,000-$2,000 | 0.465% | |
>$2,000-$3,000 | 0.460% | |
>$3,000-$6,000 | 0.445% | |
>$6,000-$7,500 | 0.430% | |
>$7,500-$9,000 | 0.415% | |
>$9,000-$10,000 | 0.410% | |
>$10,000-$12,000 | 0.400% | |
>$12,000-$15,000 | 0.390% | |
>$15,000-$20,000 | 0.380% | |
>$20,000-$24,000 | 0.370% | |
>$24,000-$50,000 | 0.350% | |
>$50,000 | 0.330% | |
VP – Loomis Sayles Growth Fund | $0-$500 | 0.710% |
VP – MFS Value Fund | >$500-$1,000 | 0.705% |
VP – T. Rowe Price Large Cap Value Fund | >$1,000-$2,000 | 0.650% |
VP – Los Angeles Capital Large Cap Growth Fund | >$2,000-$3,000 | 0.550% |
>$3,000-$12,000 | 0.540% | |
>$12,000 | 0.530% | |
VP
– Mid Cap Growth Fund
VP – Mid Cap Value Fund |
$0-$500 | 0.820% |
>$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% | |
VP – Morgan Stanley Advantage Fund | $0-$500 | 0.710% |
>$500-$1,000 | 0.705% | |
>$1,000-$1,500 | 0.650% | |
>$1,500-$2,000 | 0.600% | |
>$2,000-$3,000 | 0.550% | |
>$3,000-$12,000 | 0.540% | |
>$12,000 | 0.530% | |
VP – Oppenheimer International Growth Fund | $0-$500 | 0.930% |
VP – Pyramis International Equity Fund | >$500-$1,000 | 0.925% |
>$1,000-$2,000 | 0.870% | |
>$2,000-$3,000 | 0.770% | |
>$3,000-$12,000 | 0.760% | |
>$12,000 | 0.750% | |
VP – Overseas Core Fund | $0-$250 | 0.880% |
>$250-$500 | 0.855% | |
>$500-$750 | 0.825% | |
>$750-$1,000 | 0.800% | |
>$1,000-$1,500 | 0.770% | |
>$1,500-$3,000 | 0.720% | |
>$3,000-$6,000 | 0.700% | |
>$6,000-$12,000 | 0.680% | |
>$12,000-$20,000 | 0.670% | |
>$20,000-$24,000 | 0.660% | |
>$24,000-$50,000 | 0.650% | |
>$50,000 | 0.620% |
Statement of Additional Information – [May 1, 2018] | 88 |
Fund |
Assets
(millions) |
Annual
rate at
each asset level |
VP – Partners Core Bond Fund (e) | $0-$500 | 0.500% |
>$500-$1,000 | 0.495% | |
>$1,000-$2,000 | 0.480% | |
>$2,000-$3,000 | 0.460% | |
>$3,000-$6,000 | 0.445% | |
>$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% | |
VP – Select Large Cap Equity Fund | $0-$500 | 0.770% |
>$500-$1,000 | 0.720% | |
>$1,000-$1,500 | 0.670% | |
>$1,500-$3,000 | 0.620% | |
>$3,000-$6,000 | 0.600% | |
>$6,000-$12,000 | 0.580% | |
>$12,000 | 0.570% | |
VP – Select Smaller-Cap Value Fund | $0-$500 | 0.870% |
VP – Partners Small Cap Growth Fund (d) | >$500-$1,000 | 0.820% |
VP – Partners Small Cap Value Fund (d) | >$1,000-$3,000 | 0.770% |
VP – U.S. Equities Fund | >$3,000-$12,000 | 0.760% |
>$12,000 | 0.750% | |
VP – Seligman Global Technology Fund (c) | $0-$500 | 0.915% |
>$500-$1,000 | 0.910% | |
>$1,000-$3,000 | 0.905% | |
>$3,000-$4,000 | 0.865% | |
>$4,000-$6,000 | 0.815% | |
>$6,000-$12,000 | 0.765% | |
>$12,000 | 0.755% | |
VP – U.S. Government Mortgage Fund | $0-$500 | 0.430% |
VP – Wells Fargo Short Duration Government Fund (d) | >$500-$1,000 | 0.425% |
>$1,000-$2,000 | 0.415% | |
>$2,000-$3,000 | 0.410% | |
>$3,000-$6,000 | 0.395% | |
>$6,000-$7,500 | 0.380% | |
>$7,500-$9,000 | 0.365% | |
>$9,000-$10,000 | 0.360% | |
>$10,000-$12,000 | 0.350% | |
>$12,000-$15,000 | 0.340% | |
>$15,000-$20,000 | 0.330% | |
>$20,000-$24,000 | 0.320% | |
>$24,000-$50,000 | 0.300% | |
>$50,000 | 0.280% | |
VP – Westfield Mid Cap Growth Fund | $0-$500 | 0.810% |
>$500-$1,000 | 0.805% | |
>$1,000-$2,000 | 0.750% | |
>$2,000-$3,000 | 0.700% | |
>$3,000-$12,000 | 0.690% | |
>$12,000 | 0.680% |
(a) | Effective October 1, 2017, the management fee schedule changed resulting in a fee rate decrease for all asset levels. |
(b) | When calculating asset levels for purposes of determining fee breakpoints, asset levels are based on net assets of the Fund, including assets invested in any wholly-owned subsidiary advised by the Investment Manager (“Subsidiaries”). Fees payable by the Fund under this agreement shall be reduced by any management services fees paid to the Investment Manager by any Subsidiaries under separate management agreements with the Subsidiaries. |
(c) | Effective July 1, 2017, the management fee schedule changed resulting in a fee rate decrease for all asset levels. |
(d) | Effective July 1, 2016, the management fee schedule changed resulting in a fee rate decrease for all asset levels. |
(e) | Effective May 1, 2017, the management fee schedule changed resulting in a fee rate decrease for all asset levels. |
Statement of Additional Information – [May 1, 2018] | 89 |
Management Services Fees | |||
2016 | 2015 | 2014 | |
For Funds with fiscal period ending December 31 | |||
VP – Aggressive Portfolio | $797,196 | N/A | N/A |
VP – American Century Diversified Bond Fund | 13,774,265 | N/A | N/A |
VP – Balanced Fund | 4,763,188 | N/A | N/A |
VP – BlackRock Global Inflation-Protected Securities Fund | 471,647 | N/A | N/A |
VP – CenterSquare Real Estate Fund | 1,818,751 | N/A | N/A |
VP – Columbia Wanger International Equities Fund | 610,613 | N/A | N/A |
VP – Commodity Strategy Fund | 1,299,489 | N/A | N/A |
VP – Conservative Portfolio | 345,947 | N/A | N/A |
VP – Core Equity Fund | 512,682 | N/A | N/A |
VP – DFA International Value Fund | 10,867,274 | N/A | N/A |
VP – Disciplined Core Fund | 20,045,674 | N/A | N/A |
VP – Dividend Opportunity Fund | 7,705,253 | N/A | N/A |
VP – Eaton Vance Floating-Rate Income Fund | 592,629 | N/A | N/A |
VP – Emerging Markets Bond Fund | 519,406 | N/A | N/A |
Statement of Additional Information – [May 1, 2018] | 90 |
Management Services Fees | |||
2016 | 2015 | 2014 | |
VP – Emerging Markets Fund | $4,979,317 | N/A | N/A |
VP – Global Bond Fund | 760,642 | N/A | N/A |
VP – Government Money Market Fund | 930,572 | N/A | N/A |
VP – High Yield Bond Fund | 2,010,315 | N/A | N/A |
VP – Income Opportunities Fund | 1,778,125 | N/A | N/A |
VP – Intermediate Bond Fund | 16,638,025 | N/A | N/A |
VP – Large Cap Growth Fund | 6,988,682 | N/A | N/A |
VP – Large Cap Index Fund | 451,663 | N/A | N/A |
VP – Limited Duration Credit Fund | 2,913,607 | N/A | N/A |
VP – Loomis Sayles Growth Fund | 11,431,665 | N/A | N/A |
VP – Los Angeles Capital Large Cap Growth Fund | 5,285,465 | N/A | N/A |
VP – MFS Blended Research Core Equity Fund | 8,108,536 | N/A | N/A |
VP – MFS Value Fund | 9,437,652 | N/A | N/A |
VP – Mid Cap Growth Fund | 2,215,122 | N/A | N/A |
VP – Mid Cap Value Fund | 1,332,877 | N/A | N/A |
VP – Moderate Portfolio | 4,521,377 | N/A | N/A |
VP – Moderately Aggressive Portfolio | 2,551,985 | N/A | N/A |
VP – Moderately Conservative Portfolio | 1,010,729 | N/A | N/A |
VP – Morgan Stanley Advantage Fund | 5,098,123 | N/A | N/A |
VP – MV Moderate Growth Fund | 15,583,924 | N/A | N/A |
VP – Oppenheimer International Growth Fund | 13,645,900 | N/A | N/A |
VP – Overseas Core Fund | 5,454,983 | N/A | N/A |
VP – Partners Core Bond Fund | 11,344,496 | N/A | N/A |
VP – Partners Small Cap Growth Fund | 3,660,608 | N/A | N/A |
VP – Partners Small Cap Value Fund | 4,966,551 | N/A | N/A |
VP – Pyramis International Equity Fund | 13,510,828 | N/A | N/A |
VP – Select Large Cap Equity Fund (a) | N/A | N/A | N/A |
VP – Select Large-Cap Value Fund | 4,337,996 | N/A | N/A |
VP – Select Smaller-Cap Value Fund | 791,889 | N/A | N/A |
VP – Seligman Global Technology Fund | 392,686 | N/A | N/A |
VP – T. Rowe Price Large Cap Value Fund | 9,267,324 | N/A | N/A |
VP – TCW Core Plus Bond Fund | 10,120,409 | N/A | N/A |
VP – U.S. Equities Fund | 5,828,666 | N/A | N/A |
VP – U.S. Government Mortgage Fund | 3,723,498 | N/A | N/A |
VP – Victory Sycamore Established Value Fund | 2,083,102 | N/A | N/A |
VP – Wells Fargo Short Duration Government Fund | 3,461,474 | N/A | N/A |
VP – Westfield Mid Cap Growth Fund | 2,004,709 | N/A | N/A |
(a) | No historical information is given for the Fund because the Fund had not commenced operations as of the date of this SAI. |
Statement of Additional Information – [May 1, 2018] | 91 |
Investment Advisory Services Fees | |||
Fund | 2016 | 2015 | 2014 |
VP - Aggressive Portfolio | $111,766 | $55,502 (a) | N/A |
VP - American Century Diversified Bond Fund | $5,975,793 | $16,803,199 | $13,642,791 |
VP - Balanced Fund | $1,982,606 | $6,217,315 | $6,065,947 |
VP - BlackRock Global Inflation-Protected Securities Fund | $200,475 | $2,935,317 | $7,935,153 |
VP - CenterSquare Real Estate Fund | $579,504 | $1,859,524 | $2,404,815 |
VP - Columbia Wanger International Equities Fund | $781,399 | $4,472,034 | $6,543,936 |
VP - Commodity Strategy Fund | $82,518 | $302,096 | $608,599 |
VP - Conservative Portfolio | $65,597 | $30,792 (a) | N/A |
VP - Core Equity Fund | $248,118 | $857,680 | $856,192 |
VP - DFA International Value Fund | $5,168,273 | $15,094,103 | $11,898,365 |
VP - Disciplined Core Fund | $7,990,251 | $22,478,813 | $15,272,697 |
VP - Dividend Opportunity Fund | $3,318,587 | $14,082,422 | $19,147,719 |
VP - Eaton Vance Floating-Rate Income Fund | $246,065 | $1,954,546 | $4,515,608 |
VP - Emerging Markets Bond Fund | $184,866 | $723,813 | $1,291,957 |
VP - Emerging Markets Fund | $3,726,672 | $12,339,148 | $11,264,531 |
VP - Global Bond Fund | $345,265 | $2,104,604 | $4,389,429 |
VP - Government Money Market Fund | $461,169 | $1,626,527 | $1,810,553 |
VP - High Yield Bond Fund | $865,790 | $3,024,392 | $3,384,876 |
VP - Income Opportunities Fund | $1,122,268 | $4,743,338 | $6,749,777 |
VP - Intermediate Bond Fund | $7,072,003 | $18,727,955 | $12,303,227 |
VP - Large Cap Growth Fund | $2,964,994 | $9,561,760 | $8,699,644 |
VP - Large Cap Index Fund | $100,247 | $318,575 | $279,617 |
VP - Limited Duration Credit Fund | $1,213,701 | $5,967,192 | $11,674,392 |
VP - Loomis Sayles Growth Fund | $4,240,686 | $11,308,372 | $7,553,462 |
VP - Los Angeles Capital Large Cap Growth Fund | $2,742,868 | $9,795,325 | $8,960,596 |
VP - MFS Blended Research Core Equity Fund | $3,904,063 | $13,177,697 | $12,045,692 |
Statement of Additional Information – [May 1, 2018] | 92 |
Investment Advisory Services Fees | |||
Fund | 2016 | 2015 | 2014 |
VP - MFS Value Fund | $3,882,003 | $13,405,143 | $13,861,096 |
VP - Mid Cap Growth Fund | $728,498 | $2,592,055 | $3,395,397 |
VP - Mid Cap Value Fund | $308,742 | $2,022,258 | $4,493,381 |
VP - Moderate Portfolio | $906,615 | $447,480 (a) | N/A |
VP - Moderately Aggressive Portfolio | $470,060 | $225,835 (a) | N/A |
VP - Moderately Conservative Portfolio | $186,541 | $85,394 (a) | N/A |
VP - Morgan Stanley Advantage Fund | $2,357,826 | $8,583,601 | $8,995,422 |
VP - MV Moderate Growth Fund | $6,057,675 | $17,864,244 | $14,033,814 |
VP - Oppenheimer International Growth Fund | $6,000,754 | $18,323,907 | $16,441,468 |
VP - Overseas Core Fund | $1,034,793 | $2,841,750 | $3,074,699 |
VP - Partners Core Bond Fund | $4,861,434 | $14,312,624 | $13,426,064 |
VP - Partners Small Cap Growth Fund | $1,650,861 | $5,115,336 | $5,002,012 |
VP - Partners Small Cap Value Fund | $3,343,746 | $12,883,522 | $16,166,737 |
VP - Pyramis International Equity Fund | $5,840,536 | $17,043,226 | $12,322,525 |
VP - Select Large-Cap Value Fund | $1,781,870 | $6,562,242 | $6,485,859 |
VP - Select Smaller-Cap Value Fund | $373,692 | $1,388,558 | $1,447,401 |
VP - Seligman Global Technology Fund | $338,025 | $1,123,742 | $1,069,079 |
VP - T. Rowe Price Large Cap Value Fund | $3,890,437 | $12,627,538 | $12,581,998 |
VP - TCW Core Plus Bond Fund | $4,416,081 | $11,863,202 | $7,396,332 |
VP - U.S. Equities Fund | $3,193,417 | $7,042,204 | $4,138,710 |
VP - U.S. Government Mortgage Fund | $1,652,659 | $5,888,228 | $6,799,244 |
VP - Victory Sycamore Established Value Fund | $565,842 | $4,010,962 | $7,245,260 |
VP - Wells Fargo Short Duration Government Fund | $1,867,937 | $7,836,497 | $10,689,730 |
VP - Westfield Mid Cap Growth Fund | $544,294 | $3,399,285 | $6,229,316 |
(a) | For the period from September 1, 2015 to December 31, 2015. |
Statement of Additional Information – [May 1, 2018] | 93 |
Fund | Subadviser |
Parent
Company/Other Information |
Fee Schedule |
VP – American Century Diversified Bond Fund |
American
Century
(effective May 10, 2010) |
A | 0.160% on the first $500 million, declining to 0.080% as assets increase (a) |
VP – BlackRock Global Inflation-Protected Securities Fund |
BlackRock
(effective October 19, 2012) |
B | 0.150% on the first $250 million, declining to 0.050% as assets increase |
VP – CenterSquare Real Estate Fund |
CenterSquare
(effective June 1, 2016) |
Y | 0.400% on the first $200 million, declining to 0.300% as assets increase |
VP – Columbia Wanger International Equities Fund |
Columbia
WAM
(effective May 10, 2010) |
C | 0.700% on the first $150 million, declining to 0.600% as assets increase |
VP – Commodity Strategy Fund |
Threadneedle
(effective April 30, 2013) |
F | 0.250% on all assets |
VP – DFA International Value Fund |
DFA
(effective November 16, 2011) |
D | 0.210% on all asset levels |
VP – Eaton Vance Floating-Rate Income Fund |
Eaton
Vance
(effective May 10, 2010) |
E | 0.300% on all asset levels |
VP – Loomis Sayles Growth Fund |
Loomis
Sayles
(effective March 21, 2014) |
P | 0.270% on all asset levels |
VP – Los Angeles Large Cap Growth Fund |
Los
Angeles Capital
(effective May 1, 2017) |
L | 0.300% on the first $100 million, declining to 0.130% as assets increase |
VP – MFS Blended Research Core Equity Fund |
MFS
(effective May 2, 2016) |
I | 0.200% on the first $500 million, declining to 0.130% as assets increase |
VP – MFS Value Fund |
MFS
(effective May 10, 2010) |
I | 0.350% on the first $100 million, declining to 0.175% as assets increase (a) |
VP – Morgan Stanley Advantage Fund |
MSIM
(effective May 2, 2016) |
J | 0.300% on the first $500 million, declining to 0.225% as assets increase |
VP – Oppenheimer International Growth Fund |
Oppenheimer
(effective May 1, 2016) |
R | 0.450% on the first $300 million, declining to 0.300% as assets increase |
Statement of Additional Information – [May 1, 2018] | 94 |
Fund | Subadviser |
Parent
Company/Other Information |
Fee Schedule |
VP – Overseas Core Fund |
Threadneedle
(effective July 9, 2004) |
F | 0.350% on all assets |
VP – Partners Core Bond Fund |
JPMIM
(effective May 10, 2010) |
G | 0.110% on all asset levels (b) |
WellsCap
(effective May 1, 2017) |
M | 0.180% on assets up to $500 million, declining to 0.100% as assets increase | |
VP – Partners Small Cap Growth Fund |
BMO
(effective May 1, 2017) |
V | 0.300% on the first $200 million, declining to 0.200% as assets increase (c) |
Kennedy
(effective November 14, 2016) |
U | 0.500% on the first $100 million, declining to 0.450% as assets increase | |
WellsCap
(effective May 10, 2010) |
M | 0.480% on all asset levels | |
VP – Partners Small Cap Value Fund |
Denver
Investments
(effective July 16, 2007) |
W | 0.550% on the first $50 million, declining to 0.450% as assets increase (a) |
Jacobs
Levy
(effective May 1, 2017) |
N | 0.450% on the first $200 million, declining to 0.400% as assets increase | |
Nuveen
Asset Management
(effective May 1, 2017) |
O | 0.450% on all asset levels | |
SBH
(effective August 20, 2014) |
S | 0.550% on the first $10 million, declining to 0.400% as assets increase | |
VP – Pyramis International Equity Fund |
Pyramis
(effective May 10, 2010) |
Q | 0.360% on the first $350 million, declining to 0.320% as assets increase |
VP – T. Rowe Price Large Cap Value Fund |
T.
Rowe Price
(effective November 14, 2016) |
K | 0.500% on the first $50 million, declining to 0.275% on all assets as asset levels increase |
VP – TCW Core Plus Bond Fund |
TCW
(effective March 21, 2014) |
T | 0.180% on the first $500 million, declining to 0.050% as asset levels increase (c) |
VP – U.S. Equities Fund |
Columbia
WAM
(effective May 10, 2010) |
C | 0.600% on the first $100 million, declining to 0.500% as assets increase |
VP – Victory Sycamore Established Value Fund |
Victory
Capital
(effective November 16, 2012) |
X | 0.320% on the first $400 million, declining to 0.300% as assets increase |
VP – Wells Fargo Short Duration Government Fund |
WellsCap
(effective May 10, 2010) |
M | 0.150% on assets up to $250 million, declining to 0.120% as assets increase (d) |
VP – Westfield Mid Cap Growth Fund |
Westfield
(effective September 18, 2017) |
H | 0.400% on assets up to $250 million, declining to 0.300% as asset levels increase |
Statement of Additional Information – [May 1, 2018] | 95 |
Statement of Additional Information – [May 1, 2018] | 96 |
Statement of Additional Information – [May 1, 2018] | 97 |
Subadvisory Fees Paid | ||||
Fund | Subadviser | 2016 | 2015 | 2014 |
VP – Partners Small Cap Growth Fund | BMO (c) | N/A | N/A | N/A |
Former
subadviser:
Palisade (November 16, 2002 to November 14, 2016) |
$696,942 | $788,791 | $765,438 | |
Former
subadviser:
The London Company (May 10, 2010 to April 30, 2017) |
911,888 | 864,227 | 873,753 | |
Kennedy | 118,085 (f) | N/A | N/A | |
WellsCap | 1,048,209 | 1,038,157 | 985,979 | |
VP – Partners Small Cap Value Fund | Denver Investments | 983,103 | 1,310,907 | 1,896,758 |
Former
subadviser:
BHMS (March 12, 2004 to April 30, 2017) |
945,738 | 1,182,190 | 1,710,029 | |
Former
subadviser:
Donald Smith (March 12, 2004 to June 21, 2016) |
392,808 | 1,268,026 | 1,886,099 | |
Former
subadviser:
Turner Investments (June 6, 2008 to Aug. 19, 2014) |
N/A | N/A | 869,016 (g) | |
Former
subadviser:
River Road (April 24, 2006 to April 30, 2017) |
800,802 | 1,121,922 | 1,724,915 | |
Former
subadviser:
Snow Capital (August 20, 2014 to April 30, 2017) |
730,499 | 1,092,839 | 426,814 (h) | |
Jacobs Levy (c) | N/A | N/A | N/A | |
Nuveen Asset Management (c) | N/A | N/A | N/A | |
SBH | 904,013 | 1,228,652 | 388,832 (h) | |
VP – Pyramis International Equity Fund | Pyramis | 7,424,096 | 6,911,210 | 4,939,849 |
VP – T. Rowe Price Large Cap Value Fund |
Former
subadviser:
NFJ (May 10, 2010 to November 14, 2016) |
4,648,289 | 5,486,311 | 5,456,902 |
T. Rowe Price | 781,807 (f) | N/A | N/A | |
VP – TCW Core Plus Bond Fund |
Former
subadviser:
Pacific Investment Management Company LLC (May 10, 2010 to March 20, 2014) |
N/A | N/A | 536,104 |
TCW | 2,462,294 | 2,184,399 | 1,243,139 (b) | |
VP – U.S. Equities Fund | Columbia WAM | 1,285,858 | 1,708,641 | 2,516,408 |
VP – Victory Sycamore Established Value Fund | Victory Capital | 1,088,217 | 1,634,664 | 2,949,374 |
VP – Wells Fargo Short Duration Government Fund | WellsCap | 1,685,179 | 2,323,530 | 3,116,477 |
VP – Westfield Mid Cap Growth Fund |
Former
subadviser:
Jennison (May 10, 2010 to September 18, 2017) |
1,125,280 | 1,515,926 | 2,649,410 |
Westfield (c) | N/A | N/A | N/A |
(a) | For the period from June 1, 2016 to December 31, 2016. |
(b) | For the period from March 21, 2014 to December 31, 2014. |
(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 May 2, 2016 to December 31, 2016. |
(e) | For the period from May 1, 2016 to December 31, 2016. |
(f) | For the period from November 14, 2016 to December 31, 2016. |
Statement of Additional Information – [May 1, 2018] | 98 |
(g) | For the period from January 1, 2014 to August 19, 2014. |
(h) | For the period from August 20, 2014 to December 31, 2014. |
Statement of Additional Information – [May 1, 2018] | 99 |
Statement of Additional Information – [May 1, 2018] | 100 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager |
Number
and type
of account* |
Approximate
Total Net Assets |
Performance
Based Accounts** |
Potential
Conflicts of Interest |
Structure
of
Compensation |
VP – Disciplined Core Fund | Brian Condon |
20
RICs
4 PIVs 44 other accounts |
$8.53
billion
$134.75 million $5.69 billion |
None | Columbia Management | Columbia Management |
Peter Albanese |
6
RICs
3 PIVs 37 other accounts |
$7.48
billion
$134.69 million $5.53 billion |
||||
VP – Dividend Opportunity Fund | Steve Schroll |
2
RICs
1 PIV 9 other accounts |
$4.34
billion
$6.56 million $91.14 million |
None | Columbia Management | Columbia Management |
Paul Stocking |
2
RICs
1 PIV 15 other accounts |
$4.34
billion
$6.56 million $98.50 million |
||||
Dean Ramos |
2
RICs
1 PIV 9 other accounts |
$4.34
billion
$6.56 million $89.36 million |
||||
VP – Eaton Vance Floating-Rate Income Fund |
Eaton
Vance:
Scott H. Page |
13 RICs 12 PIVs 8 other accounts |
$23.51 billion $8.25 billion $4.00 billion |
1 PIV ($2.40 M) |
Eaton Vance |
Eaton Vance |
Craig P. Russ |
9
RICs
4 PIVs 9 other accounts |
$18.97
billion
$5.81 billion $4.86 billion |
None | |||
Andrew Sveen | 5 RICs | $2.12 billion | None | |||
VP – Emerging Markets Bond Fund | James Carlen |
3
RICs
14 PIVs 7 other accounts |
$454.74
million
$16.39 billion $53.22 million |
None | Columbia Management | Columbia Management |
Christopher Cooke (a) | None | None | None | Threadneedle | Threadneedle | |
VP – Emerging Markets Fund | Dara J. White |
2
RICs
2 PIV 7 other accounts |
$1.28
billion
$633.99 million $107.00 million |
None | Columbia Management | Columbia Management |
Robert B. Cameron |
2
RICs
1 PIV 9 other accounts |
$1.28
billion
$633.66 million $105.62 million |
||||
Jasmine Huang |
4
RICs
1 PIV 12 other accounts |
$1.58
billion
$633.66 million $104.98 million |
||||
Young Kim |
2
RICs
1 PIV 7 other accounts |
$1.28
billion
$633.66 million $104.53 million |
||||
Perry Vickery | 8 other accounts | $1.19 million | ||||
VP – Global Bond Fund | Gene Tannuzzo |
6
RICs
1 PIV 97 other accounts |
$4.64
billion
$0.40 million $1.20 billion |
None | Columbia Management | Columbia Management |
Adrian Hilton | 5 PIVs | $856.20 million | Threadneedle | Threadneedle | ||
VP – High Yield Bond Fund | Brian Lavin |
13
RICs
1 PIV 9 other accounts |
$19.50
billion
$57.30 million $222.79 million |
None | Columbia Management | Columbia Management |
Jennifer Ponce de Leon |
3
RICs
3 PIVs 44 other accounts |
$2.10
billion
$800.04 million $8.16 billion |
Statement of Additional Information – [May 1, 2018] | 101 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager |
Number
and type
of account* |
Approximate
Total Net Assets |
Performance
Based Accounts** |
Potential
Conflicts of Interest |
Structure
of
Compensation |
VP – Income Opportunities Fund | Brian Lavin |
13
RICs
1 PIV 9 other accounts |
$19.58
billion
$57.30 million $222.79 million |
None | Columbia Management | Columbia Management |
VP – Intermediate Bond Fund | Gene Tannuzzo (h) |
7
RICs
74 other accounts |
$5.37
billion
$1.24 billion |
None | Columbia Management | Columbia Management |
Jason Callan |
8
RICs
7 PIVs 4 other accounts |
$10.25
million
$15.45 billion $0.42 million |
||||
VP – Large Cap Growth Fund | Peter Deininger |
2
RICs
8 other accounts |
$4.95
billion
$245.97 million |
None | Columbia Management | Columbia Management |
John Wilson |
2
RICs
10 other accounts |
$4.95
billion
$258.72 million |
||||
Tchintcia S. Barros |
2
RICs
7 other accounts |
$4.95
billion
$245.60 million |
||||
VP – Large Cap Index Fund | Christopher Lo |
15
RICs
1 PIV 61 other accounts |
$12.39
billion
$220.42 million $803.01 million |
None | Columbia Management | Columbia Management |
Vadim Shteyn |
3
RICs
1 PIV 299 other accounts |
$11.48
billion
$220.42 million $603.95 million |
||||
VP – Limited Duration Credit Fund | Tom Murphy |
12
RICs
29 PIVs 35 other accounts |
$2.26
billion
$35.41 billion $4.97 billion |
None | Columbia Management | Columbia Management |
Tim Doubek |
10
RICs
1 PIV 34 other accounts |
$2.23
billion
$0.62 million $4.65 billion |
||||
Royce Wilson |
1
RIC
3 other accounts |
$747.21
million
$0.55 million |
||||
VP – Loomis Sayles Growth Fund |
Loomis
Sayles:
Aziz Hamzaogullari |
16 RICs 12 PIVs 92 other accounts |
$16.61 billion $2.41 billion $10.43 billion |
1 PIV ($533.00 M) |
Loomis Sayles |
Loomis Sayles |
VP – Los Angeles Large Cap Growth Fund |
Los
Angeles Capital:
Thomas Stevens (b) |
14 RICs 13 PIVs 37 other accounts |
$4.50 billion $5.23 billion $14.40 billion |
1 RIC ($2.38 B) 4 PIVs ($2.82 B) 5 other accounts ($8.27 B) |
Los Angeles Capital |
Los Angeles Capital |
Hal Reynolds (b) |
13
RICs
13 PIVs 37 other accounts |
$4.42
billion
$5.23 billion $14.40 billion |
1
RIC
($2.38 B) 4 PIVs ($2.82 B) 5 other accounts ($8.27 B) |
|||
Daniel Allen (b) |
10
RICs
13 PIVs 37 other accounts |
$1.31
billion
$5.23 billion $14.40 billion |
4
PIVs
($2.82 B) 5 other accounts ($8.27 B) |
|||
Daniel Arche (b) |
1
RIC
5 PIVs 13 other accounts |
$88.6
million
$2.94 billion $1.84 billion |
2
PIVs
($2.16 B) |
Statement of Additional Information – [May 1, 2018] | 102 |
Statement of Additional Information – [May 1, 2018] | 103 |
Statement of Additional Information – [May 1, 2018] | 104 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager |
Number
and type
of account* |
Approximate
Total Net Assets |
Performance
Based Accounts** |
Potential
Conflicts of Interest |
Structure
of
Compensation |
VP – Partners Core Bond Fund |
JPMIM:
Peter Simons |
13 RICs 4 PIVs 48 other accounts |
$38.78 billion $10.29 billion $10.20 billion |
1 other account ($105.00 M) |
JPMIM |
JPMIM |
Barbara Miller |
12
RICs
2 PIVs 13 other accounts |
$40.85
billion
$9.61 billion $696.00 million |
None | |||
Richard Figuly |
14
RICs
14 PIVs 25 other accounts |
$27.54
billion
$2.88 billion $8.52 billion |
1
other account
($969.00 M) |
|||
WellsCap:
Thomas O’Connor (b) |
9 RICs 4 PIVs 40 other accounts |
$15.96 billion $3.39 billion $14.12 billion |
1 PIV ($34.23 M) 2 other accounts ($694.03 M) |
WellsCap |
WellsCap |
|
Troy Ludgood (b)(i) | ||||||
Maulik Bhansali (e) | None | None | None | |||
Jarad Vasquez (e) | ||||||
VP – Partners Small Cap Growth Fund |
BMO:
David Corris (b) |
8 RICs 6 PIVs 121 other accounts |
$1.43 billion $4.55 billion $4.70 billion |
None |
BMO |
BMO |
Thomas Lettenberger (b) |
5
RICs
26 other accounts |
$626.03
million
$218.81 million |
||||
Kennedy:
John Rackers |
43 other accounts |
$149.00 million |
None |
Kennedy |
Kennedy |
|
WellsCap:
Thomas C. Ognar |
7 RICs 6 PIVs 62 other accounts |
$9.93 billion $1.07 billion $2.20 billion |
2 other accounts ($114.98 M) |
WellsCap |
WellsCap |
|
Joseph M. Eberhardy | ||||||
Bruce C. Olson | ||||||
VP – Partners Small Cap Value Fund |
Denver
Investments:
Derek Anguilm |
6 RICs 98 other accounts |
$397.16 million $970.11 million |
2 other accounts ($423.29 M) |
Denver Investments |
Denver Investments |
Troy Dayton | ||||||
Mark Adelmann | ||||||
Lisa Ramirez | ||||||
Alex Ruehle |
7
RICs
98 other accounts |
$410.50
million
$970.11 million |
||||
Jacobs
Levy:
Bruce Jacobs (b) |
9 RICs 13 PIVs 70 other accounts |
$1.85 billion $1.88 billion $3.86 billion |
6 other accounts ($1.11 B) |
Jacobs Levy |
Jacobs Levy |
|
Kenneth Levy (b) | ||||||
Nuveen
Asset Management:
Karen Bowie (b) |
1 RIC |
$1.20 billion |
None |
Nuveen Asset Management |
Nuveen Asset Management |
|
SBH:
Mark Dickherber |
1 RIC 1 PIV 60 other accounts |
$60.30 million $30.00 million $820.40 million |
None |
SBH |
SBH |
|
Shaun Nicholson |
Statement of Additional Information – [May 1, 2018] | 105 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager |
Number
and type
of account* |
Approximate
Total Net Assets |
Performance
Based Accounts** |
Potential
Conflicts of Interest |
Structure
of
Compensation |
VP – Pyramis International Equity Fund |
Pyramis:
Cesar Hernandez |
3 RICs 16 PIVs 42 other accounts |
$1.04 billion $8.29 billion $11.19 billion |
6 other accounts ($2.02 B) |
Pyramis |
Pyramis |
VP – Select Large Cap Equity Fund | Peter Santoro (d) |
7
RIC
1 PIVs 61 other accounts |
$13.62
billion
$6.34 million $1.82 billion |
None | Columbia Management | Columbia Management |
Melda Mergen (d) |
4
RIC
13 other accounts |
$2.35
billion
$413.10 million |
None | Columbia Management | Columbia Management | |
VP – Select Large-Cap Value Fund | Richard S. Rosen |
3
RICs
1 PIV 468 other accounts |
$1.61
billion
$46.65 million $2.85 billion |
None | Columbia Management | Columbia Management |
Kari Montanus |
3
RICs
1 PIV 464 other accounts |
$1.61
billion
$46.65 million $2.84 billion |
||||
Richard Taft |
3
RICs
1 PIV 29 other accounts |
$1.61
billion
$46.65 million $2.60 billion |
||||
VP – Select Smaller-Cap Value Fund | Richard S. Rosen |
3
RICs
1 PIV 468 other accounts |
$2.60
billion
$46.65 million $2.85 billion |
None | Columbia Management | Columbia Management |
Kari Montanus |
3
RICs
1 PIV 464 other accounts |
$2.60
billion
$46.65 million $2.84 billion |
||||
Richard Taft |
3
RICs
1 PIV 29 other accounts |
$2.60
billion
$46.65 million $2.60 billion |
||||
VP – Seligman Global Technology Fund | Paul Wick |
4
RICs
2 PIVs 4 other accounts |
$5.39
billion
$672.14 million $19.16 million |
1 PIV ($603.15 M) | Columbia Management |
Columbia
Management
– Tech Team |
Shekhar Pramanick |
3
RICs
5 other accounts |
$5.11
billion
$2.05 million |
None | |||
Sanjay Devgan |
3
RICs
3 other accounts |
$5.11
billion
$0.66 million |
None | |||
Jeetil Patel |
4
RICs
6 other accounts |
$5.39
billion
$3.30 million |
None | |||
Christopher Boova |
4
RICs
8 other accounts |
$5.39
billion
$5.23 million |
None | |||
Vimal Patel (k) | 6 other accounts | $2.49 million | None | |||
VP – T. Rowe Price Large Cap Value Fund |
T.
Rowe Price:
Heather McPherson |
5 RICs 2 PIVs 25 other accounts |
$9.03 billion $1.39 billion $4.38 billion |
None |
T. Rowe Price |
T. Rowe Price |
Mark Finn |
7
RICs
4 PIVs 30 other accounts |
$13.47
billion
$6.83 billion $5.46 billion |
||||
John Linehan |
14
RICs
6 PIVs 31 other accounts |
$39.99
billion
$9.14 billion $6.04 billion |
Statement of Additional Information – [May 1, 2018] | 106 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager |
Number
and type
of account* |
Approximate
Total Net Assets |
Performance
Based Accounts** |
Potential
Conflicts of Interest |
Structure
of
Compensation |
VP – TCW Core Plus Bond Fund |
TCW:
Tad Rivelle |
28 RICs 44 PIVs 241 other accounts |
$108.81 billion $9.14 billion $35.39 billion |
23 PIVs ($1.68 B) 9 other accounts ($4.16 B) |
TCW |
TCW |
Laird Landmann |
27
RICs
44 PIVs 241 other accounts |
$100.28
billion
$9.18 billion $35.39 billion |
23
PIVs
($1.68 B) 9 other accounts ($4.16 B) |
|||
Stephen Kane |
29
RICs
47 PIVs 241 other accounts |
$100.28
billion
$10.34 billion $35.39 billion |
23
PIVs
($1.68 B) 9 other accounts ($4.16 B) |
|||
Bryan Whalen |
25
RICs
42 PIVs 241 other accounts |
$108.78
billion
$9.09 billion $35.39 billion |
23
PIVs
($1.68 B) 9 other accounts ($4.16 B) |
|||
VP – U.S. Equities Fund |
Columbia
Management Peter Albanese |
7 RICs 3 PIVs 37 other accounts |
$12.29 billion $134.69 million $5.53 billion |
None |
Columbia Management |
Columbia Management |
Brian Condon |
20
RICs
4 PIVs 44 other accounts |
$12.69
billion
$134.75 million $5.69 billion |
||||
Jarl Ginsberg |
4
RICs
28 other accounts |
$2.99
billion
$108.87 million |
||||
Christian Stadlinger |
4
RICs
22 other accounts |
$2.99
billion
$112.92 million |
||||
David Hoffman |
3
RICs
2 PIVs 7 other accounts |
$3.85
billion
$235.52 million $57.24 million |
||||
Columbia
WAM:
Rich Watson (h) |
6 other accounts |
$20.51 million |
1 other account ($19.6 M) |
Columbia WAM |
Columbia WAM |
|
Matt Litfin |
3
RICs
7 other accounts |
$6.16
billion
$144.21 million |
None | |||
VP – U.S. Government Mortgage Fund | Jason J. Callan |
8
RICs
7 PIVs 4 other accounts |
$14.16
billion
$15.45 billion $0.42 million |
None | Columbia Management | Columbia Management |
Tom Heuer |
3
RICs
5 other accounts |
$3.54
billion
$1.80 million |
||||
VP – Victory Sycamore Established Value Fund |
Victory
Capital:
Gary H. Miller |
4 RICs 6 PIVs 18 other accounts |
$12.15 billion $421.41 million $527.15 million |
None |
Victory Capital |
Victory Capital |
Gregory M. Conners | ||||||
Jeffrey M. Graff | ||||||
James Albers | ||||||
Michael Rodarte |
Statement of Additional Information – [May 1, 2018] | 107 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager |
Number
and type
of account* |
Approximate
Total Net Assets |
Performance
Based Accounts** |
Potential
Conflicts of Interest |
Structure
of
Compensation |
VP – Wells Fargo Short Duration Government Fund |
WellsCap:
Thomas O’Connor |
8 RICs 4 PIVs 39 other accounts |
$14.70 billion $3.31 billion $13.87 billion |
1 PIV ($33.92 M) 2 other accounts ($687.41 M) |
WellsCap |
WellsCap |
Troy Ludgood (i) | ||||||
Maulik Bhansali (e) | None | None | None | |||
Jarad Vasquez (e) | ||||||
VP – Westfield Mid Cap Growth Fund |
Westfield:
William Muggia (c) |
10 RICs 6 PIVs 375 other accounts |
$2.43 billion $903.92 million $9.00 billion |
1 PIV ($22.30 M) 22 other accounts ($1.45 B) |
Westfield |
Westfield |
Richard Lee (c) |
9
RICs
3 PIVs 323 other accounts |
$2.33
billion
$851.97 million $8.60 billion |
21
other accounts
($1.30 B) |
|||
Ethan Meyers (c) |
9
RICs
3 PIVs 314 other accounts |
$2.33
billion
$851.97 million $8.60 billion |
21
other accounts
($1.30 B) |
* | RIC refers to a Registered Investment Company; PIV refers to a Pooled Investment Vehicle. |
** | Number 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) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of March 31, 2017. |
(b) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of February 28, 2017. |
(c) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of May 31, 2017. |
(d) | The Fund had not commenced operations as of the date of this SAI; reporting information is provided as of October 31, 2017. |
(e) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of August 31, 2017. |
(f) | The reporting information for Performance Based Accounts is provided as of September 30, 2017; all other reporting information is provided as of December 31, 2016. |
(g) | The portfolio manager will begin managing the Fund effective December 29, 2017; reporting information is provided as of September 30, 2017. |
(h) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of September 30, 2017. |
(i) | Troy Ludgood has announced his intention to transition to a new role with Wells Fargo Asset Management on April 30, 2018. After April 30, 2018, all references to Troy Ludgood in the SAI for the above mentioned fund is hereby removed. |
(j) | The portfolio manager will begin managing the Fund on or about May 1, 2018; reporting information is provided as of [______]. |
(k) | The portfolio manager began managing the Fund after its fiscal year end; reporting information is provided as of December 31, 2017. |
Statement of Additional Information – [May 1, 2018] | 108 |
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 |
Statement of Additional Information – [May 1, 2018] | 109 |
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. |
CenterSquare: From time to time, potential conflicts of interest may arise between a portfolio manager’s management of the investments of the Fund, on the one hand, and the management of other accounts, on the other. The portfolio managers oversee the investment of various types of accounts in the same strategy, such as mutual funds, pooled investment vehicles and separate accounts for individuals and institutions. Investment decisions generally are applied to all accounts utilizing that particular strategy, taking into consideration client restrictions, instructions and individual needs. A portfolio manager may manage an account whose fees may be higher or lower than the fee charged to the Fund to provide for varying client circumstances. 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 client trades. Additionally, the management of the Fund and other accounts may result in a portfolio manager devoting unequal time and attention to the management of the Fund or other accounts. | |
During the normal course of managing assets for multiple clients of varying types and asset levels, the portfolio managers may encounter conflicts of interest, that could, if not properly addressed, be harmful to one or more of our clients. Those of a material nature that are encountered most frequently involve security selection, employee personal securities trading, proxy voting and the allocation of securities. To mitigate these conflicts and ensure its clients are not impacted negatively by the adverse actions of CenterSquare or its employees, CenterSquare has implemented a series of policies including, but not limited to, its Code of Conduct, which addresses avoidance of conflicts of interest, Personal Security Trading Policy, which addresses personal security trading and requires the use of approved brokers, Trade Allocation/Aggregation Policy, which addresses fairness of trade allocation to client accounts, and the Proxy and Trade Error Policies which are designed to prevent and detect conflicts when they occur. CenterSquare reasonably believes that these and other policies combined with the periodic review and testing performed by its compliance professionals adequately protects the interest of its clients. A portfolio manager may also face other potential conflicts of interest in managing the Fund, and the description above is not a complete description of every conflict of interest that could be deemed to exist in managing both the Fund and the other accounts listed above. |
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 – [May 1, 2018] | 110 |
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 – [May 1, 2018] | 111 |
Statement of Additional Information – [May 1, 2018] | 112 |
■ | Time Management. The management of the Fund and other Accounts may result in a portfolio manager devoting unequal time and attention to the management of the Fund and/or Accounts. DFA seeks to manage such competing interests for the time and attention of portfolio managers by having portfolio managers focus on a particular investment discipline. Accounts managed by a portfolio manager within an investment discipline may be managed using the same investment approach. |
■ | Investment Opportunities. It is possible that at times identical securities will be held by the Fund and one or more Accounts. However, positions in the same security may vary and the length of time that the Fund may hold investments in the same security may likewise vary. If a portfolio manager identifies a limited investment opportunity that may be suitable for the Fund and one or more Accounts, the Fund may not be able to take full advantage of that opportunity due to an allocation of filled purchase or sale orders across all eligible Accounts. To address these situations, DFA has adopted procedures for allocating portfolio transactions across multiple Accounts. |
■ | Broker Selection. With respect to securities transactions for the Fund, DFA determines which broker to use to execute each order, consistent with its duty to seek best execution of the transaction. However, with respect to certain Accounts (such as separately managed accounts), DFA may be limited by the client with respect to the selection of brokers or may be instructed to direct trades through a particular broker. In these cases, DFA or its affiliates may place separate, non-simultaneous, transactions for the Fund and another Account that may temporarily affect the market price of the security or the execution of the transaction, or both, to the detriment of the Fund or the Account. |
■ | Performance-Based Fees. For some Accounts, DFA may be compensated based on the profitability of the Account, such as by a performance-based management fee. These incentive compensation structures may create a conflict of interest for DFA with regard to Accounts where DFA is paid based on a percentage of assets because the portfolio manager may have an incentive to allocate securities preferentially to the Accounts where DFA might share in investment gains. |
■ | Investment in an Account. A portfolio manager or his/her relatives may invest in an Account that he or she manages and a conflict may arise where he or she may therefore have an incentive to treat the Account in which the portfolio manager or his/her relatives invest preferentially as compared to other Accounts for which he or she has portfolio management responsibilities. |
Statement of Additional Information – [May 1, 2018] | 113 |
Statement of Additional Information – [May 1, 2018] | 114 |
Statement of Additional Information – [May 1, 2018] | 115 |
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 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. |
Statement of Additional Information – [May 1, 2018] | 116 |
MFS: MFS seeks to identify potential conflicts of interest resulting from a portfolio manager’s management of both the Fund and other accounts, and has adopted policies and procedures designed to address such potential conflicts. | |
The management of multiple funds and accounts (including proprietary accounts) gives rise to conflicts of interest if the funds and accounts have different objectives and strategies, benchmarks, time horizons and fees as a portfolio manager must allocate his or her time and investment ideas across multiple funds and accounts. In certain instances there are securities which are suitable for the Fund’s portfolio as well as for accounts of MFS or its subsidiaries with similar investment objectives. MFS trade allocation policies may give rise to conflicts of interest if the Fund’s orders do not get fully executed or are delayed in getting executed due to being aggregated with those of other accounts of MFS or its subsidiaries. A portfolio manager may execute transactions for another fund or account that may adversely affect the value of the Fund’s investments. Investments selected for funds or accounts other than the Fund may outperform investments selected for the Fund. | |
When two or more clients are simultaneously engaged in the purchase or sale of the same security, the securities are allocated among clients in a manner believed by MFS to be fair and equitable to each. Allocations may be based on many factors and may not always be pro rata based on assets managed. The allocation methodology could have a detrimental effect on the price or volume of the security as far as the Fund is concerned. | |
MFS and/or a portfolio manager may have a financial incentive to allocate favorable or limited opportunity investments or structure the timing of investments to favor accounts other than the Fund, for instance, those that pay a higher advisory fee and/or have a performance adjustment and/or include an investment by the portfolio manager. | |
MSIM: Morgan Stanley Investment Management Inc. (“MSIM”) and/or its affiliates (together "Morgan Stanley") provide a broad array of discretionary and non-discretionary investment management services and products for institutional accounts and individual investors. In addition, Morgan Stanley is a diversified global financial services firm that engages in a broad spectrum of activities including financial advisory services, asset management activities, sponsoring and managing private investment funds, engaging in broker-dealer transactions and other activities. Investors should be aware that there will be occasions when Morgan Stanley may encounter potential conflicts of interest in connection with its investment management services. | |
Other Accounts. In addition to responsibilities with respect to the management and investment activities of the Fund, MSIM and its affiliates may have similar responsibilities with respect to various other existing and future pooled investment vehicles and client accounts. Such other private investment funds, registered investment companies and any other existing or future pooled investment vehicles and separately managed accounts advised or managed by MSIM or any of its affiliates are referred to in this Statement of Additional Information collectively as the "Other Accounts." The existence of such multiple vehicles and accounts necessarily creates a number of potential conflicts of interest. | |
Investment Activities of the Fund and Other Accounts. In the course of providing investment advisory or other services to Other Accounts, MSIM and its affiliates might come into possession of material, nonpublic information that affects MSIM’s ability to buy, sell or hold Fund investments. In addition, affiliates of MSIM might own, and effect transactions in, securities of companies which MSIM and/or its affiliates cover in investment research materials or to whom affiliates of MSIM provide investment banking services or make a market in such securities, or in which MSIM, its affiliates and their respective shareholders, members, managers, partners, directors, officers and employees have positions of influence or financial interests. As a result, such persons might possess information relating to such securities that is not known to the individuals of MSIM responsible for managing the Fund's investments, or might be subject to confidentiality or other restrictions by law, contract or internal procedures. | |
The terms under which MSIM and its affiliates provide management and other services to Other Accounts may differ significantly from those applicable to the Fund. In particular, arrangements with certain Other Accounts might provide for MSIM and its affiliates to receive fees that are higher than the Advisory Fees payable by shareholders of the Fund. MSIM does not receive performance-based compensation in respect of its investment management activities on behalf of the Fund, but may simultaneously manage Other Accounts for which MSIM receives greater fees or other compensation (including performance-based fees or allocations) than it receives in respect of the Fund, which may create a conflict of interest. | |
Potential conflicts also may arise due to the fact that certain securities or instruments may be held in some Other Accounts but not in the Fund, or certain Other Accounts may have different levels of holdings in certain securities or instruments than those of the Fund. In addition, MSIM or its affiliates may give advice or take action with respect to the investments of one or more Other Accounts that may not be given or taken with respect to the Fund or Other Accounts with similar investment programs, objectives, and strategies. Accordingly, the Fund and Other Accounts with similar strategies may not hold the same securities or instruments or achieve the same performance. MSIM and its affiliates also may advise Other Accounts with conflicting programs, objectives or strategies. Different clients, including funds advised by MSIM or an affiliate, may invest in different classes of securities of the same issuer, depending on the respective client's investment objectives and |
Statement of Additional Information – [May 1, 2018] | 117 |
policies. As a result, MSIM and its affiliates may at times seek to satisfy their fiduciary obligations to certain Other Accounts owning one class of securities of a particular issuer by pursuing or enforcing rights on behalf of such Other Accounts with respect to such class of securities, and those activities may have an adverse effect on the Fund or certain Other Accounts, which may own a different class of securities of such issuer. | |
Allocation of Investment Opportunities between Fund and Other Accounts. MSIM expects to conduct the Fund's investment program in a manner that is similar to the investment programs of certain of the Other Accounts, particularly where the investment objectives and policies of Other Accounts overlap (in whole or in part) with those of the Fund. However, there are or are expected to be differences among the Fund and the Other Accounts with respect to investment objectives, investment strategies, investment parameters and restrictions, portfolio management personnel, tax considerations, liquidity considerations, legal and/or regulatory considerations, asset levels, timing and size of investor capital contributions and withdrawals, cash flow considerations, available cash, market conditions and other criteria deemed relevant by MSIM and its affiliates (the nature and extent of the differences will vary from fund to fund). Furthermore, MSIM may manage or advise multiple Accounts (including Other Accounts in which Morgan Stanley and its personnel have an interest) that have investment objectives that are similar to the Fund and that may seek to make investments or sell investments in the same securities or other instruments, sectors or strategies as the Fund. This creates potential conflicts, particularly in circumstances where the availability of such investment opportunities is limited. | |
Notwithstanding these differences, there may be circumstances where the Fund and all Other Accounts participate in parallel investment transactions at the same time and on the same terms. MSIM seeks to allocate portfolio transactions equitably whenever concurrent decisions are made to purchase or sell securities for the Fund and any Other Account. To the extent that MSIM seeks to acquire the same security at the same time for more than one client account, it may not be possible to acquire a sufficiently large quantity of the security, or the price at which the security is obtained for clients may vary. Similarly, clients may not be able to obtain the same price for, or as large an execution of, an order to sell a particular security when MSIM is trading for more than one account at the same time. If MSIM manages accounts that engage in short sales of securities of the type in which the Fund invests, MSIM could be seen as harming the performance of the Fund for the benefit of the accounts engaging in short sales if the short sales cause the market value of the securities to fall. | |
Transactions with Affiliates. MSIM might purchase securities from underwriters or placement agents in which an affiliate is a member of a syndicate or selling group, as a result of which an affiliate might benefit from the purchase through receipt of a fee or otherwise. MSIM will not purchase securities on behalf of the Fund from an affiliate that is acting as a manager of a syndicate or selling group. Purchases by MSIM on behalf of the Fund from an affiliate acting as a placement agent must meet the requirements of applicable law. | |
Furthermore, Morgan Stanley may face conflicts of interest when the Fund uses service providers affiliated with Morgan Stanley because Morgan Stanley receives greater overall fees when they are used. | |
Nuveen Asset Management: Actual or apparent conflicts of interest may arise when a portfolio manager has day-to-day management responsibilities with respect to more than one account. More specifically, portfolio managers who manage multiple accounts are presented a number of potential conflicts, including, among others, those discussed below. | |
The management of multiple accounts may result in a portfolio manager devoting unequal time and attention to the management of each account. Nuveen Asset Management seeks to manage such competing interests for the time and attention of portfolio managers by having portfolio managers focus on a particular investment discipline. Most accounts managed by a portfolio manager in a particular investment strategy are managed using the same investment models. | |
If a portfolio manager identifies a limited investment opportunity which may be suitable for more than one account, an account may not be able to take full advantage of that opportunity due to an allocation of filled purchase or sale orders across all eligible accounts. To deal with these situations, Nuveen Asset Management has adopted procedures for allocating limited opportunities across multiple accounts. | |
With respect to many of its clients’ accounts, Nuveen Asset Management determines which broker to use to execute transaction orders, consistent with its duty to seek best execution of the transaction. However, with respect to certain other accounts, Nuveen Asset Management may be limited by the client with respect to the selection of brokers or may be instructed to direct trades through a particular broker. In these cases, Nuveen Asset Management may place separate, non-simultaneous, transactions for a fund and other accounts which may temporarily affect the market price of the security or the execution of the transaction, or both, to the detriment of the fund or the other accounts. | |
Some clients are subject to different regulations. As a consequence of this difference in regulatory requirements, some clients may not be permitted to engage in all the investment techniques or transactions or to engage in these transactions to the same extent as the other accounts managed by the portfolio manager. Finally, the appearance of a conflict of interest may arise where Nuveen Asset Management has an incentive, such as a performance-based management fee, which relates to the management of some accounts, with respect to which a portfolio manager has day-to-day management responsibilities. |
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Nuveen Asset Management has adopted certain compliance procedures which are designed to address these types of conflicts common among investment managers. However, there is no guarantee that such procedures will detect each and every situation in which a conflict arises. | |
Oppenheimer: The investment activities of Oppenheimer and its affiliates with respect to other funds and accounts they manage may present potential conflicts of interest that could, under certain circumstances, disadvantage or adversely affect the Fund and its shareholders. Oppenheimer or their affiliates advise other funds and accounts that have investment objectives and strategies that differ from, and may be contrary to, those of the Fund. That may result in another fund or account holding investment positions that are adverse to the Fund's investment strategies or activities. Other funds or accounts advised by Oppenheimer or its affiliates may also have conflicting interests arising from investment objectives and strategies that are similar to those of the Fund. For example, those funds and accounts may engage in, and compete for, the same types of investment opportunities as the Fund or invest in securities of the same issuers that have different features and interests as compared to securities held by the Fund. These features (such as seniority, guarantees and differential voting rights) may, under certain circumstances, come into conflict with or disadvantage securities held by the Fund. Because Oppenheimer and its affiliates may carry out the investment activities of those other funds or accounts without regard to the investment objectives or performance of the Fund, it is possible that the value of investments held by the Fund or the Fund's investment strategies may be adversely affected. | |
The Fund's investment performance will usually differ from the performance of other funds or accounts that are also advised by Oppenheimer or its affiliates even in cases where the investment objectives and strategies of the relevant funds or accounts are similar. When managing multiple funds or accounts, Oppenheimer and its affiliates may make decisions with respect to investment positions held by certain funds or accounts that may cause the Fund to experience losses during periods in which other funds or accounts achieve gains. This may include causing another fund or account to take actions with respect to an issuer's liquidation, restructuring, default or corporate actions that may conflict with the interests of the Fund. Similar conflicts may also arise when the Fund and other funds or accounts invest in different parts of an issuer's capital structure, such as when the Fund holds equity or debt obligations of an issuer, and another fund or account holds more senior (or junior) debt obligations of the same issuer, or when the Fund and other funds or accounts hold securities of different issuers that have competing claims to the same assets or sources of payment. In such circumstances, decisions regarding whether to trigger an event of default, the terms of any potential workout or restructuring of a distressed issuer, liquidating or selling an investment, corporate actions, litigation or other investment decisions may, and often do, result in conflicts of interest. The Fund may receive lower returns on its investment in an issuer as a result of actions taken with respect to the same or related issuers by other investors, including other funds or accounts managed by Oppenheimer or its affiliates. | |
Oppenheimer or its affiliates may manage funds or accounts with different fee rates and/or fee structures, including funds or accounts that pay advisory fees based on account performance ("performance fee accounts"). Such differences in fee arrangements may raise potential conflicts of interest by creating an incentive to favor higher-fee accounts. For example, Oppenheimer or its affiliates could potentially allocate the most attractive investments to higher-fee accounts or performance fee accounts, or the trading of higher-fee accounts could potentially be favored as to timing and/or execution price. | |
Oppenheimer has adopted policies and procedures designed to mitigate where possible potential conflicts of interest identified by Oppenheimer. However, such policies and procedures may also limit the Fund's investment activities and affect its performance. For example, the investment activities of such funds or accounts may result in Oppenheimer’s or its affiliates' receipt of material non-public information concerning certain securities, which could lead to restrictions in the trading of such securities or other investment activities of the Fund or other funds or accounts managed by Oppenheimer or its affiliates. In certain cases, Oppenheimer or its affiliates may avoid certain investment opportunities or actions that would potentially give rise to conflicts with other funds or accounts, which could also have the effect of limiting the Fund's investment opportunities and performance. In other cases, Oppenheimer or its affiliates may choose not to or fail to avoid investment opportunities or action that would potentially give rise to conflicts with other funds or accounts, which could under certain circumstances disadvantage the Fund while advantaging other funds or accounts or vice versa. | |
Oppenheimer and its affiliates may also face other potential conflicts of interest in managing the Fund, and the information above is not a complete description of every conflict that could be deemed to exist when simultaneously managing the Fund and other funds and accounts. | |
Pyramis: A portfolio managers’ compensation plan (described below) may give rise to potential conflicts of interest. Although investors in a fund may invest through either tax-deferred accounts or taxable accounts, a portfolio manager’s compensation is linked to the pre-tax performance of the fund, rather than its after-tax performance. A portfolio managers’ base pay tends to increase with additional and more complex responsibilities that include increased assets under management, and a portion of the bonus relates to marketing efforts, which together indirectly link compensation to sales. |
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When a portfolio manager takes over a fund or an account, the time period over which performance is measured may be adjusted to provide a transition period in which to assess the portfolio. The management of multiple funds and accounts (including proprietary accounts) may give rise to potential conflicts of interest if the funds and accounts have different objectives, benchmarks, time horizons, and fees as a portfolio managers must allocate their time and investment ideas across multiple funds and accounts. In addition, a fund’s trade allocation policies and procedures may give rise to conflicts of interest if the fund’s orders do not get fully executed due to being aggregated with those of other accounts managed by Pyramis or an affiliate. A portfolio manager may execute transactions for another fund or account that may adversely impact the value of securities held by the Portfolios. Securities selected for funds or accounts other than the Portfolios may outperform the securities selected for the Portfolios. Portfolio managers may be permitted to invest in the funds they manage, even if a fund is closed to new investors. Trading in personal accounts, which may give rise to potential conflicts of interest, is restricted by a fund’s Code of Ethics. | |
SBH: The Code of Ethics and the Compliance Manual detail the requirements that each employee must disclose all potential conflicts of interest to the Chief Compliance Officer. Where warranted issuers (securities) may be placed on a watchlist to prevent any real or perceived conflict. | |
T. Rowe Price: Portfolio managers at T. Rowe Price and its affiliates typically manage multiple accounts. These accounts may include, among others, mutual funds, separate accounts (assets managed on behalf of institutions such as pension funds, colleges and universities, and foundations), offshore funds and common trust funds. Portfolio managers make investment decisions for each portfolio based on the investment objectives, policies, practices, and other relevant investment considerations that the managers believe are applicable to that portfolio. Consequently, portfolio managers may purchase (or sell) securities for one portfolio and not another portfolio. T. Rowe Price and its affiliates have adopted brokerage and trade allocation policies and procedures which they believe are reasonably designed to address any potential conflicts associated with managing multiple accounts for multiple clients. Also, the portfolio managers’ compensation is determined in the same manner with respect to all portfolios managed by the portfolio manager. | |
The T. Rowe Price Funds may, from time to time, own shares of Morningstar, Inc. Morningstar is a provider of investment research to individual and institutional investors, and publishes ratings on mutual funds, including the T. Rowe Price Funds. T. Rowe Price manages the Morningstar retirement plan and T. Rowe Price and its affiliates pay Morningstar for a variety of products and services. In addition, Morningstar may provide investment consulting and investment management services to clients of T. Rowe Price or its affiliates. | |
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. |
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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. | |
Victory Capital: Victory Capital states that its portfolio managers are often responsible for managing one or more mutual funds as well as other accounts, such as separate accounts, and other pooled investment vehicles, such as collective trust funds or unregistered hedge funds. A portfolio manager may manage other accounts which have materially higher fee arrangements than the Fund and may, in the future, manage other accounts which have a performance-based fee. A portfolio manager also may make personal investments in accounts they manage or support. The side-by-side management of the Fund along with other accounts may raise potential conflicts of interest by incenting a portfolio manager to direct a disproportionate amount of: (1) their attention; (2) limited investment opportunities, such as less liquid securities or initial public offerings; and/or (3) desirable trade allocations, to such other accounts. In addition, certain trading practices, such as cross-trading between the Fund and another account, raise conflict of interest issues. The Fund and Victory Capital have policies and procedures in place, including the Victory Capital’s internal review process, that are intended to mitigate those conflicts. | |
WellsCap: WellsCap’s portfolio managers often provide investment management for separate accounts advised in the same or similar investment style as that provided to mutual funds. While management of multiple accounts could potentially lead to conflicts of interest over various issues such as trade allocation, fee disparities and research acquisition, WellsCap has implemented policies and procedures for the express purpose of ensuring that clients are treated fairly and that potential conflicts of interest are minimized. | |
Westfield: The simultaneous management of multiple accounts by our investment professionals creates a possible conflict of interest as they must allocate their time and investment ideas across multiple accounts. This may result in the Investment Committee or portfolio manager allocating unequal attention and time to the management of each client account as each has different objectives, benchmarks, investment restrictions and fees. For most client accounts, investment decisions are made at the Investment Committee level. Once an idea has been approved, it is implemented across all eligible and participating accounts within the strategy. Client specific restrictions are monitored by the Compliance team. | |
Although the Investment Committee collectively acts as portfolio manager on most client accounts, there are some client accounts that are managed by a portfolio manager who also serves as a member of the Investment Committee. This can create a conflict of interest because investment decisions for these individually managed accounts do not require approval by the Investment Committee; thus, there is an opportunity for individually managed client accounts to trade in a security ahead of Investment Committee managed client accounts. Trade orders for individually managed accounts must be communicated to the Investment Committee. Additionally, the Compliance team performs periodic reviews of such accounts to ensure procedures have been followed. | |
Westfield has clients with performance-based fee arrangements. A conflict of interest can arise between those portfolios that incorporate a performance fee and those that do not. When the same securities are recommended for both types of accounts, it is Westfield’s policy to allocate investments, on a pro-rata basis, to all participating and eligible accounts, regardless of the account’s fee structure. Our Operations team performs monthly reviews of each Investment Committee run product’s model portfolio versus each client account. Discrepancies are researched, and exceptions are documented. |
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In placing each transaction for a client’s account, Westfield seeks best execution of that transaction except in cases where Westfield does not have the authority to select the broker or dealer, as stipulated by the client. We attempt to bundle directed brokerage accounts with non-directed accounts, and then utilize step-out trades to satisfy the directed arrangements. Clients who do not allow step-out trades will typically go last. | |
Because of our interest in receiving third party research services, there may be an incentive for Westfield to select a broker or dealer based on such interest rather than the clients’ interest in receiving most favorable execution. To mitigate the conflict that Westfield may have an incentive beyond best execution to utilize a particular broker, broker and research votes are conducted and reviewed on a quarterly basis. These votes provide the opportunity to recognize the unique research efforts of a wide variety of firms, as well as the opportunity to compare aggregate commission dollars with a particular broker to ensure appropriate correlation. | |
Some Westfield clients have elected to retain certain brokerage firms as consultants or to invest their assets through a broker-sponsored wrap program for which Westfield acts as a manager. Several of these firms are on our approved broker list. Since Westfield may gain new clients through such relationships, and will interact closely with such firms to service the client, there may be an incentive for Westfield to select a broker or dealer based on such interest rather than the clients’ interest. To help ensure independence in the brokerage selection process, brokerage selection is handled by our Traders, while client relationships are managed by our Marketing/Client Service team. | |
Personal accounts may give rise to conflicts of interest. Westfield and its employees will, from time to time, for their own investment accounts, purchase, sell, hold or own securities or other assets which may be recommended for purchase, sale or ownership for one or more clients. Westfield has a Code of Ethics which regulates trading in such accounts; requirements include regular reporting and preclearance of transactions. Compliance reviews personal trading activity regularly. | |
Westfield serves as manager to the General Partners of private funds, for which we also provide investment advisory services. Westfield and its employees have also invested their own funds in such vehicles and other investment strategies that are advised by the firm. Allowing such investments and having a financial interest in the private funds can create an incentive for the firm to favor these accounts because our financial interests are more directly tied to the performance of such accounts. To help ensure all clients are treated equitably and fairly, Westfield allocates investment opportunities on a pro-rata basis. Compliance conducts periodic reviews of client accounts to ensure procedures have been followed. |
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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. |
CenterSquare: CenterSquare’s corporate compensation structure is comprised of three components: base pay, short-term incentive and deferred incentives. Individuals’ packages are designed with the appropriate component combinations to match specific positions. |
■ | Base pay: salary is competitive for all businesses across BNY Mellon’s businesses and geographies; base pay levels link pay with performance and reflect the market value of the position, individual performance and company business results. |
■ | Short-term income plan: annual cash bonus plan that is based on a number of factors including individual performance, individual contribution to meeting business unit goals, career development goals and adherence to corporate values. |
■ | Deferred compensation plan: long-term compensation that is made available generally to Senior Executives of the firm; invests in a combination of Bank of New York Mellon stock and in a mutual fund vehicle within CenterSquare’s Global Real Estate Securities strategy. |
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■ | Base salary. Each portfolio manager is paid a base salary. DFA considers the factors described above to determine each portfolio manager’s base salary. |
■ | Semi-Annual Bonus. Each portfolio manager may receive a semi-annual bonus. The amount of the bonus paid to each portfolio manager is based upon the factors described above. |
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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 VP – Loomis Sayles Growth 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. | |
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 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. | |
MFS: Portfolio manager compensation is reviewed annually. As of December 31, 2016, portfolio manager total cash compensation is a combination of base salary and performance bonus: | |
Base Salary — Base salary represents a smaller percentage of portfolio manager total cash compensation than performance bonus. | |
Performance Bonus — Generally, the performance bonus represents more than a majority of portfolio manager total cash compensation. | |
The performance bonus is based on a combination of quantitative and qualitative factors, generally with more weight given to the former and less weight given to the latter. |
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The quantitative portion is based on the pre-tax performance of assets managed by the portfolio manager over one-, three-, and five-year periods relative to peer group universes and/or indices (“benchmarks”). As of December 31, 2016, the Russell 1000 ® Value Index was used to measure the performance of Nevin Chitkara and Steve Gorham for the Variable Portfolio – MFS ® Value Fund. As of December 31, 2016 the Standard & Poor's 500 Index was used to measure the performance of Matt Krummell, Jim Fallon, Jonathan Sage and Jed Stocks for the Variable Portfolio – MFS ® Blended Research ® Core Equity Fund. | |
Additional or different benchmarks, including versions of indices, custom indices, and linked indices that combine performance of different indices for different portions of the time period, may also be used. Consideration is given to portfolio performance over one, three, and five years with emphasis placed on the longer periods. For portfolio managers who have served more than five years, additional longer-term performance periods are also considered. For portfolio managers who have served for less than five years, performance periods are adjusted as appropriate. | |
The qualitative portion is based on the results of an annual internal peer review process (conducted by other portfolio managers, analysts, and traders) and management’s assessment of overall portfolio manager contributions to investor relations and the investment process (distinct from fund and other account performance). This performance bonus may be in the form of cash and/or a deferred cash award, at the discretion of management. A deferred cash award is issued for a cash value and becomes payable over a three-year vesting period if the portfolio manager remains in the continuous employ of MFS or its affiliates. During the vesting period, the value of the unfunded deferred cash award will fluctuate as though the portfolio manager had invested the cash value of the award in an MFS Fund(s) selected by the portfolio manager. A selected fund may be, but is not required to be, a fund that is managed by the portfolio manager. | |
Portfolio managers also typically benefit from the opportunity to participate in the MFS Equity Plan. Equity interests are awarded by management, on a discretionary basis, taking into account tenure at MFS, contribution to the investment process, and other factors. | |
Finally, portfolio managers also participate in benefit plans (including a defined contribution plan and health and other insurance plans) and programs available generally to other employees of MFS. The percentage such benefits represent of any portfolio manager’s compensation depends upon the length of the individual’s tenure at MFS and salary level, as well as other factors. | |
MSIM: Morgan Stanley’s compensation structure is based on a total reward system of base salary and incentive compensation, which is paid either in the form of cash bonus, or for employees meeting the specified deferred compensation eligibility threshold, partially as a cash bonus and partially as mandatory deferred compensation. Deferred compensation granted to Investment Management employees are generally granted as a mix of deferred cash awards under the Investment Management Alignment Plan (IMAP and equity-based awards in the form of stock units. The portion of incentive compensation granted in the form of a deferred compensation award and the terms of such awards are determined annually by the Compensation, Management Development and Succession Committee of the Morgan Stanley Board of Directors. | |
Base salary compensation . Generally, portfolio managers receive base salary compensation based on the level of their position with the Adviser. | |
Incentive compensation . In addition to base compensation, portfolio managers may receive discretionary year-end compensation. | |
Incentive compensation may include: | |
• Cash Bonus. |
• Defer | red Compensation: |
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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 |
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Administrative Services Fees | |||
2016 | 2015 | 2014 | |
For Funds with fiscal period ending December 31 | |||
VP – Aggressive Portfolio | $196,215 | $643,405 | $694,114 |
VP – American Century Diversified Bond Fund | 830,095 | 2,342,071 | 1,920,543 |
VP – Balanced Fund | 178,901 | 560,883 | 547,347 |
VP – BlackRock Global Inflation-Protected Securities Fund | 31,894 | 446,469 | 1,186,088 |
VP – CenterSquare Real Estate Fund | 54,542 | 175,015 | 226,337 |
VP – Columbia Wanger International Equities Fund | 66,048 | 385,895 | 569,322 |
VP – Commodity Strategy Fund | 12,003 | 43,941 | 88,523 |
VP – Conservative Portfolio | 100,909 | 313,541 | 379,533 |
VP – DFA International Value Fund | 462,793 | 1,353,034 | 1,072,359 |
VP – Disciplined Core Fund | 662,058 | 1,879,533 | 1,320,373 |
VP – Dividend Opportunity Fund | 298,754 | 1,276,493 | 1,741,500 |
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Administrative Services Fees | |||
2016 | 2015 | 2014 | |
VP – Eaton Vance Floating-Rate Income Fund | $27,341 | $216,473 | $490,892 |
VP – Emerging Markets Bond Fund | 24,417 | 95,598 | 170,636 |
VP – Emerging Markets Fund | 268,772 | 887,494 | 813,677 |
VP – Global Bond Fund | 48,458 | 292,645 | 602,562 |
VP – Government Money Market Fund | 83,847 | 295,038 | 326,515 |
VP – High Yield Bond Fund | 103,906 | 362,523 | 403,866 |
VP – Income Opportunities Fund | 133,840 | 558,279 | 785,422 |
VP – Intermediate Bond Fund | 986,459 | 2,652,268 | 1,845,460 |
VP – Large Cap Growth Fund | 245,849 | 792,452 | 722,136 |
VP – Large Cap Index Fund | 100,247 | 318,575 | 279,617 |
VP – Limited Duration Credit Fund | 200,617 | 951,236 | 1,722,200 |
VP – Loomis Sayles Growth Fund | 366,850 | 984,859 | 662,776 |
VP – Los Angeles Capital Large Cap Growth Fund | 239,496 | 849,602 | 780,040 |
VP – MFS Blended Research Core Equity Fund | 302,607 | 1,016,625 | 933,134 |
VP – MFS Value Fund | 334,452 | 1,167,201 | 1,211,111 |
VP – Mid Cap Growth Fund | 57,512 | 204,632 | 267,962 |
VP – Mid Cap Value Fund | 24,374 | 159,639 | 353,329 |
VP – Moderate Portfolio | 1,344,963 | 4,319,734 | 4,560,860 |
VP – Moderately Aggressive Portfolio | 670,640 | 2,194,977 | 2,435,034 |
VP – Moderately Conservative Portfolio | 267,796 | 875,168 | 1,003,697 |
VP – Morgan Stanley Advantage Fund | 207,409 | 748,623 | 783,271 |
VP – MV Moderate Growth Fund | 1,078,151 | 3,158,775 | 2,442,171 |
VP – Oppenheimer International Growth Fund | 542,705 | 1,657,390 | 1,472,945 |
VP – Overseas Core Fund | 104,443 | 286,893 | 310,939 |
VP – Partners Core Bond Fund | 681,516 | 2,008,481 | 1,890,941 |
VP – Partners Small Cap Growth Fund | 151,439 | 469,410 | 458,785 |
VP – Partners Small Cap Value Fund | 277,140 | 1,061,321 | 1,325,487 |
VP – Pyramis International Equity Fund | 526,683 | 1,539,359 | 1,109,473 |
VP – Select Large-Cap Value Fund | 149,851 | 552,017 | 545,025 |
VP – Select Smaller-Cap Value Fund | 37,842 | 140,615 | 146,574 |
VP – Seligman Global Technology Fund | 28,465 | 94,632 | 90,028 |
VP – T. Rowe Price Large Cap Value Fund | 335,207 | 1,091,273 | 1,085,469 |
VP – TCW Core Plus Bond Fund | 643,995 | 1,726,353 | 1,071,701 |
VP – U.S. Equities Fund | 321,803 | 699,219 | 377,669 |
VP – U.S. Government Mortgage Fund | 301,143 | 1,061,731 | 1,215,702 |
VP – Victory Sycamore Established Value Fund | 43,525 | 303,530 | 543,533 |
VP – Wells Fargo Short Duration Government Fund | 260,536 | 1,088,581 | 1,483,434 |
VP – Westfield Mid Cap Growth Fund | 43,542 | 267,529 | 481,805 |
Statement of Additional Information – [May 1, 2018] | 137 |
Share Class | Distribution Fee | Service Fee | Combined Total |
Class 1 | None | None | None |
Class 2 | Up to 0.25% | 0.00% | Up to 0.25% |
Class 3 | Up to 0.125% | 0.00% | Up to 0.125% |
Class 4 | Up to 0.25% | 0.00% | Up to 0.25% |
Statement of Additional Information – [May 1, 2018] | 138 |
Fund | Class 1 | Class 2 | Class 3 | Class 4 |
For Funds with fiscal period ending December 31 | ||||
VP – Aggressive Portfolio | N/A | $3,418,210 | N/A | $3,716,165 |
VP – American Century Diversified Bond Fund | $0 | 23,002 | N/A | N/A |
VP – Balanced Fund | 0 | 7 | $1,247,237 | N/A |
VP – BlackRock Global Inflation-Protected Securities Fund | 0 | 22,574 | 161,252 | N/A |
VP – CenterSquare Real Estate Fund | 0 | 58,589 | N/A | N/A |
VP – Columbia Wanger International Equities Fund | 0 | 59,202 | N/A | N/A |
VP – Commodity Strategy Fund | 0 | 15,950 | N/A | N/A |
VP – Conservative Portfolio | N/A | 1,497,737 | N/A | 2,305,289 |
VP – Core Equity Fund | N/A | N/A | N/A | N/A |
VP – DFA International Value Fund | 0 | 23,340 | N/A | N/A |
VP – Disciplined Core Fund | 0 | 42,436 | 1,516,153 | N/A |
VP – Dividend Opportunity Fund | 0 | 129,126 | 1,211,331 | N/A |
VP – Eaton Vance Floating-Rate Income Fund | 0 | 77,999 | N/A | N/A |
VP – Emerging Markets Bond Fund | 0 | 65,824 | N/A | N/A |
VP – Emerging Markets Fund | 0 | 48,394 | 244,880 | N/A |
VP – Global Bond Fund | 0 | 23,145 | 210,409 | N/A |
VP – Government Money Market Fund | 0 | 91,124 | 341,574 | N/A |
VP – High Yield Bond Fund | 0 | 107,835 | 513,401 | N/A |
VP – Income Opportunities Fund | 0 | 142,590 | 255,914 | N/A |
VP – Intermediate Bond Fund | 0 | 78,366 | 920,719 | N/A |
VP – Large Cap Growth Fund | 0 | 210,613 | 279,875 | N/A |
VP – Large Cap Index Fund | 0 | 28,277 | 390,869 | N/A |
VP – Limited Duration Credit Fund | 0 | 75,638 | N/A | N/A |
VP – Loomis Sayles Growth Fund | 0 | 61,561 | N/A | N/A |
VP – Los Angeles Capital Large Cap Growth Fund | 0 | 16,141 | N/A | N/A |
VP – MFS Blended Research Core Equity Fund | 0 | 20,751 | 55,488 | N/A |
VP – MFS Value Fund | 0 | 63,565 | N/A | N/A |
VP – Mid Cap Growth Fund | 0 | 31,600 | 320,085 | N/A |
VP – Mid Cap Value Fund | 0 | 46,143 | 113,975 | N/A |
VP – Moderate Portfolio | N/A | 19,158,208 | N/A | 29,940,452 |
VP – Moderately Aggressive Portfolio | N/A | 11,286,845 | N/A | 12,842,521 |
VP – Moderately Conservative Portfolio | N/A | 3,938,100 | N/A | 5,861,315 |
VP – Morgan Stanley Advantage Fund | 0 | 17,958 | N/A | N/A |
VP – MV Moderate Growth Fund | N/A | 30,175,116 | N/A | N/A |
VP – Oppenheimer International Growth Fund | 0 | 52,954 | N/A | N/A |
VP – Overseas Core Fund | 0 | 136,548 | 366,666 | N/A |
VP – Partners Core Bond Fund | 0 | 22,100 | N/A | N/A |
VP – Partners Small Cap Growth Fund | 0 | 11,353 | N/A | N/A |
VP – Partners Small Cap Value Fund | 0 | 11,242 | 157,821 | N/A |
Statement of Additional Information – [May 1, 2018] | 139 |
Fund | Class 1 | Class 2 | Class 3 | Class 4 |
VP – Pyramis International Equity Fund | $0 | $17,662 | N/A | N/A |
VP – Select Large Cap Equity Fund (a) | N/A | N/A | N/A | N/A |
VP – Select Large-Cap Value Fund | 0 | 31,700 | $54,090 | N/A |
VP – Select Smaller-Cap Value Fund | 0 | 55,822 | 85,821 | N/A |
VP – Seligman Global Technology Fund | 0 | 111,995 | N/A | N/A |
VP – T. Rowe Price Large Cap Value Fund | 0 | 22,344 | N/A | N/A |
VP – TCW Core Plus Bond Fund | 0 | 13,354 | N/A | N/A |
VP – U.S. Equities Fund | 0 | 32,751 | N/A | N/A |
VP – U.S. Government Mortgage Fund | 0 | 62,434 | 187,690 | N/A |
VP – Victory Sycamore Established Value Fund | 0 | 45,391 | 42,760 | N/A |
VP – Wells Fargo Short Duration Government Fund | 0 | 51,169 | N/A | N/A |
VP – Westfield Mid Cap Growth Fund | 0 | 31,765 | N/A | N/A |
(a) | No historical information is given for the Fund because the Fund had not commenced operations as of the date of this SAI. |
Statement of Additional Information – [May 1, 2018] | 140 |
Amounts Reimbursed | |||
2016 | 2015 | 2014 | |
For Funds with fiscal period ending December 31 | |||
VP – Aggressive Portfolio | $0 | $0 | $0 |
VP – American Century Diversified Bond Fund | 0 | 0 | 243,850 |
VP – Balanced Fund | 0 | 188,114 | 0 |
VP – BlackRock Global Inflation-Protected Securities Fund | 42,878 | 43,434 | 0 |
VP – CenterSquare Real Estate Fund | 39,948 | 126,961 | 426,334 |
VP – Columbia Wanger International Equities Fund | 192,512 | 132,665 | 632,890 |
VP – Commodity Strategy Fund | 0 | 0 | 0 |
VP – Conservative Portfolio | 0 | 0 | 0 |
VP – Core Equity Fund | 96,995 | 91,216 | 100,840 |
VP – DFA International Value Fund | 0 | 0 | 1,457,046 |
VP – Disciplined Core Fund | 0 | 0 | 0 |
VP – Dividend Opportunity Fund | 0 | 0 | 0 |
VP – Eaton Vance Floating-Rate Income Fund | 138,890 | 182,285 | 488,984 |
VP – Emerging Markets Bond Fund | 0 | 0 | 0 |
VP – Emerging Markets Fund | 170,959 | 356,960 | 232,825 |
VP – Global Bond Fund | 176,653 | 117,619 | 144,805 |
VP – Government Money Market Fund | 158,398 | 216,301 | 2,613,513 |
Statement of Additional Information – [May 1, 2018] | 141 |
Amounts Reimbursed | |||
2016 | 2015 | 2014 | |
VP – High Yield Bond Fund | $3,805 | $149,164 | $155,339 |
VP – Income Opportunities Fund | 32,940 | 63,321 | 20,016 |
VP – Intermediate Bond Fund | 0 | 0 | 0 |
VP – Large Cap Growth Fund | 419,957 | 111,626 | 153,232 |
VP – Large Cap Index Fund | 152 | 5,809 | 0 |
VP – Limited Duration Credit Fund | 30,446 | 84,937 | 0 |
VP – Loomis Sayles Growth Fund | 0 | 0 | 0 |
VP – Los Angeles Capital Large Cap Growth Fund | 0 | 0 | 0 |
VP – MFS Blended Research Core Equity Fund | 416,495 | 979,256 | 929,702 |
VP – MFS Value Fund | 0 | 0 | 0 |
VP – Mid Cap Growth Fund | 603,519 | 485,144 | 178,413 |
VP – Mid Cap Value Fund | 69,311 | 66,532 | 40,319 |
VP – Moderate Portfolio | 0 | 0 | 0 |
VP – Moderately Aggressive Portfolio | 0 | 0 | 0 |
VP – Moderately Conservative Portfolio | 0 | 0 | 0 |
VP – Morgan Stanley Advantage Fund | 0 | 0 | 0 |
VP – MV Moderate Growth Fund | 0 | 0 | 0 |
VP – Oppenheimer International Growth Fund | 0 | 0 | 0 |
VP – Overseas Core Fund | 291,335 | 308,190 | 18,173 |
VP – Partners Core Bond Fund | 147,474 | 186,260 | 255,403 |
VP – Partners Small Cap Growth Fund | 240,533 | 346,681 | 338,982 |
VP – Partners Small Cap Value Fund | 806,684 | 1,923,520 | 2,960,803 |
VP – Pyramis International Equity Fund | 85,520 | 0 | 0 |
VP – Select Large Cap Equity Fund (a) | N/A | N/A | N/A |
VP – Select Large-Cap Value Fund | 434,546 | 463,462 | 547,687 |
VP – Select Smaller-Cap Value Fund | 139,230 | 140,637 | 96,470 |
VP – Seligman Global Technology Fund | 189,274 | 265,059 | 232,512 |
VP – T. Rowe Price Large Cap Value Fund | 0 | 0 | 0 |
VP – TCW Core Plus Bond Fund | 0 | 0 | 0 |
VP – U.S. Equities Fund | 0 | 0 | 330,083 |
VP – U.S. Government Mortgage Fund | 0 | 0 | 0 |
VP – Victory Sycamore Established Value Fund | 88,937 | 75,079 | 13,600 |
VP – Wells Fargo Short Duration Government Fund | 42,652 | 540 | 7 |
VP – Westfield Mid Cap Growth Fund | 73,443 | 33,572 | 148,330 |
(a) | No historical information is given for the Fund because the Fund had not commenced operations as of the date of this SAI. |
Fees Waived | |||
2016 | 2015 | 2014 | |
For Funds with fiscal period ending December 31 | |||
VP – Government Money Market Fund | $768,175 | $1,995,017 | $0 |
VP – Income Opportunities Fund | 0 | 0 | 87,211 |
Statement of Additional Information – [May 1, 2018] | 142 |
Fees Waived | |||
2016 | 2015 | 2014 | |
VP – Limited Duration Credit Fund | $0 | $0 | $184,898 |
VP – TCW Core Plus Bond Fund | 248,634 | 500,000 | 376,712 |
Statement of Additional Information – [May 1, 2018] | 143 |
Statement of Additional Information – [May 1, 2018] | 144 |
Statement of Additional Information – [May 1, 2018] | 145 |
Statement of Additional Information – [May 1, 2018] | 146 |
Statement of Additional Information – [May 1, 2018] | 147 |
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 |
Statement of Additional Information – [May 1, 2018] | 148 |
Name, address, year of birth |
Position
held with Subsidiary
and length of service |
Principal occupation during past five years |
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) |
CVPCSF
Offshore Fund, Ltd.
(Subsidiary of VP - Commodity Strategy Fund) |
$0 - $500 | 0.630% |
>$500 - $1,000 | 0.580% | |
>$1,000 - $3,000 | 0.550% | |
>$3,000 - $6,000 | 0.520% | |
>$6,000 - $12,000 | 0.500% | |
>$12,000 | 0.490% |
(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 – [May 1, 2018] | 149 |
Statement of Additional Information – [May 1, 2018] | 150 |
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 |
George
S. Batejan
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1953 |
Trustee since 1/17 | Executive Vice President, Global Head of Technology and Operations, Janus Capital Group, Inc., 2010-2016 | 125 | Advisory Board Member, University of Colorado Business School since November 2015; former Chairman of the Board, NICSA (National Investment Company Services Association) (Executive Committee, Nominating Committee and Governance Committee), 2014-2016; former Director, Intech Investment Management, 2011-2016; former Board Member, Metro Denver Chamber of Commerce, 2015-2016 | Compliance, Contracts, Investment Review |
Kathleen
Blatz
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1954 |
Trustee since 1/06 for RiverSource Funds and since 6/11 for Nations Funds | Attorney, specializing in arbitration and mediation; Chief Justice, Minnesota Supreme Court, 1998-2006; Associate Justice, Minnesota Supreme Court, 1996-1998; Fourth Judicial District Court Judge, Hennepin County, 1994-1996; Attorney in private practice and public service, 1984-1993; State Representative, Minnesota House of Representatives, 1979-1993, which included service on the Tax and Financial Institutions and Insurance Committees | 125 | Trustee, BlueCross BlueShield of Minnesota (Chair of the Business Development Committee 2014-2017) since 2009; Chair of the Robina Foundation since August 2013 | Board Governance, Compliance, Contracts, Executive, Investment Review |
Statement of Additional Information – [May 1, 2018] | 151 |
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 |
Edward
J. Boudreau, Jr.
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1944 |
Chair of the Board since 1/18; Trustee since 6/11 for RiverSource Funds and since 1/05 for Nations Funds | Managing Director, E.J. Boudreau & Associates (consulting) since 2000; FINRA Industry Arbitrator, 2002 – present; Chairman and Chief Executive Officer, John Hancock Investments (asset management), Chairman and Interested Trustee for open-end and closed-end funds offered by John Hancock, 1989-2000; John Hancock Mutual Life Insurance Company, including Senior Vice President and Treasurer and Senior Vice President Information Technology, 1968-1988 | 125 | Former Trustee, Boston Museum of Science (Chair of Finance Committee), 1985-2013; former Trustee, BofA Funds Series Trust (11 funds), 2005-2011 | Board Governance, Compliance, Contracts, Executive, Investment Review |
Pamela
G. Carlton
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1954 |
Trustee since 7/07 for RiverSource Funds and since 6/11 for Nations Funds | President, Springboard- Partners in Cross Cultural Leadership (consulting company) since 2003; Managing Director of US Equity Research, JP Morgan Chase, 1999-2003; Director of US Equity Research, Chase Asset Management, 1996- 1999; Co-Director Latin America Research, 1993-1996, COO Global Research, 1992-1996, Co-Director of US Research, 1991-1992, Investment Banker, Morgan Stanley, 1982-1991 | 125 | Trustee, New York Presbyterian Hospital Board (Executive Committee and Chair of Human Resources Committee) since 1996; Director, Darien Rowayton Bank (Audit Committee) since 2017 | Audit, Board Governance, Contracts, Executive, Investment Review |
Statement of Additional Information – [May 1, 2018] | 152 |
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
P. Carmichael
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1943 |
Trustee since 6/11 for RiverSource Funds and since 2003 for Nations Funds | Retired; Co-founder, The Succession Fund (provides exit strategies to owners of privately held companies), 1998-2007; Adjunct Professor of Finance, Kelley School of Business, Indiana University, 1993-2007; Senior Vice President, Sara Lee Corporation, 1991-1993; Senior Vice President and Chief Financial Officer, Beatrice Foods Company, 1984-1990; Vice President, Esmark, Inc., 1973-1984; Associate, Price Waterhouse, 1968-1972 | 125 | Director, The Finish Line (athletic shoes and apparel) since July 2003; former Director, Cobra Electronics Corporation (electronic equipment manufacturer), 1994-August 2014; former Director, Spectrum Brands, Inc. (consumer products), 2002-2009; former Director, Simmons Company (bedding), 2004-2010; former Trustee, BofA Funds Series Trust (11 funds) 2003-2011; former Director, McMoRan Exploration Company (oil and gas exploration and development) 2010-2013; former Director, International Textile Corp., 2012-2016; former Director, hhgregg 2015-2017 | Audit, Board Governance, Contracts, Executive, Investment Review |
Patricia
M. Flynn
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1950 |
Trustee since 11/04 for RiverSource Funds and since 6/11 for Nations Funds | Trustee Professor of Economics and Management, Bentley University since 1976 (also teaches and conducts research on corporate governance); Dean, McCallum Graduate School of Business, Bentley University, 1992-2002 | 125 | Trustee, MA Taxpayers Foundation since 1997; Board of Directors, The MA Business Roundtable since 2003; Board of Governors, Innovation Institute, MA Technology Collaborative since 2010 | Audit, Board Governance, Contracts, Investment Review |
Brian
J. Gallagher
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1954 |
Trustee since 12/17 | Retired; Partner with Deloitte & Touche LLP and its predecessors, 1986-2016 | 123 | None | Audit, Contracts, Investment Review |
Catherine
James Paglia
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1952 |
Trustee since 11/04 for RiverSource Funds and since 6/11 for Nations Funds | Director, Enterprise Asset Management, Inc. (private real estate and asset management company) since September 1998; Managing Director and Partner, Interlaken Capital, Inc., 1989-1997; Managing Director, Morgan Stanley, 1982-1989; Vice President, Investment Banking, 1980-1982, Associate, Investment Banking, 1976-1980, Dean Witter Reynolds, Inc. | 125 | Director, Valmont Industries, Inc. (irrigation systems manufacturer) since 2012; Trustee, Carleton College (on the Investment Committee); Trustee, Carnegie Endowment for International Peace (on the Investment Committee) | Audit, Board Governance, Contracts, Executive, Investment Review |
Statement of Additional Information – [May 1, 2018] | 153 |
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 |
Minor
M. Shaw
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1947 |
Trustee since 6/11 for RiverSource Funds and since 2003 for Nations Funds | President, Micco LLC (private investments) since 2011; President, Micco Corp. (family investment business), 1998-2011 | 125 | Director, BlueCross BlueShield of South Carolina since April 2008; Director, National Association of Corporate Directors, Carolinas Chapter, since 2013; Board Chair, Hollingsworth Funds since 2016; Advisory Board member, Duke Energy Corp. since October 2016; Chair of the Duke Endowment; Chair of Greenville – Spartanburg Airport Commission; former Trustee, BofA Funds Series Trust (11 funds), 2003-2011; former Director, Piedmont Natural Gas, 2004-2016 | Board Governance, Compliance, Contracts, Investment Review |
Sandra
Yeager
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1964 |
Trustee since 12/17 | Retired; President and founder, Hanoverian Capital, LLC (SEC registered investment advisor firm), 2008-2016 | 123 | Director, NAPE Education Foundation since October 2016 | Compliance, Contracts, Investment Review |
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 |
Anthony
M. Santomero
c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1946 |
Trustee since 6/11 for RiverSource Funds and since 1/08 for Nations Funds | Richard K. Mellon Professor Emeritus of Finance, The Wharton School, University of Pennsylvania, since 2002; Senior Advisor, McKinsey & Company (consulting), 2006-2008; President, Federal Reserve Bank of Philadelphia, 2000-2006; Professor of Finance, The Wharton School, University of Pennsylvania, 1972-2002 | 123 | Trustee, Penn Mutual Life Insurance Company since March 2008; Director, Renaissance Reinsurance Ltd. since May 2008; Director, Citigroup Inc. since 2009; Director, Citibank, N.A. since 2009; former Trustee, BofA Funds Series Trust (11 funds), 2008-2011 | Compliance, Contracts, Executive, Investment Review |
* | Dr. Santomero is not an affiliated person of the Investment Manager or Ameriprise Financial. However, he is currently deemed by the Funds to be an “interested person” (as defined in the 1940 Act) of the Funds because he serves as a Director of Citigroup Inc. and Citibank, N.A., companies that may directly or through subsidiaries and affiliates engage from time-to-time in brokerage execution, principal transactions and lending relationships with the Funds or accounts advised/managed by the Investment Manager. |
Statement of Additional Information – [May 1, 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 |
William
F. Truscott
c/o Columbia Management Investment Advisers, LLC, 225 Franklin St. Boston, MA 02110 1960 |
Trustee since 11/01 for RiverSource Funds and since 6/11 for Nations Funds; Senior Vice President since 2002 for RiverSource Funds and since 5/10 for Nations Funds | 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. | 191 | 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 – [May 1, 2018] | 155 |
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 – [May 1, 2018] | 156 |
Statement of Additional Information – [May 1, 2018] | 157 |
Statement of Additional Information – [May 1, 2018] | 158 |
Statement of Additional Information – [May 1, 2018] | 159 |
Board Member |
Aggregate
Dollar Range of Equity Securities in all Funds in the Columbia Funds Complex Overseen by the Trustee |
George S. Batejan | Over $100,000 |
Kathleen Blatz | Over $100,000 |
Edward J. Boudreau Jr. | Over $100,000 (a) |
Pamela G. Carlton | Over $100,000 (a) |
William P. Carmichael | Over $100,000 (a) |
Patricia M. Flynn | Over $100,000 (a) |
Brian J. Gallagher | Over $100,000 |
Catherine James Paglia | Over $100,000 (a) |
Minor M. Shaw | Over $100,000 (a)(b) |
Sandra L. Yeager | None |
(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. |
(b) | Ms. Shaw invests in a Section 529 Plan managed by the Investment Manager that allocates assets to various open-end funds, including Columbia Funds. The amount shown in the table includes the value of her interest in this plan determined as if her investment in the plan were invested directly in the Columbia Fund pursuant to the plan’s target allocations. |
Statement of Additional Information – [May 1, 2018] | 160 |
Board Member |
Aggregate
Dollar Range of Equity Securities in all Funds in the Columbia Funds Complex Overseen by the Trustee |
Anthony Santomero | Over $100,000 (a) |
William F. Truscott | Over $100,000 |
(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. |
Trustees (a) |
Total
Cash Compensation
from Fund Complex Paid to Trustee (b) |
Amount
Deferred
from Total Compensation (c) |
George Batejan (d) | N/A | N/A |
Kathleen Blatz | $320,000 | 0 |
Edward Boudreau | $302,500 | $136,125 |
Pamela Carlton | $320,000 | 0 |
William Carmichael | $295,000 | 0 |
Patricia Flynn | $290,000 | $290,000 |
Brian Gallagher (d) | N/A | N/A |
William Hawkins (e) | $410,000 | $102,500 |
R. Glenn Hilliard (e) | $240,833 | 0 |
Catherine Paglia | $320,000 | $160,000 |
Leroy Richie (e) | $285,000 | 0 |
Anthony Santomero | $300,000 | 0 |
Minor Shaw | $290,000 | $145,000 |
John Taft (f) | N/A | N/A |
Alison Taunton-Rigby (e) | $305,000 | $305,000 |
Sandra Yeager (d) | N/A | N/A |
(a) | Trustee compensation is paid by the Funds and is comprised of a combination of a base fee and meeting fees, with the exception of the Chair of the Board, who receives a base annual compensation. Payment of compensation is administered by a company providing limited administrative services to the Funds and to the Board. |
(b) | Includes any portion of cash compensation Trustees elected to defer during the fiscal period. |
(c) | The Trustees may elect to defer a portion of the total cash compensation payable. Additional information regarding the Deferred Compensation Plan is described below. |
(d) | Mr. Batejan became a Trustee effective January 1, 2017, and Mr. Gallagher and Ms. Yeager each became a Trustee effective December 31, 2017. Each of these Trustees received no compensation from the Funds or the Columbia Funds Complex prior to these respective dates. |
(e) | Mr. Hilliard served as Trustee until October 28, 2016, Mr. Richie served as Trustee until December 31, 2016, and Mr. Hawkins and Ms. Taunton-Rigby each served as Trustee until January 1, 2018. Each former Trustee stopped receiving compensation from the Funds and the Columbia Funds Complex as of these respective dates. |
(f) | Mr. Taft served as a Trustee from January 1, 2017 through January 1, 2018. Mr. Taft received no compensation from the Funds or the Columbia Funds Complex prior to January 1, 2017 or subsequent to January 1, 2018. |
Statement of Additional Information – [May 1, 2018] | 161 |
Statement of Additional Information – [May 1, 2018] | 162 |
Fund |
Aggregate
Compensation from Fund
Independent Trustees |
|||||||
Batejan (a) | Blatz | Boudreau | Carlton | Carmichael | Flynn | Gallagher (b) | Hawkins (c) | |
VP - Emerging Markets Fund | N/A | $1,777 | $1,739 | $1,777 | $1,651 | $1,617 | N/A | $2,324 |
Amount Deferred | N/A | $0 | $783 | $0 | $0 | $1,617 | N/A | $551 |
VP - Global Bond Fund | N/A | $1,057 | $1,033 | $1,057 | $972 | $955 | N/A | $1,376 |
Amount Deferred | N/A | $0 | $465 | $0 | $0 | $955 | N/A | $326 |
VP - Government Money Market Fund | N/A | $1,290 | $1,261 | $1,290 | $1,188 | $1,166 | N/A | $1,676 |
Amount Deferred | N/A | $0 | $567 | $0 | $0 | $1,166 | N/A | $397 |
VP - High Yield Bond Fund | N/A | $1,368 | $1,336 | $1,368 | $1,258 | $1,236 | N/A | $1,780 |
Amount Deferred | N/A | $0 | $601 | $0 | $0 | $1,236 | N/A | $422 |
VP - Income Opportunities Fund | N/A | $1,397 | $1,367 | $1,397 | $1,293 | $1,269 | N/A | $1,821 |
Amount Deferred | N/A | $0 | $615 | $0 | $0 | $1,269 | N/A | $432 |
VP - Intermediate Bond Fund | N/A | $6,816 | $6,656 | $6,816 | $6,263 | $6,150 | N/A | $8,852 |
Amount Deferred | N/A | $0 | $2,995 | $0 | $0 | $6,150 | N/A | $2,098 |
VP - Large Cap Growth Fund | N/A | $2,428 | $2,371 | $2,428 | $2,231 | $2,193 | N/A | $3,158 |
Amount Deferred | N/A | $0 | $1,067 | $0 | $0 | $2,193 | N/A | $748 |
VP - Large Cap Index Fund | N/A | $1,214 | $1,186 | $1,214 | $1,116 | $1,096 | N/A | $1,580 |
Amount Deferred | N/A | $0 | $534 | $0 | $0 | $1,096 | N/A | $374 |
VP - Limited Duration Credit Fund | N/A | $1,875 | $1,831 | $1,875 | $1,724 | $1,693 | N/A | $2,438 |
Amount Deferred | N/A | $0 | $824 | $0 | $0 | $1,693 | N/A | $578 |
VP - Loomis Sayles Growth Fund | N/A | $3,588 | $3,496 | $3,588 | $3,281 | $3,229 | N/A | $4,647 |
Amount Deferred | N/A | $0 | $1,573 | $0 | $0 | $3,229 | N/A | $1,101 |
VP - Los Angeles Capital Large Cap Growth Fund | N/A | $2,224 | $2,175 | $2,224 | $2,051 | $2,013 | N/A | $2,901 |
Amount Deferred | N/A | $0 | $979 | $0 | $0 | $2,013 | N/A | $687 |
VP - MFS Blended Research Core Equity Fund | N/A | $2,765 | $2,700 | $2,765 | $2,543 | $2,498 | N/A | $3,598 |
Amount Deferred | N/A | $0 | $1,215 | $0 | $0 | $2,498 | N/A | $853 |
VP - MFS Value Fund | N/A | $3,121 | $3,044 | $3,121 | $2,862 | $2,813 | N/A | $4,054 |
Amount Deferred | N/A | $0 | $1,370 | $0 | $0 | $2,813 | N/A | $961 |
VP - Mid Cap Growth Fund | N/A | $1,254 | $1,223 | $1,254 | $1,150 | $1,131 | N/A | $1,631 |
Amount Deferred | N/A | $0 | $550 | $0 | $0 | $1,131 | N/A | $386 |
VP - Mid Cap Value Fund | N/A | $1,068 | $1,042 | $1,068 | $978 | $963 | N/A | $1,389 |
Amount Deferred | N/A | $0 | $469 | $0 | $0 | $963 | N/A | $329 |
VP - Moderate Portfolio | N/A | $23,004 | $22,458 | $23,004 | $21,159 | $20,779 | N/A | $29,904 |
Amount Deferred | N/A | $0 | $10,106 | $0 | $0 | $20,779 | N/A | $7,087 |
VP - Moderately Aggressive Portfolio | N/A | $11,770 | $11,494 | $11,770 | $10,831 | $10,635 | N/A | $15,311 |
Amount Deferred | N/A | $0 | $5,172 | $0 | $0 | $10,635 | N/A | $3,628 |
VP - Moderately Conservative Portfolio | N/A | $5,276 | $5,151 | $5,276 | $4,852 | $4,765 | N/A | $6,858 |
Amount Deferred | N/A | $0 | $2,318 | $0 | $0 | $4,765 | N/A | $1,625 |
VP - Morgan Stanley Advantage Fund | N/A | $2,090 | $2,042 | $2,090 | $1,924 | $1,890 | N/A | $2,723 |
Amount Deferred | N/A | $0 | $919 | $0 | $0 | $1,890 | N/A | $645 |
VP - MV Moderate Growth Fund | N/A | $14,258 | $13,905 | $14,258 | $13,084 | $12,862 | N/A | $18,511 |
Amount Deferred | N/A | $0 | $6,257 | $0 | $0 | $12,862 | N/A | $4,387 |
VP - Oppenheimer International Growth Fund | N/A | $3,427 | $3,344 | $3,427 | $3,151 | $3,096 | N/A | $4,457 |
Amount Deferred | N/A | $0 | $1,505 | $0 | $0 | $3,096 | N/A | $1,056 |
VP - Overseas Core Fund | N/A | $1,683 | $1,637 | $1,683 | $1,524 | $1,505 | N/A | $2,170 |
Amount Deferred | N/A | $0 | $737 | $0 | $0 | $1,505 | N/A | $514 |
VP - Partners Core Bond Fund | N/A | $4,686 | $4,576 | $4,686 | $4,309 | $4,231 | N/A | $6,086 |
Amount Deferred | N/A | $0 | $2,059 | $0 | $0 | $4,231 | N/A | $1,442 |
VP - Partners Small Cap Growth Fund | N/A | $1,534 | $1,498 | $1,534 | $1,408 | $1,384 | N/A | $1,996 |
Amount Deferred | N/A | $0 | $674 | $0 | $0 | $1,384 | N/A | $473 |
VP - Partners Small Cap Value Fund | N/A | $1,901 | $1,861 | $1,901 | $1,757 | $1,723 | N/A | $2,483 |
Amount Deferred | N/A | $0 | $838 | $0 | $0 | $1,723 | N/A | $588 |
Statement of Additional Information – [May 1, 2018] | 163 |
Fund |
Aggregate
Compensation from Fund
Independent Trustees |
|||||||
Batejan (a) | Blatz | Boudreau | Carlton | Carmichael | Flynn | Gallagher (b) | Hawkins (c) | |
VP - Pyramis International Equity Fund | N/A | $3,378 | $3,296 | $3,378 | $3,105 | $3,052 | N/A | $4,393 |
Amount Deferred | N/A | $0 | $1,483 | $0 | $0 | $3,052 | N/A | $1,041 |
VP - Select Large Cap Equity Fund (d) | $935 | $1,025 | $1,355 | $1,025 | $984 | $935 | $935 | N/A |
Amount Deferred | $0 | $0 | $610 | $103 | $0 | $935 | $0 | N/A |
VP - Select Large-Cap Value Fund | N/A | $1,770 | $1,728 | $1,770 | $1,626 | $1,598 | N/A | $2,306 |
Amount Deferred | N/A | $0 | $778 | $0 | $0 | $1,598 | N/A | $546 |
VP - Select Smaller-Cap Value Fund | N/A | $1,014 | $990 | $1,014 | $932 | $916 | N/A | $1,320 |
Amount Deferred | N/A | $0 | $446 | $0 | $0 | $916 | N/A | $313 |
VP - Seligman Global Technology Fund | N/A | $941 | $920 | $941 | $867 | $851 | N/A | $1,228 |
Amount Deferred | N/A | $0 | $414 | $0 | $0 | $851 | N/A | $291 |
VP - T. Rowe Price Large Cap Value Fund | N/A | $3,065 | $2,991 | $3,065 | $2,815 | $2,766 | N/A | $3,985 |
Amount Deferred | N/A | $0 | $1,346 | $0 | $0 | $2,766 | N/A | $944 |
VP - TCW Core Plus Bond Fund | N/A | $4,406 | $4,302 | $4,406 | $4,053 | $3,979 | N/A | $5,723 |
Amount Deferred | N/A | $0 | $1,936 | $0 | $0 | $3,979 | N/A | $1,356 |
VP - U.S. Equities Fund | N/A | $2,131 | $2,084 | $2,131 | $1,971 | $1,933 | N/A | $2,783 |
Amount Deferred | N/A | $0 | $938 | $0 | $0 | $1,933 | N/A | $660 |
VP - U.S. Government Mortgage Fund | N/A | $2,380 | $2,325 | $2,380 | $2,190 | $2,150 | N/A | $3,094 |
Amount Deferred | N/A | $0 | $1,046 | $0 | $0 | $2,150 | N/A | $733 |
VP - Victory Sycamore Established Value Fund | N/A | $1,209 | $1,179 | $1,209 | $1,107 | $1,090 | N/A | $1,572 |
Amount Deferred | N/A | $0 | $530 | $0 | $0 | $1,090 | N/A | $372 |
VP - Wells Fargo Short Duration Government Fund | N/A | $2,162 | $2,112 | $2,162 | $1,990 | $1,953 | N/A | $2,811 |
Amount Deferred | N/A | $0 | $950 | $0 | $0 | $1,953 | N/A | $666 |
VP - Westfield Mid Cap Growth Fund | N/A | $1,195 | $1,165 | $1,195 | $1,094 | $1,077 | N/A | $1,553 |
Amount Deferred | N/A | $0 | $524 | $0 | $0 | $1,077 | N/A | $368 |
(a) | Mr. Batejan became a Trustee effective January 1, 2017, and as such he received no compensation from the Funds or the Columbia Funds Complex prior to such date. |
(b) | Mr. Gallagher and Ms. Yeager each became a Trustee effective December 31, 2017, and as such have received no compensation from the Funds or the Columbia Funds Complex prior to such date. |
(c) | Mr. Hawkins and Ms. Taunton-Rigby each served as Trustee until January 1, 2018, and stopped receiving compensation from the Funds and the Columbia Funds Complex as of such date. |
(d) | This Fund has not completed its first full year of operations since its organization. The compensation shown for this Fund is the estimated amount that will be paid from January 4, 2018 to December 31, 2018. |
Fund |
Aggregate
Compensation from Fund
Independent Trustees |
|||||||
Hilliard (a) | Paglia | Richie (b) | Santomero | Shaw | Taft (c) | Taunton-Rigby (d) | Yeager (e) | |
For Funds with fiscal period ending December 31 | ||||||||
VP - Aggressive Portfolio | $3,197 | $4,113 | $3,685 | $3,952 | $3,752 | N/A | $3,879 | N/A |
Amount Deferred | $0 | $2,040 | $0 | $0 | $1,876 | N/A | $3,879 | N/A |
VP - American Century Diversified Bond Fund | $4,436 | $5,723 | $5,124 | $5,501 | $5,219 | N/A | $5,396 | N/A |
Amount Deferred | $0 | $2,838 | $0 | $0 | $2,610 | N/A | $5,396 | N/A |
VP - Balanced Fund | $1,522 | $1,982 | $1,774 | $1,902 | $1,805 | N/A | $1,868 | N/A |
Amount Deferred | $0 | $983 | $0 | $0 | $903 | N/A | $1,868 | N/A |
VP - BlackRock Global Inflation-Protected Securities Fund | $788 | $1,019 | $913 | $979 | $929 | N/A | $960 | N/A |
Amount Deferred | $0 | $505 | $0 | $0 | $464 | N/A | $960 | N/A |
VP - CenterSquare Real Estate Fund | $901 | $1,191 | $1,068 | $1,140 | $1,085 | N/A | $1,127 | N/A |
Amount Deferred | $0 | $591 | $0 | $0 | $543 | N/A | $1,127 | N/A |
VP - Columbia Wanger International Equities Fund | $820 | $1,039 | $935 | $1,001 | $954 | N/A | $983 | N/A |
Amount Deferred | $0 | $515 | $0 | $0 | $477 | N/A | $983 | N/A |
VP - Commodity Strategy Fund | $778 | $1,070 | $960 | $1,020 | $974 | N/A | $1,016 | N/A |
Amount Deferred | $0 | $531 | $0 | $0 | $487 | N/A | $1,016 | N/A |
VP - Conservative Portfolio | $1,988 | $2,583 | $2,311 | $2,480 | $2,353 | N/A | $2,435 | N/A |
Amount Deferred | $0 | $1,281 | $0 | $0 | $1,176 | N/A | $2,435 | N/A |
Statement of Additional Information – [May 1, 2018] | 164 |
Fund |
Aggregate
Compensation from Fund
Independent Trustees |
|||||||
Hilliard (a) | Paglia | Richie (b) | Santomero | Shaw | Taft (c) | Taunton-Rigby (d) | Yeager (e) | |
VP - Core Equity Fund | $833 | $1,078 | $965 | $1,035 | $982 | N/A | $1,015 | N/A |
Amount Deferred | $0 | $534 | $0 | $0 | $491 | N/A | $1,015 | N/A |
VP - DFA International Value Fund | $2,396 | $3,115 | $2,790 | $2,989 | $2,838 | N/A | $2,937 | N/A |
Amount Deferred | $0 | $1,545 | $0 | $0 | $1,419 | N/A | $2,937 | N/A |
VP - Disciplined Core Fund | $4,493 | $5,890 | $5,266 | $5,648 | $5,353 | N/A | $5,547 | N/A |
Amount Deferred | $0 | $2,921 | $0 | $0 | $2,677 | N/A | $5,547 | N/A |
VP - Dividend Opportunity Fund | $2,165 | $2,805 | $2,511 | $2,694 | $2,556 | N/A | $2,644 | N/A |
Amount Deferred | $0 | $1,391 | $0 | $0 | $1,278 | N/A | $2,644 | N/A |
VP - Eaton Vance Floating-Rate Income Fund | $772 | $1,001 | $896 | $961 | $912 | N/A | $943 | N/A |
Amount Deferred | $0 | $496 | $0 | $0 | $456 | N/A | $943 | N/A |
VP - Emerging Markets Bond Fund | $766 | $996 | $892 | $957 | $907 | N/A | $939 | N/A |
Amount Deferred | $0 | $494 | $0 | $0 | $454 | N/A | $939 | N/A |
VP - Emerging Markets Fund | $1,430 | $1,790 | $1,617 | $1,727 | $1,651 | N/A | $1,701 | N/A |
Amount Deferred | $0 | $888 | $0 | $0 | $826 | N/A | $1,701 | N/A |
VP - Global Bond Fund | $826 | $1,066 | $955 | $1,024 | $972 | N/A | $1,005 | N/A |
Amount Deferred | $0 | $529 | $0 | $0 | $486 | N/A | $1,005 | N/A |
VP - Government Money Market Fund | $1,013 | $1,300 | $1,166 | $1,251 | $1,188 | N/A | $1,227 | N/A |
Amount Deferred | $0 | $645 | $0 | $0 | $594 | N/A | $1,227 | N/A |
VP - High Yield Bond Fund | $1,066 | $1,380 | $1,236 | $1,325 | $1,258 | N/A | $1,301 | N/A |
Amount Deferred | $0 | $684 | $0 | $0 | $629 | N/A | $1,301 | N/A |
VP - Income Opportunities Fund | $1,115 | $1,410 | $1,269 | $1,357 | $1,293 | N/A | $1,333 | N/A |
Amount Deferred | $0 | $699 | $0 | $0 | $647 | N/A | $1,333 | N/A |
VP - Intermediate Bond Fund | $5,317 | $6,873 | $6,150 | $6,602 | $6,263 | N/A | $6,477 | N/A |
Amount Deferred | $0 | $3,408 | $0 | $0 | $3,132 | N/A | $6,477 | N/A |
VP - Large Cap Growth Fund | $1,890 | $2,449 | $2,193 | $2,351 | $2,231 | N/A | $2,308 | N/A |
Amount Deferred | $0 | $1,214 | $0 | $0 | $1,116 | N/A | $2,308 | N/A |
VP - Large Cap Index Fund | $943 | $1,225 | $1,096 | $1,176 | $1,116 | N/A | $1,154 | N/A |
Amount Deferred | $0 | $607 | $0 | $0 | $558 | N/A | $1,154 | N/A |
VP - Limited Duration Credit Fund | $1,462 | $1,891 | $1,693 | $1,816 | $1,724 | N/A | $1,783 | N/A |
Amount Deferred | $0 | $938 | $0 | $0 | $862 | N/A | $1,783 | N/A |
VP - Loomis Sayles Growth Fund | $2,754 | $3,619 | $3,229 | $3,467 | $3,281 | N/A | $3,402 | N/A |
Amount Deferred | $0 | $1,794 | $0 | $0 | $1,640 | N/A | $3,402 | N/A |
VP - Los Angeles Capital Large Cap Growth Fund | $1,767 | $2,243 | $2,013 | $2,159 | $2,051 | N/A | $2,116 | N/A |
Amount Deferred | $0 | $1,112 | $0 | $0 | $1,025 | N/A | $2,116 | N/A |
VP - MFS Blended Research Core Equity Fund | $2,158 | $2,788 | $2,498 | $2,678 | $2,543 | N/A | $2,630 | N/A |
Amount Deferred | $0 | $1,383 | $0 | $0 | $1,271 | N/A | $2,630 | N/A |
VP - MFS Value Fund | $2,419 | $3,147 | $2,813 | $3,020 | $2,862 | N/A | $2,963 | N/A |
Amount Deferred | $0 | $1,561 | $0 | $0 | $1,431 | N/A | $2,963 | N/A |
VP - Mid Cap Growth Fund | $964 | $1,264 | $1,131 | $1,213 | $1,150 | N/A | $1,191 | N/A |
Amount Deferred | $0 | $627 | $0 | $0 | $575 | N/A | $1,191 | N/A |
VP - Mid Cap Value Fund | $818 | $1,077 | $963 | $1,032 | $978 | N/A | $1,014 | N/A |
Amount Deferred | $0 | $534 | $0 | $0 | $489 | N/A | $1,014 | N/A |
VP - Moderate Portfolio | $17,977 | $23,192 | $20,779 | $22,279 | $21,159 | N/A | $21,884 | N/A |
Amount Deferred | $0 | $11,502 | $0 | $0 | $10,579 | N/A | $21,884 | N/A |
VP - Moderately Aggressive Portfolio | $9,234 | $11,867 | $10,635 | $11,404 | $10,831 | N/A | $11,197 | N/A |
Amount Deferred | $0 | $5,885 | $0 | $0 | $5,415 | N/A | $11,197 | N/A |
VP - Moderately Conservative Portfolio | $4,115 | $5,319 | $4,765 | $5,109 | $4,852 | N/A | $5,018 | N/A |
Amount Deferred | $0 | $2,638 | $0 | $0 | $2,426 | N/A | $5,018 | N/A |
VP - Morgan Stanley Advantage Fund | $1,635 | $2,107 | $1,890 | $2,025 | $1,924 | N/A | $1,989 | N/A |
Amount Deferred | $0 | $1,045 | $0 | $0 | $962 | N/A | $1,989 | N/A |
VP - MV Moderate Growth Fund | $10,947 | $14,373 | $12,862 | $13,784 | $13,084 | N/A | $13,558 | N/A |
Statement of Additional Information – [May 1, 2018] | 165 |
Fund |
Aggregate
Compensation from Fund
Independent Trustees |
|||||||
Hilliard (a) | Paglia | Richie (b) | Santomero | Shaw | Taft (c) | Taunton-Rigby (d) | Yeager (e) | |
Amount Deferred | $0 | $7,129 | $0 | $0 | $6,542 | N/A | $13,558 | N/A |
VP - Oppenheimer International Growth Fund | $2,668 | $3,455 | $3,096 | $3,317 | $3,151 | N/A | $3,261 | N/A |
Amount Deferred | $0 | $1,713 | $0 | $0 | $1,576 | N/A | $3,261 | N/A |
VP - Overseas Core Fund | $1,256 | $1,699 | $1,505 | $1,622 | $1,524 | N/A | $1,585 | N/A |
Amount Deferred | $0 | $841 | $0 | $0 | $762 | N/A | $1,585 | N/A |
VP - Partners Core Bond Fund | $3,650 | $4,724 | $4,231 | $4,539 | $4,309 | N/A | $4,457 | N/A |
Amount Deferred | $0 | $2,343 | $0 | $0 | $2,155 | N/A | $4,457 | N/A |
VP - Partners Small Cap Growth Fund | $1,194 | $1,547 | $1,384 | $1,486 | $1,408 | N/A | $1,456 | N/A |
Amount Deferred | $0 | $767 | $0 | $0 | $704 | N/A | $1,456 | N/A |
VP - Partners Small Cap Value Fund | $1,514 | $1,918 | $1,723 | $1,847 | $1,757 | N/A | $1,811 | N/A |
Amount Deferred | $0 | $951 | $0 | $0 | $878 | N/A | $1,811 | N/A |
VP - Pyramis International Equity Fund | $2,623 | $3,405 | $3,052 | $3,269 | $3,105 | N/A | $3,214 | N/A |
Amount Deferred | $0 | $1,689 | $0 | $0 | $1,553 | N/A | $3,214 | N/A |
VP - Select Large Cap Equity Fund (f) | N/A | $1,025 | N/A | $984 | $935 | $935 | N/A | $935 |
Amount Deferred | N/A | $769 | N/A | $98 | $467 | $0 | N/A | $0 |
VP - Select Large-Cap Value Fund | $1,364 | $1,784 | $1,598 | $1,712 | $1,626 | N/A | $1,683 | N/A |
Amount Deferred | $0 | $885 | $0 | $0 | $813 | N/A | $1,683 | N/A |
VP - Select Smaller-Cap Value Fund | $795 | $1,023 | $916 | $983 | $932 | N/A | $963 | N/A |
Amount Deferred | $0 | $507 | $0 | $0 | $466 | N/A | $963 | N/A |
VP - Seligman Global Technology Fund | $738 | $949 | $851 | $912 | $867 | N/A | $895 | N/A |
Amount Deferred | $0 | $470 | $0 | $0 | $433 | N/A | $895 | N/A |
VP - T. Rowe Price Large Cap Value Fund | $2,370 | $3,090 | $2,766 | $2,966 | $2,815 | N/A | $2,914 | N/A |
Amount Deferred | $0 | $1,532 | $0 | $0 | $1,407 | N/A | $2,914 | N/A |
VP - TCW Core Plus Bond Fund | $3,436 | $4,442 | $3,979 | $4,268 | $4,053 | N/A | $4,191 | N/A |
Amount Deferred | $0 | $2,203 | $0 | $0 | $2,026 | N/A | $4,191 | N/A |
VP - U.S. Equities Fund | $1,688 | $2,147 | $1,933 | $2,067 | $1,971 | N/A | $2,034 | N/A |
Amount Deferred | $0 | $1,065 | $0 | $0 | $985 | N/A | $2,034 | N/A |
VP - U.S. Government Mortgage Fund | $1,870 | $2,399 | $2,150 | $2,307 | $2,190 | N/A | $2,263 | N/A |
Amount Deferred | $0 | $1,190 | $0 | $0 | $1,095 | N/A | $2,263 | N/A |
VP - Victory Sycamore Established Value Fund | $918 | $1,219 | $1,090 | $1,168 | $1,107 | N/A | $1,148 | N/A |
Amount Deferred | $0 | $605 | $0 | $0 | $554 | N/A | $1,148 | N/A |
VP - Wells Fargo Short Duration Government Fund | $1,695 | $2,180 | $1,953 | $2,096 | $1,990 | N/A | $2,056 | N/A |
Amount Deferred | $0 | $1,081 | $0 | $0 | $995 | N/A | $2,056 | N/A |
VP - Westfield Mid Cap Growth Fund | $911 | $1,204 | $1,077 | $1,154 | $1,094 | N/A | $1,135 | N/A |
Amount Deferred | $0 | $597 | $0 | $0 | $547 | N/A | $1,135 | N/A |
(a) | Mr. Hilliard served as Trustee until October 28, 2016, and stopped receiving compensation from the Funds and the Columbia Funds Complex as of such date. |
(b) | Mr. Richie served as Trustee until December 31, 2016, and stopped receiving compensation from the Funds and the Columbia Funds Complex as of such date. |
(c) | Mr. Taft served as a Trustee from January 1, 2017 through January 1, 2018. Mr. Taft received no compensation from the Funds or the Columbia Funds Complex prior to January 1, 2017 or subsequent to January 1, 2018. |
(d) | Mr. Hawkins and Ms. Taunton-Rigby each served as Trustee until January 1, 2018, and stopped receiving compensation from the Funds and the Columbia Funds Complex as of such date. |
(e) | Mr. Gallagher and Ms. Yeager each became a Trustee effective December 31, 2017, and as such have received no compensation from the Funds or the Columbia Funds Complex prior to such date. |
(f) | This Fund has not completed its first full year of operations since its organization. The compensation shown for this Fund is the estimated amount that will be paid from January 4, 2018 to December 31, 2018. |
Statement of Additional Information – [May 1, 2018] | 166 |
Statement of Additional Information – [May 1, 2018] | 167 |
Statement of Additional Information – [May 1, 2018] | 168 |
Statement of Additional Information – [May 1, 2018] | 169 |
Total Brokerage Commissions | |||
Fund | 2016 | 2015 | 2014 |
For Funds with fiscal period ending December 31 | |||
VP – Aggressive Portfolio | $86,506 | $49,217 | $0 |
VP – American Century Diversified Bond Fund | 50,236 | 23,445 | 64,278 |
VP – Balanced Fund | 338,720 | 303,362 | 321,521 |
VP – BlackRock Global Inflation-Protected Securities Fund | 16,741 | 71,728 | 189,077 |
VP – CenterSquare Real Estate Fund | 658,464 | 156,139 | 283,201 |
VP – Columbia Wanger International Equities Fund | 543,074 | 1,159,429 | 595,712 |
VP – Commodity Strategy Fund | 0 | 0 | 0 |
VP – Conservative Portfolio | 10,682 | 9,743 | 0 |
VP – Core Equity Fund | 115,938 | 68,340 | 89,298 |
VP – DFA International Value Fund | 268,766 | 448,501 | 304,892 |
VP – Disciplined Core Fund | 2,831,001 | 1,192,626 | 1,025,456 |
VP – Dividend Opportunity Fund | 1,033,860 | 2,323,764 | 3,138,628 |
VP – Eaton Vance Floating-Rate Income Fund | 151 | 0 | 0 |
VP – Emerging Markets Bond Fund | 516 | 3,012 | 2,787 |
VP – Emerging Markets Fund | 2,829,963 | 3,638,700 | 3,510,697 |
VP – Global Bond Fund | 38,184 | 38,524 | 150,662 |
VP – Government Money Market Fund | 0 | 0 | 0 |
VP – High Yield Bond Fund | 1,302 | 450 | 742 |
VP – Income Opportunities Fund | 2,142 | 865 | 1,485 |
VP – Intermediate Bond Fund | 355,754 | 113,068 | 54,657 |
VP – Large Cap Growth Fund | 535,099 | 511,627 | 779,311 |
VP – Large Cap Index Fund | 6,462 | 2,257 | 1,640 |
VP – Limited Duration Credit Fund | 37,095 | 58,718 | 87,679 |
VP – Loomis Sayles Growth Fund | 440,201 | 319,950 | 901,744 |
VP – Los Angeles Capital Large Cap Growth Fund | 942,315 | 841,260 | 867,383 |
Statement of Additional Information – [May 1, 2018] | 170 |
Total Brokerage Commissions | |||
Fund | 2016 | 2015 | 2014 |
VP – MFS Blended Research Core Equity Fund | $1,209,239 | $1,011,089 | $821,125 |
VP – MFS Value Fund | 253,244 | 215,288 | 344,853 |
VP – Mid Cap Growth Fund | 565,006 | 349,370 | 475,050 |
VP – Mid Cap Value Fund | 192,809 | 214,348 | 511,967 |
VP – Moderate Portfolio | 333,388 | 323,902 | 0 |
VP – Moderately Aggressive Portfolio | 158,813 | 190,397 | 0 |
VP – Moderately Conservative Portfolio | 66,497 | 44,066 | 0 |
VP – Morgan Stanley Advantage Fund | 989,058 | 235,007 | 253,793 |
VP – MV Moderate Growth Fund | 1,906,729 | 5,184,059 | 1,524,619 |
VP – Oppenheimer International Growth Fund | 2,987,662 | 1,638,667 | 1,474,279 |
VP – Overseas Core Fund | 939,587 | 396,893 | 499,241 |
VP – Partners Core Bond Fund | 0 | 0 | 0 |
VP – Partners Small Cap Growth Fund | 764,454 | 689,294 | 549,090 |
VP – Partners Small Cap Value Fund | 1,665,452 | 1,671,710 | 2,804,079 |
VP – Pyramis International Equity Fund | 2,421,231 | 2,719,506 | 1,975,230 |
VP – Select Large Cap Equity Fund (a) | N/A | N/A | N/A |
VP – Select Large-Cap Value Fund | 351,451 | 126,580 | 182,260 |
VP – Select Smaller-Cap Value Fund | 163,830 | 128,521 | 173,777 |
VP – Seligman Global Technology Fund | 112,012 | 139,038 | 183,814 |
VP – T. Rowe Price Large Cap Value Fund | 663,534 | 1,125,615 | 749,321 |
VP – TCW Core Plus Bond Fund | 29,656 | 17,108 | 1,990 |
VP – U.S. Equities Fund | 4,222,557 | 1,619,370 | 242,432 |
VP – U.S. Government Mortgage Fund | 165,925 | 131,773 | 338,693 |
VP – Victory Sycamore Established Value Fund | 322,678 | 458,266 | 879,264 |
VP – Wells Fargo Short Duration Government Fund | 14,533 | 0 | 0 |
VP – Westfield Mid Cap Growth Fund | 129,783 | 239,601 | 548,326 |
(a) | No historical information is given for the Fund because the Fund had not commenced operations as of the date of this SAI. |
Statement of Additional Information – [May 1, 2018] | 171 |
Broker |
Nature
of
Affiliation |
Aggregate
dollar amount of commissions paid to broker |
Percent
of
aggregate brokerage commissions |
Percent
of
aggregate dollar amount of transactions involving payment of commissions |
Aggregate
dollar amount of commissions paid to broker |
Aggregate
dollar amount of commissions paid to broker |
|
Fund | 2016 | 2015 | 2014 | ||||
For Funds with fiscal period ending December 31 | |||||||
VP – CenterSquare Real Estate Fund | Morgan Stanley & Co. International | (1) | $0 | 0.00% | 0.00% | $402 | $3,083 |
(1) | Morgan Stanley & Co. International was an affiliated broker-dealer of the Fund by virtue of being under common control with the Fund’s former subadviser, MSIM, who ceased subadvising the Fund effective June 1, 2016. |
Brokerage directed for research | ||
Fund | Amount of Transactions | Amount of Commissions Imputed or Paid |
For Funds with fiscal period ending December 31 | ||
VP – Aggressive Portfolio | $15,679,730 | $5,667 |
VP – American Century Diversified Bond Fund | 0 | 0 |
VP – Balanced Fund | 314,674,585 | 140,281 |
VP – BlackRock Global Inflation-Protected Securities Fund | 0 | 0 |
VP – CenterSquare Real Estate Fund | 679,371,900 | 89,675 |
VP – Columbia Wanger International Equities Fund | 13,093,702 | 12,894 |
VP – Commodity Strategy Fund | 0 | 0 |
VP – Conservative Portfolio | 0 | 0 |
VP – Core Equity Fund | 98,337,496 | 41,445 |
VP – DFA International Value Fund | 0 | 0 |
VP – Disciplined Core Fund | 2,325,944,295 | 976,135 |
VP – Dividend Opportunity Fund | 807,259,024 | 531,774 |
VP – Eaton Vance Floating-Rate Income Fund | 0 | 0 |
VP – Emerging Markets Bond Fund | 0 | 0 |
VP – Emerging Markets Fund | 245,552,245 | 349,301 |
VP – Global Bond Fund | 0 | 0 |
VP – Government Money Market Fund | 0 | 0 |
VP – High Yield Bond Fund | 0 | 0 |
VP – Income Opportunities Fund | 0 | 0 |
VP – Intermediate Bond Fund | 0 | 0 |
Statement of Additional Information – [May 1, 2018] | 172 |
Brokerage directed for research | ||
Fund | Amount of Transactions | Amount of Commissions Imputed or Paid |
VP – Large Cap Growth Fund | $750,435,682 | $230,652 |
VP – Large Cap Index Fund | 0 | 0 |
VP – Limited Duration Credit Fund | 0 | 0 |
VP – Loomis Sayles Growth Fund | 1,016,898,992 | 278,969 |
VP – Los Angeles Capital Large Cap Growth Fund | 1,044,470,119 | 357,282 |
VP – MFS Blended Research Core Equity Fund | 3,303,848,564 | 273,937 |
VP – MFS Value Fund | 838,242,165 | 58,730 |
VP – Mid Cap Growth Fund | 259,745,807 | 166,548 |
VP – Mid Cap Value Fund | 67,598,851 | 47,716 |
VP – Moderate Portfolio | 79,839,538 | 28,855 |
VP – Moderately Aggressive Portfolio | 26,474,945 | 9,568 |
VP – Moderately Conservative Portfolio | 15,851,443 | 5,729 |
VP – Morgan Stanley Advantage Fund | 2,705,018,048 | 535,761 |
VP – MV Moderate Growth Fund | 304,796,653 | 113,450 |
VP – Oppenheimer International Growth Fund | 4,016,376,790 | 2,570,513 |
VP – Overseas Core Fund | 361,355,548 | 489,338 |
VP – Partners Core Bond Fund | 0 | 0 |
VP – Partners Small Cap Growth Fund | 30,513,094 | 30,987 |
VP – Partners Small Cap Value Fund | 642,855,012 | 635,765 |
VP – Pyramis International Equity Fund | 1,801,381,533 | 2,073,500 |
VP – Select Large Cap Equity Fund (a) | N/A | N/A |
VP – Select Large-Cap Value Fund | 175,375,438 | 83,992 |
VP – Select Smaller-Cap Value Fund | 21,452,735 | 21,219 |
VP – Seligman Global Technology Fund | 31,910,371 | 16,492 |
VP – T. Rowe Price Large Cap Value Fund | 136,489,900 | 101,717 |
VP – TCW Core Plus Bond Fund | 0 | 0 |
VP – U.S. Equities Fund | 644,685,843 | 582,438 |
VP – U.S. Government Mortgage Fund | 0 | 0 |
VP – Victory Sycamore Established Value Fund | 247,321,568 | 118,009 |
VP – Wells Fargo Short Duration Government Fund | 0 | 0 |
VP – Westfield Mid Cap Growth Fund | 55,905,687 | 30,085 |
(a) | No historical information is given for the Fund because the Fund had not commenced operations as of the date of this SAI. |
Statement of Additional Information – [May 1, 2018] | 173 |
Statement of Additional Information – [May 1, 2018] | 174 |
Fund | Issuer |
Value
of securities owned
at end of fiscal period |
VP – Dividend Opportunity Fund | Credit Suisse AG | $7,955,771 |
JPMorgan Chase & Co. | $10,616,863 | |
JPMorgan Chase Bank | $10,727,476 | |
Morgan Stanley | $14,183,367 | |
VP – Eaton Vance Floating-Rate Income Fund | None | N/A |
VP – Emerging Markets Bond Fund | None | N/A |
VP – Emerging Markets Fund | None | N/A |
VP – Global Bond Fund | Citigroup Mortgage Loan Trust, Inc. | $2,934,109 |
E*TRADE Financial Corp. | $143,820 | |
VP – Government Money Market Fund | None | N/A |
VP – High Yield Bond Fund | E*TRADE Financial Corp. | $993,480 |
VP – Income Opportunities Fund | E*TRADE Financial Corp. | $2,113,440 |
VP – Intermediate Bond Fund | Chase Issuance Trust | $8,739,557 |
Citigroup, Inc. | $17,997,501 | |
Citigroup Commercial Mortgage Trust | $8,330,089 | |
Citigroup Mortgage Loan Trust, Inc. | $42,667,790 | |
Credit Suisse Mortgage Capital Certificates | $36,470,257 | |
Credit Suisse Commercial Mortgage Trust | $1,076,839 | |
Credit Suisse Securities (USA) LLC | $6,236,233 | |
E*TRADE Financial Corp. | $1,569,780 | |
GS Mortgage Securities Corp. II | $2,411,978 | |
JPMorgan Chase Capital XXI | $41,728,626 | |
JPMorgan Chase Capital XXIII | $15,855,378 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $3,725,483 | |
JPMorgan Resecuritization Trust | $5,260,916 | |
LB-UBS Commercial Mortgage Trust | $2,494,797 | |
Morgan Stanley Capital I Trust | $6,790,270 | |
Morgan Stanley Re-Remic Trust | $11,992,866 | |
Morgan Stanley Resecuritization Trust | $3,344,916 | |
PNC Bank | $4,862,257 | |
VP – Large Cap Growth Fund | The Goldman Sachs Group, Inc. | $31,348,794 |
VP – Large Cap Index Fund | Affiliated Managers Group, Inc. | $157,651 |
Ameriprise Financial, Inc. | $347,797 | |
Citigroup, Inc. | $3,364,273 | |
E*TRADE Financial Corp. | $188,357 | |
Franklin Resources, Inc. | $272,706 | |
The Goldman Sachs Group, Inc. | $1,759,718 | |
JPMorgan Chase & Co. | $6,133,234 | |
Morgan Stanley | $1,210,420 | |
PNC Financial Services Group, Inc.(The) | $1,130,536 | |
The Charles Schwab Corp. | $945,859 | |
VP – Limited Duration Credit Fund | None | N/A |
VP – Loomis Sayles Growth Fund | None | N/A |
VP – Los Angeles Capital Large Cap Growth Fund | JPMorgan Chase & Co. | $10,294,397 |
VP – MFS Blended Research Core Equity Fund | Citigroup, Inc. | $33,576,583 |
JPMorgan Chase & Co. | $27,290,852 |
Statement of Additional Information – [May 1, 2018] | 175 |
Fund | Issuer |
Value
of securities owned
at end of fiscal period |
VP – MFS Value Fund | Citigroup, Inc. | $36,603,234 |
Franklin Resources, Inc. | $10,509,123 | |
The Goldman Sachs Group, Inc. | $49,350,166 | |
JPMorgan Chase & Co. | $97,607,796 | |
PNC Financial Services Group, Inc.(The) | $26,010,501 | |
VP – Mid Cap Growth Fund | None | N/A |
VP – Mid Cap Value Fund | E*TRADE Financial Corp. | $4,289,670 |
VP – Moderate Portfolio | None | N/A |
VP – Moderately Aggressive Portfolio | None | N/A |
VP – Moderately Conservative Portfolio | None | N/A |
VP – Morgan Stanley Advantage Fund | None | N/A |
VP – MV Moderate Growth Fund | Citigroup, Inc. | $2,887,584 |
The Goldman Sachs Group, Inc. | $1,976,657 | |
JPMorgan Chase & Co. | $3,444,006 | |
Morgan Stanley | $1,514,571 | |
VP – Oppenheimer International Growth Fund | None | N/A |
VP – Overseas Core Fund | None | N/A |
VP – Partners Core Bond Fund | Bear Stearns Adjustable Rate Mortgage Trust | $687,335 |
Bear Stearns Alt-A Trust | $811,621 | |
Bear Stearns Asset-Backed Securities Trust | $381,162 | |
Bear Stearns Commercial Mortgage Securities | $23,631 | |
Chase Funding Trust | $1,643,834 | |
Citigroup, Inc. | $12,296,070 | |
Citigroup Commercial Mortgage Trust | $870,904 | |
Citigroup/Deutsche Bank Commercial Mortgage Trust | $5,745 | |
Citigroup Mortgage Loan Trust, Inc. | $2,514,545 | |
Credit Suisse Mortgage Capital Certificates | $2,108,745 | |
Credit Suisse Group AG | $2,365,878 | |
Credit Suisse Group Funding Guernsey Ltd. | $2,680,454 | |
Credit Suisse First Boston Mortgage Securities Corp. | $1,465,746 | |
GS Mortgage Securities Trust | $1,229,130 | |
GS Mortgage Securities Corp. II | $3,027,236 | |
The Goldman Sachs Group, Inc. | $20,609,127 | |
Jefferies Group LLC | $2,121,687 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $640,470 | |
JPMorgan Mortgage Trust | $1,257,083 | |
JPMorgan Resecuritization Trust | $19,498 | |
LB-UBS Commercial Mortgage Trust | $448,818 | |
Merrill Lynch Mortgage Trust | $3,117,918 | |
Merrill Lynch/Countrywide Commercial Mortgage Trust | $460,110 | |
Banc of America Merrill Lynch Commercial Mortgage, Inc. | $145,282 | |
Morgan Stanley | $17,647,024 | |
Morgan Stanley Mortgage Loan Trust | $451,628 | |
Morgan Stanley Re-Remic Trust | $3,310,622 | |
Morgan Stanley Capital I Trust | $38,910 | |
PNC Bank NA | $1,621,330 | |
The Charles Schwab Corp. | $332,515 |
Statement of Additional Information – [May 1, 2018] | 176 |
Fund | Issuer |
Value
of securities owned
at end of fiscal period |
VP – Partners Small Cap Growth Fund | Eaton Vance Corp. | $7,585,515 |
VP – Partners Small Cap Value Fund | None | N/A |
VP – Pyramis® International Equity Fund | Credit Suisse Group AG | $18,054,878 |
VP – Select Large Cap Equity Fund (a) | N/A | N/A |
VP – Select Large-Cap Value Fund | Citigroup, Inc. | $41,601,000 |
JPMorgan Chase & Co. | $38,830,500 | |
Morgan Stanley | $39,081,250 | |
VP – Select Smaller-Cap Value Fund | None | N/A |
VP – Seligman Global Technology Fund | None | N/A |
VP – T. Rowe Price Large Cap Value Fund | Citigroup, Inc. | $37,488,444 |
JPMorgan Chase & Co. | $84,055,089 | |
Morgan Stanley | $58,021,925 | |
PNC Financial Services Group, Inc.(The) | $10,959,152 | |
VP – TCW Core Plus Bond Fund | Bear Stearns Asset-Backed Securities I Trust | $10,339,288 |
The Bear Stearns Companies LLC | $2,645,595 | |
Citigroup, Inc. | $21,593,645 | |
Citigroup Commercial Mortgage Trust | $18,133,467 | |
Citigroup Mortgage Loan Trust, Inc. | $18,379,529 | |
Credit Suisse Mortgage Capital Certificates | $19,796,301 | |
Credit Suisse Commercial Mortgage Trust | $1,338,672 | |
Credit Suisse First Boston Mortgage Securities Corp. | $2,742,990 | |
The Goldman Sachs Group, Inc. | $21,213,586 | |
JPMorgan Chase & Co. | $22,540,858 | |
JPMorgan Chase Bank NA | $3,130,007 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $13,302,867 | |
Merrill Lynch First Franklin Mortgage Loan Trust | $3,217,832 | |
Merrill Lynch Mortgage-Backed Securities Trust | $3,104,657 | |
Morgan Stanley | $20,063,727 | |
Morgan Stanley Mortgage Loan Trust | $3,214,812 | |
VP – U.S. Equities Fund | E*TRADE Financial Corp. | $2,598,750 |
Piper Jaffray Companies | $4,748,750 | |
Stifel Financial Corp. | $1,873,125 | |
VP – U.S. Government Mortgage Fund | Citigroup Mortgage Loan Trust, Inc. | $14,002,831 |
Credit Suisse Mortgage Capital Certificates | $21,701,327 | |
Credit Suisse Securities (USA) LLC | $15,534,729 | |
Jefferies Resecuritization Trust | $880,085 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $188,508 | |
Banc of America Merrill Lynch Commercial Mortgage, Inc. | $7,019,840 | |
VP – Victory Sycamore Established Value Fund | None | N/A |
VP – Wells Fargo Short Duration Government Fund | GS Mortgage Securities Trust | $4,469,212 |
GS Mortgage Securities Corp. Trust | $1,222,185 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $11,676,971 | |
JPMBB Commercial Mortgage Securities Trust | $904,711 | |
Morgan Stanley Bank of America Merrill Lynch Trust | $333,950 | |
Morgan Stanley Capital I Trust | $1,294,568 |
Statement of Additional Information – [May 1, 2018] | 177 |
Fund | Issuer |
Value
of securities owned
at end of fiscal period |
VP – Westfield Mid Cap Growth Fund | Affiliated Managers Group, Inc. | $6,934,588 |
TD Ameritrade Holding Corp. | $5,234,660 |
(a) | No historical information is given for the Fund because the Fund had not commenced operations as of the date of this SAI. |
Statement of Additional Information – [May 1, 2018] | 178 |
Statement of Additional Information – [May 1, 2018] | 179 |
■ | 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 – [May 1, 2018] | 180 |
Statement of Additional Information – [May 1, 2018] | 181 |
Statement of Additional Information – [May 1, 2018] | 182 |
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 – [May 1, 2018] | 183 |
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 – [May 1, 2018] | 184 |
Identity of Recipient | Conditions/restrictions on use of information |
Frequency
of
Disclosure |
||
Bloomberg, L.P. | Used by certain subadvisers for trade order management, trade fail management and aggregation tools, portfolio and risk analytics, research reports, analytical information and reports, analytical and statistical information, market data, trade management and compliance, attribution analysis, and/or financial modeling. Used by certain subadvisers to support trading system and activity and for evaluation and assessment of execution and practices. Used by certain subadvisers for transaction cost analysis on subadviser trades on transactional data. Used by certain subadvisers for portfolio management research, strategy and data analysis. Used by certain subadvisers for trade order and compliance management. | Daily | ||
BNY Mellon, N.A. | Used by certain subadvisers for middle-office operational services and fund accounting services. | Daily | ||
Brown Brothers Harriman & Co. | Used by certain subadvisers for trade matching and SWIFT messaging and for accounting systems. | Daily | ||
Brown Smith Wallace LLC | Used by certain subadvisers for auditing services. | Annually | ||
Capital IQ, Inc. | Used by certain subadvisers for market data. | Daily | ||
Charles River Development, Ltd. | Used by certain subadvisers for order management and compliance; for supporting the trading OMS system, and for OMS trading system and compliance. | Daily or As Needed | ||
Charles River Systems, Inc. | Used by certain subadvisers for trade management and compliance. | Daily | ||
Citigroup, Inc. | Used by certain subadvisers for middle-office operational services. | Daily | ||
Clearwater Analytics, LLC | Used by certain subadvisers for client reporting. | Daily | ||
Cogent Consulting LLC | Used by certain subadvisers for commission rate evaluation and reporting. | Daily | ||
Depository Trust & Clearing Corp. | Used by certain subadvisers for archiving broker commissions. | Daily | ||
Eagle Investment Systems, LLC | Used by certain subadvisers for accounting systems; for internal reporting requirements, and as an enterprise investment management data repository. | Daily | ||
Electra Information Systems, Inc. | Used by certain subadvisers for portfolio holdings reconciliation, to provide custodian values for reconciliation and to provide monthly audited client statements for market value reconciliations. | Daily | ||
Ernst & Young, LLP | Used by certain subadvisers to provide general audit services. | Semi-annually |
Statement of Additional Information – [May 1, 2018] | 185 |
Identity of Recipient | Conditions/restrictions on use of information |
Frequency
of
Disclosure |
||
eVestment OMNI | Used by certain subadvisers for marketing and reporting. | Quarterly | ||
Eze Software Group, LLC | Used by certain subadvisers for trade order management; for commission and research commission reconciliation with broker dealers, and for trade order management and trade compliance analysis. | Daily | ||
FactSet Research Systems, Inc. | Used by certain subadvisers for analytical and statistical information and research; for market data; for portfolio analytics and risk analysis; for portfolio performance attribution and risk analytics; for monitoring securities and shares owned in the portfolio, running intra-day performance and running portfolio reports; for quantitative analysis for marketing, performance and distribution; for client reporting, and for portfolio and security attribution. | Daily | ||
Fidelity ActionsXchange, Inc. | Used by certain subadvisers for managing corporate actions. | Daily | ||
Fidelity Corporate Action Solutions | Used by certain subadvisers for collecting and instructing on corporate actions utilizing SWIFT. | Daily | ||
Financial Recovery Technologies, LLC | Used by certain subadvisers for class action monitoring. | Quarterly | ||
Financial Tracking Technologies, LLC | Used by certain subadvisers for compliance monitoring. | Daily | ||
FX Connect, LLC | Used by certain subadvisers for FX derivatives reconciliation. | Daily | ||
FX Transparency, LLC | Used by certain subadvisers for FX TACA analysis or transactional data. | Quarterly | ||
Glass Lewis & Company, LLC | Used by certain subadvisers for proxy voting services. | Daily | ||
Global Relay Communications, Inc. | Used by certain subadvisers for capturing electronic messages per regulatory requirement. | Daily | ||
Global Trading Analytics, LLC | Used by certain subadvisers for transaction cost analysis of currency trading. | Daily | ||
Goldman Sachs Group, Inc. | Used by certain subadvisers for clearing treasury futures. | Daily | ||
IHS Markit, Ltd | Used by certain subadvisers to confirm and settle bank loan trades and for matching credit default swaps and interest rate swaps. | Daily | ||
Institutional Shareholder Services Inc. (ISS) | Used by certain subadvisers for proxy voting services. | Daily | ||
Intercontinental Exchange, Inc. | Used by certain subadvisers for pricing and valuation. | Daily | ||
InvestCloud | Used by certain subadvisers for reporting. | Daily | ||
Investment Technology Group, Inc. | Used by certain subadvisers for transaction cost analysis reporting. | Daily |
Statement of Additional Information – [May 1, 2018] | 186 |
Identity of Recipient | Conditions/restrictions on use of information |
Frequency
of
Disclosure |
||
LightSpeed Data Solutions, Inc. | Used by certain subadvisers for post-trade settlement and trade communications. | Daily | ||
Lipper, Inc. | Used by certain subadvisers for asset allocation purposes. | Daily | ||
Liquidnet Holdings, Inc. | Used by certain subadvisers for commission tracking and reporting. | Daily | ||
MSCI, Inc. | Used by certain subadvisers for portfolio evaluation, for portfolio analytics and analysis, for risk analysis and reporting and for analytical information and research. | Daily | ||
Omgeo, LLC | Used by certain subadvisers for trade settlement, trade order management or trade settlements and trade affirmations. Used by certain subadvisers to publish account instructions to brokers, to send allocations to brokers and for confirmation/affirmation matching. Used by certain sub-advisers for electronically providing allocations to counterparties and electronic trade matching, affirmation of confirms. | Daily | ||
Quantitative Services Group | Used by certain subadvisers for trade execution analysis. | Daily | ||
RiskMetrics Solutions, Inc. | Used by certain subadvisers for analytical information and research. | Daily | ||
Schwab Compliance Technologies, Inc. | Used by certain subadvisers for compliance automation software and for monitoring periods of personal trading. | Daily | ||
SEI Investments Company | Used by certain subadvisers for position, account information, back-office and accounting systems. | Daily | ||
SS&C Technologies, Inc. | Used by certain subadvisers for portfolio accounting and for SWIFT messaging and reconciliation. | Daily | ||
State Street Bank and Trust Company | Used by certain subadvisers for investment operations and for FX trade matching and SWIFT messaging. | Daily | ||
State Street Global Services | Used by certain subadvisers for collateral management and SWIFT messaging enrichment for daily trade communication. | Daily | ||
Style Research, Inc. | Used by certain subadvisers for analytical information and research. | Monthly | ||
SWIFT, Scrl. | Used by certain subadvisers for trade information. | Daily | ||
Trade Informatics, LLC | Used by certain subadvisers for trade cost analysis. | Daily | ||
Tradeweb Markets, LLC | Used by certain subadvisers to confirm TBA, Treasuries and Discount Notes. | Daily | ||
TriOptima, AB | Used by certain subadvisers for derivatives reconciliation and for daily reconciliations on collateral management. | Daily |
Statement of Additional Information – [May 1, 2018] | 187 |
Identity of Recipient | Conditions/restrictions on use of information |
Frequency
of
Disclosure |
||
Wilshire Associates, Inc. | Used by certain subadvisers for composite information management and to support composite information management. | Daily or Monthly | ||
Yield Book, Inc. | Used by certain subadvisers for analytics. | Daily |
■ | Allianz Life Insurance Company of North America |
■ | Allianz Life Insurance Company of New York |
■ | American General Life Insurance Company |
■ | Ameritas Life Insurance Corp |
■ | Ameritas Life Insurance Corp of New York |
■ | Delaware Life Insurance Co of New York |
■ | Delaware Life Insurance Company |
■ | Genworth Life & Annuity Insurance |
■ | Genworth Life Insurance Company of New York |
■ | Independence Life & Annuity Co |
■ | Integrity Life Insurance Company |
■ | Jefferson National Life Insurance Company |
■ | Jefferson National Life Insurance Company of New York |
■ | Liberty Life Assurance Company |
■ | Lincoln Life & Annuity Company of New York |
■ | National Integrity Life Insurance Company |
■ | Nationwide Financial Services, Inc. |
■ | New York Life Insurance & Annuity Corporation |
■ | Principal Life Insurance Company |
■ | Principal National Life Insurance Company |
Statement of Additional Information – [May 1, 2018] | 188 |
■ | Security Benefit Life Insurance |
■ | The Lincoln National Life Insurance Company |
■ | The United States Life Insurance Company in the City of New York |
■ | Transamerica Life Insurance Company |
■ | Transamerica Financial Life Insurance Company |
■ | Transamerica Advisors Life Insurance Company |
■ | Transamerica Advisors Life Insurance Company of New York |
■ | Transamerica Premier Life Insurance Company |
■ | Voya Insurance & Annuity Company |
■ | Voya Retirement Insurance & Annuity Company |
Statement of Additional Information – [May 1, 2018] | 189 |
■ | American United Life Insurance Company |
■ | Equitrust Life Insurance Company |
■ | Farm Bureau Life Insurance Company |
■ | Great West Life & Annuity Company of New York |
■ | Great West Life & Annuity Company |
■ | Guardian Insurance & Annuity Company |
■ | Hartford Life Insurance Company |
■ | Liberty Life Assurance Company of Boston |
■ | MEMBERS Life Insurance Company/CUNA |
■ | Midland National Life Insurance Company |
■ | Prudential Annuities Life Assurance Corporation |
■ | RiverSource Life Insurance Company |
■ | RiverSource Life Insurance Co. of New York |
■ | Symetra Life Insurance Company |
Statement of Additional Information – [May 1, 2018] | 190 |
Statement of Additional Information – [May 1, 2018] | 191 |
Statement of Additional Information – [May 1, 2018] | 192 |
Statement of Additional Information – [May 1, 2018] | 193 |
Statement of Additional Information – [May 1, 2018] | 197 |
Statement of Additional Information – [May 1, 2018] | 198 |
Fund |
Total
Capital Loss Carryovers |
Amount Expiring in | Amount not Expiring | ||||
2017 | 2018 | 2019 | Short-term | Long-term | |||
For Funds with fiscal period ending December 31 | |||||||
VP – Commodity Strategy Fund | $484 | $0 | $0 | $0 | $484 | $0 | |
VP – DFA International Value Fund | $19,103,160 | $0 | $0 | $0 | $3,313,847 | $15,789,313 | |
VP – Eaton Vance Floating-Rate Income Fund | $16,705,165 | $0 | $0 | $0 | $0 | $16,705,165 | |
VP – Emerging Markets Bond Fund | $11,608,606 | $0 | $0 | $0 | $1,417,058 | $10,191,548 | |
VP – Emerging Markets Fund | $83,534,863 | $0 | $0 | $0 | $69,366,731 | $14,168,132 | |
VP – Global Bond Fund | $2,552,935 | $0 | $0 | $0 | $0 | $2,552,935 | |
VP – Government Money Market Fund | $2,321,204 | $2,314,650 | $6,554 | $0 | $0 | $0 | |
VP – High Yield Bond Fund | $79,386,558 | $72,257,550 | $0 | $0 | $3,724,859 | $3,404,149 | |
VP – Income Opportunities Fund | $8,956,423 | $0 | $0 | $0 | $2,925,994 | $6,030,429 | |
VP – Limited Duration Credit Fund | $36,016,754 | $0 | $0 | $0 | $19,996,692 | $16,020,062 | |
VP – Overseas Core Fund | $107,742,219 | $69,528,803 | $0 | $0 | $22,714,033 | $15,499,383 |
Statement of Additional Information – [May 1, 2018] | 199 |
Fund |
Total
Capital Loss Carryovers |
Amount Expiring in | Amount not Expiring | ||||
2017 | 2018 | 2019 | Short-term | Long-term | |||
VP – Pyramis International Equity Fund | $112,476,797 | $0 | $0 | $0 | $76,418,520 | $36,058,277 |
Statement of Additional Information – [May 1, 2018] | 200 |
Statement of Additional Information – [May 1, 2018] | 201 |
Statement of Additional Information – [May 1, 2018] | 202 |
Statement of Additional Information – [May 1, 2018] | 203 |
Statement of Additional Information – [May 1, 2018] | 204 |
Statement of Additional Information – [May 1, 2018] | 205 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
VP – Aggressive Portfolio |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
95.51% | 95.05% |
Class 4 | 94.59% | |||
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 4
|
5.41% | N/A | |
VP – American Century Diversified Bond Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 88.68% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
15.19% | N/A | |
JPMCB
NA CUST FOR
VP CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
5.82% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
43.32% | N/A |
Statement of Additional Information – [May 1, 2018] | 206 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
14.47% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
10.10% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
95.35% | N/A | |
VP – Balanced Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 1
|
100.00% | N/A (a) |
Class 2 | 100.00% | |||
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
93.99% | 93.99% | |
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
6.01% | N/A | |
VP – BlackRock Global Inflation-Protected Securities Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 1
|
100.00% | N/A (a) |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
92.80% | 93.29% | |
Class 3 | 93.35% | |||
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
7.12% | N/A | |
Class 3 | 6.65% | |||
VP – CenterSquare Real Estate Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 92.57% (a) |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
11.47% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
49.91% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
30.57% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
6.57% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
96.37% | N/A |
Statement of Additional Information – [May 1, 2018] | 207 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
VP – Columbia Wanger International Equities Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 70.36% (a) |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
11.43% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
48.76% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
31.66% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
6.86% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
96.11% | 27.60% | |
VP – Commodity Strategy Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 93.74% (a) |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
12.58% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
43.34% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
31.89% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
8.67% | N/A | |
NEW
YORK LIFE INSURANCE & ANNUITY
CORP ATTN CHRISTINE DEMPSEY 169 LACKAWANNA AVE PARSIPPANY NJ 07054-1007 |
Class 2
|
70.51% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
27.05% | N/A | |
VP – Conservative Portfolio |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
92.76% | 93.23% |
Class 4 | 93.57% | |||
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
7.24% | N/A | |
Class 4 | 6.43% |
Statement of Additional Information – [May 1, 2018] | 208 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
VP – Core Equity Fund |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 1
|
100.00% | 100.00% |
VP – DFA International Value Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 93.71% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
20.63% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
22.72% | N/A | |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
6.51% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
28.04% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
16.55% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
94.75% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
5.23% | N/A | |
VP – Disciplined Core Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 69.32% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
22.52% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
27.90% | N/A | |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
5.17% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
22.68% | N/A |
Statement of Additional Information – [May 1, 2018] | 209 |
Statement of Additional Information – [May 1, 2018] | 210 |
Statement of Additional Information – [May 1, 2018] | 211 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
96.13% | 93.85% | |
Class 3 | 93.71% | |||
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
6.29% | N/A | |
VP – Government Money Market Fund |
DELAWARE
LIFE INSURANCE COMPANY
1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 1
|
51.54% | N/A |
DELAWARE
LIFE INSURANCE COMPANY
OF NEW YORK 1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 1
|
10.39% | N/A | |
JPMCB
NA CUST FOR
VP CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
18.71% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
5.27% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
87.06% | 80.26% | |
Class 3 | 93.91% | |||
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
12.91% | N/A | |
Class 3 | 6.09% | |||
VP – High Yield Bond Fund |
JPMCB
NA CUST FOR
VARIABLE PORTFOLIO MULTI MANAGER DIVERSIFIED INCOME FUND 14201 DALLAS PKWY FL 10 DALLAS TX 75254-2916 |
Class 1
|
59.59% | N/A |
JPMCB
NA CUST
FOR VARIABLE PORTFOLIO MULTI MANAGER INTEREST RATE ADAPTIVE FUND 14201 DALLAS PKWY FL 10 DALLAS TX 75254-2916 |
Class 1
|
40.05% | N/A | |
MIDLAND
NATIONAL LIFE INS CO
4350 WESTOWN PKWY WEST DES MOINES IA 50266-1036 |
Class 2
|
8.20% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
88.65% | 94.01% | |
Class 3 | 95.45% | |||
VP – Income Opportunities Fund |
DELAWARE
LIFE INSURANCE COMPANY
1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2
|
11.33% | N/A |
HARTFORD
LIFE INSURANCE COMPANY
ATTN DAVID TEN BROECK P O BOX 2999 HARTFORD CT 06104-2999 |
Class 1
|
8.54% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
43.34% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
14.55% | N/A |
Statement of Additional Information – [May 1, 2018] | 212 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
JPMCB
NA CUST FOR
VP MODERATELY CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
8.39% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
81.71% | 63.59% | |
Class 3 | 95.05% | |||
VARIABLE
SEPARATE ACCOUNT OF
ANCHOR NATIONAL LIFE INSURANCE CO 2727-A ALLEN PARKWAY, 4-D1 ATTN: VARIABLE ANNUITY ACCOUNTING HOUSTON TX 77019-2107 |
Class 1
|
10.14% | N/A | |
VP – Intermediate Bond Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 77.63% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
14.32% | N/A | |
JPMCB
NA CUST FOR
VP CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
6.58% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
42.48% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
15.73% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
11.01% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
95.82% | N/A | |
Class 3 | 93.80% | |||
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
6.20% | N/A | |
VP – Large Cap Growth Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 69.56% (a) |
DELAWARE
LIFE INSURANCE COMPANY
1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2
|
64.62% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
19.84% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
23.50% | N/A |
Statement of Additional Information – [May 1, 2018] | 213 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
8.58% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
23.49% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
12.00% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
28.27% | N/A | |
Class 3 | 96.33% | |||
VP – Large Cap Index Fund |
DELAWARE
LIFE INSURANCE COMPANY
1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2
|
89.66% | N/A |
DELAWARE
LIFE INSURANCE COMPANY
OF NEW YORK 1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2
|
10.31% | N/A | |
JPMORGAN
AS CUSTODIAN FOR COLUMBIA
VARIABLE PORTFOLIO U S FLEXIBLE MODERATE GROWTH FUND 14201 DALLAS PKWY FL 11 DALLAS TX 75254-2916 |
Class 1
|
30.55% | N/A | |
JPMORGAN
AS CUSTODIAN FOR COLUMBIA
VARIABLE PORTFOLIO U S FLEXIBLE GROWTH FUND 14201 DALLAS PKWY FL 11 DALLAS TX 75254-2916 |
Class 1
|
67.34% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
92.86% | 72.46% | |
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
7.14% | N/A | |
VP – Limited Duration Credit Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 84.54% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
5.82% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
22.68% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
32.05% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
15.16% | N/A |
Statement of Additional Information – [May 1, 2018] | 214 |
Statement of Additional Information – [May 1, 2018] | 215 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
22.04% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
96.76% | N/A | |
VP – MFS Blended Research Core Equity Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 89.39% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
18.65% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
21.43% | N/A | |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
5.76% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
23.54% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
17.56% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
5.12% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
96.56% | N/A | |
Class 3 | 93.66% | |||
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
6.34% | N/A | |
VP – MFS Value Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 95.98% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
7.62% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
8.82% | N/A |
Statement of Additional Information – [May 1, 2018] | 216 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
6.18% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
50.69% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
17.50% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
6.91% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
93.93% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
6.06% | N/A | |
VP – Mid Cap Growth Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 33.06% (a) |
HARTFORD
LIFE INSURANCE COMPANY
ATTN DAVID TEN BROECK P O BOX 2999 HARTFORD CT 06104-2999 |
Class 1
|
7.23% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
37.13% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
49.44% | N/A | |
KANSAS
CITY LIFE INS
ATTN ACCOUNTING OPERATIONS-VARIABLE PO BOX 219139 KANSAS CITY MO 64121-9139 |
Class 2
|
23.22% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
73.80% | 57.51% | |
Class 3 | 94.13% | |||
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
5.87% | N/A | |
VP – Mid Cap Value Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 52.04% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
38.26% | N/A |
Statement of Additional Information – [May 1, 2018] | 217 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
50.42% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
96.02% | 39.70% | |
Class 3 | 96.10% | |||
VP – Moderate Portfolio |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
94.07% | 93.95% |
Class 4 | 93.87% | |||
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
5.93% | N/A | |
Class 4 | 6.13% | |||
VP – Moderately Aggressive Portfolio |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
94.59% | 94.35% |
Class 4 | 94.12% | |||
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
5.41% | N/A | |
Class 4 | 5.88% | |||
VP – Moderately Conservative Portfolio |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
93.83% | 93.94% |
Class 4 | 94.02% | |||
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
6.17% | N/A | |
Class 4 | 5.98% | |||
VP – Morgan Stanley Advantage Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 91.28% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
14.91% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
18.74% | N/A | |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
6.44% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
33.26% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
18.39% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
95.84% | N/A |
Statement of Additional Information – [May 1, 2018] | 218 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
VP – MV Moderate Growth Fund |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
93.55% | 93.55% |
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
6.45% | N/A | |
VP – Oppenheimer International Growth Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 92.86% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
18.49% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
20.61% | N/A | |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
6.88% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
28.37% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
19.54% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
92.20% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
7.79% | N/A | |
VP – Overseas Core Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 63.14% (a) |
DELAWARE
LIFE INSURANCE COMPANY
1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2
|
11.37% | N/A | |
GE
LIFE & ANNUITY ASSURANCE CO
ATTN VARIABLE ACCOUNTING 6610 W BROAD ST BLDG 3 5TH FL RICHMOND VA 23230-1702 |
Class 2
|
28.21% | N/A | |
HARTFORD
LIFE INSURANCE COMPANY
ATTN DAVID TEN BROECK P O BOX 2999 HARTFORD CT 06104-2999 |
Class 2
|
17.76% | N/A | |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
7.75% | N/A |
Statement of Additional Information – [May 1, 2018] | 219 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
50.87% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
33.25% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
5.27% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
32.31% | 29.03% | |
Class 3 | 93.33% | |||
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
6.67% | N/A | |
VP – Partners Core Bond Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 89.13% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
6.78% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
16.38% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
38.05% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
14.43% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
13.75% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
94.96% | N/A | |
VP – Partners Small Cap Growth Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 92.51% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
23.44% | N/A |
Statement of Additional Information – [May 1, 2018] | 220 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
26.54% | N/A | |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
5.73% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
21.89% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
15.71% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
89.96% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
10.00% | N/A | |
VP – Partners Small Cap Value Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 78.56% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
21.72% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
23.49% | N/A | |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
6.17% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
24.72% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
17.46% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
93.34% | N/A | |
Class 3 | 94.83% | |||
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
6.61% | N/A | |
Class 3 | 5.17% | |||
VP – Pyramis International Equity Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 92.90% (a) |
Statement of Additional Information – [May 1, 2018] | 221 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
17.47% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
19.97% | N/A | |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
7.58% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
28.79% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
19.34% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
94.87% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
5.09% | N/A | |
VP – Select Large-Cap Value Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 88.41% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
15.30% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
16.98% | N/A | |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
17.06% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
13.38% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
30.89% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
98.51% | N/A | |
Class 3 | 96.73% | |||
VP – Select Smaller-Cap Value Fund |
AMERITAS
LIFE INSURANCE CORP
5900 O ST LINCOLN NE 68510-2234 |
Class 2
|
34.31% | N/A |
Statement of Additional Information – [May 1, 2018] | 222 |
Statement of Additional Information – [May 1, 2018] | 223 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
92.99% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
6.99% | N/A | |
VP – TCW Core Plus Bond Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 87.37% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
5.47% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
19.42% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
42.92% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
10.75% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
8.98% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
94.87% | N/A | |
VP – U.S. Equities Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 92.01% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
15.25% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
18.58% | N/A | |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
7.56% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
35.22% | N/A |
Statement of Additional Information – [May 1, 2018] | 224 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
16.70% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
96.80% | N/A | |
VP – U.S. Government Mortgage Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 75.72% (a) |
DELAWARE
LIFE INSURANCE COMPANY
1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2
|
44.87% | N/A | |
DELAWARE
LIFE INSURANCE COMPANY
OF NEW YORK 1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2
|
8.13% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
19.46% | N/A | |
JPMCB
NA CUST FOR
VP CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
6.58% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
41.43% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
10.31% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
10.43% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
45.12% | N/A | |
Class 3 | 94.95% | |||
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3
|
5.05% | N/A | |
VP – Victory Sycamore Established Value Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 76.97% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
21.77% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
26.59% | N/A |
Statement of Additional Information – [May 1, 2018] | 225 |
Fund | Shareholder Name and Address | Share Class |
Percentage
of Class |
Percentage
of Fund
(if greater than 25%) |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
6.02% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
20.60% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
17.01% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
95.82% | N/A | |
Class 3 | 97.32% | |||
VP – Wells Fargo Short Duration Government Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 93.74% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
14.33% | N/A | |
JPMCB
NA CUST FOR
VP CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
6.62% | N/A | |
JPMCB
NA CUST FOR
VP MODERATE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
55.22% | N/A | |
JPMCB
NA CUST FOR
VP MODERATELY CONSERVATIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
19.45% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE
DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
85.73% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE
DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2
|
14.22% | N/A | |
VP – Westfield Mid Cap Growth Fund |
COLUMBIA
MGMT INVESTMENT ADVSR LLC
ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A
|
N/A | 89.96% (a) |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY GROWTH FUND 14201 N DALLAS PKWAY FL 13 DALLAS TX 75254-2916 |
Class 1
|
21.08% | N/A | |
JPMCB
NA CUST FOR
COLUMBIA VP-MANAGED VOLATILITY MODERATE GROWTH FUND 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
25.82% | N/A | |
JPMCB
NA CUST FOR
VP AGGRESSIVE 14201 N DALLAS PKWY FL 13 DALLAS TX 75254-2916 |
Class 1
|
6.31% | N/A |
Statement of Additional Information – [May 1, 2018] | 226 |
(a) | A combination of investments made by the Investment Manager and/or by other Funds managed by the Investment Manager. |
Statement of Additional Information – [May 1, 2018] | 227 |
Statement of Additional Information – [May 1, 2018] | 228 |
Statement of Additional Information – [May 1, 2018] | A-1 |
Statement of Additional Information – [May 1, 2018] | A-2 |
Statement of Additional Information – [May 1, 2018] | A-3 |
Statement of Additional Information – [May 1, 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 – [May 1, 2018] | B-1 |
Statement of Additional Information – [May 1, 2018] | B-2 |
Statement of Additional Information – [May 1, 2018] | B-3 |
Statement of Additional Information – [May 1, 2018] | B-4 |
Statement of Additional Information – [May 1, 2018] | B-5 |
Statement of Additional Information – [May 1, 2018] | B-6 |
Statement of Additional Information – [May 1, 2018] | B-7 |
Statement of Additional Information – [May 1, 2018] | B-8 |
Statement of Additional Information – [May 1, 2018] | B-9 |
Statement of Additional Information – [May 1, 2018] | B-10 |
PART C. OTHER INFORMATION
Item 28. Exhibits
(a)(1) | Amendment No. 1 to the Agreement and Declaration of Trust effective September 11, 2007, is incorporated by reference to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(1)), filed on September 28, 2007. |
(a)(2) | Amendment No. 2 to the Agreement and Declaration of Trust effective April 9, 2008, is incorporated by reference to Post-Effective Amendment No. 2 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(2)), filed on April 21, 2008. |
(a)(3) | Amendment No. 3 to the Agreement and Declaration of Trust effective January 8, 2009, is incorporated by reference to Post-Effective Amendment No. 5 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(3)), filed on April 29, 2009. |
(a)(4) | Amendment No. 4 to the Agreement and Declaration of Trust effective January 14, 2010, is incorporated by reference to Post-Effective Amendment No. 8 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(4)), filed on April 14, 2010. |
(a)(5) | Amendment No. 5 to the Agreement and Declaration of Trust effective April 6, 2010, is incorporated by reference to Post-Effective Amendment No. 9 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(5)), filed on April 29, 2010. |
(a)(6) | Amendment No. 6 to the Agreement and Declaration of Trust effective November 11, 2010, is incorporated by reference to Post-Effective Amendment No. 15 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(6)), filed on April 29, 2011. |
(a)(7) | Amendment No. 7 to the Agreement and Declaration of Trust effective January 11, 2011, is incorporated by reference to Post-Effective Amendment No. 15 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(7)), filed on April 29, 2011. |
(a)(8) | Amendment No. 8 to the Agreement and Declaration of Trust effective September 15, 2011, is incorporated by reference to Post-Effective Amendment No. 20 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(8)), filed on March 2, 2012. |
(a)(9) | Amendment No. 9 to the Agreement and Declaration of Trust effective January 12, 2012, is incorporated by reference to Post-Effective Amendment No. 20 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(9)), filed on March 2, 2012. |
(a)(10) | Amendment No. 10 to the Agreement and Declaration of Trust effective June 14, 2012, is incorporated by reference to Post-Effective Amendment No. 31 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(10)), filed on April 26, 2013. |
(a)(11) | Amendment No. 11 to the Agreement and Declaration of Trust effective September 13, 2012, is incorporated by reference to Post-Effective Amendment No. 31 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(11)), filed on April 26, 2013. |
(a)(12) | Amendment No. 12 to the Agreement and Declaration of Trust effective January 16, 2013, is incorporated by reference to Post-Effective Amendment No. 31 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(12)), filed on April 26, 2013. |
(a)(13) | Amendment No. 13 to the Agreement and Declaration of Trust effective April 17, 2013, is incorporated by reference to Post-Effective Amendment No. 31 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(13)), filed on April 26, 2013. |
(a)(14) | Amendment No. 14 to the Agreement and Declaration of Trust effective April 11, 2014, is incorporated by reference to Post-Effective Amendment No. 38 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(14)), filed on April 29, 2014. |
(a)(15) | Amendment No. 15 to the Agreement and Declaration of Trust effective April 14, 2015, is incorporated by reference to Post-Effective Amendment No. 46 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(15)), filed on May 15, 2015. |
(a)(16) | Amendment No. 16 to the Agreement and Declaration of Trust effective April 19, 2016, is incorporated by reference to Post-Effective Amendment No. 50 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(16)), filed on April 28, 2016. |
(a)(17) | Amendment No. 17 to the Agreement and Declaration of Trust effective November 14, 2016, is incorporated by reference to Post-Effective Amendment No. 54 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(17)), filed on February 17, 2017. |
(a)(18) | Amendment No. 18 to the Agreement and Declaration of Trust effective April 21, 2017, is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(18)), filed on April 27, 2017. |
(a)(19) | Amendment No. 19 to the Agreement and Declaration of Trust effective November 14, 2017, is incorporated by reference to Post-Effective Amendment No. 59 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (a)(19)), filed on December 19, 2017. |
(a)(20) | Amendment No. 20 to the Agreement and Declaration of Trust effective December 19, 2017, is filed electronically herewith as Exhibit (a)(20) to Post-Effective Amendment No. 61 to Registration Statement No. 333-146374 of the Registrant on Form N-1A. |
(b) | By-laws, effective September 6, 2007, most recently amended February 10, 2016, are incorporated by reference to Post-Effective Amendment No. 50 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (b)), filed on April 28, 2016. |
(c) | Stock Certificate: Not Applicable. |
(d)(1) | Management Agreement (amended and restated), dated April 25, 2016, between Columbia Management Investment Advisers, LLC, Registrant, Columbia Funds Series Trust and Columbia Funds Series Trust II, is incorporated by reference to Post-Effective Amendment No. 50 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(1)), filed on April 28, 2016. |
(d)(1)(i) | Schedule A and Schedule B, effective September 30, 2017, to the Management Agreement between Columbia Management Investment Advisers, LLC, the Registrant, Columbia Funds Series Trust and Columbia Funds Series Trust II, effective April 25, 2016, are incorporated by reference to Post-Effective Amendment No. 168 to Registration Statement No. 333-131683 of Columbia Funds Series Trust II on Form N-1A (Exhibit (d)(2)), filed on September 27, 2017. |
(d)(2) | Management Agreement, dated November 15, 2017, between Columbia Management Investment Advisers, LLC, the Registrant, Columbia Funds Series Trust and Columbia Funds Series Trust II, is incorporated by reference to Post-Effective Amendment No. 59 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(2)), filed on December 19, 2017. |
(d)(2)(i) | Schedule A and Schedule B, effective February 2, 2018, to the Management Agreement between Columbia Management Investment Advisers, LLC, the Registrant, Columbia Funds Series Trust and Columbia Funds Series Trust II, effective November 15, 2017, are incorporated by reference to Post-Effective Amendment No. 175 to Registration Statement No. 333-131683 of Columbia Funds Series Trust II on Form N-1A (Exhibit (d)(2)(i)), filed on February 16, 2018. |
(d)(3) | Management Agreement, effective May 1, 2016, between Columbia Management Investment Advisers, LLC and CVPCSF Offshore Fund, Ltd., a wholly-owned subsidiary of Columbia Variable Portfolio - Commodity Strategy Fund, a series of Columbia Funds Variable Series Trust II, is incorporated by reference to Post-Effective Amendment No. 50 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(3)), filed on April 28, 2016. |
(d)(4) | Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and American Century Investment Management, Inc., is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(4)), filed on May 15, 2014. |
(d)(4)(i) | Amendment No. 1, as of September 20, 2017, to the Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and American Century Investment Management, Inc., is incorporated by reference to Post-Effective Amendment No. 59 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(4)(i)), filed on December 19, 2017. |
(d)(5) | Subadvisory Agreement, dated September 13, 2012, between Columbia Management Investment Advisers, LLC and BlackRock Financial Management, Inc., is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(6)), filed on May 15, 2014. |
(d)(6) | Subadvisory Agreement, dated February 15, 2017, between Columbia Management Investment Advisers, LLC and BMO Asset Management Corp., is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(6)), filed on April 27, 2017. |
(d)(7) | Subadvisory Agreement, dated January 2, 2018, between Columbia Management Investment Advisers, LLC and CenterSquare Investment Management LLC, is filed electronically herewith as Exhibit (d)(7) to Post-Effective Amendment No. 61 to Registration Statement No. 333-146374 of the Registrant on Form N-1A. |
(d)(8) | Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and Columbia Wanger Asset Management, LLC, is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(7)), filed on May 15, 2014. |
(d)(9) | Subadvisory Agreement, dated July 16, 2007, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and Denver Investment Advisors LLC, is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(8)), filed on May 15, 2014. |
(d)(9)(i) | Amendment No. 1, as of September 20, 2017, to the Subadvisory Agreement, dated July 16, 2007, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and Denver Investment Advisors LLC, is incorporated by reference to Post-Effective Amendment No. 59 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(9)(i)), filed on December 19, 2017. |
(d)(10) | Subadvisory Agreement, dated September 23, 2011, amended December 5, 2013 (Amendment No. 1), between Columbia Management Investment Advisers, LLC and Dimensional Fund Advisors, L.P., is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(9)), filed on May 15, 2014. |
(d)(10)(i) | Amendment No. 2, as of June 5, 2014, to the Subadvisory Agreement, dated September 23, 2011, amended December 5, 2013, between Columbia Management Investment Advisers, LLC and Dimensional Fund Advisors, L.P., is incorporated by reference to Post-Effective Amendment No. 41 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(10)), filed on August 20, 2014. |
(d)(11) | Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and Eaton Vance Management, is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(11)), filed on May 15, 2014. |
(d)(12) | Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and J.P. Morgan Investment Management Inc., is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(14)), filed on May 15, 2014. |
(d)(12)(i) | Amendment No. 1, as of June 17, 2014, to the Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and J.P. Morgan Investment Management Inc., is incorporated by reference to Post-Effective Amendment No. 42 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(16)), filed on August 20, 2014. |
(d)(12)(ii) | Amendment No. 2, as of April 21, 2017, to the Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and J.P. Morgan Investment Management Inc., is incorporated by reference to Post-Effective Amendment No. 57 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(15)), filed on September 18, 2017. |
(d)(13) | Subadvisory Agreement, dated February 15, 2017, between Columbia Management Investment Advisers, LLC and Jacobs Levy Equity Management, Inc., is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(16)), filed on April 27, 2017. |
(d)(14) | Subadvisory Agreement, dated September 14, 2016, between Columbia Management Investment Advisers, LLC and Kennedy Capital Management, Inc., is incorporated by reference to Post-Effective Amendment No. 53 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(16)), filed on November 14, 2016. |
(d)(15) | Subadvisory Agreement, dated January 15, 2014, between Columbia Management Investment Advisers, LLC and Loomis, Sayles & Company, L.P., is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(16)), filed on May 15, 2014. |
(d)(15)(i) | Amendment No. 1, as of November 19, 2015, to the Subadvisory Agreement, dated January 15, 2014, between Columbia Management Investment Advisers, LLC and Loomis, Sayles & Company, L.P., is incorporated by reference to Post-Effective Amendment No. 50 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(17)), filed on April 28, 2016. |
(d)(16) | Subadvisory Agreement, dated February 15, 2017, between Columbia Management Investment Advisers, LLC and Los Angeles Capital Management and Equity Research, Inc., is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(21)), filed on April 27, 2017. |
(d)(17) | Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and Massachusetts Financial Services Company, is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(18)), filed on May 15, 2014. |
(d)(17)(i) | Amendment No. 1, as of February 10, 2016, to the Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC and Massachusetts Financial Services Company, is incorporated by reference to Post-Effective Amendment No. 50 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(20)), filed on April 28, 2016. |
(d)(17)(ii) | Amendment No. 2, as of September 20, 2017, to the Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC and Massachusetts Financial Services Company, is incorporated by reference to Post-Effective Amendment No. 59 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(17)(ii)), filed on December 19, 2017. |
(d)(18) | Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and Morgan Stanley Investment Management, Inc., is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(20)), filed on May 15, 2014. |
(d)(18)(i) | Amendment No. 1, as of February 10, 2016, to the Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC and Morgan Stanley Investment Management, Inc., is incorporated by reference to Post-Effective Amendment No. 50 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(22)), filed on April 28, 2016. |
(d)(19) | Subadvisory Agreement, dated February 15, 2017, between Columbia Management Investment Advisers, LLC and Nuveen Asset Management, LLC, is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(26)), filed on April 27, 2017. |
(d)(20) | Subadvisory Agreement, dated February 10, 2016, between Columbia Management Investment Advisers, LLC and OppenheimerFunds Inc., is incorporated by reference to Post-Effective Amendment No. 50 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(24)), filed on April 28, 2016. |
(d)(21) | Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and Pyramis Global Advisors, LLC (FIAM LLC), is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(23)), filed on May 15, 2014. |
(d)(22) | Subadvisory Agreement, dated June 18, 2014, between Columbia Management Investment Advisers, LLC and Segall Bryant & Hamill, LLC, is incorporated by reference to Post-Effective Amendment No. 41 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(27)), filed on August 20, 2014. |
(d)(23) | Subadvisory Agreement, dated September 14, 2016, between Columbia Management Investment Advisers, LLC and T. Rowe Price Associates, Inc., is incorporated by reference to Post-Effective Amendment No. 53 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(29)), filed on November 14, 2016. |
(d)(24) | Subadvisory Agreement, dated January 15, 2014, between Columbia Management Investment Advisers, LLC and TCW Investment Management Company, is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(26)), filed on May 15, 2014. |
(d)(25) | Amended and Restated Subadvisory Agreement, dated June 11, 2008, last amended January 16, 2013, between Columbia Management Investment Advisers, LLC and Threadneedle International Limited, is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(27)), filed on May 15, 2014. |
(d)(26) | Subadvisory Agreement, dated June 19, 2013, between Columbia Management Investment Advisers, LLC and Victory Capital Management Inc., is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(29)), filed on May 15, 2014. |
(d)(27) | Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and Wells Capital Management Incorporated, is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(30)), filed on May 15, 2014. |
(d)(27)(i) | Amendment No. 1, as of July 18, 2014, to the Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and Wells Capital Management Incorporated, is incorporated by reference to Post-Effective Amendment No. 42 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(34)), filed on October 15, 2014. |
(d)(27)(ii) | Amendment No. 2, dated April 21, 2017, to the Subadvisory Agreement, dated April 8, 2010, between Columbia Management Investment Advisers, LLC (formerly RiverSource Investments, LLC) and Wells Capital Management Incorporated, is incorporated by reference to Post-Effective Amendment No. 57 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(35)), filed on September 18, 2017. |
(d)(28) | Subadvisory Agreement, dated June 21, 2017, between Columbia Management Investment Advisers, LLC and Westfield Capital Management Company, L.P., is incorporated by reference to Post-Effective Amendment No. 57 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (d)(36)), filed on September 18, 2017. |
(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. 50 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (e)(1)), filed on April 28, 2016. |
(e)(1)(i) | Schedule I, dated November 15, 2017, and Schedule II, dated September 7, 2010, to the Distribution Agreement, amended and restated as of March 1, 2016, between Registrant and Columbia Management Investment Distributors, Inc., are incorporated by reference to Post-Effective Amendment No. 59 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (e)(1)(i)), filed on December 19, 2017. |
(f) | Deferred Compensation Plan, adopted as of December 31, 2011, is incorporated by reference to Post-Effective Amendment No. 52 to Registration Statement No. 333-131683 of Columbia Funds Series Trust II on Form N-1A (Exhibit (f)), filed on February 24, 2012. |
(g)(1) | Second Amended and Restated Master Global Custody Agreement with JPMorgan Chase Bank, N.A., dated March 7, 2011, is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (g)(1)), filed on May 15, 2014. |
(g)(2) | Addendum (related to Columbia Variable Portfolio Emerging Markets Fund and Columbia Variable Portfolio Managed Volatility Fund, now known as Columbia Variable Portfolio Managed Volatility Moderate Growth Fund), dated March 9, 2012, and Addendum (related to Columbia Variable Portfolio Commodity Strategy Fund), dated March 15, 2013, to the Second Amended and Restated Master Global Custody Agreement with JPMorgan Chase Bank, N.A., dated March 7, 2011, are incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (g)(2)), filed on May 15, 2014. |
(g)(3) | Side letter (related to the China Connect Service on behalf of Columbia Variable Portfolio - Emerging Markets Fund), dated December 19, 2014, to the Second Amended and Restated Master Global Custody Agreement with JPMorgan Chase Bank, N.A., dated March 7, 2011, is incorporated by reference to Post-Effective Amendment No. 44 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (g)(3)), filed on February 20, 2015. |
(g)(4) | Addendum (related to Columbia Variable Portfolio Select Large Cap Equity Fund), dated November 8, 2017, to the Second Amended and Restated Master Global Custody Agreement with JPMorgan Chase Bank, N.A., dated March 7, 2011, is incorporated by reference to Post-Effective Amendment No. 59 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (g)(4)), filed on December 19, 2017. |
(h)(1) | Shareholder Services Agreement by and between the Registrant and Columbia Management Investment Services Corp., dated July 1, 2017, is incorporated by reference to Post-Effective Amendment No. 57 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (h)(1)), filed on September 18, 2017. |
(h)(1)(i) | Schedule A, dated November 15, 2017 and Schedule B, effective July 1, 2017, to the Shareholder Services Agreement by and between the Registrant and Columbia Management Investment Services Corp., dated July 1, 2017, are incorporated by reference to Post-Effective Amendment No. 59 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (h)(1)(i)), filed on December 19, 2017. |
(h)(2) | 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, Columbia Funds Series Trust and Columbia Funds Series Trust II, is incorporated by reference to Post-Effective Amendment No. 145 to Registration Statement No. 333-131683 of Columbia Funds Series Trust II on Form N-1A (Exhibit (h)(5)), filed on June 27, 2016. |
(h)(2)(i) | Schedule A, as of February 2, 2018, 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, Columbia Funds Series Trust and Columbia Funds Series Trust II, is incorporated by reference to Post-Effective Amendment No. 175 to Registration Statement No. 333-131683 of Columbia Funds Series Trust II on Form N-1A (Exhibit (h)(3)(i)), filed on February 16, 2018. |
(h)(3) | Agreement and Plan of Reorganization, dated September 11, 2007, between RiverSource Variable Portfolio Funds, each a series of a Minnesota corporation, and corresponding RiverSource Variable Portfolio Funds, each a series of RiverSource Variable Series Trust, now known as Columbia Funds Variable Series Trust II, a Massachusetts business trust, and between RiverSource Variable Portfolio Core Bond Fund, a series of RiverSource Variable Series Trust, and RiverSource Variable Portfolio Diversified Bond Fund, a series of RiverSource Variable Series Trust, now known as Columbia Funds Variable Series Trust II, is incorporated by reference to Post-Effective Amendment No. 2 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (h)(5)), filed on April 21, 2008. |
(h)(4) | 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 the Registrant on Form N-1A (Exhibit (h)(9)), filed on April 29, 2011. |
(h)(5) | Agreement and Plan of Redomiciling, dated December 20, 2010, is incorporated by reference to Post-Effective Amendment No. 15 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (h)(10)), filed on April 29, 2011. |
(h)(6) | Agreement and Plan of Reorganization, dated October 9, 2012, is incorporated by reference to Post-Effective Amendment No. 117 to Registration Statement No. 333-8966 of Columbia Funds Series Trust on Form N-1A (Exhibit (h)(7)), filed on May 30, 2013. |
(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 Columbia Funds Series Trust I on Form N-1A (Exhibit (h)(14)), filed on April 16, 2015. |
(h)(9) | 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 Columbia Funds Series Trust I on Form N-1A (Exhibit (h)(9)(i)), filed on April 11, 2016. |
(i)(1) | Opinion and consent of counsel as to the legality of the securities being registered is incorporated by reference to Post-Effective Amendment No. 38 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (i)), filed on April 29, 2014. |
(i)(2) | Opinion and consent of counsel as to the legality of the securities being registered for Columbia Variable Portfolio Select Large Cap Equity Fund is incorporated by reference to Post-Effective Amendment No. 59 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (i)(2)), filed on December 19, 2017. |
(j) | Consent of Independent Registered Public Accounting Firm: To be filed by Amendment. |
(k) | Omitted Financial Statements: Not Applicable. |
(l) | Initial Capital Agreement: Not Applicable. |
(m)(1) | Plan of Distribution and Agreement of Distribution, effective May 1, 2009, amended and restated March 7, 2011, between Registrant and Columbia Management Investment Distributors, Inc., is incorporated by reference to Post-Effective Amendment No. 38 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (m)(1)), filed on April 29, 2014. |
(m)(1)(i) | Schedule A, effective November 15, 2017, to the Plan of Distribution and Agreement of Distribution, effective May 1, 2009, amended and restated March 7, 2011, between Registrant and Columbia Management Investment Distributors, Inc. is incorporated by reference to Post-Effective Amendment No. 59 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (m)(1)(i)), filed on December 19, 2017. |
(n) | Rule 18f 3(d), amended and restated November 15, 2017, is incorporated by reference to Post-Effective Amendment No. 59 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (n)), filed on December 19, 2017. |
(o) | Reserved. |
(p)(1) | Code of Ethics adopted under Rule 17j-1 for Registrant, effective April 14, 2014, is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(1)), filed on May 15, 2014. |
(p)(2) | Ameriprise Global Asset Management Personal Trading Account Dealing and Code of Ethics Policy, effective December 27, 2017, is incorporated by reference to Post-Effective Amendment No. 315 to Registration Statement No. 2-99356 of Columbia Funds Series Trust I on Form N-1A (Exhibit (p)(2)), filed on February 1, 2018. |
(p)(3) | American Century Investment Management, Inc. Code of Ethics, dated December 19, 2016, is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(3)), filed on April 27, 2017. |
(p)(4) | BlackRock Financial Management, Inc. Code of Ethics, dated January 11, 2017, is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(4)), filed on April 27, 2017. |
(p)(5) | BMO Asset Management, Corp. Code of Ethics, dated December 2016, is incorporated by reference to Post-Effective Amendment No. 295 to Registration Statement No. 2-99356 of Columbia Funds Series Trust I on Form N-1A (Exhibit (p)(12)), filed on April 26, 2017. |
(p)(6) | CenterSquare Investment Management LLC Code of Ethics to be filed by Amendment. |
(p)(7) | Columbia Wanger Asset Management, LLC Code of Ethics, effective January 2, 2007, last amended January 6, 2016, is incorporated by reference to Post-Effective Amendment No. 50 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(6)), filed on April 28, 2016. |
(p)(8) | Denver Investment Advisors LLC Code of Ethics, amended, effective June 1, 2013, is incorporated by reference to Post-Effective Amendment No. 39 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(7)), filed on May 15, 2014. |
(p)(9) | Dimensional Fund Advisors, L.P. Code of Ethics, effective January 1, 2017, is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(9)), filed on April 27, 2017. |
(p)(10) | Eaton Vance Management Code of Ethics, effective September 1, 2000, as revised February 8, 2017, is incorporated by reference to Post-Effective Amendment No. 57 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(10)), filed on September 18, 2017. |
(p)(11) | J.P. Morgan Investment Management Inc. Code of Ethics, effective February 1, 2005, last revised July 8, 2016, is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(11)), filed on April 27, 2017. |
(p)(12) | Jacobs Levy Equity Management, Inc. Code of Ethics, dated January 1, 2016, is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(12)), filed on April 27, 2017. |
(p)(13) | Kennedy Capital Management, Inc. Code of Ethics, as amended November 19, 2015, is incorporated by reference to Post-Effective Amendment No. 53 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(13)), filed on November 14, 2016. |
(p)(14) | Loomis, Sayles & Company, L.P. Code of Ethics, 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 Columbia Funds Series Trust I on Form N-1A (Exhibit (p)(11)), filed on April 26, 2017. |
(p)(15) | Los Angeles Capital Management and Equity Research, Inc. Code of Ethics, dated December 30, 2016, is incorporated by reference to Post-Effective Amendment No. 295 to Registration Statement No. 2-99356 of Columbia Funds Series Trust I on Form N-1A (Exhibit (p)(15)), filed on February 7, 2017. |
(p)(16) | Massachusetts Financial Services Company Code of Ethics, effective date October 31, 2016, is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(17)), filed on April 27, 2017. |
(p)(17) | Morgan Stanley Investment Management Inc. Code of Ethics, effective March 22, 2016, is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(18)), filed on April 27, 2017. |
(p)(18) | Nuveen Asset Management, LLC Code of Ethics, dated July 1, 2017, is incorporated by reference to Post-Effective Amendment No. 57 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(18)), filed on September 18, 2017. |
(p)(19) | OppenheimerFunds Inc. Code of Ethics, dated May 26, 2016, is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(20)), filed on April 27, 2017. |
(p)(20) | FIAM LLC (Pyramis Global Advisors, LLC) Code of Ethics, dated 2017, is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(21)), filed on April 27, 2017. |
(p)(20)(i) | FIAM LLC (Pyramis Global Advisors, LLC) Code of Ethics for Personal Investing European Region, dated February 21, 2017 is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(21)(i)), filed on April 27, 2017. |
(p)(20)(ii) | FIAM LLC (Pyramis Global Advisors, LLC) Code of Ethics for Personal Investing Asia Pacific Region, dated February 21, 2017, is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(21)(i)), filed on April 27, 2017. |
(p)(21) | Segall Bryant & Hamill, LLC Code of Ethics, dated July 2013, is incorporated by reference to Post-Effective Amendment No. 41 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(24)), filed on August 20, 2014. |
(p)(22) | T. Rowe Price Group, Inc. and Its Affiliates Code of Ethics, as of March 1, 2017, is incorporated by reference to Post-Effective Amendment No. 57 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(22)), filed on September 18, 2017. |
(p)(23) | TCW Investment Management Company Code of Ethics, dated March 13, 2017, is incorporated by reference to Post-Effective Amendment No. 295 to Registration Statement No. 2-99356 of Columbia Funds Series Trust I on Form N-1A (Exhibit (p)(7)), filed on April 26, 2017. |
(p)(24) | Victory Capital Management Inc. Code of Ethics, effective July 30, 2016, is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(25)), filed on April 27, 2017. |
(p)(25) | Wells Capital Management Incorporated Code of Ethics, dated September 30, 2016, is incorporated by reference to Post-Effective Amendment No. 278 to Registration Statement No. 2-99356 of Columbia Funds Series Trust I on Form N-1A (Exhibit (p)(14)), filed on October 5, 2016. |
(p)(26) | Westfield Capital Management Company, L.P. Code of Ethics, as of June 9, 2016, is incorporated by reference to Post-Effective Amendment No. 57 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(26)), filed on September 18, 2017. |
(q)(1) | Trustees Power of Attorney to sign Amendments to this Registration Statement, dated January 1, 2018, is filed electronically herewith as Exhibit (q)(1) to Post-Effective Amendment No. 61 to Registration Statement No. 333-146374 of the Registrant on Form N-1A. |
(q)(2) | Power of Attorney for Michael G. Clarke, dated May 23, 2016, is incorporated by reference to Post-Effective Amendment No. 52 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (p)(3)), filed on June 1, 2016. |
(q)(3) | Power of Attorney for Christopher O. Petersen, dated February 16, 2015, is incorporated by reference to Post-Effective Amendment No. 44 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (q)(5)), filed on February 20, 2015. |
(q)(4) | Power of Attorney for Amy K. Johnson, dated May 11, 2016, is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (q)(4)), filed on April 27, 2017. |
(q)(5) | Power of Attorney for Anthony P. Haugen, dated May 11, 2016, is incorporated by reference to Post-Effective Amendment No. 55 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (q)(5)), filed on April 27, 2017. |
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 VII of the Registrants Agreement and Declaration of Trust, as amended, provides that no trustee or officer of the Registrant shall be subject to any liability to any person in connection with Registrant property or the affairs of the Registrant, and no trustee shall be responsible or liable in any event for any neglect or wrongdoing of any officer, agent, employee, investment adviser or principal underwriter of the Registrant or for the act or omission of any other trustee, all as more fully set forth in the Agreement and Declaration of Trust, which is filed as an exhibit to this registration statement. Article 5 of the Registrants Bylaws provides that the Registrant shall indemnify and hold harmless its trustees and officers (including persons who serve at the Registrants request as directors, officers or trustees of another organization in which the Registrant has any interest) (Covered Persons) against liabilities and expenses in connection with the defense or disposition of any proceeding in which such Covered Person may be or may have been involved or with which such Covered Person may be or may have been threatened by reason of any alleged act or omission as a trustee or officer or by reason of his or her being or having been such a Covered Person, under specified circumstances, all as more fully set forth in the Bylaws, which are filed as an exhibit to the 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.
The Registrants Declaration of Trust provides that nothing in the Declaration of Trust shall protect any trustee or officer against any liabilities to the 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 or position with or on behalf of the Registrant and the Registrants Bylaws provides that no Covered Person shall be indemnified against any liability to the Registrant or its shareholders by reason of willful misfeasance, bad faith, gross negligence or reckless disregard of the duties involved in the conduct of such 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 (the 1933 Act) 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 1933 Act 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 (Columbia Management), the Registrants investment adviser, or any 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.
(1) | Columbia Management, a wholly owned subsidiary of Ameriprise Financial, Inc., performs investment advisory services for the Registrant and certain other clients. Information regarding the business of Columbia Management and the directors and principal officers of Columbia Management is also included in the Form ADV filed by Columbia Management 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 Columbia Management, certain directors and officers of Columbia Management also hold various positions with, and engage in business for, Ameriprise Financial, Inc. or its other subsidiaries. |
(2) | American Century Investment Management, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of American Century Investment Management, Inc. is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by American Century Investment Management, Inc. and is incorporated herein by reference. Information about the business of American Century Investment Management, Inc. and the directors and principal executive officers of American Century Investment Management, Inc. is also included in the Form ADV filed by American Century Investment Management, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-8174), which is incorporated herein by reference. |
(3) | BlackRock Financial Management, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of BlackRock Financial Management, Inc. is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by BlackRock Financial Management, Inc. and is incorporated herein by reference. Information about the business of BlackRock Financial Management, Inc. and the directors and principal executive officers of BlackRock Financial Management, Inc. is also included in the Form ADV filed by BlackRock Financial Management, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-48433), which is incorporated herein by reference. |
(4) | 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. |
(5) | CenterSquare Investment Management LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of CenterSquare Investment Management LLC is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by CenterSquare Investment Management LLC and is incorporated herein by reference. Information about the business of CenterSquare Investment Management LLC and the directors and principal executive officers of CenterSquare Investment Management LLC is also included in the Form ADV filed by CenterSquare Investment Management LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-111965), which is incorporated herein by reference. |
(6) | Columbia Wanger Asset Management, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Columbia Wanger Asset Management, LLC is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by Columbia Wanger Asset Management, LLC and is incorporated herein by reference. Information about the business of Columbia Wanger Asset Management, LLC and the directors and principal executive officers of Columbia Wanger Asset Management, LLC is also included in the Form ADV filed by Columbia Wanger Asset Management, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-41391), which is incorporated herein by reference. |
(7) | Denver Investment Advisors LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Denver Investment Advisors LLC is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by Denver Investment Advisors LLC and is incorporated herein by reference. Information about the business of Denver Investment Advisors LLC and the directors and principal executive officers of Denver Investment Advisors LLC is also included in the Form ADV filed by Denver Investment Advisors LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-47933), which is incorporated herein by reference. |
(8) |
Dimensional Fund Advisors, L.P. performs investment management services for the Registrant and certain other clients. Information regarding the business of Dimensional Fund Advisors, L.P. is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by |
Dimensional Fund Advisors, L.P. and is incorporated herein by reference. Information about the business of Dimensional Fund Advisors, L.P. and the directors and principal executive officers of Dimensional Fund Advisors, L.P. is also included in the Form ADV filed by Dimensional Fund Advisors, L.P. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-16283), which is incorporated herein by reference. |
(9) | Eaton Vance Management performs investment management services for the Registrant and certain other clients. Information regarding the business of Eaton Vance Management is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by Eaton Vance Management and is incorporated herein by reference. Information about the business of Eaton Vance Management and the directors and principal executive officers of Eaton Vance Management is also included in the Form ADV filed by Eaton Vance Management with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-15930), which is incorporated herein by reference. |
(10) | J.P. Morgan Investment Management Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of J.P. Morgan Investment Management Inc. is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by J.P. Morgan Investment Management Inc. and is incorporated herein by reference. Information about the business of J.P. Morgan Investment Management Inc. and the directors and principal executive officers of J.P. Morgan Investment Management Inc. is also included in the Form ADV filed by J.P. Morgan Investment Management Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-21011), which is incorporated herein by reference. |
(11) | Jacobs Levy Equity Management, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of Jacobs Levy Equity Management, Inc. is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by Jacobs Levy Equity Management, Inc. and is incorporated herein by reference. Information about the business of Jacobs Levy Equity Management, Inc. and the directors and principal executive officers of Jacobs Levy Equity Management, Inc. is also included in the Form ADV filed by Jacobs Levy Equity Management, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-28257), which is incorporated herein by reference. |
(12) | Kennedy Capital Management, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of Kennedy Capital Management, Inc., is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by Kennedy Capital Management, Inc., and is incorporated herein by reference. Information about the business of Kennedy Capital Management, Inc., and the directors and principal executive officers of Kennedy Capital Management, Inc., is also included in the Form ADV filed by Kennedy Capital Management, Inc., with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-15323), which is incorporated herein by reference. |
(13) | Loomis, Sayles & Company, L.P. performs investment management services for the Registrant and certain other clients. Information regarding the business of Loomis, Sayles & Company, L.P. is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by Loomis, Sayles & Company, L.P. and is incorporated herein by reference. Information about the business of Loomis, Sayles & Company, L.P. and the directors and principal executive officers of Loomis, Sayles & Company, L.P.is also included in the Form ADV filed by Loomis, Sayles & Company, L.P. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-170), which is incorporated herein by reference. |
(14) | 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. |
(15) | Massachusetts Financial Services Company performs investment management services for the Registrant and certain other clients. Information regarding the business of Massachusetts Financial Services Company is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by Massachusetts Financial Services Company and is incorporated herein by reference. Information about the business of Massachusetts Financial Services Company and the directors and principal executive officers of Massachusetts Financial Services Company is also included in the Form ADV filed by Massachusetts Financial Services Company with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-17352), which is incorporated herein by reference. |
(16) | Morgan Stanley Investment Management, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of Morgan Stanley Investment Management, Inc. is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by Morgan Stanley Investment Management, Inc. and is incorporated herein by reference. Information about the business of Morgan Stanley Investment Management, Inc. and the directors and principal executive officers of Morgan Stanley Investment Management, Inc. is also included in the Form ADV filed by Morgan Stanley Investment Management, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-15757), which is incorporated herein by reference. |
(17) | Nuveen Asset Management, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Nuveen Asset Management, LLC is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by Nuveen Asset Management, LLC and is incorporated herein by reference. Information about the business of Nuveen Asset Management, LLC and the directors and principal executive officers of Nuveen Asset Management, LLC is also included in the Form ADV filed by Nuveen Asset Management, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-71957), which is incorporated herein by reference. |
(18) | OppenheimerFunds, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of OppenheimerFunds, Inc. is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by OppenheimerFunds, Inc. and is incorporated herein by reference. Information about the business of OppenheimerFunds, Inc. and the directors and principal executive officers of OppenheimerFunds, Inc. is also included in the Form ADV filed by OppenheimerFunds, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-8253), which is incorporated herein by reference. |
(19) | Pyramis Global Advisors, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Pyramis Global Advisors, LLC is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by Pyramis Global Advisors, LLC and is incorporated herein by reference. Information about the business of Pyramis Global Advisors, LLC and the directors and principal executive officers of Pyramis Global Advisors, LLC is also included in the Form ADV filed by Pyramis Global Advisors, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-63658), which is incorporated herein by reference. |
(20) | Segall Bryant & Hamill, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Segall Bryant & Hamill LLC is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by Segall Bryant & Hamill LLC and is incorporated herein by reference. Information about the business of Segall Bryant & Hamill LLC and the directors and principal executive officers of Segall Bryant & Hamill LLC is also included in the Form ADV filed by Segall Bryant & Hamill LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-47232), which is incorporated herein by reference. |
(21) | T. Rowe Price Associates, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of T. Rowe Price Associates, Inc. is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by T. Rowe Price Associates, Inc. and is incorporated herein by reference. Information about the business of T. Rowe Price Associates, Inc. and the directors and principal executive officers of T. Rowe Price Associates, Inc. is also included in the Form ADV filed by T. Rowe Price Associates, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-856), which is incorporated herein by reference. |
(22) | TCW Investment Management Company performs investment management services for the Registrant and certain other clients. Information regarding the business of TCW Investment Management Company is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by TCW Investment Management Company and is incorporated herein by reference. Information about the business of TCW Investment Management Company and the directors and principal executive officers of TCW Investment Management Company is also included in the Form ADV filed by TCW Investment Management Company with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-29075), which is incorporated herein by reference. |
(23) | Threadneedle International Limited performs investment management services for the Registrant and certain other clients. Information regarding the business of Threadneedle International Limited is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are 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. |
(24) | Victory Capital Management Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of Victory Capital Management Inc. is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by Victory Capital Management Inc. and is incorporated herein by reference. Information about the business of Victory Capital Management Inc. and the directors and principal executive officers of Victory Capital Management Inc. is also included in the Form ADV filed by Victory Capital Management Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-46878), which is incorporated herein by reference. |
(25) | Wells Capital Management Incorporated performs investment management services for the Registrant and certain other clients. Information regarding the business of Wells Capital Management Incorporated is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by Wells Capital Management Incorporated and is incorporated herein by reference. Information about the business of Wells Capital Management Incorporated and the directors and principal executive officers of Wells Capital Management Incorporated is also included in the Form ADV filed by Wells Capital Management Incorporated with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-21122), which is incorporated herein by reference. |
(26) | Westfield Capital Management Company, L.P. performs investment management services for the Registrant and certain other clients. Information regarding the business of Westfield Capital Management Company, L.P. is set forth in the Prospectuses and Statement of Additional Information of the Registrants series that are subadvised by Westfield Capital Management Company, L.P. and is incorporated herein by reference. Information about the business of Westfield Capital Management Company, L.P. and the directors and principal executive officers of Westfield Capital Management Company, L.P. is also included in the Form ADV filed by Westfield Capital Management Company, L.P. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-69413), 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 with Principal Underwriter |
Positions and Offices with Registrant |
||
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 | ||
Shweta J. Jhanji | 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 Investment Company Act of 1940 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, American Century Investment Management, Inc., 4500 Main Street, Kansas City, MO 64111; |
| Registrants subadviser, BlackRock Financial Management, Inc., 55 East 52 nd Street, New York, NY 10055; |
| Registrants subadviser, BMO Asset Management, Corp., 115 South LaSalle Street, 11th Floor, Chicago, IL, 60603; |
| Registrants subadviser, CenterSquare Investment Management LLC, 630 W Germantown Pike, Suite 300, Plymouth Meeting, PA 19462; |
| Registrants subadviser, Columbia Wanger Asset Management, LLC, 227 West Monroe Street, Chicago, IL 60606; |
| Registrants subadviser, Denver Investment Advisors LLC, 370 17 th Street, Suite 5000, Denver, CO 80202; |
| Registrants subadviser, Dimensional Fund Advisors, L.P., 6300 Bee Cave Road, Building One, Austin, TX 78746; |
| Registrants subadviser, Eaton Vance Management, Two International Place, Boston, MA 02110; |
| Registrants subadviser, FIAM LLC (d/b/a Pyramis Global Advisors), 900 Salem Street, Smithfield, RI 02917; |
| Registrants subadviser, J.P. Morgan Investment Management Inc., 270 Park Avenue, New York, NY 10017; |
| Registrants subadviser, Jacobs Levy Equity Management, Inc., 100 Campus Drive, 2 nd Floor West, Florham Park, NJ 07932; |
| Registrants subadviser, Kennedy Capital Management, Inc., 10829 Olive Boulevard, Saint Louis, MO 63141; |
| Registrants subadviser, Loomis, Sayles & Company, L.P., One Financial Center, Boston, MA 02111; |
| Registrants subadviser, Los Angeles Capital Management and Equity Research, Inc., 11150 Santa Monica Blvd., Suite 200, Los Angeles, CA 90025; |
| Registrants subadviser, Massachusetts Financial Services Company, 111 Huntington Ave., Boston, MA 02199; |
| Registrants subadviser, Morgan Stanley Investment Management, Inc., 522 Fifth Avenue, New York, NY 10036; |
| Registrants subadviser, Nuveen Asset Management, LLC, 333 West Wacker Drive, Chicago, IL 60606; |
| Registrants subadviser, OppenheimerFunds, Inc. 225 Liberty Street, New York, NY 10281; |
| Registrants subadviser, Segall Bryant & Hamill LLC, 540 West Madison Street, Suite 1900, Chicago, IL 60661-2551; |
| Registrants subadviser, T. Rowe Price Associates, Inc., 100 East Pratt Street, Baltimore, MD 21202; |
| 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, UK; |
| Registrants subadviser, Victory Capital Management Inc., 4900 Tiedeman Road, 4 th Floor, Brooklyn, OH 44144; |
| Registrants subadviser, Wells Capital Management Incorporated, 525 Market Street, San Francisco, CA 94105; |
| Registrants subadviser, Westfield Capital Management Company, L.P., One Financial Center, Boston, MA 02111; |
| Former subadviser, Barrow, Hanley, Mewhinney & Strauss, LLC, 2200 Ross Avenue, 31 st Floor, Dallas, TX 75201; |
| Former subadviser, Davis Selected Advisers, L.P., 2949 East Elvira Road, Suite 101, Tucson, AZ 85756; |
| Former subadviser, Donald Smith & Co., Inc., 152 West 57 th Street, 22 nd Floor, New York, NY 10019; |
| Former subadviser, Goldman Sachs Asset Management, L.P., 200 West Street, New York, NY 10282; |
| Former subadviser, Holland Capital Management LLC, 303 W. Madison Street, Suite 700, Chicago, IL 60606; |
| Former subadviser, Invesco Advisers, Inc., 1555 Peachtree Street, N.E., Atlanta, GA 30309; |
| Former subadviser, Jennison Associates LLC, 466 Lexington Avenue, New York, NY 10017; |
| Former subadviser, The London Company of Virginia, 1801 Bayberry Court, Suite 301, Richmond, VA 23226; |
| Former subadviser, Marsico Capital Management, LLC, 1200 17 th Street, Suite 1600, Denver, CO 80202; |
| Former subadviser, Mondrian Investment Partners Limited, 10 Gresham Street, 5th Floor, London EC2V7JD, UK; |
| Former subadviser, NFJ Investment Group LLC, 2100 Ross Avenue, Suite 700, Dallas, TX 75201; |
| Former subadviser, Pacific Investment Management Company LLC, 650 Newport Center Drive, Newport Beach, CA 92660; |
| Former subadviser, Palisade Capital Management, L.L.C., One Bridge Plaza North, Suite 695, Fort Lee, NJ 07024; |
| Former subadviser, River Road Asset Management, LLC, 462 South Fourth Street, Suite 2000, Louisville, KY 40202; |
| Former subadviser, Sit Investment Associates, Inc., 3300 IDS Center, 80 South Eighth Street, Minneapolis, MN 55402; |
| Former subadviser, Snow Capital Management L.P., 2000 Georgetowne Drive, Suite 200, Sewickley, PA 15143; |
| Former subadviser, Turner Investments, L.P., 1205 Westlakes Drive, Suite 100, Berwyn, PA 19312; |
| Former subadviser, Winslow Capital Management, LLC, 4720 IDS Center, 80 South Eighth Street, Minneapolis, MN 55402; |
| 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; and |
| Registrants custodian, JPMorgan Chase Bank, N.A., 1 Chase Manhattan Plaza, New York, NY 10005. |
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 VARIABLE SERIES TRUST II, 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 21 st day of February, 2018.
COLUMBIA FUNDS VARIABLE SERIES TRUST II | ||
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 21 st day of February, 2018.
Signature | Capacity | Signature | Capacity | |||
/s/ Christopher O. Petersen Christopher O. Petersen |
President (Principal Executive Officer) |
/s/ Brian J. Gallagher* Brian J. Gallagher |
Trustee | |||
/s/ Michael G. Clarke* Michael G. Clarke |
Chief Financial Officer (Principal Financial Officer) Chief Accounting Officer (Principal Accounting Officer) |
/s/ Catherine James Paglia* Catherine James Paglia |
Trustee | |||
/s/ Edward J. Boudreau, Jr.* Edward J. Boudreau, Jr. |
Chair of the Board |
/s/ Anthony M. Santomero* Anthony M. Santomero |
Trustee | |||
/s/ George S. Batejan* George S. Batejan |
Trustee |
/s/ Minor M. Shaw* Minor M. Shaw |
Trustee | |||
/s/ Kathleen A. Blatz* Kathleen A. Blatz |
Trustee |
/s/ William F. Truscott* William F. Truscott |
Trustee | |||
/s/ Pamela G. Carlton* Pamela G. Carlton |
Trustee |
/s/ Sandra Yeager* Sandra Yeager |
Trustee | |||
/s/ William P. Carmichael* William P. Carmichael |
Trustee | |||||
/s/ Patricia M. Flynn* Patricia M. Flynn |
Trustee |
* | 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. 52 to Registration Statement No. 333-146374 of the Registrant on Form N-1A (Exhibit (q)(3)), filed with the Commission on June 1, 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. 61 to Registration Statement No. 333-146374 of the Registrant on Form N-1A. |
Exhibit Index
(a)(20) | Amendment No. 20 to the Agreement and Declaration of Trust effective December 19, 2017. |
(d)(7) | Subadvisory Agreement, dated January 2, 2018, between Columbia Management Investment Advisers, LLC and CenterSquare Investment Management LLC. |
(q)(1) | Trustees Power of Attorney to sign Amendments to this Registration Statement, dated January 1, 2018. |
COLUMBIA FUNDS VARIABLE SERIES TRUST II
AMENDMENT NO. 20 TO THE
AGREEMENT AND DECLARATION OF TRUST
WHEREAS, Section 5 of Article III of the Agreement and Declaration of Trust (the Declaration of Trust) of Columbia Funds Variable Series Trust II (the Trust), dated September 11, 2007, as amended from time to time, a copy of which is on file in the Office of the Secretary of The Commonwealth of Massachusetts, authorizes the Trustees of the Trust to amend the Declaration of Trust to establish, to change or abolish and rescind the designation of any Series or class of Shares without authorization by vote of the Shareholders of the Trust; and
WHEREAS, Section 8 of Article VIII of the Declaration of Trust authorizes the Trustees of the Trust to amend the Declaration of Trust to correct inconsistent provisions.
NOW, THEREFORE, The undersigned, being at least a majority of the Trustees of the Trust, do hereby certify that we have authorized the creation of one additional Series of the Trust, Columbia Variable Portfolio Select Large Cap Equity Fund and have authorized the following amendment to said Declaration of Trust:
1. | Section 6 of Article III is hereby amended by replacing the text preceding paragraph (a) with the following: |
Without limiting the authority of the Trustees as set forth in Section 5, inter alia, to establish and designate any further Series or classes or to modify the rights and preferences of any Series or class, the following Series shall be, and are hereby, established and designated;
Columbia Variable Portfolio Balanced Fund
Columbia Variable Portfolio Commodity Strategy Fund
Columbia Variable Portfolio Core Equity Fund
Columbia Variable Portfolio Disciplined Core Fund
Columbia Variable Portfolio Dividend Opportunity Fund
Columbia Variable Portfolio Emerging Markets Bond Fund
Columbia Variable Portfolio Emerging Markets Fund
Columbia Variable Portfolio Global Bond Fund
Columbia Variable Portfolio Government Money Market Fund
Columbia Variable Portfolio High Yield Bond Fund
Columbia Variable Portfolio Income Opportunities Fund
Columbia Variable Portfolio Intermediate Bond Fund
Columbia Variable Portfolio Large Cap Growth Fund
Columbia Variable Portfolio Large Cap Index Fund
Columbia Variable Portfolio Limited Duration Credit Fund
Columbia Variable Portfolio Managed Volatility Moderate Growth Fund
Columbia Variable Portfolio Mid Cap Growth Fund
Columbia Variable Portfolio Mid Cap Value Fund
Columbia Variable Portfolio Select International Equity Fund
Columbia Variable Portfolio Select Large Equity Fund
Columbia Variable Portfolio Select Large - Cap Value Fund
Columbia Variable Portfolio Select Smaller - Cap Value Fund
Columbia Variable Portfolio Seligman Global Technology Fund
Columbia Variable Portfolio U.S. Equities Fund
Columbia Variable Portfolio U.S. Government Mortgage Fund
Variable Portfolio Aggressive Portfolio
Variable Portfolio American Century Diversified Bond Fund
Variable Portfolio BlackRock Global Inflation-Protected Securities Fund
Variable Portfolio CenterSquare Real Estate Fund
Variable Portfolio Columbia Wanger International Equities Fund
Variable Portfolio Conservative Portfolio
Variable Portfolio DFA International Value Fund
Variable Portfolio Eaton Vance Floating-Rate Income Fund
Variable Portfolio J.P. Morgan Core Bond Fund
Variable Portfolio Loomis Sayles Growth Fund
Variable Portfolio Los Angeles Capital Large Cap Growth Fund
Variable Portfolio MFS ® Blended Research ® Core Equity Fund
Variable Portfolio MFS ® Value Fund
Variable Portfolio Moderate Portfolio
Variable Portfolio Moderately Aggressive Portfolio
Variable Portfolio Moderately Conservative Portfolio
Variable Portfolio Morgan Stanley Advantage Fund
Variable Portfolio Oppenheimer International Growth Fund
Variable Portfolio Partners Core Bond Fund
Variable Portfolio Partners Small Cap Growth Fund
Variable Portfolio Partners Small Cap Value Fund
Variable Portfolio Pyramis ® International Equity Fund
Variable Portfolio T. Rowe Price Large Cap Value Fund
Variable Portfolio TCW Core Plus Bond Fund
Variable Portfolio Victory Sycamore Established Value Fund
Variable Portfolio Wells Fargo Short Duration Government Fund
Variable Portfolio Westfield Mid Cap Growth Fund
Shares of each Series established in this Section 6 shall have the following rights and preferences relative to Shares of each other Series, and Shares of each class of a Multi-Class Series shall have such rights and preferences relative to other classes of the same Series as are set forth in the Declaration of Trust, together with such other rights and preferences relative to such other classes as are set forth in the Trusts Rule 18f-3 Plan, registration statement as from time to time amended, and any applicable resolutions of the Trustees establishing and designating such class of Shares.
The rest of this Section 6 remains unchanged.
2. | Section 9 of Article VIII is hereby amended by replacing the text with the following: |
The address of the Trust is 225 Franklin Street, Boston, Massachusetts 02110. The address of each of the Trustees is 225 Franklin Street, Boston, Massachusetts 02110.
The foregoing amendment is effective as of December 19, 2017.
[The remainder of this page intentionally left blank.]
IN WITNESS WHEREOF, the undersigned has signed this Amendment No. 20 to the Declaration of Trust on December 19, 2017.
/s/ George S. Batejan |
/s/ William A. Hawkins |
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George S. Batejan | William A. Hawkins | |||
/s/ Kathleen A. Blatz |
/s/ Catherine James Paglia |
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Kathleen A. Blatz | Catherine James Paglia | |||
/s/ Edward J. Boudreau, Jr. |
/s/ Anthony M. Santomero |
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Edward J. Boudreau, Jr. | Anthony M. Santomero | |||
/s/ Pamela G. Carlton |
/s/ Minor M. Shaw |
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Pamela G. Carlton | Minor M. Shaw | |||
/s/ William P. Carmichael |
/s/ John G. Taft |
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William P. Carmichael | John G. Taft | |||
/s/ Patricia M. Flynn |
/s/ Alison Taunton-Rigby |
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Patricia M. Flynn | Alison Taunton-Rigby | |||
/s/ William F. Truscott |
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William F. Truscott |
Registered Agent: | Corporation Service Company | |
84 State Street | ||
Boston, MA 02109 |
SUBADVISORY AGREEMENT
Agreement made as of the 2nd day of January 2018 and between Columbia Management Investment Advisers, LLC, a Minnesota limited liability company (Investment Manager), and CenterSquare Investment Management LLC, a Delaware limited liability company (Subadviser).
WHEREAS, the portfolio listed in Schedule A (the Fund) is a series of an open-end investment company registered under the Investment Company Act of 1940, as amended (the 1940 Act).
WHEREAS, Investment Manager entered into a Management Agreement (the Advisory Agreement) with the Fund pursuant to which Investment Manager provides investment advisory services to the Fund.
WHEREAS, Investment Manager and the Fund each desire to retain Subadviser to provide investment advisory services to the Fund, and Subadviser is willing to render such investment advisory services.
WHEREAS, the effective date of this Agreement is January 2, 2018.
NOW, THEREFORE, the parties, intending to be legally bound, agree as follows:
1. | Subadvisers Duties . |
(a) | Portfolio Management . Subject to supervision by Investment Manager and the Funds Board of Directors/Trustees (the Board), Subadviser shall manage the investment operations and the composition of that portion of the assets of the Fund which is allocated to Subadviser from time to time by Investment Manager (which portion may include any or all of the Funds assets), including the purchase, retention, and disposition thereof, in accordance with the Funds investment objectives, policies, and restrictions as set forth in the Funds prospectus (Prospectus) and the Funds Statement of Additional Information (SAI) as the same may be revised from time to time, and subject to the following understandings: |
(i) |
Investment Decisions . Subadviser shall determine from time to time what investments and securities will be purchased, retained, or sold with respect to that portion of the Fund allocated to it by Investment Manager, and what portion of such assets will be invested or held uninvested as cash. Subadviser is prohibited from consulting with any other subadviser of the Fund concerning transactions of the Fund in securities or other assets, other than for purposes of complying with the conditions of Rule 12d3-1(a) or (b) of the 1940 Act. Subadviser will not be responsible for voting proxies issued by companies held in the Fund although Investment |
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Manager may consult with Subadviser from time to time regarding the voting of proxies of securities owned by the Fund. Subadviser will not be responsible for filing claims in class action settlements related to securities currently or previously held by that portion of the Fund allocated to it by Investment Manager, although Investment Manager may consult with Subadviser from time to time regarding the filing of claims in class action settlements. |
(ii) | Investment Limits . In the performance of its duties and obligations under this Agreement, Subadviser shall act in conformity with applicable limits and requirements, as amended from time to time, as set forth in the (a) Funds Prospectus and the Funds SAI; (b) instructions and directions of Investment Manager and of the Board as provided to Subadviser; and (c) requirements of the 1940 Act, the Internal Revenue Code of 1986, as amended (the Code), as applicable to the Fund, and all other applicable federal and state laws and regulations. Investment Manager agrees to give Subadviser prompt written notice if Investment Manager believes any recommendations, advice or investments to be in violation of (a), (b) or (c) above. |
(iii) | Portfolio Transactions . |
(A) |
Trading . With respect to the securities and other investments to be purchased or sold for the Fund, Subadviser shall place orders with or through such persons, brokers, dealers, or futures commission merchants (including, but not limited to, broker-dealers that are affiliated persons of Investment Manager or Subadviser (as that term is defined by the 1940 Act) selected by Subadviser; provided, however, that such orders shall be consistent with Subadvisers brokerage policy; conform with federal securities laws; and be consistent with seeking best execution. The Subadviser may consider the research, investment information, and other services provided by, and the financial responsibility of, brokers, dealers, or futures commission merchants who may effect, or be a party to, any such transaction or other transactions to which Subadvisers other clients may be a party in accordance with Section 28(e) of the Securities Exchange Act of 1934, as amended. To the extent permitted by law, and consistent with its obligation to seek best execution, Subadviser may execute transactions or pay a broker-dealer a commission, spread or markup in excess of that which another broker-dealer might have charged for executing a transaction provided that Subadviser determines, in good faith, that the execution is appropriate or the commission, spread or markup is reasonable in relation to the value of the brokerage and/or research services provided, viewed in terms of either that particular transaction or Subadvisers overall responsibilities with respect to |
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the Fund and other clients for which it acts as subadviser. Notwithstanding anything herein to the contrary, to the extent Subadviser is directed by Investment Manager to use a particular broker or brokers to borrow securities to cover securities sold short, Subadviser shall have no responsibility for setting the rate charged to borrow a security or otherwise ensuring that the rate charged by such broker to borrow a security is favorable. |
(B) | Aggregation of Trades . Subadviser, to the extent permitted by applicable laws and regulations, may, but shall be under no obligation to, aggregate the securities or other investments to be sold or purchased for the Fund as well as other clients of Subadviser in order to seek best execution. In such event, allocation of the securities or futures contracts so purchased or sold, as well as the expenses incurred in the transaction, will be made by Subadviser in the manner Subadviser considers to be the most equitable and consistent with its fiduciary obligations to the Fund and to such other clients. |
(C) | Subadviser will not arrange purchases or sales of securities or other investments between the Fund and other accounts advised by Subadviser or its affiliated persons (as that term is defined by the 1940 Act) unless (a) such purchases or sales are in accordance with applicable law (including Rule 17a-7 of the 1940 Act) and the Funds policies and procedures as provided in writing to Subadviser along with any amendments, and (b) Subadviser determines the purchase or sale is in the best interests of the Fund. |
(iv) | Records and Reports . Subadviser (a) shall maintain such books and records for such time periods as are required of an SEC-registered investment adviser to an investment company registered under the 1940 Act, (b) shall render to the Board such periodic and special reports as the Board (or a Committee thereof) or Investment Manager may reasonably request in writing, and (c) shall meet with any persons at the request of Investment Manager or the Board for the purpose of reviewing Subadvisers performance under this Agreement at reasonable times and upon reasonable advance notice. |
(v) | Transaction Reports. Subadviser shall provide Investment Manager a daily trade file with information relating to all transactions concerning the allocated portion of the Funds assets for which Subadviser is responsible and shall provide Investment Manager with such other information regarding the Fund upon Investment Managers reasonable request. Subadviser shall affirm or send a trade file of these transactions as instruction to the custodian of the Fund. |
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(b) | Compliance Program and Ongoing Certification(s ). As requested, Subadviser shall timely provide to Investment Manager (i) information and commentary for the Funds annual and semi-annual reports, in a format approved by Investment Manager, and shall (a) certify that such information and commentary does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the information and commentary not misleading, in a format reasonably requested by Investment Manager, as it may be amended from time to time, and (b) provide (i) additional certifications related to Subadvisers management of the Fund in order to support the Funds filings on Form N-CSR and Form N-Q, and the Funds Principal Executive Officers and Principal Financial Officers certifications under Rule 30a-2 of the 1940 Act, thereon; in a format reasonably requested by Investment Manager, as it may be amended from time to time, (ii) a quarterly sub-certification with respect to compliance matters related to Subadviser and Subadvisers management of the Fund, in a format reasonably requested by Investment Manager, as it may be amended from time to time; (iii) an annual certification from Subadvisers Chief Compliance Officer, appointed under Rule 206(4)-7 of the Investment Advisers Act of 1940 (the Advisers Act), or his or her designee with respect to the design and operation of Subadvisers compliance program, in a format reasonably requested by Investment Manager, as it may be amended from time to time; and (iv) from time to time Subadviser shall provide such certifications to assist Investment Manager in fulfilling Investment Managers obligations under Rule 38a-1 of the 1940 Act, as are reasonably requested by the Fund or Investment Manager. In addition, Subadviser will, from time to time, provide a written assessment of its compliance program in conformity with current industry standards that is reasonably acceptable to Investment Manager to enable the Fund to fulfill its obligations under Rule 38a-1 of the 1940 Act. |
(c) | Maintenance of Records . Subadviser shall timely furnish to Investment Manager all information relating to Subadvisers services hereunder which Subadviser is required by law or regulation to keep and which are needed by Investment Manager to maintain the books and records of the Fund required under the 1940 Act. Subadviser agrees that all records which it maintains for the Fund are the property of the Fund and Subadviser will surrender promptly to the Fund any of such records upon the Funds request; provided, however, that Subadviser may retain a copy of such records. Subadviser further agrees to preserve for the periods prescribed under the 1940 Act any such records as are required to be maintained by it pursuant to paragraph 1(a) hereof. |
(d) | Insurance and Code of Ethics . Subadviser will provide the Fund with reasonable evidence that, with respect to its activities on behalf of the Fund, Subadviser is maintaining (i) commercially reasonable errors and omissions insurance and (ii) an appropriate Code of Ethics and related reporting procedures. |
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(e) | Confidentiality . Each of the parties hereto agrees that it shall exercise the same standard of care that it uses to protect its own confidential and proprietary information (Confidential Information), but no less than reasonable care, to protect the Confidential Information of the other party. As used herein, Confidential Information, includes, but is not limited, to Fund Portfolio Information, which refers to confidential and proprietary information with regard to (i) the portfolio holdings and characteristics of the portion of the Fund allocated to Subadviser that Subadviser manages under the terms of this Agreement, and (ii) any copies of any agreements between the Investment Manager and its various counterparties and all the terms and provisions contained therein, which the Investment Manager (which term shall include the Investment Managers directors, officers, employees, agents, advisors, proposed financing sources, attorneys and accountants) may furnish, disclose or reveal to Subadviser (which term shall include Subadvisers directors, officers, employees, agents, advisors, proposed financing sources, attorneys and accountants). Each party hereby agrees to restrict access to the other partys Confidential Information to its employees who will use it only for the purpose of providing services under this Agreement. The foregoing shall not prevent a party from disclosing Confidential Information (1) that is publicly known or becomes publicly known through no unauthorized act; (2) that is rightfully received from a third party without obligation of confidentiality; (3)(a) that, in the case of Investment Managers Confidential Information, is approved in writing by Investment Manager for disclosure, (3)(b) that, in the case of Subadvisers Confidential Information, is approved in writing by Subadviser for disclosure; (4) that is disclosed in the course of a regulatory examination or that is required to be disclosed pursuant to a requirement of a governmental or regulatory agency or law, so long as the non-disclosing party provides (to the extent permitted under applicable law) the disclosing party (i.e., the party whose Confidential Information would be disclosed) with prompt written notice of such requirement prior to any such disclosure; however, Subadviser is not required to provide such notice if information is provided on an aggregate basis without specific attribution to the Fund; (5) to affiliates that have a reason to know such information; (6) to the custodian of the Fund; (7) to brokers and dealers that are counterparties for trades for the Fund, as well as trade data repositories; (8) to futures commission merchants executing or clearing transactions in connection with the Fund, if applicable; and (9) to third party service providers to Subadviser subject to confidentiality agreements or duties. Notwithstanding the foregoing, to the extent Fund Portfolio Information is similar to investments for other clients of Subadviser, Subadviser may disclose such investments without direct reference to the Fund. Investment Manager agrees that Subadviser may identify Investment Manager or the Fund by name in Subadvisers current client list. Such list may be used with third parties. |
(f) | Cooperation . As reasonably requested by Investment Manager or the Board and in accordance with the scope of Subadvisers obligations and responsibilities contained in this Agreement, Subadviser will cooperate with, and provide reasonable assistance to, Investment Manager or the Fund as needed in order for Investment Manager and the Fund to comply with applicable laws, rules and regulations, including, but not limited to, compliance with the Sarbanes-Oxley Act and the rules and regulations promulgated by the SEC thereunder and the evaluation of any actions under U.S. or foreign securities laws pursuant to which the Fund may be able to assert a potential claim. |
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2. | Investment Managers Duties . Investment Manager shall continue to have responsibility for all other services to be provided to the Fund pursuant to the Advisory Agreement and shall oversee and review Subadvisers performance of its duties under this Agreement. Investment Manager shall also retain direct portfolio management responsibility with respect to any assets of the Fund which are not allocated by it to the portfolio management of Subadviser as provided in paragraph 1(a) hereof or to any other subadviser. Investment Manager will periodically provide to Subadviser a list of the affiliated persons of Investment Manager or the Fund to which investment restrictions apply, and will specifically identify in writing (a) all publicly traded companies that issue securities in which the Fund may not invest, together with ticker symbols for all such companies, and (b) any affiliated brokers and any restrictions that apply to the use of those brokers by Subadviser. Neither Subadviser nor any of its directors, officers, partners, principals, employees or agents shall have responsibility whatsoever for, and shall incur no liability on account of (i) diversification, selection or establishment of such investment objectives, policies and restrictions of the Fund, (ii) advice on, or management of, any assets for the Fund other than the assets for which Investment Manager has delegated investment discretion to Subadviser, (iii) filing of any tax or information returns or forms, withholding or paying any taxes, or seeking any exemption or refund, (iv) registration of the Fund with any government or agency, (v) administration of the plans and trusts investing in the Fund, or (vi) overall Fund compliance with requirements of the 1940 Act and Subchapter M of the Code, relating to percentage limitations applicable to the Funds assets that would require knowledge of the Funds holdings other than the assets subject to this Agreement. |
3. | Documents Provided to Subadviser . Investment Manager has delivered or will deliver to Subadviser current copies and supplements thereto of each of the Prospectus and SAI pertaining to the Fund, and will promptly deliver to it all future amendments and supplements, if any. |
4. | Compensation of Subadviser . For the services provided and the expenses assumed pursuant to this Agreement, Investment Manager will pay to Subadviser, effective from the date of this Agreement, a fee which shall be determined daily and paid monthly, on or before the last business day of the next succeeding calendar month, at the annual rates set forth in the attached Schedule A which Schedule can be modified from time to time upon mutual agreement of the parties to reflect changes in annual rates, subject to appropriate approvals required by the 1940 Act, if any. If this Agreement becomes effective or terminates before the end of any month, the fee for the period from the effective date to the end of the month or from the beginning of such month to the date of termination, as the case may be, shall be prorated according to the proportion that such portion of the month bears to the full month in which such effectiveness or termination occurs. During the term of this Agreement, Subadviser will pay all expenses incurred by it in connection with its activities under this Agreement other than costs in connection with the purchase or sale of securities and other assets (including brokerage commissions, if any) for the Fund. |
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5. | Expenses . Subadviser shall bear all expenses incurred by it and its staff with respect to all activities in connection with the performance of Subadvisers services under this Agreement, including but not limited to salaries, overhead, travel, preparation of Board materials, review of marketing materials relating to Subadviser or other information provided by Subadviser to Investment Manager and/or the Funds distributor, and marketing support. Subadviser agrees to pay to Investment Manager the cost of generating a prospectus supplement, but such costs shall not exceed $10,000 per prospectus supplement. Such costs shall include preparation, filing, printing, and distribution (including mailing) of the supplement, if the Subadviser makes any changes that require immediate disclosure in the prospectus or any required regulatory documents that may be caused by changes to its structure or ownership, to investment personnel, to investment style or management, or otherwise (Changes), and at the time of notification to the Fund or Investment Manager by the Subadviser of such Changes, the Fund is not generating a supplement for other purposes or the Fund or the Investment Manager does not wish to add such Changes to a pending supplement. In the event two or more subadvisers, if applicable, each require a supplement simultaneously, the expense (other than the costs of printing and mailing) of a combined supplement will be shared pro rata with such other subadviser(s) based upon the number of pages required by each such subadviser, and each such subadviser shall pay its pro rata share of printing and mailing costs and expenses based upon the number of supplements required to be printed and mailed, provided however that Subadvisers pro-rata amount shall not exceed $10,000. All other expenses not specifically assumed by Subadviser hereunder or by Investment Manager under the Advisory Agreement are borne by the applicable Fund. |
In the event that there is a proposed change in control of Subadviser that would act to terminate this Agreement, if a vote of shareholders to approve continuation of this Agreement is at that time deemed by counsel to the Fund to be required by the 1940 Act or any rule or regulation thereunder, Subadviser agrees to assume all reasonable costs associated with soliciting shareholders of the appropriate Fund(s), to approve continuation of this Agreement. Such expenses include the reasonable costs of preparation, filing and mailing of a proxy statement, and of soliciting proxies.
In the event that such proposed change in control of Subadviser shall occur and the Fund is operating under an exemptive order issued by the SEC to Investment Manager with respect to the appointment of subadvisers absent shareholder approval, Subadviser agrees to assume all reasonable costs and expenses (including the costs of preparation, mailing and filing) associated with the preparation of an information statement, required by the exemptive order containing all information that would be included in a proxy statement.
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6. | Representations of Subadviser . Subadviser represents and warrants as follows: |
(a) | Subadviser (i) is registered as an investment adviser under the Advisers Act and will continue to be so registered for so long as this Agreement remains in effect; (ii) is not an affiliated person of the Investment Manager or of the Fund within the meaning of Section 2(a)(3) of the 1940 Act (other than by virtue of serving as a subadviser to the Fund); (iii) is not prohibited by the 1940 Act or the Advisers Act from performing the services contemplated by this Agreement; (iv) has appointed a Chief Compliance Officer under Rule 206(4)-7 of the Advisers Act; (v) has adopted written policies and procedures that are reasonably designed to prevent violations of the Advisers Act from occurring, detect violations that have occurred, correct promptly any violations that have occurred, and will provide prompt notice of any material violations relating to the Fund to Investment Manager; (vi) has met and will seek to continue to meet for so long as this Agreement remains in effect, any other applicable federal or state requirements, or the applicable requirements of any regulatory or industry self-regulatory agency necessary to be met in order to perform the services contemplated by this Agreement; (vii) has the authority to enter into and perform the services contemplated by this Agreement; and (viii) will promptly notify Investment Manager (1) in the event that Subadviser becomes an affiliated person of the Investment Manager or of the Fund within the meaning of Section 2(a)(3) of the 1940 Act, other than by virtue of serving as a subadviser to the Fund; (2) of the occurrence of any event that would disqualify Subadviser from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act, (3) in the event the Securities and Exchange Commission (the SEC) or other governmental authority has: censured Subadviser; placed limitations upon the activities, functions or operations of Subadviser; or has commenced proceedings or an investigation that may result in any of these actions, (4) upon having a reasonable basis for believing that the Fund has ceased to qualify or might not qualify as a regulated investment company under Subchapter M of the Code and (5) of any material fact known to Subadviser respecting or relating to Subadviser that is not contained in the Prospectus, and is required to be stated therein or necessary to make the statements therein not misleading, or of any statement relating to Subadviser contained therein that becomes untrue in any material respect. |
(b) | Subadviser has adopted a written code of ethics complying with the requirements of Rule 17j-1 under the 1940 Act and will provide Investment Manager with a copy of the code of ethics. Within 60 days of the end of the last calendar quarter of each year that this Agreement is in effect, a duly authorized officer of Subadviser shall certify to Investment Manager that there has been no material violation of Subadvisers code of ethics or, if such a violation has occurred, that appropriate action was taken in response to such violation. To the extent Subadviser has approved any material changes to its code of ethics, such revised code together with an explanation of such amendments shall be promptly (but in no event later than 60 days) provided to Investment Manager. |
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(c) | Subadviser has provided Investment Manager with a copy of a document intended to address the disclosures specified in Form ADV Part 2A, and promptly will furnish a copy of any amendments to such document to Investment Manager (at least annually). |
(d) | Subadviser will promptly notify Investment Manager of any changes in its controlling shareholder, in the key personnel who are either the portfolio manager(s) responsible for the Fund or the Chief Executive Officer of Subadviser, or if there is otherwise an actual change in control or management of Subadviser. |
7. | Representations of Investment Manager . Investment Manager represents and warrants as follows: |
(a) | Investment Manager (i) is registered as an investment adviser under the Advisers Act and will continue to be so registered for so long as this Agreement remains in effect; (ii) is not prohibited by the 1940 Act or the Advisers Act from performing the services contemplated by this Agreement; (iii) has appointed a Chief Compliance Officer under Rule 206(4)-7 of the Advisers Act; (iv) has adopted written policies and procedures that are reasonably designed to prevent violations of the Advisers Act from occurring, detect violations that have occurred, correct promptly any violations that have occurred, and will provide prompt notice of any material violations relating to the Fund to the Subadviser; (v) has met and will seek to continue to meet for so long as this Agreement remains in effect, any other applicable federal or state requirements, or the applicable requirements of any regulatory or industry self-regulatory agency necessary to be met in order to perform the services contemplated by this Agreement; (vi) has the authority to enter into and perform the services contemplated by this Agreement; and (vii) will promptly notify Subadviser (1) of the occurrence of any event that would disqualify Investment Manager from serving as an investment adviser of an investment company pursuant to Section 9(a) of the 1940 Act or otherwise, (2) in the event the SEC or other governmental authority has: censured Investment Manager; placed limitations upon its activities, functions or operations; or has commenced proceedings or an investigation that may result in any of these actions or (3) upon having a reasonable basis for believing that the Fund has ceased to qualify or might not qualify as a regulated investment company under Subchapter M of the Code. |
(b) | Investment Manager agrees that neither it nor any of its affiliates will in any way refer directly or indirectly to its relationship with Subadviser, or any of its affiliates in offering, marketing, or other promotional materials without the prior written consent of Subadviser; provided that Investment Manager shall not be required to obtain Subadvisers prior written consent to make factual statements regarding the fact that Subadviser serves as subadviser to the Fund, in responding to requests for information, in required disclosures or in responding to regulatory inquiries. |
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(c) | The Fund is and will continue to be the owner of all assets for which Investment Manager delegates investment discretion to Subadviser from time to time, and there are and will continue to be no restrictions on the pledge, hypothecation, transfer, sale or public distribution of such assets. |
(d) | Investment Manager is establishing and will be maintaining the Funds account with Subadviser solely for the purpose of investing the relevant assets and not with a view to obtaining information regarding portfolio holdings or investment decisions in order to effect securities transactions based upon such information or to provide such information to another party, and that Investment Manager and its employees, officers and directors shall not use account holdings information for any of the foregoing purposes. |
(e) | The Board has approved the appointment of Subadviser pursuant to this Agreement, and either shareholder approval of this Agreement has been obtained, or shareholder approval of this Agreement is not required under section 15 of the 1940 Act. |
8. | Liability and Indemnification . |
(a) |
Subadviser assumes no responsibility under this Agreement other than to render the services provided by it under this Agreement. Except as may otherwise be provided by the 1940 Act or any other federal securities law, Subadviser, any of its affiliates and any of the officers, partners, employees, consultants, or agents thereof shall not be liable for any losses, claims, damages, liabilities, or litigation (including legal and other expenses) incurred or suffered by the Fund, Investment Manager, or any affiliated persons thereof (within the meaning of Section 2(a)(3) of the 1940 Act) or controlling persons thereof (as described in Section 15 of the Securities Act of 1933, as amended (the 1933 Act) ) (collectively, Fund and Investment Manager Indemnitees) as a result of any error of judgment or mistake of law by Subadviser with respect to the Fund, except that nothing in this Agreement shall operate or purport to operate in any way to exculpate, waive, or limit the liability of Subadviser for, and Subadviser shall indemnify and hold harmless the Fund and Investment Manager Indemnitees against any and all losses, claims, damages, liabilities, or litigation (including reasonable legal and other expenses) to which any of the Fund and Investment Manager Indemnitees may become subject under the 1933 Act, the 1940 Act, the Advisers Act, or under any other statute, at common law, or otherwise arising out of or by reason of (i) any willful misconduct, bad faith, reckless disregard, or negligence of Subadviser in the performance of any of its duties or obligations hereunder; (ii) any untrue statement of a material fact regarding Subadviser contained in the Prospectus and SAI, proxy materials, reports, advertisements, sales literature, or other materials pertaining to the Fund or the omission to state therein a material fact regarding Subadviser known to Subadviser which was required to be stated therein or necessary to make the statements therein not misleading, if such statement or omission was made in reliance upon written information furnished to Investment |
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Manager or the Fund by Subadviser Indemnitees (as defined below) for use therein; provided, however, that Subadviser has had a reasonable opportunity to review information regarding Subadviser contained in the Prospectus and SAI, proxy materials, reports, advertisements, sales literature or other materials pertaining to the Fund as set forth in section 11; or (iii) any violation of federal or state statutes or regulations by Subadviser. It is further understood and agreed that Subadviser may rely upon information furnished to it by Investment Manager that it reasonably believes to be accurate and reliable. Subadviser shall be liable for any loss incurred by the Fund, the Investment Manager or their respective affiliates to the extent such losses arise out of any act or omission directly attributable to Subadviser which results, directly or indirectly, in an error in the net asset value of the Fund. The federal securities laws impose liabilities in certain circumstances on persons who act in good faith, and therefore nothing herein shall in any way constitute a waiver or limitation of any rights which Investment Manager may have under any securities laws. Neither Subadviser nor any Subadviser Indemnitees (as defined below) shall be liable for any loss or damage arising or resulting from the acts or omissions of the custodian of the Fund, any broker, financial institution or any other third party with or through whom Subadviser arranges or enters into a transaction in respect of the Fund, except to the extent that Subadviser or its affiliate instructed such broker, financial institution or third party to take such action or omission and such instruction constitutes willful misconduct, bad faith, reckless disregard, or negligence of Subadviser. Investment Manager understands and acknowledges that Subadviser does not warrant that the portion of the assets of the Fund managed by Subadviser will achieve any particular rate of return or that its performance will match any benchmark index or other standard or objective. |
(b) |
Except as may otherwise be provided by the 1940 Act or any other federal securities law, Investment Manager and the Fund shall not be liable for any losses, claims, damages, liabilities, or litigation (including legal and other expenses) incurred or suffered by Subadviser or any of its affiliated persons thereof (within the meaning of Section 2(a)(3) of the 1940 Act) or controlling persons (as described in Section 15 of the 1933 Act) (collectively, Subadviser Indemnitees) as a result of any error of judgment or mistake of law by Investment Manager with respect to the Fund, except that nothing in this Agreement shall operate or purport to operate in any way to exculpate, waive, or limit the liability of Investment Manager for, and Investment Manager shall indemnify and hold harmless Subadviser Indemnitees against any and all losses, claims, damages, liabilities, or litigation (including reasonable legal and other expenses) to which any of Subadviser Indemnitees may become subject under the 1933 Act, the 1940 Act, the Advisers Act, or under any other statute, at common law, or otherwise arising out of or by reason of (i) any willful misconduct, bad faith, reckless disregard, or negligence of Investment Manager in the performance of any of its duties or obligations hereunder; (ii) any untrue statement of a material fact contained in the Prospectus and SAI, proxy materials, reports, advertisements, sales literature, or other materials pertaining to the Fund or the |
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omission to state therein a material fact known to Investment Manager which was required to be stated therein or necessary to make the statements therein not misleading, unless such statement or omission concerned Subadviser and was made in reliance upon written information furnished to Investment Manager or the Fund by a Subadviser Indemnitee for use therein, or (iii) any violation of federal or state statutes or regulations by Investment Manager or the Fund. |
(c) | After receipt by Investment Manager or Subadviser, its affiliates, or any officer, director, employee, or agent of any of the foregoing, entitled to indemnification as stated in (a) or (b) above (Indemnified Party) of notice of the commencement of any action, if a claim in respect thereof is to be made against any person obligated to provide indemnification under this section (Indemnifying Party), such Indemnified Party shall notify the Indemnifying Party in writing of the commencement thereof within five (5) business days of receipt the summons or other first written notification giving information of the nature of the claim that has been served upon the Indemnified Party; provided that the failure to so notify the Indemnifying Party will not relieve the Indemnifying Party from any liability under this section, except to the extent that the omission results in damages to the Indemnifying Party caused solely as a result of the failure to give such notice. The Indemnifying Party, upon the request of the Indemnified Party, shall retain counsel satisfactory to the Indemnified Party to represent the Indemnified Party in the proceeding, and shall pay the fees and disbursements of such counsel related to such proceeding. In any such proceeding, any Indemnified Party shall have the right to retain its own counsel, but the fees and expenses of such counsel shall be at the expense of such Indemnified Party unless (1) the Indemnifying Party and the Indemnified Party shall have mutually agreed to the retention of such counsel, or (2) the named parties to any such proceeding (including any impleaded parties) include both the Indemnifying Party and the Indemnified Party and representation by both parties by the same counsel would be inappropriate due to actual or potential differing interests between them. The Indemnifying Party shall not be liable for any settlement of any proceeding effected without its written consent, which consent shall not be unreasonably withheld, but if settled with such consent or if there be a final judgment for the plaintiff, the Indemnifying Party agrees to indemnify the Indemnified Party from and against any loss or liability by reason of such settlement or judgment. |
(d) | Under no circumstances shall any party hereto be liable to another for special, punitive or consequential damages, arising under or in connection with this Agreement, even if previously informed of the possibility of such damages. |
9. | Duration and Termination . |
(a) |
Unless sooner terminated as provided herein, this Agreement shall continue for two years from the date written above. Thereafter, if not terminated, this Agreement shall continue automatically for successive periods of 12 months each, provided that such continuance is specifically approved at least annually (i) by a |
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vote of a majority of the Board members who are not parties to this Agreement or interested persons (as that term is defined in the 1940 Act) of any such party, or (ii) by a vote of the holders of a majority of the outstanding voting securities (as defined in the 1940 Act) of the Fund. |
(b) | Notwithstanding the foregoing, this Agreement may be terminated at any time, without the payment of any penalty, by the Board or by vote of a majority of the outstanding voting securities (as defined in the 1940 Act) of the Fund on 60 days written notice to Subadviser. This Agreement may also be terminated, without the payment of any penalty, by Investment Manager (i) upon 60 days written notice to Subadviser; (ii) upon material breach by Subadviser of any of the representations and warranties set forth in this Agreement, if such breach has not been cured within 20 days after written notice of such breach; or (iii) immediately if, in the reasonable judgment of Investment Manager, Subadviser becomes unable to discharge its duties and obligations under this Agreement, including circumstances such as the insolvency of Subadviser or other circumstances that could adversely affect the Fund. Subadviser may terminate this Agreement at any time, without payment of any penalty, (1) upon 60 days written notice to Investment Manager; or (2) upon material breach by Investment Manager of any representations and warranties set forth in the Agreement, if such breach has not been cured within 20 days after written notice of such breach. This Agreement shall terminate automatically in the event of its assignment (as that term is defined in the 1940 Act) or upon the termination of the Advisory Agreement. |
(c) | In the event of termination of the Agreement, those paragraphs of the Agreement which govern conduct of the parties future interactions with respect to Subadviser having provided investment management services to the Fund(s) for the duration of the Agreement, including, but not limited to, paragraphs 1(a)(iv)(a), 1(c), 1(d), 1(e), 1(f), 8(a), 8(b), 8(c), 15, 17, 18, 20 and 21 shall survive such termination of the Agreement. |
10. | Subadvisers Services Are Not Exclusive . Nothing in this Agreement shall limit or restrict the right of Subadviser or any of its partners, officers, or employees to engage in any other business or to devote his or her time and attention in part to the management or other aspects of any business, whether of a similar or a dissimilar nature, or limit or restrict Subadvisers right to engage in any other business or to render services of any kind to any other mutual fund, corporation, firm, individual, or association or other entity. Subadviser acts as adviser to other clients and may, subject to compliance with its fiduciary obligations, give advice, and take action, with respect to any of those which may differ from the advice given, or the timing or nature of action taken, with respect to the Fund. Subject to its fiduciary obligation to the Fund, Subadviser shall have no obligation to purchase or sell for the Fund, or to recommend for purchase or sale by the Fund, any security which Subadviser, its principals, affiliates or employees may purchase or sell for themselves or for any other clients. |
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11. | References to Subadviser . Subadviser hereby grants to Investment Manager during the term of this Agreement, the right to use Subadvisers name as required for public filings and marketing materials in accordance with the terms described herein. Investment Manager agrees to furnish to Subadviser at its principal office all prospectuses, SAIs, proxy statements, reports to shareholders, sales literature, or other material prepared for distribution to sales personnel, shareholders of the Fund or the public, that refer to Subadviser prior to the use thereof, and not to use such material if Subadviser reasonably objects in writing five (5) business days (or such other time as may be mutually agreed upon) after receipt thereof. Such materials may be furnished to Subadviser hereunder by first-class or overnight mail, electronic or facsimile transmission, or hand delivery. |
12. | Notices . Any notice, statement, consent or approval required or permitted to be given in connection with this Agreement (Notice) shall be in writing and shall be sufficiently given if delivered (whether in person, by post, by courier service or other personal method of delivery), or if transmitted by facsimile or other electronic means of communication: |
In the case of Subadviser:
CenterSquare Investment Management LLC
Attn: Liz Conklin, Director of Operations
630 West Germantown Pike
Suite 300
Plymouth Meeting, PA 19462
Tel: (610) 818-4649
Fax: (610) 818-4641
with a copy to:
operations@centersquare.com
In the case of Investment Manager:
Paul Mikelson
Vice President, Subadvised Strategies
Columbia Threadneedle Investments
707 2 nd Ave. S, Routing: H17 435
Minneapolis, MN 55402
Tel: (612) 671-4452
Fax: (612) 671-0618
with a copy to:
Christopher O. Petersen
Vice President and Lead Chief Counsel
Ameriprise Financial, Inc.
5228 Ameriprise Financial Center, Routing: 27/5228
Minneapolis, MN 55474
Tel: (612) 671-4321
Fax: (612) 671-2680
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Any Notice delivered or transmitted to a party as provided above shall be deemed to have been given and received on the day it is delivered or transmitted, provided that it is delivered or transmitted on any day that is not a Saturday, Sunday, or statutory holiday in the jurisdiction where the Notice is received (Business Day) prior to 5:00 p.m. local time in the place of delivery or receipt. However, if the Notice is delivered or transmitted after 5:00 p.m. local time or if such day is not a Business Day then the Notice shall be deemed to have been given and received on the next Business Day.
Any party may, from time to time, change its address by giving Notice to the other party in accordance with the provisions of this section.
13. | Amendments . This Agreement may be amended by mutual consent, subject to approval by the Board and the Funds shareholders to the extent required by the 1940 Act. |
14. | Assignment . This Agreement shall terminate automatically in the event of its assignment (as that term is defined in the 1940 Act). The Subadviser shall notify the Investment Manager in writing reasonably in advance of any proposed/potential assignment, including any change of control (as that term is defined in the 1940 Act) of Subadviser, to enable the Investment Manager to consider whether an assignment under the 1940 Act and the rules and regulations promulgated thereunder has occurred, and to take the steps necessary to enter into a new contract with the Subadviser or such other steps as the Investment Manager and/or the Board may deem appropriate. Notwithstanding the foregoing, no assignment shall be deemed to result from any changes in the directors, officers, or employees of Investment Manager or Subadviser except as otherwise provided by the 1940 Act or the rules and regulations thereunder. |
15. | Governing Law . This Agreement, and, in the event of termination of the Agreement, those paragraphs that survive such termination of the Agreement under paragraph 9(c), shall be governed by the laws of the commonwealth of Massachusetts, without giving effect to the conflicts of laws principles thereof, or any applicable provisions of the 1940 Act. To the extent that the laws of the commonwealth of Massachusetts, or any of the provision of this Agreement, conflict with applicable provisions of the 1940 Act, the latter shall control. The Investment Manager and Subadviser hereby consent to the jurisdiction of a state of federal court situated in the Commonwealth of Massachusetts in connection with any dispute arising hereunder. Any action or dispute between the Investment Manager and the Subadviser arising out of this Agreement shall be brought exclusively in the state of federal courts of the Commonwealth of Massachusetts. The Investment Manager and Subadviser hereby irrevocably waive, to the fullest extent permitted by applicable law, any objection which either party may now or hereafter have to the laying of venue of any such proceeding brought in such a court and any claim that such proceeding brought in such a court has been brought in an inconvenient forum. |
15 | Page |
16. | Entire Agreement . This Agreement embodies the entire agreement and understanding among the parties hereto, and supersedes all prior agreements and understandings relating to the subject matter hereof. |
17. | Severability . Should any part of this Agreement be held invalid by a court decision, statute, rule, or otherwise, the remainder of this Agreement shall not be affected thereby. This Agreement and, in the event of termination of the Agreement, those paragraphs that survive such termination of the Agreement under paragraph 9(c), shall be binding upon and shall inure to the benefit of the parties hereto and their respective successors. |
18. | Interpretation . Any questions of interpretation of any term or provision of this Agreement having a counterpart in or otherwise derived from a term or provision of the 1940 Act shall be resolved by reference to such term or provision in the 1940 Act and to interpretation thereof, if any, by the federal courts or, in the absence of any controlling decision of any such court, by rules, regulations, or orders of the SEC validly issued pursuant to the 1940 Act. Where the effect of a requirement of the 1940 Act reflected in any provision of this Agreement is altered by a rule, regulation, or order of the SEC, whether of special or general application, such provision shall be deemed to incorporate the effect of such rule, regulation, or order. |
19. | Headings . The headings in this Agreement are intended solely as a convenience and are not intended to modify any other provision herein. |
20. | Authorization . Each of the parties represents and warrants that the execution and delivery of this Agreement and the consummation of the transactions contemplated by this Agreement have been duly authorized by all necessary corporate action by such party and when so executed and delivered, this Agreement will be the valid and binding obligation of such party in accordance with its terms. |
21. | No Third-Party Beneficiaries . The Fund is intended to be a third party beneficiary of this Agreement. For the avoidance of doubt, and without in any way implying that there are any other third-party beneficiaries to the Agreement or any other agreement with respect to the Trust or any of its series, no person other than the Investment Manager and the Subadviser is a party to this Agreement or shall be entitled to any right or benefit arising under or in respect of this Agreement (with the exception of the Fund), and there are no other third-party beneficiaries of this Agreement. Without limiting the generality of the foregoing, nothing in this Agreement is intended to, or shall be read to, (i) create in any other person (including without limitation any shareholder of any Fund) any direct, indirect, derivative, or other rights against the Investment Manager or Subadviser, or (ii) create or give rise to any duty or obligation on the part of the Investment Manager or Subadviser (including without limitation any fiduciary duty) to any person other than the Fund, all of which rights, benefits, duties, and obligations are hereby expressly excluded. |
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IN WITNESS WHEREOF, the parties hereto have caused this instrument to be executed by their officers designated below as of the day and year first above written.
Columbia Management Investment Advisers, LLC |
CenterSquare Investment Management LLC | |||||||
By: |
/s/ David Weiss |
By: |
/s/ Jason Barg |
|||||
Signature | Signature | |||||||
Name: |
David Weiss |
Name: |
Jason Barg |
|||||
Printed | Printed | |||||||
Title: |
Assistant Secretary |
Title: |
Authorized Signer |
17 | Page |
SUBADVISORY AGREEMENT
SCHEDULE A
[REDACTED DATA]
18 | Page |
COLUMBIA FUNDS SERIES TRUST
COLUMBIA FUNDS SERIES TRUST II
COLUMBIA FUNDS VARIABLE SERIES TRUST II
COLUMBIA ETF TRUST
COLUMBIA ETF TRUST I
COLUMBIA ETF TRUST II
(each a Registrant)
POWER OF ATTORNEY
Each of the undersigned, as trustees of the above listed investment companies that previously have filed registration statements and amendments thereto pursuant to the requirements of the Securities Act of 1933 and/or the Investment Company Act of 1940 with the Securities and Exchange Commission, constitutes and appoints Michael G. Clarke, Christopher O. Petersen, Paul B. Goucher, Michael E. DeFao, Ryan C. Larrenaga, Joseph DAlessandro, Megan E. Garcy, Robert M. Kurucza and George M. Silfen, 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 the 1 st day of January, 2018.
/s/ George S. Batejan |
Trustee | |
George S. Batejan | ||
/s/ Kathleen A. Blatz |
Trustee | |
Kathleen A. Blatz | ||
/s/ Edward J. Boudreau, Jr. |
Trustee | |
Edward J. Boudreau, Jr. | ||
/s/ Pamela G. Carlton |
Trustee | |
Pamela G. Carlton | ||
/s/ William P. Carmichael |
Trustee | |
William P. Carmichael | ||
/s/ Patricia M. Flynn |
Trustee | |
Patricia M. Flynn | ||
/s/ Brian J. Gallagher |
Trustee | |
Brian J. Gallagher | ||
/s/ Catherine James Paglia |
Trustee | |
Catherine James Paglia | ||
/s/ Anthony M. Santomero |
Trustee | |
Anthony M. Santomero | ||
/s/ Minor M. Shaw |
Trustee | |
Minor M. Shaw | ||
/s/ William F. Truscott |
Trustee | |
William F. Truscott | ||
/s/ Sandra Yeager |
Trustee | |
Sandra Yeager |