THE SECURITIES ACT OF 1933 | ☒ |
Pre-Effective Amendment No. | ☐ |
Post-Effective Amendment No. 404 | ☒ |
THE INVESTMENT COMPANY ACT OF 1940 | ☒ |
Amendment No. 408 | ☒ |
Daniel J. Beckman c/o Columbia Management Investment Advisers, LLC 290 Congress Street Boston, Massachusetts 02210 |
Ryan C. Larrenaga, Esq. c/o Columbia Management Investment Advisers, LLC 290 Congress Street Boston, Massachusetts 02210 |
Class | Ticker Symbol | |
A | CREAX | |
Advisor (Class Adv) | CRERX | |
C | CRECX | |
Institutional (Class Inst) | CREEX | |
Institutional 2 (Class Inst2) | CRRVX | |
Institutional 3 (Class Inst3) | CREYX | |
R | CRSRX |
(a) | This charge is imposed on certain investments of between $1 million and $50 million redeemed within 18 months after purchase, as follows: 1.00% if redeemed within 12 months after purchase, and 0.50% if redeemed more than 12, but less than 18, months after purchase, with certain limited exceptions. |
(b) | This charge applies to redemptions within 12 months after purchase, with certain limited exceptions. |
(c) | Columbia Management Investment Advisers, LLC and certain of its affiliates have contractually agreed to waive fees and/or to reimburse expenses (excluding transaction costs and certain other investment related expenses, interest, taxes, acquired fund fees and expenses, and infrequent and/or unusual expenses) through April 30, 2024, unless sooner terminated at the sole discretion of the Fund’s Board of Trustees. Under this agreement, the Fund’s net operating expenses, subject to applicable exclusions, will not exceed the annual rates of 1.25% for Class A, 1.00% for Class Adv, 2.00% for Class C, 1.00% for Class Inst, 0.87% for Class Inst2, 0.81% for Class Inst3 and 1.50% for Class R. |
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■ | 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 A (whether or not shares are redeemed) | $695 | $953 | $1,230 | $2,019 |
Class Adv (whether or not shares are redeemed) | $102 | $323 | $561 | $1,246 |
Class C (assuming redemption of all shares at the end of the period) | $303 | $632 | $1,086 | $2,153 |
Class C (assuming no redemption of shares) | $203 | $632 | $1,086 | $2,153 |
Class Inst (whether or not shares are redeemed) | $102 | $323 | $561 | $1,246 |
Class Inst2 (whether or not shares are redeemed) | $89 | $286 | $500 | $1,116 |
Class Inst3 (whether or not shares are redeemed) | $83 | $267 | $467 | $1,045 |
Class R (whether or not shares are redeemed) | $153 | $478 | $827 | $1,811 |
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Year by Year Total Return (%) as of December 31 Each Year* |
Best and Worst Quarterly Returns During the Period Shown in the Bar Chart | ||
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Best | 4th Quarter 2021 | 17.24% |
Worst | 1st Quarter 2020 | -22.29% |
* | Year to Date return as of March 31, 2023: 4.79% |
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Share Class Inception Date |
1 Year | 5 Years | 10 Years | |
Class A | 11/01/2002 | |||
returns before taxes | -29.61% | 2.61% | 5.35% | |
returns after taxes on distributions | -30.58% | 0.56% | 3.15% | |
returns after taxes on distributions and sale of Fund shares | -16.97% | 1.74% | 3.78% | |
Class Adv returns before taxes | 11/08/2012 | -25.15% | 4.08% | 6.23% |
Class C returns before taxes | 10/13/2003 | -26.57% | 3.06% | 5.19% |
Class Inst returns before taxes | 04/01/1994 | -25.13% | 4.10% | 6.24% |
Class Inst2 returns before taxes | 03/07/2011 | -25.05% | 4.22% | 6.38% |
Class Inst3 returns before taxes | 03/01/2017 | -25.00% | 4.29% | 6.36% |
Class R returns before taxes | 09/27/2010 | -25.50% | 3.58% | 5.71% |
FTSE Nareit Equity REITs Index (reflects no deductions for fees, expenses or taxes) | -24.37% | 3.68% | 6.53% |
Portfolio Management | Title | Role with Fund | Managed Fund Since | |||
Arthur Hurley, CFA | Senior Portfolio Manager | Portfolio Manager | 2006 |
Online | Regular Mail | Express Mail | By Telephone | |||
columbiathreadneedleus.com/investor/ | Columbia Management Investment Services Corp. P.O. Box 219104 Kansas City, MO 64121-9104 |
Columbia Management Investment Services Corp. c/o SS&C GIDS, Inc. 430 W 7th Street, Suite 219104 Kansas City, MO 64105-1407 |
800.422.3737 |
Class | Category of eligible account | For accounts other than Systematic Investment Plan accounts (as described in the Fund’s Prospectus) |
For Systematic Investment Plan accounts |
Classes A & C | All accounts other than IRAs | $2,000 | $100 |
IRAs | $1,000 | $100 | |
Classes Adv & Inst | All eligible accounts | $0, $1,000 or $2,000 depending upon the category of eligible investor |
$100 |
Classes Inst2 & R | All eligible accounts | None | N/A |
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Class | Category of eligible account | For accounts other than Systematic Investment Plan accounts (as described in the Fund’s Prospectus) |
For Systematic Investment Plan accounts |
Class Inst3 | All eligible accounts | $0, $1,000, $2,000 or $1 million depending upon the category of eligible investor |
$100 (for certain eligible investors) |
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■ | overall economic and market conditions; and |
■ | the financial condition and management of a company, including its competitive position, the quality of its balance sheet and earnings, its future prospects, and the potential for growth and stock price appreciation. |
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Portfolio Management | Title | Role with Fund | Managed Fund Since | |||
Arthur Hurley, CFA | Senior Portfolio Manager | Portfolio Manager | 2006 |
■ | compensation and other benefits received by the Investment Manager and other Ameriprise Financial affiliates related to the management/administration of a Columbia Fund and the sale of its shares; |
■ | the allocation of, and competition for, investment opportunities among the Fund, other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates, or Ameriprise Financial itself and its affiliates; |
■ | separate and potentially divergent management of a Columbia Fund and other funds and accounts advised/managed by the Investment Manager and other Ameriprise Financial affiliates; |
■ | regulatory and other investment restrictions on investment activities of the Investment Manager and other Ameriprise Financial affiliates and accounts advised/managed by them; |
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■ | insurance and other relationships of Ameriprise Financial affiliates with companies and other entities in which a Columbia Fund invests; and |
■ | regulatory and other restrictions relating to the sharing of information between Ameriprise Financial and its affiliates, including the Investment Manager, and a Columbia Fund. |
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* | The website references in this prospectus are inactive links and information contained in or otherwise accessible through the referenced websites does not form a part of this prospectus. |
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■ | The amount you plan to invest. |
■ | How long you intend to remain invested in the Fund. |
■ | The fees (e.g., sales charge or “load”) and expenses for each share class. |
■ | Whether you may be eligible for a reduction or waiver of sales charges when you buy or sell shares. |
■ | The net asset value (NAV) per share is the price of a share calculated by the Fund every business day. |
■ | The offering price per share is the NAV per share plus any front-end sales charge (or load) that applies. |
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Share Class | Eligible Investors(a); Minimum Initial Investments(b); Conversion Features(c) |
Front-End Sales Charges(d) |
Contingent Deferred Sales Charges (CDSCs)(d) |
Sales Charge Reductions/Waivers |
Maximum Distribution and/or Service Fees(e) |
similar institutions; (iii) broker-dealers, banks, trust companies and similar institutions that clear Fund share transactions for their client or customer investment advisory or similar accounts through designated financial intermediaries and their mutual fund trading platforms that have been granted specific written authorization from the Transfer Agent with respect to Class Adv eligibility apart from selling, servicing or similar agreements; (iv) 501(c)(3) charitable organizations; (v) 529 plans; (vi) health savings accounts; (vii) investors participating in a fee-based advisory program sponsored by a financial intermediary or other entity that is not compensated by the Fund for those services, other than payments for shareholder servicing or sub-accounting performed in place of the Transfer Agent; and (viii) commissionable brokerage platforms where the financial intermediary, acting as broker on behalf of its customer, charges the customer a commission for effecting transactions in Fund shares, provided that the financial intermediary has an agreement with the Distributor that specifically authorizes offering Class Adv shares within such platform.(f) Minimum Initial Investment: None, except in the case of (viii) above, which is $2,000 ($1,000 for IRAs; $100 for monthly Systematic Investment Plan accounts) |
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Class C | Eligibility: Available to the general public for investment Minimum Initial Investment: $2,000 ($1,000 for IRAs; $100 for monthly Systematic Investment Plan accounts) Purchase Order Limit for Tax-Exempt Funds: $499,999(h), none for omnibus retirement plans Purchase Order Limit for Taxable Funds: $999,999(h); none for omnibus retirement plans Conversion Feature: Yes. Effective April 1, 2021, Class C shares generally automatically convert to Class A shares of the same Fund in the month of or the month following the 8-year anniversary of the Class C |
None | 1.00% on certain investments redeemed within one year of purchase(i) | Waivers: Yes, on Fund distribution reinvestments. For additional waivers, see Choosing a Share Class – CDSC Waivers – Class A, Class C and Class V Financial intermediary-specific CDSC waivers are also available, see Appendix A |
Distribution Fee: 0.75% Service Fee: 0.25% |
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Share Class | Eligible Investors(a); Minimum Initial Investments(b); Conversion Features(c) |
Front-End Sales Charges(d) |
Contingent Deferred Sales Charges (CDSCs)(d) |
Sales Charge Reductions/Waivers |
Maximum Distribution and/or Service Fees(e) |
shares purchase date. Prior to April 1, 2021, Class C shares generally automatically converted to Class A shares of the same Fund in the month of or the month following the 10-year anniversary of the Class C shares purchase date.(c) | |||||
Class Inst |
Eligibility: Available only to certain eligible investors, which are subject to different minimum investment requirements, ranging from $0 to $2,000, including investors who purchase Fund shares through commissionable brokerage platforms where the financial intermediary holds the shares in an omnibus account and, acting as broker on behalf of its customer, charges the customer a commission for effecting transactions in Fund shares, provided that the financial intermediary has an agreement with the Distributor that specifically authorizes offering Class Inst shares within such platform; closed to (i) accounts of financial intermediaries that clear Fund share transactions for their client or customer accounts through designated financial intermediaries and their mutual fund trading platforms that have been given specific written notice from the Transfer Agent of the termination of their eligibility for new purchases of Class Inst shares and (ii) omnibus group retirement plans, subject to certain exceptions(f)(j) Minimum Initial Investment: See Eligibility above |
None | None | N/A | None |
Class Inst2 |
Eligibility: Available only to (i) certain registered investment advisers and family offices that clear Fund share transactions for their client or customer accounts through designated financial intermediaries and their mutual fund trading platforms that have been granted specific written authorization from the Transfer Agent with respect to Class Inst2 eligibility apart from selling, servicing or similar agreements; (ii) omnibus retirement plans(j); (iii) health savings accounts, provided that the financial intermediary has an agreement with the Distributor that specifically authorizes offering Class Inst2 shares within such platform and that Fund shares are held in an omnibus account; and (iv) institutional investors that are clients of the | None | None | N/A | None |
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Share Class | Eligible Investors(a); Minimum Initial Investments(b); Conversion Features(c) |
Front-End Sales Charges(d) |
Contingent Deferred Sales Charges (CDSCs)(d) |
Sales Charge Reductions/Waivers |
Maximum Distribution and/or Service Fees(e) |
Columbia Threadneedle Global Institutional Distribution Team that invest in Class Inst2 shares for their own account through platforms approved by the Distributor or an affiliate thereof to offer and/or service Class Inst2 shares within such platform. Minimum Initial Investment: None |
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Class Inst3 |
Eligibility: Available to (i) group retirement plans that maintain plan-level or omnibus accounts with the Fund(j); (ii) institutional investors that are clients of the Columbia Threadneedle Global Institutional Distribution Team that invest in Class Inst3 shares for their own account through platforms approved by the Distributor or an affiliate thereof to offer and/or service Class Inst3 shares within such platform; (iii) collective trust funds; (iv) affiliated or unaffiliated mutual funds (e.g., funds operating as funds-of-funds); (v) fee-based platforms of financial intermediaries (or the clearing intermediary they trade through) that have an agreement with the Distributor or an affiliate thereof that specifically authorizes the financial intermediary to offer and/or service Class Inst3 shares within such platform, provided also that Fund shares are held in an omnibus account; (vi) commissionable brokerage platforms where the financial intermediary, acting as broker on behalf of its customer, charges the customer a commission for effecting transactions in Fund shares, provided that the financial intermediary has an agreement with the Distributor that specifically authorizes offering Class Inst3 shares within such platform and that Fund shares are held in an omnibus account; (vii) health savings accounts, provided that the financial intermediary has an agreement with the Distributor that specifically authorizes offering Class Inst3 shares within such platform and that Fund shares are held in an omnibus account; and (viii) bank trust departments, subject to an agreement with the Distributor that specifically authorizes offering Class Inst3 shares and provided that Fund shares are held in an omnibus account. In each case above where noted that Fund shares are required | None | None | N/A | None |
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Share Class | Eligible Investors(a); Minimum Initial Investments(b); Conversion Features(c) |
Front-End Sales Charges(d) |
Contingent Deferred Sales Charges (CDSCs)(d) |
Sales Charge Reductions/Waivers |
Maximum Distribution and/or Service Fees(e) |
to be held in an omnibus account, the Distributor may, in its discretion, determine to waive this requirement.(f) Minimum Initial Investment: No minimum for the eligible investors described in (i), (iii), (iv), (v), and (vii) above; $2,000 ($1,000 for IRAs; $100 for monthly Systematic Investment Plan accounts) for the eligible investors described in (vi) above; and $1 million for all other eligible investors, unless waived in the discretion of the Distributor |
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Class R | Eligibility: Available only to eligible retirement plans, health savings accounts and, in the sole discretion of the Distributor, other types of retirement accounts held through platforms maintained by financial intermediaries approved by the Distributor Minimum Initial Investment: None |
None | None | N/A | Series of CFST & CFST I: distribution fee of 0.50% Series of CFST II: distribution and service fee of 0.50%, of which the service fee may be up to 0.25% |
Class V | Eligibility: Generally closed to new investors(j) Minimum Initial Investment: N/A |
5.75% maximum for Equity Funds (4.75% for Fixed Income Funds), declining to 0.00% on investments of $1 million or more | CDSC on certain investments of between $1 million and $50 million redeemed within 18 months after purchase, charged as follows: • 1.00% CDSC if redeemed within 12 months after purchase and • 0.50% CDSC if redeemed more than 12, but less than 18, months after purchase | Reductions: Yes, see Choosing a Share Class — Reductions/Waivers of Sales Charges – Class A and Class V Shares Front-End Sales Charge Reductions Waivers: Yes, on Fund distribution reinvestments. For additional waivers, see Choosing a Share Class — Reductions/Waivers of Sales Charges – Class A and Class V Shares Front-End Sales Charge Waivers, as well as Choosing a Share Class — CDSC Waivers – Class A, Class C and Class V |
Service Fee: up to 0.50% |
(a) | For Columbia Government Money Market Fund, new investments must be made in Class A, Class Inst, Class Inst3, or Class R shares, subject to eligibility. Class C shares of Columbia Government Money Market Fund are available as a new investment only to investors in the Distributor's proprietary 401(k) products, provided that such investor is eligible to invest in the class and transact directly with the Fund or the Transfer Agent through a third party administrator or third party recordkeeper. Columbia Government Money Market Fund offers Class Inst2 shares only to facilitate exchanges with other Funds offering such share class. |
(b) | Certain share classes are subject to minimum account balance requirements, as described in Buying, Selling and Exchanging Shares — Transaction Rules and Policies. |
(c) | For more information on the conversion of Class C shares to Class A shares, see Choosing a Share Class - Sales Charges and Commissions - Class C Shares - Conversion to Class A Shares. |
(d) | Actual front-end sales charges and CDSCs vary among the Funds. For more information on applicable sales charges, see Choosing a Share Class — Sales Charges and Commissions, and for information about certain exceptions to these sales charges, see Choosing a Share Class — Reductions/Waivers of Sales Charges. |
(e) | These are the maximum applicable distribution and/or service fees. Except for Class V shares, these fees are paid under the Fund’s Rule 12b-1 plan. Fee rates and fee components (i.e., the portion of a combined fee that is a distribution or service fee) may vary among Funds. Because these fees are paid out of Fund assets on an ongoing basis, over time these fees will increase the cost of your investment and may cost you |
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more than paying other types of distribution and/or service fees. Although Class A shares of certain series of CFST I are subject to a combined distribution and service fee of up to 0.35%, these Funds currently limit the combined fee to 0.25%. Columbia Ultra Short Duration Municipal Bond Fund and Columbia Ultra Short Term Bond Fund each pay a distribution and service fee of up to 0.15% on Class A shares. Columbia Government Money Market Fund pays a distribution and service fee of up to 0.10% on Class A shares and up to 0.75% distribution fee on Class C shares. Columbia High Yield Municipal Fund, Columbia Intermediate Duration Municipal Bond Fund and Columbia Tax-Exempt Fund each pay a service fee of up to 0.20% on Class A and Class C shares. Columbia Intermediate Duration Municipal Bond Fund pays a distribution fee of up to 0.65% on Class C shares. For more information on distribution and service fees, see Choosing a Share Class — Distribution and Service Fees. |
(f) | Columbia Ultra Short Duration Municipal Bond Fund and Columbia Ultra Short Term Bond Fund must be purchased through financial intermediaries that, by written agreement with the Distributor, are specifically authorized to sell the Funds’ shares. Additionally, for Columbia Ultra Short Duration Municipal Bond Fund, Direct-at-Fund Accounts held at the Fund’s Transfer Agent that do not or no longer have a financial intermediary assigned to these Fund accounts may purchase shares. Class Adv shares of Columbia Ultra Short Duration Municipal Bond Fund and Columbia Ultra Short Term Bond Fund are also available to certain registered investment advisers that clear Fund share transactions for their client accounts through designated financial intermediaries with mutual fund trading platforms that have been granted specific written authorization from the Transfer Agent (apart from selling, servicing or similar agreements) to sell Class Inst2 shares, which are not offered by the Funds. Class Inst3 shares of Columbia Ultra Short Term Bond Fund that were open and funded accounts prior to November 30, 2018 (the conversion date from the former unnamed share class to Class Inst3 shares) are eligible for additional investment; however, any account established after that date must meet the current Class Inst3 eligibility requirements. |
(g) | For Columbia Short Duration Municipal Bond Fund, a CDSC of 0.50% is charged on certain investments of $500,000 or more redeemed within 12 months after purchase. The following Funds are not subject to a front-end sales charge or a CDSC on Class A shares: Columbia Government Money Market Fund, Columbia Large Cap Enhanced Core Fund, Columbia Large Cap Index Fund, Columbia Mid Cap Index Fund, Columbia Small Cap Index Fund, Columbia Ultra Short Duration Municipal Bond Fund, Columbia Ultra Short Term Bond Fund and Columbia U.S. Treasury Index Fund. |
(h) | If you are eligible to invest in Class A shares without a front-end sales charge, you should discuss your options with your financial intermediary. For more information, see Choosing a Share Class – Reductions/Waivers of Sales Charges. |
(i) | There is no CDSC on redemptions from Class C shares of Columbia Government Money Market Fund. |
(j) | These share classes are closed to new accounts, or closed to previously eligible investors, subject to certain conditions, as summarized below and described in more detail under Buying, Selling and Exchanging Shares — Buying Shares — Eligible Investors: |
26 | Prospectus 2023 |
■ | depends on the amount you are investing (generally, the larger the investment, the smaller the percentage sales charge), and |
■ | is based on the total amount of your purchase and the value of your account (and any other accounts eligible for aggregation of which you or your financial intermediary notifies the Fund). |
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Class A Shares — Front-End Sales Charge — Breakpoint Schedule* | ||||
Breakpoint Schedule For: | Dollar amount of shares bought(a) |
Sales charge as a % of the offering price(b) |
Sales charge as a % of the net amount invested(b) |
Amount retained by or paid to financial intermediaries as a % of the offering price |
Equity Funds, Columbia Adaptive Risk Allocation Fund, Columbia Commodity Strategy Fund, Columbia Multi Strategy Alternatives Fund, and Funds-of-Funds (equity)* |
$0–$49,999 | 5.75% | 6.10% | 5.00% |
$50,000–$99,999 | 4.50% | 4.71% | 3.75% | |
$100,000–$249,999 | 3.50% | 3.63% | 3.00% | |
$250,000–$499,999 | 2.50% | 2.56% | 2.15% | |
$500,000–$999,999 | 2.00% | 2.04% | 1.75% | |
$1,000,000 or more | 0.00% | 0.00% | 0.00%(c) | |
Fixed Income Funds (except those listed below) and Funds-of-Funds (fixed income)* |
$0-$49,999 | 4.75% | 4.99% | 4.00% |
$50,000–$99,999 | 4.25% | 4.44% | 3.50% | |
$100,000–$249,999 | 3.50% | 3.63% | 3.00% | |
$250,000–$499,999 | 2.50% | 2.56% | 2.15% | |
$500,000–$999,999 | 2.00% | 2.04% | 1.75% | |
$1,000,000 or more | 0.00% | 0.00% | 0.00%(c) | |
Tax-Exempt Funds (other than Columbia Short Duration Municipal Bond Fund) | $0-$99,999 | 3.00% | 3.09% | 2.50% |
$100,000–$249,999 | 2.50% | 2.56% | 2.15% | |
$250,000–$499,999 | 1.50 % | 1.53% | 1.25% | |
$500,000 or more | 0.00% | 0.00% | 0.00%(c) | |
Columbia Floating Rate Fund, Columbia Limited Duration Credit Fund, Columbia Mortgage Opportunities Fund, Columbia Quality Income Fund, and Columbia Total Return Bond Fund |
$0-$99,999 | 3.00% | 3.09% | 2.50% |
$100,000–$249,999 | 2.50% | 2.56% | 2.15% | |
$250,000–$499,999 | 2.00% | 2.04% | 1.75% | |
$500,000–$999,999 | 1.50% | 1.52% | 1.25% | |
$1,000,000 or more | 0.00% | 0.00% | 0.00%(c) | |
Columbia Short Term Bond Fund | $0-$99,999 | 1.00% | 1.01% | 0.75% |
$100,000–$249,999 | 0.75% | 0.76% | 0.50% | |
$250,000–$999,999 | 0.50% | 0.50% | 0.40% | |
$1,000,000 or more | 0.00% | 0.00% | 0.00%(c) | |
Columbia Short Duration Municipal Bond Fund | $0-$99,999 | 1.00% | 1.01% | 0.75% |
$100,000–$249,999 | 0.75% | 0.76% | 0.50% | |
$250,000–$499,999 | 0.50% | 0.50% | 0.40% | |
$500,000 or more | 0.00% | 0.00% | 0.00%(c) | |
* | The following Funds are not subject to a front-end sales charge or CDSC on Class A shares: Columbia Government Money Market Fund, Columbia Large Cap Enhanced Core Fund, Columbia Large Cap Index Fund, Columbia Mid Cap Index Fund, Columbia Small Cap Index Fund, Columbia Ultra Short Duration Municipal Bond Fund, Columbia Ultra Short Term Bond Fund and Columbia U.S. Treasury Index Fund. "Funds-of-Funds (equity)" includes Columbia Capital Allocation Aggressive Portfolio, Columbia Capital Allocation Moderate Aggressive Portfolio, Columbia Capital Allocation Moderate Conservative Portfolio and Columbia Capital Allocation Moderate Portfolio. "Funds-of-Funds (fixed income)" includes Columbia Capital Allocation Conservative Portfolio and Columbia Income Builder Fund. Columbia Balanced Fund, Columbia Flexible Capital Income Fund and Columbia Global Opportunities Fund are treated as equity Funds for purposes of the table. |
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(a) | Purchase amounts and account values may be aggregated among all eligible Fund accounts for the purposes of this table. See Choosing a Share Class — Reductions/Waivers of Sales Charges for a discussion of account value aggregation. |
(b) | Because the offering price is calculated to two decimal places, the dollar amount of the sales charge as a percentage of the offering price and your net amount invested for any particular purchase of Fund shares may be higher or lower depending on whether downward or upward rounding was required during the calculation process. Purchase price includes the sales charge. |
(c) | For information regarding cumulative commissions paid to your financial intermediary when you buy $1 million or more of Class A shares of a Taxable Fund or $500,000 or more of Class A shares of a Tax-Exempt Fund, see Class A Shares — Commissions below. |
■ | If you purchased Class A shares of any Tax-Exempt Fund (other than Columbia Short Duration Municipal Bond Fund) without paying a front-end sales charge because your eligible accounts aggregated $500,000 or more at the time of purchase, you will incur a CDSC of 0.75% if you redeem those shares within 12 months after purchase. Subsequent Class A share purchases that bring your aggregate account value to $500,000 or more will also be subject to a CDSC of 0.75% if you redeem those shares within 12 months after purchase. |
■ | If you purchased Class A shares of Columbia Short Duration Municipal Bond Fund without paying a front-end sales charge because your eligible accounts aggregated $500,000 or more at the time of purchase, you will incur a CDSC of 0.50% if you redeem those shares within 12 months after purchase. Subsequent Class A share purchases that bring your aggregate account value to $500,000 or more will also be subject to a CDSC of 0.50% if you redeem those shares within 12 months after purchase. |
■ | If you purchased Class A shares of any Taxable Fund without paying a front-end sales charge because your eligible accounts aggregated between $1 million and $50 million at the time of purchase, you will incur a CDSC if you redeem those shares within 18 months after purchase, which is charged as follows: 1.00% CDSC if shares are redeemed within 12 months after purchase; and 0.50% CDSC if shares are redeemed more than 12, but less than 18, months after purchase. Subsequent Class A share purchases that bring your aggregate account value to $1 million or more (but less than $50 million) will also be subject to a CDSC if you redeem them within 18 months after purchase as described in the previous sentence. |
* | The commission level applies to the applicable asset level; therefore, for example, for a purchase of $5 million, the Distributor would pay a commission of 0.75% on the first $3,999,999 and 0.50% on the balance. |
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** | The commission level on purchases of Class A shares of Columbia Short Duration Municipal Bond Fund is: 0.50% on purchases of $500,000 to $19,999,999 and 0.25% on purchases of $20 million or more. |
Class A Shares of Taxable Funds — Commission Schedule (Paid by the Distributor to Financial Intermediaries)* | |
Purchase Amount | Commission Level** (as a % of net asset value per share) |
$1 million – $2,999,999 | 1.00% |
$3 million – $49,999,999 | 0.50% |
$50 million or more | 0.25% |
* | Not applicable to Funds that do not assess a front-end sales charge. |
** | The commission level applies to the applicable asset level; therefore, for example, for a purchase of $5 million, the Distributor would pay a commission of 1.00% on the first $2,999,999 and 0.50% on the balance. |
■ | Class C share accounts that are Direct-at-Fund Accounts and Networked Accounts for which the Transfer Agent (and not your financial intermediary) sends you Fund account transaction confirmations and statements, convert on or about the 15th day of the month (if the 15th is not a business day, then the next business day thereafter) that they become eligible for automatic conversion provided that the Fund has records that Class C shares have been held for the requisite time period. |
■ | For purposes of determining the month when your Class C shares are eligible for conversion, the start of the holding period is the first day of the month in which your purchase was made. Your financial intermediary may choose a different day of the month to convert Class C shares. Please contact your financial intermediary for more information on calculating the holding period. |
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■ | Any shares you received from reinvested distributions on these shares generally will convert to Class A shares at the same time. |
■ | You’ll receive the same dollar value of Class A shares as the Class C shares that were automatically converted. Class C shares that you received from an exchange of Class C shares of another Fund will convert based on the day you bought the original shares. |
■ | In addition to the above automatic conversion of Class C to Class A shares policy, the Transfer Agent seeks to convert Class C shares as soon as administratively feasible, regardless of how long such shares have been owned, to Class A shares of the same Fund for Direct-at-Fund Accounts (as defined below) that do not or no longer have a financial intermediary assigned to them. Direct-at-Fund Accounts that do not have a financial intermediary assigned to them are not permitted to purchase Class C shares; Class C share purchase orders received by Direct-at-Fund Accounts that do not have a financial intermediary assigned to the account will automatically be invested in Class A shares of the same Fund. |
■ | No sales charge or other charges apply in connection with these automatic conversions, and the conversions are free from U.S. federal income tax. |
■ | depends on the amount you are investing (generally, the larger the investment, the smaller the percentage sales charge), and |
■ | is based on the total amount of your purchase and the value of your account (and any other accounts eligible for aggregation of which you notify your financial intermediary or, in the case of Direct-at-Fund Accounts (as defined below), you notify the Fund). |
Prospectus 2023 | 31 |
Class V Shares — Front-End Sales Charge — Breakpoint Schedule | ||||
Breakpoint Schedule For: | Dollar amount of shares bought(a) |
Sales charge as a % of the offering price(b) |
Sales charge as a % of the net amount invested(b) |
Amount retained by or paid to Financial Intermediaries as a % of the offering price |
Equity Funds | $0–$49,999 | 5.75% | 6.10% | 5.00% |
$50,000–$99,999 | 4.50% | 4.71% | 3.75% | |
$100,000–$249,999 | 3.50% | 3.63% | 2.75% | |
$250,000–$499,999 | 2.50% | 2.56% | 2.00% | |
$500,000–$999,999 | 2.00% | 2.04% | 1.75% | |
$1,000,000 or more | 0.00% | 0.00% | 0.00%(c) | |
Fixed Income Funds | $0–$49,999 | 4.75% | 4.99% | 4.25% |
$50,000–$99,999 | 4.50% | 4.71% | 3.75% | |
$100,000–$249,999 | 3.50% | 3.63% | 2.75% | |
$250,000–$499,999 | 2.50% | 2.56% | 2.00% | |
$500,000–$999,999 | 2.00% | 2.04% | 1.75% | |
$1,000,000 or more | 0.00% | 0.00% | 0.00%(c) | |
(a) | Purchase amounts and account values are aggregated among all eligible Fund accounts for the purposes of this table. |
(b) | Because the offering price is calculated to two decimal places, the dollar amount of the sales charge as a percentage of the offering price and your net amount invested for any particular purchase of Fund shares may be higher or lower depending on whether downward or upward rounding was required during the calculation process. |
(c) | For more information regarding cumulative commissions paid to your financial intermediary when you buy $1 million or more of Class V shares, see Class V Shares — Commissions below. |
■ | If you purchased Class V shares without a front-end sales charge because your eligible accounts aggregated between $1 million and $50 million at the time of purchase, you will incur a CDSC if you redeem those shares within 18 months after purchase, which is charged as follows: 1.00% CDSC if shares are redeemed within 12 months after purchase, and 0.50% CDSC if shares are redeemed more than 12, but less than 18, months after purchase. |
■ | Subsequent Class V share purchases that bring your aggregate account value to $1 million or more (but less than $50 million) will also be subject to a CDSC if you redeem them within the time periods noted above. |
32 | Prospectus 2023 |
Class V Shares — Commission Schedule (Paid by the Distributor to Financial Intermediaries) | |
Purchase Amount |
Commission Level* (as a % of net asset value per share) |
$3 million – $49,999,999 | 0.50% |
$50 million or more | 0.25% |
* | The commission level applies to the applicable asset level; therefore, for example, for a purchase of $5 million, the Distributor would pay a commission of 1.00% on the first $2,999,999 and 0.50% on the balance. |
Prospectus 2023 | 33 |
34 | Prospectus 2023 |
Prospectus 2023 | 35 |
Repurchases (Reinstatements) | |
Redeemed Share Class | Corresponding Repurchase Class |
Class A | Class A |
Class C | Class C |
Class V | Class V |
Distribution Fee |
Service Fee |
Combined Total | |
Class A | up to 0.25% | up to 0.25%(c) | up to 0.35%(a)(c)(d) |
Class Adv | None | None | None |
Class C | 0.75%(b)(d) | 0.25%(c) | 1.00%(c)(d) |
36 | Prospectus 2023 |
(a) | The maximum distribution and service fees for Class A shares varies among the Funds, as shown in the table below: |
Funds | Maximum Class A Distribution Fee |
Maximum Class A Service Fee |
Maximum Class A Combined Total |
Series of CFST and CFST II (other than Columbia Government Money Market Fund) |
— | — | 0.25%; these Funds pay a combined distribution and service fee |
Columbia Government Money Market Fund | — | — | 0.10% |
Columbia Ultra Short Duration Municipal Bond Fund, Columbia Ultra Short Term Bond Fund | up to 0.15% | up to 0.15% | 0.15% |
Columbia Balanced Fund, Columbia Contrarian Core Fund, Columbia Dividend Income Fund, Columbia Global Technology Growth Fund, Columbia Large Cap Growth Fund, Columbia Oregon Intermediate Municipal Bond Fund, Columbia Real Estate Equity Fund, Columbia Select Mid Cap Growth Fund, Columbia Small Cap Growth Fund, Columbia Total Return Bond Fund | up to 0.10% | up to 0.25% | up to 0.35%; these Funds may pay distribution and service fees up to a maximum of 0.35% of their average daily net assets attributable to Class A shares (comprised of up to 0.10% for distribution services and up to 0.25% for shareholder liaison services) but currently limit such fees to an aggregate fee of not more than 0.25% for Class A shares |
Columbia Adaptive Risk Allocation Fund, Columbia Bond Fund, Columbia Connecticut Intermediate Municipal Bond Fund, Columbia Corporate Income Fund, Columbia Emerging Markets Fund, Columbia Greater China Fund, Columbia International Dividend Income Fund, Columbia Massachusetts Intermediate Municipal Bond Fund, Columbia Multi Strategy Alternatives Fund, Columbia New York Intermediate Municipal Bond Fund, Columbia Select Large Cap Growth Fund, Columbia Small Cap Value Fund I, Columbia Strategic Income Fund, Columbia Strategic New York Municipal Income Fund, Columbia U.S. Social Bond Fund | — | 0.25% | 0.25% |
Columbia High Yield Municipal Fund, Columbia Intermediate Duration Municipal Bond Fund, Columbia Tax-Exempt Fund, Columbia Strategic California Municipal Income Fund | — | 0.20% | 0.20% |
Columbia U.S. Treasury Index Fund | --- | 0.15% | 0.15% |
(b) | The distribution fee for Class C shares of certain Funds varies. The annual distribution fee for Class C shares shall be 0.45% for Columbia Connecticut Intermediate Municipal Bond Fund, Columbia Massachusetts Intermediate Municipal Bond Fund, Columbia New York Intermediate Municipal Bond Fund, Columbia Oregon Intermediate Municipal Bond Fund, Columbia Strategic California Municipal Income Fund, and Columbia Strategic New York Municipal Income Fund, 0.55% for Columbia Short Term Bond Fund and Columbia Corporate Income Fund, 0.60% for Columbia High Yield Municipal Fund, Columbia Intermediate Duration Municipal Bond Fund, and Columbia Tax-Exempt Fund, and 0.65% for Columbia U.S. Treasury Index Fund, of the average daily net assets of the Fund’s Class C shares. |
(c) | The service fees for Class A and Class C shares of certain Funds vary. The annual service fee for Class A and Class C shares of Columbia High Yield Municipal Fund, Columbia Intermediate Duration Municipal Bond Fund, Columbia Tax-Exempt Fund and Class A shares of Columbia Strategic California Municipal Income Fund may equal up to 0.20% of the average daily NAV of all shares of such Fund class. The service fee for Class A and Class C shares of Columbia U.S. Treasury Index Fund shall equal up to 0.15% annually of the average daily NAV of all shares of such Fund class. |
(d) | Fee amounts noted apply to all Funds other than Columbia Government Money Market Fund, which, for Class A shares, pays distribution and service fees of 0.10%, and for Class C shares pays distribution fees of 0.75%. The payment of the distribution and/or service fees payable by |
Prospectus 2023 | 37 |
Columbia Government Money Market Fund under its Plan of Distribution has been suspended through November 30, 2023, or such earlier date as may be determined at the sole discretion of the Fund’s Board. Compensation paid to financial intermediaries is suspended for the duration of the suspension of payments under Columbia Government Money Market Fund’s Plan of Distribution. |
(e) | Class R shares of series of CFST and CFST I pay a distribution fee pursuant to a Rule 12b-1 plan. The Funds do not have a shareholder service plan for Class R shares. Series of CFST II have a distribution and shareholder service plan for Class R shares. For Class R shares of series of CFST II, the maximum fee under the plan reimbursed for distribution expenses is equal on an annual basis to 0.50% of the average daily net assets of the Fund attributable to Class R shares. Of that amount, up to 0.25% may be reimbursed for shareholder service expenses. |
(f) | The shareholder servicing fees for Class V shares are up to 0.50% of average daily net assets attributable to Class V shares for equity Funds and 0.40% for fixed income Funds. In general, the Funds currently limit such fees to a maximum of 0.25% for equity Funds and 0.15% for fixed-income Funds. These fees for Class V shares are not paid pursuant to a Rule 12b-1 plan. See Class V Shareholder Service Fees below for more information. |
38 | Prospectus 2023 |
Prospectus 2023 | 39 |
40 | Prospectus 2023 |
Prospectus 2023 | 41 |
42 | Prospectus 2023 |
Minimum Account Balance | |
Minimum Account Balance | |
For all classes and account types except those listed below | $250 (None for accounts with Systematic Investment Plans) |
Individual Retirement Accounts for all classes except those listed below | None |
Class Adv, Class Inst2, Class Inst3 and Class R | None |
Prospectus 2023 | 43 |
44 | Prospectus 2023 |
■ | 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; |
Prospectus 2023 | 45 |
■ | increased taxable gains to the Fund's remaining shareholders resulting from the need to sell securities to meet sell orders; and |
■ | increased brokerage and administrative costs. |
46 | Prospectus 2023 |
Prospectus 2023 | 47 |
48 | Prospectus 2023 |
Prospectus 2023 | 49 |
50 | Prospectus 2023 |
Prospectus 2023 | 51 |
Minimum Initial Investments | ||
Minimum Initial Investment(a) |
Minimum Initial Investment for Accounts with Systematic Investment Plans | |
For all classes and account types except those listed below | $2,000 | $100(b) |
Individual Retirement Accounts for all classes except those listed below | $1,000 | $100(c) |
Group retirement plans | None | N/A |
Class Adv and Class Inst | $0, $1,000 or $2,000(d) | $100(d) |
Class Inst2 and Class R | None | N/A |
Class Inst3 | $0, $1,000, $2,000 or $1 million(e) | $100(e) |
(a) | If your Class A, Class Adv, Class C, Class Inst, Class Inst3 or Class V shares account balance falls below the minimum initial investment amount for any reason, including a market decline, you may be asked to increase it to the minimum initial investment amount or establish a monthly Systematic Investment Plan. If you do not do so, your account will be subject to a $20 annual low balance fee and/or shares may be automatically redeemed and the proceeds mailed to you if the account falls below the minimum account balance. See Buying, Selling and Exchanging Shares — Transaction Rules and Policies above. There is no minimum initial investment in Class A shares for accounts held in an omnibus account on a mutual fund only platform offered through your financial intermediary. |
(b) | Columbia Government Money Market Fund requires minimum initial investment of $2,000 for accounts with Systematic Investment Plans. |
(c) | Columbia Government Money Market Fund requires minimum initial investment of $1,000 for accounts with Systematic Investment Plans. |
(d) | The minimum initial investment in Class Adv shares is $2,000 ($1,000 for IRAs; $100 for monthly Systematic Investment Plan accounts) for commissionable brokerage platforms where the financial intermediary, acting as broker on behalf of its customers, charges the customer a commission for effecting transactions in Fund shares, provided that the financial intermediary has an agreement with the Distributor that specifically authorizes offering Class Adv shares within such platform; for all other eligible Class Adv share investors (see Buying Shares – Eligible Investors – Class Adv Shares above), there is no minimum initial investment. The minimum initial investment amount for Class Inst shares is $0, $1,000 or $2,000 depending upon the category of eligible investor. See — Class Inst Shares Minimum Initial Investments below. The minimum initial investment amount for monthly Systematic Investment Plan accounts is the same as the amount set forth in the first two rows of the table, as applicable. |
(e) | There is no minimum initial investment in Class Inst3 shares for: group retirement plans that maintain plan-level or omnibus accounts with the Fund; collective trust funds; affiliated or unaffiliated mutual funds (e.g., funds operating as funds-of-funds); fee-based platforms of financial intermediaries (or the clearing intermediary that they trade through) that have an agreement with the Distributor or an affiliate thereof that specifically authorizes the financial intermediary to offer and/or service Class Inst3 shares within such platform and Fund shares are held in an omnibus account; and bank trust departments, subject to an agreement with the Distributor that specifically authorizes offering Class Inst3 shares and provided that Fund shares are held in an omnibus account. The minimum initial investment in Class Inst3 shares is $2,000 |
52 | Prospectus 2023 |
($1,000 for IRAs; $100 for monthly Systematic Investment Plan accounts) for commissionable brokerage platforms where the financial intermediary, acting as broker on behalf of its customer, charges the customer a commission for effecting transactions in Fund shares, provided that the financial intermediary has an agreement with the Distributor that specifically authorizes offering Class Inst3 shares within such platform and Fund shares are held in an omnibus account. The minimum initial investment in Class Inst3 shares is $1 million, unless waived in the discretion of the Distributor, for the following investors: institutional investors that are clients of the Columbia Threadneedle Global Institutional Distribution Team that invest in Class Inst3 shares for their own account through platforms approved by the Distributor or an affiliate thereof to offer and/or service Class Inst3 shares within such platform. The Distributor may, in its discretion, waive the $1 million minimum initial investment required for these Class Inst3 investors. In each case above where noted that Fund shares are required to be held in an omnibus account, the Distributor may, in its discretion, determine to waive this requirement. |
■ | Any health savings account sponsored by a third party platform. |
■ | Any investor participating in an account sponsored by a financial intermediary or other entity (that provides services to the account) that is paid a fee-based advisory fee by the investor and that is not compensated by the Fund for those services, other than payments for shareholder servicing or sub-accounting performed in place of the Transfer Agent. |
■ | Any commissionable brokerage account, if a financial intermediary has received a written approval from the Distributor to waive the minimum initial investment in Class Inst shares. |
■ | Individual retirement accounts (IRAs) on commissionable brokerage platforms where the financial intermediary, acting as broker on behalf of its customer, charges the customer a commission for effecting transactions in Fund shares, provided that the financial intermediary has an agreement with the Distributor that specifically authorizes offering Class Inst shares within such platform. |
■ | Any current employee of Columbia Management Investment Advisers LLC, the Distributor or the Transfer Agent and immediate family members of any of the foregoing who share the same address are eligible to invest in Class Inst shares through an individual retirement account (IRA). If you maintain your account with a financial intermediary, you must contact that financial intermediary each time you seek to purchase shares to notify them that you qualify for Class Inst shares. If Class Inst shares are not available at your financial intermediary, you may consider opening a Direct-at-Fund Account. It is your obligation to advise your financial intermediary or (in the case of Direct-at-Fund Accounts) the Transfer Agent that you qualify for Class Inst shares; be prepared to provide proof thereof. |
■ | Investors (except investors in individual retirement accounts (IRAs)) who purchase Fund shares through commissionable brokerage platforms where the financial intermediary holds the shares in an omnibus account and, acting as broker on behalf of its customer, charges the customer a commission for effecting transactions in Fund shares provided that the financial intermediary has an agreement with the Distributor that specifically authorizes offering Class Inst shares within such platform. |
■ | Any current employee of Columbia Management Investment Advisers LLC, the Distributor or the Transfer Agent and immediate family members of any of the foregoing who share the same address are eligible to invest in Class Inst shares (other than individual retirement accounts (IRAs), for which the minimum initial investment is $1,000). If you maintain your account with a financial intermediary, you must contact that financial intermediary each time you seek to purchase shares to notify them that you qualify for Class Inst shares. If Class Inst shares are not available |
Prospectus 2023 | 53 |
at your financial intermediary, you may consider opening a Direct-at-Fund Account. It is your obligation to advise your financial intermediary or (in the case of Direct-at-Fund Accounts) the Transfer Agent that you qualify for Class Inst shares; be prepared to provide proof thereof. |
■ | Certain financial institutions and intermediaries, such as insurance companies, trust companies, banks, endowments, investment companies or foundations, buying shares for their own account, including Ameriprise Financial and its affiliates and/or subsidiaries. |
■ | Bank trust departments that assess their clients an asset-based fee. |
■ | Certain other investors as set forth in more detail in the SAI. |
■ | Once the Transfer Agent or your financial intermediary receives your purchase order in “good form,” your purchase will be made at the Fund’s next calculated public offering price per share, which is the NAV per share plus any sales charge that applies (i.e., the trade date). |
■ | Once the Fund receives your purchase request in “good form,” you cannot cancel it after the market closes. |
■ | You generally buy Class A and Class V shares at the public offering price per share because purchases of these share classes are generally subject to a front-end sales charge. |
■ | You buy Class Adv, Class C, Class Inst, Class Inst2, Class Inst3 and Class R shares at NAV per share because no front-end sales charge applies to purchases of these share classes. |
■ | Class A shares of Columbia Ultra Short Term Bond Fund are not eligible for purchase by a Direct-at-Fund Account. |
■ | Class Inst shares of Columbia Ultra Short Duration Municipal Bond Fund and Columbia Ultra Short Term Bond Fund are not eligible for purchase by a Direct-at-Fund Account except for any current employee of Columbia Management Investment Advisers LLC, the Distributor or Transfer Agent and immediate family members of the foregoing who share the same address. |
■ | The Distributor and the Transfer Agent reserve the right to cancel your order request if the Fund does not receive payment within two business days of receiving your purchase order request. The Fund will return any payment received for orders that have been cancelled, but no interest will be paid on that money. |
■ | Financial intermediaries are responsible for sending your purchase orders to the Transfer Agent and ensuring that the Fund receives your money on time. |
■ | Shares purchased are recorded on the books of the Fund. The Fund does not issue certificates. |
■ | You generally may make a purchase only into a Fund that is accepting investments. |
54 | Prospectus 2023 |
Prospectus 2023 | 55 |
■ | Once the Transfer Agent or your financial intermediary receives your redemption order in “good form,” your shares will be sold at the Fund’s next calculated NAV per share (i.e., the trade date). Any applicable CDSC will be deducted from the amount you're selling and the balance will be remitted to you. |
■ | Once the Fund receives your redemption request in “good form,” you cannot cancel it after the market closes. |
■ | The Distributor, in its sole discretion, reserves the right to liquidate Fund shares (of any class of the Fund) held in an omnibus account of a financial intermediary that clears Fund share transactions through a clearing intermediary or platform that charges certain maintenance fees to the Fund if the value of the omnibus account, at the Fund share class (i.e., CUSIP) level, falls below $100,000 (below $2 million for Class V shares) (a CUSIP Liquidation Event). The Distributor will provide at least 90 days’ notice of a CUSIP Liquidation Event to financial intermediaries with impacted omnibus accounts. Shareholders invested in the Fund through such omnibus accounts can request |
56 | Prospectus 2023 |
through their financial intermediary a tax-free exchange to Class A shares or shareholders can consider holding their Fund shares in a Direct-at-Fund Account, provided requirements to transfer the account are fulfilled. You should discuss your options with your financial intermediary. |
■ | If you sell your shares that are held in a Direct-at-Fund Account, we will normally send the redemption proceeds by mail or electronically transfer them to your bank account the next business day after the trade date. Note that your bank may take up to three business days to post an electronic funds transfer from your account. |
■ | If you sell your shares through a financial intermediary, the Funds will normally send the redemption proceeds to your financial intermediary within two business days after the trade date. |
■ | No interest will be paid on uncashed redemption checks. |
■ | Other restrictions may apply to retirement accounts. For information about these restrictions, contact your retirement plan administrator. |
■ | For broker-dealer and wrap fee accounts: The Fund reserves the right to redeem your shares if your account falls below the Fund's minimum initial investment requirement. The Fund will notify your broker-dealer prior to redeeming shares, and will provide details on how to avoid such redemption. |
■ | Also keep in mind the Funds' Small Account Policy, which is described above in Buying, Selling and Exchanging Shares — Transaction Rules and Policies. |
■ | Exchanges are made at the NAV next calculated (plus any applicable sales charge) after your exchange order is received in “good form” (i.e., the trade date). |
■ | Once the Fund receives your exchange request in “good form,” you cannot cancel it after the market closes. |
■ | The rules for buying shares of a Fund generally apply to exchanges into that Fund, including, if your exchange creates a new Fund account, it must satisfy the minimum investment amount, unless a waiver applies. |
Prospectus 2023 | 57 |
■ | Shares of the purchased Fund may not be used on the same day for another exchange or sale. |
■ | If you exchange shares from Class A shares of Columbia Government Money Market Fund to a non-money market Fund, any further exchanges must be between shares of the same class. For example, if you exchange from Class A shares of Columbia Government Money Market Fund into Class C shares of a non-money market Fund, you may not exchange from Class C shares of that non-money market Fund back to Class A shares of Columbia Government Money Market Fund or Class A shares of any other Fund. |
■ | A sales charge may apply when you exchange shares of a Fund that were not assessed a sales charge at the time you purchased such shares. If you invest through a Direct-at-Fund Account in Columbia Government Money Market Fund, Columbia Large Cap Enhanced Core Fund, Columbia Large Cap Index Fund, Columbia Mid Cap Index Fund, Columbia Small Cap Index Fund, Columbia Ultra Short Duration Municipal Bond Fund, Columbia Ultra Short Term Bond Fund, Columbia U.S. Treasury Index Fund or any other Columbia Fund that does not impose a front-end sales charge and then you exchange into a Fund that does assess a sales charge, your transaction is subject to a front-end sales charge if you exchange into Class A shares and to a CDSC if you exchange into Class C shares of the Columbia Funds. |
■ | If you purchased Class A shares of a Columbia Fund that imposes a front-end sales charge (and you paid any applicable sales charge) and you then exchange those shares into Columbia Government Money Market Fund, Columbia Large Cap Enhanced Core Fund, Columbia Large Cap Index Fund, Columbia Mid Cap Index Fund, Columbia Small Cap Index Fund, Columbia Ultra Short Duration Municipal Bond Fund, Columbia Ultra Short Term Bond Fund, Columbia U.S. Treasury Index Fund or any other Columbia Fund that does not impose a front-end sales charge, you may exchange that amount to Class A of another Fund in the future, including dividends earned on that amount, without paying a sales charge. |
■ | If your shares are subject to a CDSC, you will not be charged a CDSC upon the exchange of those shares. Any CDSC will be deducted when you sell the shares you received from the exchange. The CDSC imposed at that time will be based on the period that begins when you bought shares of the original Fund and ends when you sell the shares of the Fund you received from the exchange. Any applicable CDSC charged will be the CDSC of the original Fund. |
■ | You may make exchanges only into a Fund that is legally offered and sold in your state of residence. Contact the Transfer Agent or your financial intermediary for more information. |
■ | You generally may make an exchange only into a Fund that is accepting investments. |
■ | The Fund may change or cancel your right to make an exchange by giving the amount of notice required by regulatory authorities (generally 60 days for a material change or cancellation). |
■ | Unless your account is part of a tax-advantaged arrangement, an exchange for shares of another Fund is a taxable event, and you may recognize a gain or loss for tax purposes. |
■ | Changing your investment to a different Fund will be treated as a sale and purchase, and you will be subject to applicable taxes on the sale and sales charges on the purchase of the new Fund. |
■ | Class Inst shares of a Fund may be exchanged for Class A or Class Inst shares of another Fund. In certain circumstances, the front-end sales charge applicable to Class A shares may be waived on exchanges of Class Inst shares for Class A shares. See Buying, Selling and Exchanging Shares — Buying Shares — Eligible Investors — Class Inst Shares for details. |
■ | Class A shares of Columbia Ultra Short Term Bond Fund are not eligible for exchange by a Direct-at-Fund Account. |
■ | Class Inst shares of Columbia Ultra Short Duration Municipal Bond Fund and Columbia Ultra Short Term Bond Fund are not eligible for exchange by a Direct-at-Fund Account except for any current employee of the Investment Manager, the Distributor or the Transfer Agent and immediate family members of any of the foregoing who share the same address. |
■ | You may generally exchange Class V shares of a Fund for Class A shares of another Fund if the other Fund does not offer Class V shares. Class V shares exchanged into Class A shares cannot be exchanged back into Class V shares. |
58 | Prospectus 2023 |
Prospectus 2023 | 59 |
■ | 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 |
60 | Prospectus 2023 |
■ | The Fund intends to qualify and to be eligible for treatment each year as a regulated investment company. A regulated investment company generally is not subject to tax at the fund level on income and gains from investments that are distributed to shareholders. However, the Fund's failure to qualify for treatment as a regulated investment company would result in Fund-level taxation, and consequently, a reduction in income available for distribution to you and in the NAV of your shares. Even if the Fund qualifies for treatment as a regulated investment company, the Fund may be subject to federal excise tax on certain undistributed income or gains. |
■ | Otherwise taxable distributions generally are taxable to you when paid, whether they are paid in cash or automatically reinvested in additional Fund shares. Dividends paid in January are deemed paid on December 31 of the prior year if the dividend was declared and payable to shareholders of record in October, November, or December of such prior year. |
■ | Distributions of the Fund's ordinary income and net short-term capital gain, if any, generally are taxable to you as ordinary income. Distributions of the Fund's net long-term capital gain, if any, generally are taxable to you as long-term capital gain. Whether capital gains are long-term or short-term is determined by how long the Fund has owned the investments that generated them, rather than how long you have owned your shares. Certain events may require the Fund to sell significant amounts of appreciated securities and make large dividends relative to the Fund’s NAV. Such events may include large net shareholder redemptions, portfolio rebalancing or fund mergers. The Fund generally provides estimates of expected capital gain dividends (if any) prior to the distribution on columbiathreadneedleus.com. |
■ | From time to time, a distribution from the Fund could constitute a return of capital. A return of capital is a return of an amount of your original investment and is not a distribution of income or capital gain from the Fund. Therefore, a return of capital is not taxable to you so long as the amount of the distribution does not exceed your tax basis in your Fund shares. A return of capital reduces your tax basis in your Fund shares, with any amounts exceeding such basis generally taxable as capital gain. |
■ | If you are an individual and you meet certain holding period and other requirements for your Fund shares, a portion of your distributions may be treated as “qualified dividend income” taxable at the lower net long-term capital gain rates instead of the higher ordinary income rates. Qualified dividend income is income attributable to the Fund's dividends received from certain U.S. and foreign corporations, as long as the Fund meets certain holding period and other requirements for the stock producing such dividends. |
■ | Certain high-income individuals (as well as estates and trusts) are subject to a 3.8% tax on net investment income. For individuals, the 3.8% tax applies to the lesser of (1) the amount (if any) by which the taxpayer's modified adjusted gross income exceeds certain threshold amounts or (2) the taxpayer's “net investment income.” |
Net investment income generally includes for this purpose dividends, including any capital gain dividends, paid by the Fund, and net gains recognized on the sale, redemption or exchange of shares of the Fund. |
■ | Certain derivative instruments when held in the Fund's portfolio subject the Fund to special tax rules, the effect of which may be to, among other things, accelerate income to the Fund, defer Fund losses, cause adjustments in the holding periods of Fund portfolio securities, or convert capital gains into ordinary income, short-term capital losses into long-term capital losses or long-term capital gains into short-term capital gains. These rules could therefore affect the amount, timing and/or character of distributions to shareholders. |
■ | Generally, a Fund realizes a capital gain or loss on an option when the option expires, or when it is exercised, sold or otherwise terminated. However, if an option is a “section 1256 contract,” which includes most traded options |
Prospectus 2023 | 61 |
on a broad-based index, and the Fund holds such option at the end of its taxable year, the Fund is deemed to sell such option at fair market value at such time and recognize any gain or loss thereon, which is generally deemed to be 60% long-term and 40% short-term capital gain or loss, as described further in the SAI. |
■ | Income and proceeds received by the Fund from sources within foreign countries may be subject to foreign taxes. If at the end of the taxable year more than 50% of the value of the Fund's assets consists of securities of foreign corporations, and the Fund makes a special election, you will generally be required to include in your income for U.S. federal income tax purposes your share of the qualifying foreign income taxes paid by the Fund in respect of its foreign portfolio securities. You may be able to claim a foreign tax credit or deduction in respect of this amount, subject to certain limitations. There is no assurance that the Fund will make this election for a taxable year, even if it is eligible to do so. |
■ | A sale, redemption or exchange of Fund shares is a taxable event. This includes redemptions where you are paid in securities. Your sales, redemptions and exchanges of Fund shares (including those paid in securities) usually will result in a taxable capital gain or loss to you, equal to the difference between the amount you receive for your shares (or are deemed to have received in the case of exchanges) and your adjusted tax basis in the shares, which is generally the amount you paid (or are deemed to have paid in the case of exchanges) for them. Any such capital gain or loss generally will be long-term capital gain or loss if you have held your Fund shares for more than one year at the time of sale or exchange. In certain circumstances, capital losses may be converted from short-term to long-term; in other circumstances, capital losses may be disallowed under the “wash sale” rules. |
■ | For sales, redemptions and exchanges of shares that were acquired in a non-qualified account after 2011, the Fund generally is required to report to shareholders and the Internal Revenue Service (IRS) cost basis information with respect to those shares. The Fund uses average cost basis as its default method of calculating cost basis. For more information regarding average cost basis reporting, other available cost basis methods, and selecting or changing to a different cost basis method, please see the SAI, columbiathreadneedleus.com, or contact the Fund at 800.345.6611. If you hold Fund shares through a financial intermediary (e.g., a brokerage firm), you should contact your financial intermediary to learn about its cost basis reporting default method and the reporting elections available to your account. |
■ | The Fund is required by federal law to withhold tax on any taxable or tax-exempt distributions and redemption proceeds paid to you (including amounts paid to you in securities and amounts deemed to be paid to you upon an exchange of shares) if: you have not provided a correct TIN or have not certified to the Fund that withholding does not apply, the IRS has notified us that the TIN listed on your account is incorrect according to its records, or the IRS informs the Fund that you are otherwise subject to backup withholding. |
62 | Prospectus 2023 |
Prospectus 2023 | 63 |
Net asset value, beginning of period |
Net investment income (loss) |
Net realized and unrealized gain (loss) |
Total from investment operations |
Distributions from net investment income |
Distributions from net realized gains |
Total distributions to shareholders | |
Class A | |||||||
Year Ended 12/31/2022 | $16.29 | 0.18 | (4.29) | (4.11) | (0.18) | (0.47) | (0.65) |
Year Ended 12/31/2021 | $12.30 | 0.09 | 4.91 | 5.00 | (0.17) | (0.84) | (1.01) |
Year Ended 12/31/2020 | $13.77 | 0.13 | (0.71) | (0.58) | (0.16) | (0.73) | (0.89) |
Year Ended 12/31/2019 | $12.07 | 0.21 | 3.11 | 3.32 | (0.21) | (1.41) | (1.62) |
Year Ended 12/31/2018 | $14.02 | 0.18 | (1.17) | (0.99) | (0.19) | (0.77) | (0.96) |
Advisor Class | |||||||
Year Ended 12/31/2022 | $16.76 | 0.22 | (4.42) | (4.20) | (0.21) | (0.47) | (0.68) |
Year Ended 12/31/2021 | $12.63 | 0.12 | 5.06 | 5.18 | (0.21) | (0.84) | (1.05) |
Year Ended 12/31/2020 | $14.13 | 0.17 | (0.75) | (0.58) | (0.19) | (0.73) | (0.92) |
Year Ended 12/31/2019 | $12.34 | 0.26 | 3.19 | 3.45 | (0.25) | (1.41) | (1.66) |
Year Ended 12/31/2018 | $14.32 | 0.23 | (1.21) | (0.98) | (0.23) | (0.77) | (1.00) |
Class C | |||||||
Year Ended 12/31/2022 | $16.29 | 0.07 | (4.27) | (4.20) | (0.08) | (0.47) | (0.55) |
Year Ended 12/31/2021 | $12.30 | (0.02) | 4.91 | 4.89 | (0.06) | (0.84) | (0.90) |
Year Ended 12/31/2020 | $13.76 | 0.04 | (0.70) | (0.66) | (0.07) | (0.73) | (0.80) |
Year Ended 12/31/2019 | $12.06 | 0.10 | 3.12 | 3.22 | (0.11) | (1.41) | (1.52) |
Year Ended 12/31/2018 | $14.02 | 0.06 | (1.16) | (1.10) | (0.09) | (0.77) | (0.86) |
Institutional Class | |||||||
Year Ended 12/31/2022 | $16.33 | 0.22 | (4.31) | (4.09) | (0.21) | (0.47) | (0.68) |
Year Ended 12/31/2021 | $12.33 | 0.12 | 4.93 | 5.05 | (0.21) | (0.84) | (1.05) |
Year Ended 12/31/2020 | $13.81 | 0.17 | (0.73) | (0.56) | (0.19) | (0.73) | (0.92) |
Year Ended 12/31/2019 | $12.10 | 0.25 | 3.12 | 3.37 | (0.25) | (1.41) | (1.66) |
Year Ended 12/31/2018 | $14.05 | 0.22 | (1.17) | (0.95) | (0.23) | (0.77) | (1.00) |
Institutional 2 Class | |||||||
Year Ended 12/31/2022 | $16.25 | 0.23 | (4.28) | (4.05) | (0.23) | (0.47) | (0.70) |
Year Ended 12/31/2021 | $12.28 | 0.14 | 4.89 | 5.03 | (0.22) | (0.84) | (1.06) |
Year Ended 12/31/2020 | $13.75 | 0.17 | (0.70) | (0.53) | (0.21) | (0.73) | (0.94) |
Year Ended 12/31/2019 | $12.06 | 0.22 | 3.15 | 3.37 | (0.27) | (1.41) | (1.68) |
Year Ended 12/31/2018 | $14.01 | 0.24 | (1.18) | (0.94) | (0.24) | (0.77) | (1.01) |
Institutional 3 Class | |||||||
Year Ended 12/31/2022 | $16.49 | 0.24 | (4.34) | (4.10) | (0.24) | (0.47) | (0.71) |
Year Ended 12/31/2021 | $12.44 | 0.16 | 4.96 | 5.12 | (0.23) | (0.84) | (1.07) |
Year Ended 12/31/2020 | $13.92 | 0.19 | (0.72) | (0.53) | (0.22) | (0.73) | (0.95) |
Year Ended 12/31/2019 | $12.19 | 0.26 | 3.16 | 3.42 | (0.28) | (1.41) | (1.69) |
Year Ended 12/31/2018 | $14.15 | 0.25 | (1.19) | (0.94) | (0.25) | (0.77) | (1.02) |
64 | Prospectus 2023 |
Net asset value, end of period |
Total return |
Total gross expense ratio to average net assets(a) |
Total net expense ratio to average net assets(a), (b) |
Net investment income (loss) ratio to average net assets |
Portfolio turnover |
Net assets, end of period (000's) | |
Class A | |||||||
Year Ended 12/31/2022 | $11.53 | (25.33%) | 1.27% (c) | 1.25% (c), (d) | 1.36% | 28% | $47,507 |
Year Ended 12/31/2021 | $16.29 | 41.74% | 1.26% | 1.26% (d) | 0.63% | 5% | $73,177 |
Year Ended 12/31/2020 | $12.30 | (3.70%) | 1.28% | 1.27% (d) | 1.07% | 32% | $55,651 |
Year Ended 12/31/2019 | $13.77 | 28.04% | 1.29% | 1.28% (d) | 1.47% | 20% | $73,522 |
Year Ended 12/31/2018 | $12.07 | (7.48%) | 1.29% | 1.29% (d) | 1.35% | 18% | $63,934 |
Advisor Class | |||||||
Year Ended 12/31/2022 | $11.88 | (25.15%) | 1.02% (c) | 1.00% (c), (d) | 1.61% | 28% | $1,420 |
Year Ended 12/31/2021 | $16.76 | 42.09% | 1.01% | 1.01% (d) | 0.85% | 5% | $2,174 |
Year Ended 12/31/2020 | $12.63 | (3.56%) | 1.03% | 1.02% (d) | 1.34% | 32% | $2,148 |
Year Ended 12/31/2019 | $14.13 | 28.47% | 1.04% | 1.04% (d) | 1.81% | 20% | $2,005 |
Year Ended 12/31/2018 | $12.34 | (7.30%) | 1.03% | 1.03% (d) | 1.69% | 18% | $480 |
Class C | |||||||
Year Ended 12/31/2022 | $11.54 | (25.86%) | 2.01% (c) | 2.00% (c), (d) | 0.53% | 28% | $1,310 |
Year Ended 12/31/2021 | $16.29 | 40.70% | 2.01% | 2.01% (d) | (0.13%) | 5% | $2,722 |
Year Ended 12/31/2020 | $12.30 | (4.44%) | 2.03% | 2.02% (d) | 0.29% | 32% | $2,807 |
Year Ended 12/31/2019 | $13.76 | 27.11% | 2.03% | 2.03% (d) | 0.68% | 20% | $4,623 |
Year Ended 12/31/2018 | $12.06 | (8.24%) | 2.04% | 2.04% (d) | 0.47% | 18% | $4,795 |
Institutional Class | |||||||
Year Ended 12/31/2022 | $11.56 | (25.13%) | 1.02% (c) | 1.00% (c), (d) | 1.63% | 28% | $82,320 |
Year Ended 12/31/2021 | $16.33 | 42.06% | 1.01% | 1.01% (d) | 0.88% | 5% | $120,982 |
Year Ended 12/31/2020 | $12.33 | (3.49%) | 1.04% | 1.02% (d) | 1.36% | 32% | $157,929 |
Year Ended 12/31/2019 | $13.81 | 28.38% | 1.03% | 1.03% (d) | 1.73% | 20% | $162,706 |
Year Ended 12/31/2018 | $12.10 | (7.23%) | 1.04% | 1.04% (d) | 1.63% | 18% | $136,079 |
Institutional 2 Class | |||||||
Year Ended 12/31/2022 | $11.50 | (25.05%) | 0.90% (c) | 0.90% (c) | 1.73% | 28% | $938 |
Year Ended 12/31/2021 | $16.25 | 42.15% | 0.90% | 0.89% | 1.02% | 5% | $1,321 |
Year Ended 12/31/2020 | $12.28 | (3.30%) | 0.91% | 0.90% | 1.41% | 32% | $920 |
Year Ended 12/31/2019 | $13.75 | 28.49% | 0.89% | 0.89% | 1.57% | 20% | $1,370 |
Year Ended 12/31/2018 | $12.06 | (7.12%) | 0.89% | 0.89% | 1.81% | 18% | $7,700 |
Institutional 3 Class | |||||||
Year Ended 12/31/2022 | $11.68 | (25.00%) | 0.84% (c) | 0.84% (c) | 1.81% | 28% | $96,459 |
Year Ended 12/31/2021 | $16.49 | 42.33% | 0.84% | 0.83% | 1.06% | 5% | $134,201 |
Year Ended 12/31/2020 | $12.44 | (3.27%) | 0.85% | 0.84% | 1.55% | 32% | $48,451 |
Year Ended 12/31/2019 | $13.92 | 28.58% | 0.84% | 0.84% | 1.84% | 20% | $44,827 |
Year Ended 12/31/2018 | $12.19 | (7.07%) | 0.85% | 0.85% | 1.88% | 18% | $59,640 |
Prospectus 2023 | 65 |
Net asset value, beginning of period |
Net investment income (loss) |
Net realized and unrealized gain (loss) |
Total from investment operations |
Distributions from net investment income |
Distributions from net realized gains |
Total distributions to shareholders | |
Class R | |||||||
Year Ended 12/31/2022 | $16.27 | 0.14 | (4.27) | (4.13) | (0.15) | (0.47) | (0.62) |
Year Ended 12/31/2021 | $12.29 | 0.06 | 4.90 | 4.96 | (0.14) | (0.84) | (0.98) |
Year Ended 12/31/2020 | $13.75 | 0.10 | (0.70) | (0.60) | (0.13) | (0.73) | (0.86) |
Year Ended 12/31/2019 | $12.05 | 0.16 | 3.13 | 3.29 | (0.18) | (1.41) | (1.59) |
Year Ended 12/31/2018 | $14.01 | 0.15 | (1.18) | (1.03) | (0.16) | (0.77) | (0.93) |
Notes to Financial Highlights | |
(a) | In addition to the fees and expenses that the Fund bears directly, the Fund indirectly bears a pro rata share of the fees and expenses of any other funds in which it invests. Such indirect expenses are not included in the Fund's reported expense ratios. |
(b) | Total net expenses include the impact of certain fee waivers/expense reimbursements made by the Investment Manager and certain of its affiliates, if applicable. |
(c) | Ratios include interfund lending expense which is less than 0.01%. |
(d) | The benefits derived from expense reductions had an impact of less than 0.01%. |
66 | Prospectus 2023 |
Net asset value, end of period |
Total return |
Total gross expense ratio to average net assets(a) |
Total net expense ratio to average net assets(a), (b) |
Net investment income (loss) ratio to average net assets |
Portfolio turnover |
Net assets, end of period (000's) | |
Class R | |||||||
Year Ended 12/31/2022 | $11.52 | (25.50%) | 1.52% (c) | 1.50% (c), (d) | 1.10% | 28% | $1,892 |
Year Ended 12/31/2021 | $16.27 | 41.34% | 1.51% | 1.51% (d) | 0.41% | 5% | $3,253 |
Year Ended 12/31/2020 | $12.29 | (3.90%) | 1.53% | 1.52% (d) | 0.78% | 32% | $2,282 |
Year Ended 12/31/2019 | $13.75 | 27.77% | 1.53% | 1.53% (d) | 1.10% | 20% | $3,726 |
Year Ended 12/31/2018 | $12.05 | (7.78%) | 1.54% | 1.54% (d) | 1.12% | 18% | $5,038 |
Prospectus 2023 | 67 |
■ | Employer-sponsored retirement plans (e.g., 401(k) plans, 457 plans, employer-sponsored 403(b) plans, profit sharing and money purchase pension plans and defined benefit plans). For purposes of this provision, employer-sponsored retirement plans do not include SEP IRAs, Simple IRAs or SAR-SEPs. |
■ | Shares purchased through reinvestment of capital gains distributions and dividend reinvestment when purchasing shares of the same fund (but not any other fund within the Columbia Fund family). |
■ | Shares exchanged from Class C shares of the same fund in the month of or following the 7-year anniversary of the purchase date. To the extent that the Fund’s Class C Shares – Conversion to Class A Shares policy (stated outside this Appendix A) provides for a waiver with respect to exchanges of Class C shares or the conversion of Class C shares following a shorter holding period, that waiver will apply. |
■ | Employees and registered representatives of Ameriprise Financial Services or its affiliates and their immediate family members. |
■ | Shares purchased by or through qualified accounts (including IRAs, Coverdell Education Savings Accounts, 401(k)s, 403(b) TSCAs subject to ERISA and defined benefit plans) that are held by a covered family member, defined as an Ameriprise financial advisor and/or the advisor’s spouse, advisor’s lineal ascendant (mother, father, grandmother, grandfather, great grandmother, great grandfather), advisor’s lineal descendant (son, step-son, daughter, step-daughter, grandson, granddaughter, great grandson, great granddaughter) or any spouse of a covered family member who is a lineal descendant. |
■ | Shares purchased from the proceeds of redemptions from another fund in the Columbia Fund family, provided (1) the repurchase occurs within 90 days following the redemption, (2) the redemption and purchase occur in the same account, and (3) redeemed shares were subject to a front-end or deferred sales load (i.e. Rights of Reinstatement). |
A-1 | Prospectus 2023 |
■ | Shares purchased through reinvestment of capital gains distributions and dividend reinvestment when purchasing shares of the same Columbia Fund. |
■ | Share purchases by employees and registered representatives of Baird or its affiliates and their family members as designated by Baird. |
■ | Shares purchased with the proceeds of redemptions from another Columbia Fund, provided (1) the repurchase occurs within 90 days following the redemption, (2) the redemption and purchase occur in the same accounts, and (3) redeemed shares were subject to a front-end or deferred sales charge (known as rights of reinstatement). |
■ | A shareholder in the Fund’s Class C shares will have their shares converted at net asset value to Class A shares of the same Columbia Fund if the shares are no longer subject to CDSC and the conversion is in line with the policies and procedures of Baird. |
■ | Employer-sponsored retirement plans or charitable accounts in a transactional brokerage account at Baird, including 401(k) plans, 457 plans, employer-sponsored 403(b) plans, profit sharing and money purchase pension plans and defined benefit plans. For purposes of this provision, employer-sponsored retirement plans do not include SEP IRAs, Simple IRAs or SAR-SEPs. |
■ | Shares sold due to death or disability of the shareholder. |
■ | Shares sold as part of a systematic withdrawal plan as described in this prospectus. |
■ | Shares purchased due to returns of excess contributions from an IRA account. |
■ | Shares sold as part of a required minimum distribution for IRA and retirement accounts due to the shareholder reaching the qualified age based on applicable IRS regulations. |
■ | Shares sold to pay Baird fees but only if the transaction is initiated by Baird. |
■ | Shares acquired through a right of reinstatement. |
■ | Breakpoints as described in this prospectus. |
■ | Rights of accumulations which entitle shareholders to breakpoint discounts will be automatically calculated based on the aggregated holding of Columbia Fund assets held by accounts within the purchaser’s household at Baird. Eligible Columbia Fund assets not held at Baird may be included in the rights of accumulations calculation only if the shareholder notifies his or her financial advisor about such assets. |
■ | Letters of Intent (LOI) allow for breakpoint discounts based on anticipated purchases of Columbia Funds through Baird, over a 13-month period of time. |
Prospectus 2023 | A-2 |
■ | Breakpoint pricing, otherwise known as volume pricing, at dollar thresholds as described in this prospectus. |
■ | The applicable sales charge on a purchase of Class A shares is determined by taking into account all share classes (except certain money market funds and any assets held in group retirement plans) of Columbia Funds and Future Scholars Program held by the shareholder or in an account grouped by Edward Jones with other accounts for the purpose of providing certain pricing considerations ("pricing groups"). If grouping assets as a shareholder, this includes all share classes held on the Edward Jones platform and/or held on another platform. The inclusion of eligible Columbia Fund assets in the ROA calculation is dependent on the shareholder notifying Edward Jones of such assets at the time of calculation. Money market funds are included only if such shares were sold with a sales charge at the time of purchase or acquired in exchange for shares purchased with a sales charge. |
■ | The employer maintaining a SEP IRA plan and/or SIMPLE IRA plan may elect to establish or change ROA for the IRA accounts associated with the plan to a plan-level grouping as opposed to including all share classes at a shareholder or pricing group level. |
■ | ROA is determined by calculating the higher of cost minus redemptions or market value (current shares x NAV). |
■ | Through a LOI, shareholders can receive the sales charge and breakpoint discounts for purchases shareholders intend to make over a 13-month period from the date Edward Jones receives the LOI. The LOI is determined by calculating the higher of cost or market value of qualifying holdings at LOI initiation in combination with the value that the shareholder intends to buy over a 13-month period to calculate the front-end sales charge and any breakpoint discounts. Each purchase the shareholder makes during that 13-month period will receive the sales charge and breakpoint discount that applies to the total amount. The inclusion of eligible Columbia Fund assets in the LOI calculation is dependent on the shareholder notifying Edward Jones of such assets at the time of calculation. Purchases made before the LOI is received by Edward Jones are not adjusted under the LOI and will not reduce the sales charge previously paid. Sales charges will be adjusted if LOI is not met. |
■ | If the employer maintaining a SEP IRA plan and/or SIMPLE IRA plan has elected to establish or change ROA for the IRA accounts associated with the plan to a plan-level grouping, LOIs will also be at the plan-level and may only be established by the employer. |
A-3 | Prospectus 2023 |
■ | Associates of Edward Jones and its affiliates and their family members who are in the same pricing group (as determined by Edward Jones under its policies and procedures) as the associate. This waiver will continue for the remainder of the associate's life if the associate retires from Edward Jones in good-standing and remains in good standing pursuant to Edward Jones' policies and procedures. |
■ | Shares purchased in an Edward Jones fee-based program. |
■ | Shares purchased through reinvestment of capital gains distributions and dividend reinvestment. |
■ | Shares purchased from the proceeds of redeemed shares of Columbia Funds so long as the following conditions are met: 1) the proceeds are from the sale of shares within 60 days of the purchase, and 2) the sale and purchase are made in the same share class and the same account or the purchase is made in an individual retirement account with proceeds from liquidations in a non-retirement account. |
■ | Shares exchanged into Class A shares from another share class so long as the exchange is into the same fund and was initiated at the discretion of Edward Jones. Edward Jones is responsible for any remaining CDSC due to the fund company, if applicable. Any future purchases are subject to the applicable sales charge as disclosed in this prospectus. |
■ | Exchanges from Class C shares to Class A shares of the same fund, generally, in the 84th month following the anniversary of the purchase date or earlier at the discretion of Edward Jones. |
■ | The death or disability of the shareholder. |
■ | Systematic withdrawals with up to 10% per year of the account value. |
■ | Return of excess contributions from an Individual Retirement Account (IRA). |
■ | Shares sold as part of a required minimum distribution for IRA and retirement accounts if the redemption is taken in or after the year the shareholder reaches qualified age based on applicable IRS regulations. |
■ | Shares sold to pay Edward Jones fees or costs in such cases where the transaction is initiated by Edward Jones. |
■ | Shares exchanged in an Edward Jones fee-based program. |
■ | Shares acquired through NAV reinstatement. |
■ | Shares redeemed at the discretion of Edward Jones for Minimum Balances, as described below. |
■ | Initial purchase minimum: $250 |
■ | Subsequent purchase minimum: none |
■ | Edward Jones has the right to redeem at its discretion Fund holdings with a balance of $250 or less. The following are examples of accounts that are not included in this policy: |
■ | A fee-based account held on an Edward Jones platform. |
■ | A 529 account held on an Edward Jones platform. |
■ | An account with an active systematic investment plan or LOI. |
Prospectus 2023 | A-4 |
■ | At any time it deems necessary, Edward Jones has the authority to exchange at NAV a shareholder's holdings in the Fund to Class A shares. |
■ | Shares purchased through reinvestment of capital gains distributions and dividend reinvestment when purchasing shares of the same fund (but not any other Columbia Fund). |
■ | Shares purchased by employees and registered representatives of Janney or its affiliates and their family members as designated by Janney. |
■ | Shares purchased from the proceeds of redemptions from another Columbia Fund, provided (1) the repurchase occurs within ninety (90) days following the redemption, (2) the redemption and purchase occur in the same account, and (3) redeemed shares were subject to a front-end or deferred sales load (i.e., right of reinstatement). |
■ | Employer-sponsored retirement plans (e.g., 401(k) plans, 457 plans, employer-sponsored 403(b) plans, profit sharing and money purchase pension plans and defined benefit plans). For purposes of this provision, employer-sponsored retirement plans do not include SEP IRAs, Simple IRAs, SAR-SEPs or Keogh plans. |
■ | Shares acquired through a right of reinstatement. |
■ | Class C shares that are no longer subject to a CDSC and are converted to Class A shares of the same fund pursuant to Janney’s policies and procedures. |
■ | Shares sold upon the death or disability of the shareholder. |
■ | Shares sold as part of a systematic withdrawal plan as described in this prospectus. |
■ | Shares purchased in connection with a return of excess contributions from an IRA account. |
■ | Shares sold as part of a required minimum distribution for IRA and retirement accounts if the redemption is taken in or after the year the shareholder reaches qualified age based on applicable IRS regulations. |
■ | Shares sold to pay Janney fees but only if the transaction is initiated by Janney. |
■ | Shares acquired through a right of reinstatement. |
■ | Shares exchanged into the same share class of a different fund. |
■ | Breakpoints as described in this prospectus. |
■ | Rights of accumulation (“ROA”), which entitle shareholders to breakpoint discounts, will be automatically calculated based on the aggregated holding of Columbia Fund assets held by accounts within the purchaser’s household at Janney. Eligible Columbia Fund assets not held at Janney may be included in the ROA calculation only if the shareholder notifies his or her financial advisor about such assets. |
■ | Letters of intent which allow for breakpoint discounts based on anticipated purchases within the Columbia Funds, over a 13-month time period. Eligible Columbia Fund assets not held at Janney may be included in the calculation of letters of intent only if the shareholder notifies his or her financial advisor about such assets. |
A-5 | Prospectus 2023 |
■ | Breakpoints as described in this prospectus. |
■ | Rights of Accumulation (ROA) which entitle shareholders to breakpoint discounts as described in this prospectus will be automatically calculated based on the aggregated holding of Columbia Fund assets held by accounts (including 529 program holdings, where applicable) within the purchaser’s household at Merrill Lynch. Eligible Columbia Fund assets not held at Merrill Lynch may be included in the ROA calculation only if the shareholder notifies his or her financial advisor about such assets. |
■ | Letters of Intent (LOI) which allow for breakpoint discounts based on anticipated purchases of Columbia Funds, through Merrill Lynch, over a 13-month period of time (if applicable). |
■ | Employer-sponsored retirement, deferred compensation and employee benefit plans (including health savings accounts) and trusts used to fund those plans, provided that the shares are not held in a commission-based brokerage account and shares are held for the benefit of the plan. |
■ | Shares purchased by a 529 Plan (does not include 529 Plan units or 529-specific share classes or equivalents). |
■ | Shares purchased through a Merrill Lynch affiliated investment advisory program. |
■ | Shares exchanged due to the holdings moving from a Merrill Lynch affiliated investment advisory program to a Merrill Lynch brokerage (non-advisory) account pursuant to Merrill Lynch’s policies relating to sales load discounts and waivers. |
■ | Shares purchased by third party investment advisors on behalf of their advisory clients through Merrill Lynch’s platform. |
■ | Shares of funds purchased through the Merrill Edge Self-Directed platform (if applicable). |
■ | Shares purchased through reinvestment of capital gains distributions and dividend reinvestment when purchasing shares of the same fund (but not any other Columbia Fund). |
■ | Shares exchanged from Class C (i.e., level-load) shares of the same fund pursuant to Merrill Lynch’s policies relating to sales load discounts and waivers. |
■ | Employees and registered representatives of Merrill Lynch or its affiliates and their family members. |
■ | Directors or Trustees of the Fund, and employees of the Fund’s investment adviser or any of its affiliates, as described in this prospectus. |
■ | Eligible shares purchased from the proceeds of redemptions from another Columbia Fund, provided (1) the repurchase occurs within 90 days following the redemption, (2) the redemption and purchase occur in the same account, and (3) redeemed shares were subject to a front-end or deferred sales load (known as Rights of Reinstatement). Automated transactions (i.e. systematic purchases and withdrawals) and purchases made after shares are automatically sold to pay Merrill Lynch’s account maintenance fees are not eligible for reinstatement. |
■ | Death or disability of the shareholder. |
Prospectus 2023 | A-6 |
■ | Shares sold as part of a systematic withdrawal plan as described in this prospectus. |
■ | Return of excess contributions from an IRA Account. |
■ | Shares sold as part of a required minimum distribution for IRA and retirement accounts pursuant to the Internal Revenue Code. |
■ | Shares sold to pay Merrill Lynch fees but only if the transaction is initiated by Merrill Lynch. |
■ | Shares acquired through a right of reinstatement. |
■ | Shares held in retirement brokerage accounts, that are exchanged for a lower cost share class due to transfer to certain fee based accounts or platforms (applicable to Class A and Class C shares only). |
■ | Shares received through an exchange due to the holdings moving from a Merrill Lynch affiliated investment advisory program to a Merrill Lynch brokerage (non-advisory) account pursuant to Merrill Lynch’s policies relating to sales load discounts and waivers. |
■ | Employer-sponsored retirement plans (e.g., 401(k) plans, 457 plans, employer-sponsored 403(b) plans, profit sharing and money purchase pension plans and defined benefit plans). For purposes of this provision, employer-sponsored retirement plans do not include SEP IRAs, Simple IRAs, SAR-SEPs or Keogh plans. |
■ | Morgan Stanley employee and employee-related accounts according to Morgan Stanley’s account linking rules. |
■ | Shares purchased through reinvestment of dividends and capital gains distributions when purchasing shares of the same fund. |
■ | Shares purchased through a Morgan Stanley self-directed brokerage account. |
■ | Class C (i.e., level-load) shares that are no longer subject to a CDSC and are exchanged for Class A shares of the same fund pursuant to Morgan Stanley Wealth Management’s share class exchange program. |
■ | Shares purchased from the proceeds of redemptions from another Columbia Fund, provided (i) the repurchase occurs within 90 days following the redemption, (ii) the redemption and purchase occur in the same account, and (iii) redeemed shares were subject to a front-end or deferred sales charge. |
A-7 | Prospectus 2023 |
■ | Shares purchased in an investment advisory program. |
■ | Shares purchased within the Columbia Funds through a systematic reinvestment of capital gains and dividend distributions. |
■ | Employees and registered representatives of Raymond James or its affiliates and their family members as designated by Raymond James. |
■ | Shares purchased from the proceeds of redemptions within the Columbia Funds, provided (1) the repurchase occurs within 90 days following the redemption, (2) the redemption and purchase occur in the same account, and (3) redeemed shares were subject to a front-end or deferred sales load (known as Rights of Reinstatement). |
■ | A shareholder in the Fund’s Class C shares will have their shares converted at net asset value to Class A shares (or the appropriate share class) of the Fund if the shares are no longer subject to a CDSC and the conversion is in line with the policies and procedures of Raymond James. |
■ | Death or disability of the shareholder. |
■ | Shares sold as part of a systematic withdrawal plan as described in this prospectus. |
■ | Return of excess contributions from an IRA Account. |
■ | Shares sold as part of a required minimum distribution for IRA and retirement accounts due to the shareholder reaching the qualified age based on applicable IRS regulations as described in this prospectus. |
■ | Shares sold to pay Raymond James fees but only if the transaction is initiated by Raymond James. |
■ | Shares acquired through a right of reinstatement. |
■ | Breakpoints as described in this prospectus. |
■ | Rights of accumulation which entitle shareholders to breakpoint discounts will be automatically calculated based on the aggregated holding of Columbia Fund assets held by accounts within the purchaser’s household at Raymond James. Eligible Columbia Fund assets not held at Raymond James may be included in the calculation of rights of accumulation only if the shareholder notifies his or her financial advisor about such assets. |
■ | Letters of intent which allow for breakpoint discounts based on anticipated purchases within the Columbia Funds, over a 13-month time period. Eligible Columbia Fund assets not held at Raymond James may be included in the calculation of letters of intent only if the shareholder notifies his or her financial advisor about such assets. |
Prospectus 2023 | A-8 |
■ | For employer-sponsored retirement plans held through a commissionable brokerage account, Class A shares are available at NAV (i.e., without a sales charge). For this purpose, employer-sponsored retirement plans include, but are not limited to, 401(k) plans, 457 plans, employer-sponsored 403(b) plans, profit sharing and money purchase pension plans and defined benefit plans. For purposes of this provision, employer-sponsored retirement plans do not include SEP IRAs, Simple IRAs, SAR-SEPs or Keogh plans. |
A-9 | Prospectus 2023 |
* |
The Fund’s Board of Trustees has approved a Plan of Liquidation and Termination pursuant to which the Fund is expected to be liquidated on or about May 5, 2023. Please refer to the Fund’s prospectus for further details regarding the liquidation. |
** | The Fund’s Board of Trustees has approved a Plan of Liquidation and Termination pursuant to which the Fund is expected to be liquidated on or about November 7, 2023. Please refer to the Fund’s prospectus for further details regarding the liquidation. |
*** | The Fund’s Board of Trustees has approved a Plan of Liquidation and Termination pursuant to which the Fund is expected to be liquidated on or about August 4, 2023. Please refer to the Fund’s prospectus for further details regarding the liquidation. |
§ | This share class is not currently available for purchase. |
Trust, Fund Name and Fiscal Year End: | Shareholder Report: |
January 31 | |
Columbia Funds Series Trust Columbia Capital Allocation Moderate Aggressive Portfolio Columbia Capital Allocation Moderate Conservative Portfolio |
Annual Report |
Columbia Funds Series Trust II Columbia Capital Allocation Aggressive Portfolio Columbia Capital Allocation Conservative Portfolio Columbia Capital Allocation Moderate Portfolio Columbia Income Builder Fund |
Annual Report |
February 28/29 | |
Columbia Funds Series Trust Columbia Convertible Securities Fund Columbia Large Cap Enhanced Core Fund Columbia Large Cap Growth Opportunity Fund Columbia Large Cap Index Fund Columbia Mid Cap Index Fund Columbia Overseas Value Fund Columbia Select Large Cap Equity Fund Columbia Select Mid Cap Value Fund Columbia Small Cap Index Fund Columbia Small Cap Value Fund II |
Annual Report |
Columbia Funds Series Trust II Columbia Global Value Fund Columbia Overseas Core Fund |
Annual Report |
March 31 | |
Columbia Funds Series Trust Columbia Short Term Bond Fund |
Annual Report |
Columbia Funds Series Trust I Columbia Adaptive Retirement 2020 Fund Columbia Adaptive Retirement 2025 Fund Columbia Adaptive Retirement 2030 Fund Columbia Adaptive Retirement 2035 Fund Columbia Adaptive Retirement 2040 Fund Columbia Adaptive Retirement 2045 Fund Columbia Adaptive Retirement 2050 Fund Columbia Adaptive Retirement 2055 Fund Columbia Adaptive Retirement 2060 Fund Columbia Select Large Cap Growth Fund Columbia Solutions Aggressive Portfolio Columbia Solutions Conservative Portfolio Multi-Manager Growth Strategies Fund |
Annual Report |
Trust, Fund Name and Fiscal Year End: | Shareholder Report: |
April 30 | |
Columbia Funds Series Trust Columbia California Intermediate Municipal Bond Fund Columbia North Carolina Intermediate Municipal Bond Fund Columbia Short Duration Municipal Bond Fund Columbia South Carolina Intermediate Municipal Bond Fund Columbia Virginia Intermediate Municipal Bond Fund |
Annual Report |
Columbia Funds Series Trust I Columbia Bond Fund Columbia Corporate Income Fund Columbia Small Cap Value Fund I Columbia Total Return Bond Fund Columbia U.S. Treasury Index Fund Multi-Manager Directional Alternative Strategies Fund |
Annual Report |
May 31 | |
Columbia Funds Series Trust I Columbia Adaptive Risk Allocation Fund Columbia Dividend Income Fund Columbia High Yield Municipal Fund Columbia Multi Strategy Alternatives Fund |
Annual Report |
Columbia Funds Series Trust II Columbia Commodity Strategy Fund Columbia Dividend Opportunity Fund Columbia Flexible Capital Income Fund Columbia High Yield Bond Fund Columbia Large Cap Value Fund Columbia Mortgage Opportunities Fund Columbia Quality Income Fund Columbia Select Large Cap Value Fund Columbia Select Small Cap Value Fund Columbia Seligman Technology and Information Fund Multi-Manager Value Strategies Fund |
Annual Report |
July 31 | |
Columbia Funds Series Trust I Columbia Large Cap Growth Fund Columbia Oregon Intermediate Municipal Bond Fund Columbia Tax-Exempt Fund Columbia Ultra Short Term Bond Fund Columbia U.S. Social Bond Fund |
Annual Report |
Columbia Funds Series Trust II Columbia Disciplined Core Fund Columbia Disciplined Growth Fund Columbia Disciplined Value Fund Columbia Floating Rate Fund Columbia Global Opportunities Fund Columbia Government Money Market Fund Columbia Income Opportunities Fund Columbia Limited Duration Credit Fund Columbia Minnesota Tax-Exempt Fund Columbia Strategic Municipal Fund |
Annual Report |
Trust, Fund Name and Fiscal Year End: | Shareholder Report: |
August 31 | |
Columbia Funds Series Trust I Columbia Balanced Fund Columbia Contrarian Core Fund Columbia Emerging Markets Fund Columbia Global Technology Growth Fund Columbia Greater China Fund Columbia International Dividend Income Fund Columbia Select Mid Cap Growth Fund Columbia Small Cap Growth Fund Columbia Strategic Income Fund Multi-Manager Alternative Strategies Fund Multi-Manager International Equity Strategies Fund Multi-Manager Small Cap Equity Strategies Fund Multi-Manager Total Return Bond Fund Multisector Bond SMA Completion Portfolio Overseas SMA Completion Portfolio |
Annual Report |
Columbia Funds Series Trust II Columbia Emerging Markets Bond Fund |
Annual Report |
October 31 | |
Columbia Funds Series Trust I Columbia Connecticut Intermediate Municipal Bond Fund Columbia Intermediate Duration Municipal Bond Fund Columbia Massachusetts Intermediate Municipal Bond Fund Columbia New York Intermediate Municipal Bond Fund Columbia Strategic California Municipal Income Fund Columbia Strategic New York Municipal Income Fund |
Annual Report |
Columbia Funds Series Trust II Columbia Select Global Equity Fund Columbia Seligman Global Technology Fund |
Annual Report |
December 31 | |
Columbia Funds Series Trust I Columbia Real Estate Equity Fund |
Annual Report |
2 | |
8 | |
12 | |
26 | |
26 | |
63 | |
99 | |
100 | |
100 | |
102 | |
102 | |
141 | |
168 | |
178 | |
178 | |
181 | |
187 | |
188 | |
192 | |
197 | |
197 | |
198 | |
201 | |
201 | |
221 | |
231 | |
231 | |
234 | |
239 | |
242 | |
249 | |
249 | |
249 | |
250 | |
258 | |
259 | |
262 | |
262 | |
263 | |
265 | |
265 | |
266 | |
268 | |
288 | |
372 | |
A-1 | |
B-1 | |
C-1 | |
S-1 |
Statement of Additional Information – April 27, 2023 | 1 |
■ | the organization of each Trust (of which the Funds are series); |
■ | the Funds’ investments; |
■ | the Funds’ investment adviser, investment subadviser(s) (if any) and other service providers, including roles and relationships of Ameriprise Financial and its affiliates, and conflicts of interest; |
■ | the governance of the Funds; |
■ | the Funds’ brokerage practices; |
■ | the share classes offered by the Funds; |
■ | the purchase, redemption and pricing of Fund shares; and |
■ | the application of U.S. federal income tax laws. |
1933 Act | Securities Act of 1933, as amended |
1934 Act | Securities Exchange Act of 1934, as amended |
1940 Act | Investment Company Act of 1940, as amended |
Adaptive Retirement Funds | The Funds within the Columbia Funds Complex that include “Adaptive Retirement” within the fund name. |
Allspring | Allspring Global Investments, LLC |
AlphaSimplex | AlphaSimplex Group, LLC |
Ameriprise Financial | Ameriprise Financial, Inc. |
AQR | AQR Capital Management, LLC |
Arrowstreet | Arrowstreet Capital, Limited Partnership |
Baillie Gifford | Baillie Gifford Overseas Limited |
Bank of America | Bank of America Corporation |
Board | A Trust’s Board of Trustees |
Statement of Additional Information – April 27, 2023 | 2 |
Boston Partners | Boston Partners Global Investors, Inc. |
Business Day | Any day on which the NYSE is open for business. A business day typically ends at the close of regular trading on the NYSE, usually at 4:00 p.m. Eastern time. If the NYSE is scheduled to close early, the business day will be considered to end as of the time of the NYSE’s scheduled close. The Fund will not treat an intraday unscheduled disruption in NYSE trading or an intraday unscheduled closing as a close of regular trading on the NYSE for these purposes and will price its shares as of the regularly scheduled closing time for that day (typically, 4:00 p.m. Eastern time). Notwithstanding the foregoing, the NAV of Fund shares may be determined at such other time or times (in addition to or in lieu of the time set forth above) as the Fund’s Board may approve or ratify. On holidays and other days when the NYSE is closed, the Fund's NAV is not calculated and the Fund does not accept buy or sell orders. However, the value of the Fund's assets may still be affected on such days to the extent that the Fund holds foreign securities that trade on days that foreign securities markets are open. |
Capital Allocation Portfolios | Collectively, Columbia Capital Allocation Aggressive Portfolio, Columbia Capital Allocation Conservative Portfolio, Columbia Capital Allocation Moderate Aggressive Portfolio, Columbia Capital Allocation Moderate Conservative Portfolio and Columbia Capital Allocation Moderate Portfolio |
Causeway | Causeway Capital Management LLC |
CEA | Commodity Exchange Act |
CFST | Columbia Funds Series Trust |
CFST I | Columbia Funds Series Trust I |
CFST II | Columbia Funds Series Trust II |
CFTC | The United States Commodity Futures Trading Commission |
Code | Internal Revenue Code of 1986, as amended |
Codes of Ethics | The codes of ethics adopted by the Funds, Columbia Management Investment Advisers, LLC (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 Threadneedle Investments | The global brand name of the Columbia and Threadneedle group of companies |
Conestoga | Conestoga Capital Advisors, LLC |
Crabel | Crabel Capital Management, LLC |
Custodian | JPMorgan Chase Bank, N.A. |
DBRS | DBRS Morningstar |
DFA | Dimensional Fund Advisors LP |
Diamond Hill | Diamond Hill Capital Management, Inc. |
Distribution Agreement | The Distribution Agreement between a 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. |
FDIC | Federal Deposit Insurance Corporation |
FHLMC | The Federal Home Loan Mortgage Corporation |
Fitch | Fitch Ratings, Inc. |
FNMA | Federal National Mortgage Association |
Statement of Additional Information – April 27, 2023 | 3 |
The Fund(s) or a Fund | One or more of the open-end management investment companies listed on the front cover of this SAI |
GICS | The Global Industry Classification Standard (GICS®). GICS was developed by and/or is the exclusive property of MSCI, Inc. (MSCI®) and S&P Global Market Intelligence Inc. (S&P Global Market Intelligence). GICS is a service mark of MSCI and S&P Global Market Intelligence and has been licensed for use by the Investment Manager. Neither GICS, MSCI, nor S&P Global Market Intelligence are affiliated with the Funds, the Investment Manager or any Columbia entity. |
GNMA | Government National Mortgage Association |
Hotchkis & Wiley | Hotchkis & Wiley Capital Management, LLC |
Independent Trustees | The Trustees of the Board who are not “interested persons” (as defined in the 1940 Act) of the Funds |
Interested Trustee | A Trustee of the Board who is currently deemed to be an “interested person” (as defined in the 1940 Act) of the Funds |
Investment Manager | Columbia Management Investment Advisers, LLC |
IRS | United States Internal Revenue Service |
Jacobs Levy | Jacobs Levy Equity Management, Inc. |
JPMIM | J.P. Morgan Investment Management Inc. |
JPMorgan | JPMorgan Chase Bank, N.A., the Funds’ custodian |
KBRA | Kroll Bond Rating Agency |
LIBOR | London Inter-bank Offered Rate* |
Loomis Sayles | Loomis, Sayles & Company, L.P. |
Los Angeles Capital | Los Angeles Capital Management LLC |
Management Agreement | The Management Agreements, as amended, if applicable, between a Trust, on behalf of the Funds, and the Investment Manager |
Manulife | Manulife Investment Management (US) LLC |
Moody’s | Moody’s Investors Service, Inc. |
Multi-Manager Strategies Funds | Multi-Manager Alternative Strategies Fund, Multi-Manager Directional Alternative Strategies Fund, Multi-Manager Growth Strategies Fund, Multi-Manager International Equity Strategies Fund, Multi-Manager Small Cap Equity Strategies Fund, Multi-Manager Total Return Bond Strategies Fund and Multi-Manager Value Strategies Fund. Shares of the Multi-Manager Strategies Funds are offered only through certain wrap fee programs sponsored and/or managed by Ameriprise Financial, Inc. or its affiliates. |
NASDAQ | National Association of Securities Dealers Automated Quotations system |
NAV | Net asset value per share of a Fund |
NRSRO | Nationally recognized statistical ratings organization (such as, for example, Moody’s, Fitch or S&P) |
NSCC | National Securities Clearing Corporation |
NYSE | New York Stock Exchange |
PGIM | PGIM, Inc., the asset management arm of Prudential Financial, Inc. |
PGIM Quantitative Solutions | PGIM Quantitative Solutions LLC (formerly, QMA LLC) |
PwC | PricewaterhouseCoopers LLP |
REIT | Real estate investment trust |
REMIC | Real estate mortgage investment conduit |
RIC | A “regulated investment company,” as such term is used in the Code |
S&P | S&P Global Ratings, a division of S&P Global Inc. (“Standard & Poor’s” and “S&P” are trademarks of S&P Global Inc. and have been licensed for use by the Investment Manager. The Columbia Funds are not sponsored, endorsed, sold or promoted by S&P Global Ratings and S&P Global Ratings makes no representation regarding the advisability of investing in the Columbia Funds.) |
Statement of Additional Information – April 27, 2023 | 4 |
SAI | This Statement of Additional Information, as amended and supplemented from time-to-time |
SEC | United States Securities and Exchange Commission |
Shares | Shares of a Fund |
SOFR | Secured Overnight Financing Rate |
Solution Series Funds | Columbia Solutions Aggressive Portfolio, Columbia Solutions Conservative Portfolio, Multisector Bond SMA Completion Portfolio and Overseas SMA Completion Portfolio |
Subadvisory Agreement | The Subadvisory Agreement among a Trust on behalf of the Fund(s), the Investment Manager and a Fund’s investment subadviser(s), as the context may require |
Subsidiary | One or more wholly-owned subsidiaries of a Fund |
TCW | TCW Investment Management Company LLC |
Threadneedle | Threadneedle International Limited |
Transfer Agency Agreement | The Transfer and Dividend Disbursing Agent Agreement between a Trust, on behalf of its Funds, and the Transfer Agent |
Transfer Agent | Columbia Management Investment Services Corp. |
Trustee(s) | One or more members of the Board |
Trusts | CFST, CFST I and CFST II, which are the registered investment companies in the Columbia Funds Complex to which this SAI relates |
Voya | Voya Investment Management Co. LLC |
Water Island | Water Island Capital, LLC |
* | Please see “LIBOR Replacement Risk” in the Information Regarding Risks section for more information about the phaseout of LIBOR and related reference rates. |
Fund Name: | Referred to as: | |
Columbia Adaptive Retirement 2020 Fund | Adaptive Retirement 2020 Fund | |
Columbia Adaptive Retirement 2025 Fund | Adaptive Retirement 2025 Fund | |
Columbia Adaptive Retirement 2030 Fund | Adaptive Retirement 2030 Fund | |
Columbia Adaptive Retirement 2035 Fund | Adaptive Retirement 2035 Fund | |
Columbia Adaptive Retirement 2040 Fund | Adaptive Retirement 2040 Fund | |
Columbia Adaptive Retirement 2045 Fund | Adaptive Retirement 2045 Fund | |
Columbia Adaptive Retirement 2050 Fund | Adaptive Retirement 2050 Fund | |
Columbia Adaptive Retirement 2055 Fund | Adaptive Retirement 2055 Fund | |
Columbia Adaptive Retirement 2060 Fund | Adaptive Retirement 2060 Fund | |
Columbia Adaptive Risk Allocation Fund | Adaptive Risk Allocation Fund | |
Columbia Balanced Fund | Balanced Fund | |
Columbia Bond Fund | Bond Fund | |
Columbia California Intermediate Municipal Bond Fund | CA Intermediate Municipal Bond Fund | |
Columbia Capital Allocation Aggressive Portfolio | Capital Allocation Aggressive Portfolio | |
Columbia Capital Allocation Conservative Portfolio | Capital Allocation Conservative Portfolio | |
Columbia Capital Allocation Moderate Aggressive Portfolio | Capital Allocation Moderate Aggressive Portfolio | |
Columbia Capital Allocation Moderate Conservative Portfolio | Capital Allocation Moderate Conservative Portfolio | |
Columbia Capital Allocation Moderate Portfolio | Capital Allocation Moderate Portfolio | |
Columbia Connecticut Intermediate Municipal Bond Fund | CT Intermediate Municipal Bond Fund | |
Columbia Contrarian Core Fund | Contrarian Core Fund | |
Columbia Commodity Strategy Fund | Commodity Strategy Fund |
Statement of Additional Information – April 27, 2023 | 5 |
Fund Name: | Referred to as: | |
Columbia Convertible Securities Fund | Convertible Securities Fund | |
Columbia Corporate Income Fund | Corporate Income Fund | |
Columbia Disciplined Core Fund | Disciplined Core Fund | |
Columbia Disciplined Growth Fund | Disciplined Growth Fund | |
Columbia Disciplined Value Fund | Disciplined Value Fund | |
Columbia Dividend Income Fund | Dividend Income Fund | |
Columbia Dividend Opportunity Fund | Dividend Opportunity Fund | |
Columbia Emerging Markets Fund | Emerging Markets Fund | |
Columbia Emerging Markets Bond Fund | Emerging Markets Bond Fund | |
Columbia Flexible Capital Income Fund | Flexible Capital Income Fund | |
Columbia Floating Rate Fund | Floating Rate Fund | |
Columbia Global Opportunities Fund | Global Opportunities Fund | |
Columbia Global Technology Growth Fund | Global Technology Growth Fund | |
Columbia Global Value Fund | Global Value Fund | |
Columbia Government Money Market Fund | Government Money Market Fund | |
Columbia Greater China Fund | Greater China Fund | |
Columbia High Yield Bond Fund | High Yield Bond Fund | |
Columbia High Yield Municipal Fund | High Yield Municipal Fund | |
Columbia Income Builder Fund | Income Builder Fund | |
Columbia Income Opportunities Fund | Income Opportunities Fund | |
Columbia Intermediate Duration Municipal Bond Fund | Intermediate Duration Municipal Bond Fund | |
Columbia International Dividend Income Fund | International Dividend Income Fund | |
Columbia Large Cap Enhanced Core Fund | Large Cap Enhanced Core Fund | |
Columbia Large Cap Growth Fund | Large Cap Growth Fund | |
Columbia Large Cap Growth Opportunity Fund | Large Cap Growth Opportunity Fund | |
Columbia Large Cap Index Fund | Large Cap Index Fund | |
Columbia Large Cap Value Fund | Large Cap Value Fund | |
Columbia Limited Duration Credit Fund | Limited Duration Credit Fund | |
Columbia Massachusetts Intermediate Municipal Bond Fund | MA Intermediate Municipal Bond Fund | |
Columbia Mid Cap Index Fund | Mid Cap Index Fund | |
Columbia Minnesota Tax-Exempt Fund | MN Tax-Exempt Fund | |
Columbia Mortgage Opportunities Fund | Mortgage Opportunities Fund | |
Columbia Multi Strategy Alternatives Fund | Multi Strategy Alternatives Fund | |
Columbia New York Intermediate Municipal Bond Fund | NY Intermediate Municipal Bond Fund | |
Columbia North Carolina Intermediate Municipal Bond Fund | NC Intermediate Municipal Bond Fund | |
Columbia Oregon Intermediate Municipal Bond Fund | OR Intermediate Municipal Bond Fund | |
Columbia Overseas Core Fund | Overseas Core Fund | |
Columbia Overseas Value Fund | Overseas Value Fund | |
Columbia Quality Income Fund | Quality Income Fund | |
Columbia Real Estate Equity Fund | Real Estate Equity Fund | |
Columbia Select Global Equity Fund | Select Global Equity Fund | |
Columbia Select Large Cap Equity Fund | Select Large Cap Equity Fund | |
Columbia Select Large Cap Growth Fund | Select Large Cap Growth Fund | |
Columbia Select Large Cap Value Fund | Select Large Cap Value Fund |
Statement of Additional Information – April 27, 2023 | 6 |
Fund Name: | Referred to as: | |
Columbia Select Mid Cap Growth Fund | Select Mid Cap Growth Fund | |
Columbia Select Mid Cap Value Fund | Select Mid Cap Value Fund | |
Columbia Select Small Cap Value Fund | Select Small Cap Value Fund | |
Columbia Seligman Global Technology Fund | Seligman Global Technology Fund | |
Columbia Seligman Technology and Information Fund | Seligman Technology and Information Fund | |
Columbia Short Duration Municipal Bond Fund | Short Duration Municipal Bond Fund | |
Columbia Short Term Bond Fund | Short Term Bond Fund | |
Columbia Small Cap Growth Fund | Small Cap Growth Fund | |
Columbia Small Cap Index Fund | Small Cap Index Fund | |
Columbia Small Cap Value Fund I | Small Cap Value Fund I | |
Columbia Small Cap Value Fund II | Small Cap Value Fund II | |
Columbia Solutions Aggressive Portfolio | Solutions Aggressive Portfolio | |
Columbia Solutions Conservative Portfolio | Solutions Conservative Portfolio | |
Columbia South Carolina Intermediate Municipal Bond Fund | SC Intermediate Municipal Bond Fund | |
Columbia Strategic California Municipal Income Fund | Strategic CA Municipal Income Fund | |
Columbia Strategic Income Fund | Strategic Income Fund | |
Columbia Strategic Municipal Income Fund | Strategic Municipal Income Fund | |
Columbia Strategic New York Municipal Income Fund | Strategic NY Municipal Income Fund | |
Columbia Tax-Exempt Fund | Tax-Exempt Fund | |
Columbia Total Return Bond Fund | Total Return Bond Fund | |
Columbia U.S. Social Bond Fund | U.S. Social Bond Fund | |
Columbia U.S. Treasury Index Fund | U.S. Treasury Index Fund | |
Columbia Ultra Short Term Bond Fund | Ultra Short Term Bond Fund | |
Columbia Virginia Intermediate Municipal Bond Fund | VA Intermediate Municipal Bond Fund | |
Multi-Manager Alternative Strategies Fund | MM Alternative Strategies Fund | |
Multi-Manager Directional Alternative Strategies Fund | MM Directional Alternative Strategies Fund | |
Multi-Manager Growth Strategies Fund | MM Growth Strategies Fund | |
Multi-Manager International Equity Strategies Fund | MM International Equity Strategies Fund | |
Multi-Manager Small Cap Equity Strategies Fund | MM Small Cap Equity Strategies Fund | |
Multi-Manager Total Return Bond Fund | MM Total Return Bond Strategies Fund | |
Multi-Manager Value Strategies Fund | MM Value Strategies Fund | |
Multisector Bond SMA Completion Portfolio | Multisector Bond SMA Completion Portfolio | |
Overseas SMA Completion Portfolio | Overseas SMA Completion Portfolio |
Statement of Additional Information – April 27, 2023 | 7 |
Fund | Fiscal Year End | Prospectus Date | Date Began Operations* |
Diversified** | Fund Investment Category*** |
Adaptive Retirement 2020 Fund | March 31 | 8/1/2022 | 10/24/2017 | Yes | Fund-of-funds – alternative |
Adaptive Retirement 2025 Fund | March 31 | 8/1/2022 | 4/4/2018 | Yes | Fund-of-funds – alternative |
Adaptive Retirement 2030 Fund | March 31 | 8/1/2022 | 10/24/2017 | Yes | Fund-of-funds – alternative |
Adaptive Retirement 2035 Fund | March 31 | 8/1/2022 | 4/4/2018 | Yes | Fund-of-funds – alternative |
Adaptive Retirement 2040 Fund | March 31 | 8/1/2022 | 10/24/2017 | Yes | Fund-of-funds – alternative |
Adaptive Retirement 2045 Fund | March 31 | 8/1/2022 | 4/4/2018 | Yes | Fund-of-funds – alternative |
Adaptive Retirement 2050 Fund | March 31 | 8/1/2022 | 10/24/2017 | Yes | Fund-of-funds – alternative |
Adaptive Retirement 2055 Fund | March 31 | 8/1/2022 | 4/4/2018 | Yes | Fund-of-funds – alternative |
Adaptive Retirement 2060 Fund | March 31 | 8/1/2022 | 10/24/2017 | Yes | Fund-of-funds – alternative |
Adaptive Risk Allocation Fund | May 31 | 10/1/2022 | 6/19/2012 | Yes | Alternative |
Balanced Fund | August 31 | 1/1/2023 | 10/1/1991 | Yes | Equity/Taxable fixed income |
Bond Fund | April 30 | 9/1/2022 | 1/9/1986 | Yes | Taxable fixed income |
CA Intermediate Municipal Bond Fund | April 30 | 9/1/2022 | 8/19/2002 | Yes | Tax-exempt fixed income |
Capital Allocation Aggressive Portfolio | January 31 | 6/1/2022 | 3/4/2004 | Yes | Fund-of-funds – equity |
Capital Allocation Conservative Portfolio | January 31 | 6/1/2022 | 3/4/2004 | Yes | Fund-of-funds – fixed income |
Capital Allocation Moderate Aggressive Portfolio | January 31 | 6/1/2022 | 10/15/1996 | Yes | Fund-of-funds – equity |
Capital Allocation Moderate Conservative Portfolio | January 31 | 6/1/2022 | 10/15/1996 | Yes | Fund-of-funds – fixed income |
Capital Allocation Moderate Portfolio | January 31 | 6/1/2022 | 3/4/2004 | Yes | Fund-of-funds – equity |
Commodity Strategy Fund | May 31 | 10/1/2022 | 7/28/2011 | Yes | Equity |
Contrarian Core Fund | August 31 | 1/1/2023 | 12/14/1992 | Yes | Equity |
Convertible Securities Fund | February 28/29 | 7/1/2022 | 9/25/1987 | Yes | Equity |
Corporate Income Fund | April 30 | 9/1/2022 | 3/5/1986 | Yes | Taxable fixed income |
CT Intermediate Municipal Bond Fund |
October 31 | 3/1/2023 | 8/1/1994 | No | Tax-exempt fixed income |
Disciplined Core Fund | July 31 | 12/1/2022 | 4/24/2003 | Yes | Equity |
Disciplined Growth Fund | July 31 | 12/1/2022 | 5/17/2007 | Yes | Equity |
Disciplined Value Fund | July 31 | 12/1/2022 | 8/1/2008 | Yes | Equity |
Dividend Income Fund | May 31 | 10/1/2022 | 3/4/1998 | Yes | Equity |
Dividend Opportunity Fund | May 31 | 10/1/2022 | 8/1/1988 | Yes | Equity |
Emerging Markets Fund | August 31 | 1/1/2023 | 1/2/1998 | Yes | Equity |
Statement of Additional Information – April 27, 2023 | 8 |
Fund | Fiscal Year End | Prospectus Date | Date Began Operations* |
Diversified** | Fund Investment Category*** |
Emerging Markets Bond Fund | August 31 | 1/1/2023 | 2/16/2006 | No | Taxable fixed income |
Flexible Capital Income Fund | May 31 | 10/1/2022 | 7/28/2011 | Yes | Flexible |
Floating Rate Fund | July 31 | 12/1/2022 | 2/16/2006 | Yes | Taxable fixed income |
Global Opportunities Fund | July 31 | 12/1/2022 | 1/28/1985 | Yes | Flexible |
Global Technology Growth Fund | August 31 | 1/1/2023 | 11/9/2000 | Yes | Equity |
Global Value Fund | February 28/29 | 7/1/2022 | 5/14/1984 | Yes | Equity |
Government Money Market Fund | July 31 | 12/1/2022 | 10/6/1975 | Yes | Taxable money market |
Greater China Fund | August 31 | 1/1/2023 | 5/16/1997 | No | Equity |
High Yield Bond Fund | May 31 | 10/1/2022 | 12/8/1983 | Yes | Taxable fixed income |
High Yield Municipal Fund | May 31 | 10/1/2022 | 3/5/1984 | Yes | Tax-exempt fixed income |
Income Builder Fund | January 31 | 6/1/2022 | 2/16/2006 | Yes | Fund-of-funds – fixed income |
Income Opportunities Fund | July 31 | 12/1/2022 | 6/19/2003 | Yes | Taxable fixed income |
Intermediate Duration Municipal Bond Fund | October 31 | 3/1/2023 | 6/14/1993 | Yes | Tax-exempt fixed income |
International Dividend Income Fund | August 31 | 1/1/2023 | 11/9/2000 | Yes | Equity |
Large Cap Enhanced Core Fund | February 28/29 | 7/1/2022 | 7/31/1996 | Yes | Equity |
Large Cap Growth Fund | July 31 | 12/1/2022 | 12/14/1990 | Yes | Equity |
Large Cap Growth Opportunity Fund | February 28/29 | 7/1/2022 | 12/31/1997 | Yes | Equity |
Large Cap Index Fund | February 28/29 | 7/1/2022 | 12/15/1993 | Yes | Equity |
Large Cap Value Fund | May 31 | 10/1/2022 | 10/15/1990 | Yes | Equity |
Limited Duration Credit Fund | July 31 | 12/1/2022 | 6/19/2003 | Yes | Taxable fixed income |
MA Intermediate Municipal Bond Fund |
October 31 | 3/1/2023 | 6/14/1993 | No | Tax-exempt fixed income |
Mid Cap Index Fund | February 28/29 | 7/1/2022 | 3/31/2000 | Yes | Equity |
MM Alternative Strategies Fund | August 31 | 1/1/2023 | 4/23/2012 | Yes | Alternative |
MM Directional Alternative Strategies Fund | April 30 | 9/1/2022 | 10/17/2016 | Yes | Alternative |
MM Growth Strategies Fund | March 31 | 8/1/2022 | 4/20/2012 | Yes | Equity |
MM International Equity Strategies Fund |
August 31 | 1/1/2023 | 5/17/2018 | Yes | Equity |
MM Small Cap Equity Strategies Fund |
August 31 | 1/1/2023 | 4/20/2012 | Yes | Equity |
MM Total Return Bond Strategies Fund |
August 31 | 1/1/2023 | 4/20/2012 | Yes | Taxable fixed income |
MM Value Strategies Fund | May 31 | 10/1/2022 | 4/20/2012 | Yes | Equity |
MN Tax-Exempt Fund | July 31 | 12/1/2022 | 8/18/1986 | No | Tax-exempt fixed income |
Mortgage Opportunities Fund | May 31 | 10/1/2022 | 4/30/2014 | Yes | Taxable fixed income |
Multisector Bond SMA Completion Portfolio |
August 31 | 1/1/2023 | 10/29/2019 | No | Taxable fixed income |
Multi Strategy Alternatives Fund | May 31 | 10/1/2022 | 1/28/2015 | Yes | Alternative |
NC Intermediate Municipal Bond Fund | April 30 | 9/1/2022 | 12/11/1992 | Yes | Tax-exempt fixed income |
NY Intermediate Municipal Bond Fund |
October 31 | 3/1/2023 | 12/31/1991 | No | Tax-exempt fixed income |
Statement of Additional Information – April 27, 2023 | 9 |
Fund | Fiscal Year End | Prospectus Date | Date Began Operations* |
Diversified** | Fund Investment Category*** |
OR Intermediate Municipal Bond Fund |
July 31 | 12/1/2022 | 7/2/1984 | Yes | Tax-exempt fixed income |
Overseas Core Fund | February 28/29 | 7/1/2022 | 3/5/2018 | Yes | Equity |
Overseas SMA Completion Portfolio |
August 31 | 1/1/2023 | 9/12/2019 | No | Equity |
Overseas Value Fund | February 28/29 | 7/1/2022 | 3/31/2008 | Yes | Equity |
Quality Income Fund | May 31 | 10/1/2022 | 2/14/2002 | Yes | Taxable fixed income |
Real Estate Equity Fund | December 31 | 5/1/2023 | 4/1/1994 | No | Equity |
SC Intermediate Municipal Bond Fund | April 30 | 9/1/2022 | 1/6/1992 | Yes | Tax-exempt fixed income |
Select Global Equity Fund | October 31 | 3/1/2023 | 5/29/1990 | Yes | Equity |
Select Large Cap Equity Fund | February 28/29 | 7/1/2022 | 10/2/1998 | Yes | Equity |
Select Large Cap Growth Fund | March 31 | 8/1/2022 | 10/1/1997 | Yes | Equity |
Select Large Cap Value Fund | May 31 | 10/1/2022 | 4/25/1997 | Yes | Equity |
Select Mid Cap Growth Fund | August 31 | 1/1/2023 | 11/20/1985 | Yes | Equity |
Select Mid Cap Value Fund | February 28/29 | 7/1/2022 | 11/20/2001 | Yes | Equity |
Select Small Cap Value Fund | May 31 | 10/1/2022 | 4/25/1997 | Yes | Equity |
Seligman Global Technology Fund | October 31 | 3/1/2023 | 5/23/1994 | No | Equity |
Seligman Technology and Information Fund | May 31 | 10/1/2022 | 6/23/1983 | No | Equity |
Short Duration Municipal Bond Fund | April 30 | 9/1/2022 | 10/7/1993 | Yes | Tax-exempt fixed income |
Short Term Bond Fund | March 31 | 8/1/2022 | 9/30/1992 | Yes | Taxable fixed income |
Small Cap Growth Fund | August 31 | 1/1/2023 | 10/1/1996 | Yes | Equity |
Small Cap Index Fund | February 28/29 | 7/1/2022 | 10/15/1996 | Yes | Equity |
Small Cap Value Fund I | April 30 | 9/1/2022 | 7/25/1986 | Yes | Equity |
Small Cap Value Fund II | February 28/29 | 7/1/2022 | 5/1/2002 | Yes | Equity |
Solutions Aggressive Portfolio | March 31 | 8/1/2022 | 10/24/2017 | Yes | Alternative |
Solutions Conservative Portfolio | March 31 | 8/1/2022 | 10/24/2017 | Yes | Alternative |
Strategic CA Municipal Income Fund |
October 31 | 3/1/2023 | 6/16/1986 | Yes | Tax-exempt fixed income |
Strategic Income Fund | August 31 | 1/1/2023 | 4/21/1977 | Yes | Taxable fixed income |
Strategic Municipal Income Fund | July 31 | 12/1/2022 | 11/24/1976 | Yes | Tax-exempt fixed income |
Strategic NY Municipal Income Fund |
October 31 | 3/1/2023 | 9/26/1986 | No | Tax-exempt fixed income |
Tax-Exempt Fund | July 31 | 12/1/2022 | 11/21/1978 | Yes | Tax-exempt fixed income |
Total Return Bond Fund | April 30 | 9/1/2022 | 12/5/1978 | Yes | Taxable fixed income |
U.S. Social Bond Fund | July 31 | 12/1/2022 | 3/26/2015 | Yes | Tax-exempt fixed income |
U.S. Treasury Index Fund | April 30 | 9/1/2022 | 6/4/1991 | Yes | Taxable fixed income |
Ultra Short Term Bond Fund | July 31 | 12/1/2022 | 3/8/2004 | Yes | Taxable fixed income |
VA Intermediate Municipal Bond Fund | April 30 | 9/1/2022 | 9/20/1989 | Yes | Tax-exempt fixed income |
* | Certain Funds reorganized into series of a Trust. The date of operations for these Funds represents the date on which the predecessor funds began operations. |
** | 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. |
Statement of Additional Information – April 27, 2023 | 10 |
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 |
CA Intermediate Municipal Bond Fund | May 14, 2019 | Columbia AMT-Free California Intermediate Muni Bond Fund |
CT Intermediate Municipal Bond Fund | May 14, 2019 | Columbia AMT-Free Connecticut Intermediate Muni Bond Fund |
Global Value Fund | June 9, 2021 | Columbia Global Equity Value Fund |
Intermediate Duration Municipal Bond Fund | September 1, 2022 May 14, 2019 |
Columbia Intermediate Municipal Bond Fund Columbia AMT-Free Intermediate Muni Bond Fund |
International Dividend Income Fund | September 2, 2020 | Columbia Global Dividend Opportunity Fund |
Large Cap Growth Opportunity Fund | January 10, 2020 | Large Cap Growth Fund III |
MA Intermediate Municipal Bond Fund | May 14, 2019 | Columbia AMT-Free Massachusetts Intermediate Muni Bond Fund |
Multi Strategy Alternatives Fund | August 1, 2019 | Columbia Alternative Beta Fund |
NC Intermediate Municipal Bond Fund | May 14, 2019 | Columbia AMT-Free North Carolina Intermediate Muni Bond Fund |
NY Intermediate Municipal Bond Fund | May 14, 2019 | Columbia AMT-Free New York Intermediate Muni Bond Fund |
OR Intermediate Municipal Bond Fund | May 14, 2019 | Columbia AMT-Free Oregon Intermediate Muni Bond Fund |
SC Intermediate Municipal Bond Fund | May 14, 2019 | Columbia AMT-Free South Carolina Intermediate Muni Bond Fund |
Select Large Cap Value Fund | October 1, 2018 | Columbia Select Large-Cap Value Fund |
Select Mid Cap Growth Fund | March 1, 2022 | Columbia Mid Cap Growth Fund |
Select Mid Cap Value Fund | July 1, 2018 | Columbia Mid Cap Value Fund |
Select Small Cap Value Fund | October 1, 2018 | Columbia Select Smaller-Cap Value Fund |
Seligman Technology and Information Fund | June 9, 2021 | Columbia Seligman Communications and Information Fund |
Short Duration Municipal Bond Fund | September 1, 2022 | Columbia Short Term Municipal Bond Fund |
Small Cap Growth Fund | June 9, 2021 | Columbia Small Cap Growth Fund I |
Ultra Short Term Bond Fund | December 1, 2018 | CMG Ultra Short Term Bond Fund |
VA Intermediate Municipal Bond Fund | May 14, 2019 | Columbia AMT-Free Virginia Intermediate Muni Bond Fund |
Statement of Additional Information – April 27, 2023 | 11 |
Fund | A Buy or sell real estate |
B Buy or sell commodities |
C Issuer Diversification |
D Concentrate in any one industry |
E Invest 80% |
F Act as an underwriter |
G Lending |
H Borrow money |
I Issue senior securities |
J Buy on margin/ sell short |
Adaptive Retirement 2020 Fund | A6 | B9 | C6 | D14 | — | F5 | G5 | H4 | I1 | — |
Adaptive Retirement 2025 Fund | A6 | B9 | C6 | D14 | — | F5 | G5 | H4 | I1 | — |
Adaptive Retirement 2030 Fund | A6 | B9 | C6 | D14 | — | F5 | G5 | H4 | I1 | — |
Adaptive Retirement 2035 Fund | A6 | B9 | C6 | D14 | — | F5 | G5 | H4 | I1 | — |
Adaptive Retirement 2040 Fund | A6 | B9 | C6 | D14 | — | F5 | G5 | H4 | I1 | — |
Adaptive Retirement 2045 Fund | A6 | B9 | C6 | D14 | — | F5 | G5 | H4 | I1 | — |
Adaptive Retirement 2050 Fund | A6 | B9 | C6 | D14 | — | F5 | G5 | H4 | I1 | — |
Adaptive Retirement 2055 Fund | A6 | B9 | C6 | D14 | — | F5 | G5 | H4 | I1 | — |
Adaptive Retirement 2060 Fund | A6 | B9 | C6 | D14 | — | F5 | G5 | H4 | I1 | — |
Adaptive Risk Allocation Fund | A7 | B10 | C6 | D15 | — | F6 | G4 | H3 | I6 | — |
Balanced Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
Bond Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
CA Intermediate Municipal Bond Fund | A4 | B5 | C2 | D6 | E3 | F3 | G3 | H2 | I3 | — |
Capital Allocation Aggressive Portfolio | A1 | B1 | C5 | D2 | — | F1 | G1 | H1 | I1 | — |
Capital Allocation Conservative Portfolio | A1 | B1 | C5 | D2 | — | F1 | G1 | H1 | I1 | — |
Capital Allocation Moderate Aggressive Portfolio | A4 | B5 | C2 | D6 | — | F3 | G3 | H2 | I3 | — |
Capital Allocation Moderate Conservative Portfolio | A4 | B5 | C2 | D6 | — | F3 | G3 | H2 | I3 | — |
Capital Allocation Moderate Portfolio | A1 | B1 | C5 | D2 | — | F1 | G1 | H1 | I1 | — |
Commodity Strategy Fund | A1 | B8 | C5 | D5 | — | F1 | G1 | H1 | I1 | — |
Contrarian Core Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
Statement of Additional Information – April 27, 2023 | 12 |
Fund | A Buy or sell real estate |
B Buy or sell commodities |
C Issuer Diversification |
D Concentrate in any one industry |
E Invest 80% |
F Act as an underwriter |
G Lending |
H Borrow money |
I Issue senior securities |
J Buy on margin/ sell short |
Convertible Securities Fund | A4 | B5 | C2 | D6 | — | F3 | G3 | H2 | I3 | — |
Corporate Income Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
CT Intermediate Municipal Bond Fund | A7 | B10 | — | D15 | E6 | F6 | G4 | H3 | I6 | — |
Disciplined Core Fund | A1 | B1 | C1 | D1 | — | F1 | G1 | H1 | I1 | — |
Disciplined Growth Fund | A1 | B2 | C1 | D1 | — | F1 | G1 | H1 | I1 | — |
Disciplined Value Fund | A1 | B2 | C5 | D1 | — | F1 | G1 | H1 | I1 | — |
Dividend Income Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
Dividend Opportunity Fund | A1 | B1 | C1 | D1 | — | F1 | G1 | H1 | I1 | — |
Emerging Markets Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
Emerging Markets Bond Fund | A1 | B3 | — | D3 | — | F1 | G1 | H1 | I1 | — |
Flexible Capital Income Fund | A1 | B8 | C5 | D5 | — | F1 | G1 | H1 | I1 | — |
Floating Rate Fund | A1 | B3 | C1 | D4 | — | F1 | G1 | H1 | I1 | — |
Global Opportunities Fund | A1 | B1 | C1 | D1 | — | F1 | G1 | H1 | I1 | — |
Global Technology Growth Fund | A7 | B10 | C6 | D8 | E13 | F6 | G4 | H3 | I6 | — |
Global Value Fund | A1 | B1 | C1 | D1 | — | F1 | G1 | H1 | I1 | — |
Government Money Market Fund | A2 | A2 | C1 | D13 | — | F1 | G1 | H1 | I1 | J1 |
Greater China Fund | A7 | B10 | C8 | D15 | — | F6 | G4 | H3 | I6 | — |
High Yield Bond Fund | A1 | B1 | C1 | D1 | — | F1 | G1 | H1 | I1 | — |
High Yield Municipal Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
Income Builder Fund | A1 | B3 | C5 | D2 | — | F1 | G1 | H1 | I1 | — |
Income Opportunities Fund | A1 | B1 | C1 | D1 | — | F1 | G1 | H1 | I1 | — |
Intermediate Duration Municipal Bond Fund | A7 | B10 | C7 | D15 | E7 | F6 | G4 | H3 | I6 | — |
International Dividend Income Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
Large Cap Enhanced Core Fund | A4 | B5 | C2 | D6 | — | F3 | G3 | H2 | I3 | — |
Large Cap Growth Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
Large Cap Growth Opportunity Fund | A4 | B5 | C2 | D6 | — | F3 | G3 | H2 | I3 | — |
Large Cap Index Fund | A4 | B5 | C2 | D6 | — | F3 | G3 | H2 | I3 | — |
Large Cap Value Fund | A1 | B1 | C1 | D1 | — | F1 | G1 | H1 | I1 | — |
Limited Duration Credit Fund | A1 | B1 | C1 | D1 | — | F1 | G1 | H1 | I1 | — |
MA Intermediate Municipal Bond Fund | A7 | B10 | — | D15 | E8 | F6 | G4 | H3 | I6 | — |
Mid Cap Index Fund | A4 | B5 | C2 | D6 | — | F3 | G3 | H2 | I3 | — |
MM Alternative Strategies Fund | A7 | B11 | C6 | D15 | — | F6 | G4 | H3 | I6 | — |
MM Directional Alternative Strategies Fund | A6 | B9 | C6 | D14 | — | F5 | G5 | H4 | I1 | — |
MM Growth Strategies Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
MM International Equity Strategies Fund | A6 | B9 | C5 | D14 | — | F5 | G5 | H4 | I1 | — |
MM Small Cap Equity Strategies Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
MM Total Return Bond Strategies Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
MM Value Strategies Fund | A1 | B7 | C5 | D12 | — | F1 | G1 | H1 | I1 | — |
MN Tax-Exempt Fund | A1 | B1 | — | D7 | E1 | F1 | G1 | H1 | I1 | — |
Mortgage Opportunities Fund | A1 | B1 | C6 | D11 | — | F1 | G1 | H1 | I1 | — |
Multisector Bond SMA Completion Portfolio | A6 | B9 | — | D14 | — | F5 | G5 | H4 | I1 | — |
Multi Strategy Alternatives Fund | A6 | B9 | C6 | D17 | — | F5 | G6 | H5 | I5 | — |
Statement of Additional Information – April 27, 2023 | 13 |
Fund | A Buy or sell real estate |
B Buy or sell commodities |
C Issuer Diversification |
D Concentrate in any one industry |
E Invest 80% |
F Act as an underwriter |
G Lending |
H Borrow money |
I Issue senior securities |
J Buy on margin/ sell short |
NC Intermediate Municipal Bond Fund | A4 | B5 | C2 | D6 | E3 | F3 | G3 | H2 | I3 | — |
NY Intermediate Municipal Bond Fund | A7 | B10 | — | D15 | E9 | F6 | G4 | H3 | I6 | — |
OR Intermediate Municipal Bond Fund | A7 | B10 | C3 | D15 | E10 | F6 | G4 | H3 | I6 | — |
Overseas Core Fund | A6 | B9 | C5 | D14 | — | F5 | G5 | H4 | I1 | — |
Overseas SMA Completion Portfolio | A6 | B9 | — | D14 | — | F5 | G5 | H4 | I1 | — |
Overseas Value Fund | A5 | B6 | C4 | D12 | — | F4 | G4 | H3 | I4 | — |
Quality Income Fund | A1 | B1 | C1 | D1 | — | F1 | G1 | H1 | I1 | — |
Real Estate Equity Fund | A7 | B10 | — | D16 | E11 | F6 | G4 | H3 | I6 | — |
SC Intermediate Municipal Bond Fund | A4 | B5 | C2 | D6 | E3 | F3 | G3 | H2 | I3 | — |
Select Global Equity Fund | A1 | B1 | C1 | D1 | — | F1 | G1 | H1 | I1 | — |
Select Large Cap Equity Fund | A4 | B5 | C2 | D6 | — | F3 | G3 | H2 | I3 | — |
Select Large Cap Growth Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
Select Large Cap Value Fund | A3 | B4 | C3 | D10 | — | F2 | G2 | I2 | I2 | J2 |
Select Mid Cap Growth Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
Select Mid Cap Value Fund | A4 | B5 | C2 | D6 | — | F3 | G3 | H2 | I3 | — |
Select Small Cap Value Fund | A3 | B4 | C3 | D10 | — | F2 | G2 | I2 | I2 | J2 |
Seligman Global Technology Fund | A3 | B4 | — | D8 | — | F2 | G2 | I2 | I2 | J2 |
Seligman Technology and Information Fund | A3 | B4 | — | D9 | — | F2 | G2 | I2 | I2 | J2 |
Short Duration Municipal Bond Fund | A4 | B5 | C2 | D6 | E4 | F3 | G3 | H2 | I3 | — |
Short Term Bond Fund | A4 | B5 | C2 | D6 | — | F3 | G3 | H2 | I3 | — |
Small Cap Growth Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
Small Cap Index Fund | A4 | B5 | C2 | D6 | — | F3 | G3 | H2 | I3 | — |
Small Cap Value Fund I | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
Small Cap Value Fund II | A4 | B5 | C2 | D6 | — | F3 | G3 | H2 | I3 | — |
Solutions Aggressive Portfolio | A6 | B9 | C6 | D14 | — | F5 | G5 | H4 | I1 | — |
Solutions Conservative Portfolio | A6 | B9 | C6 | D14 | — | F5 | G5 | H4 | I1 | — |
Strategic CA Municipal Income Fund | A7 | B10 | C6 | D15 | E5 | F6 | G4 | H3 | I6 | — |
Strategic Income Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
Strategic Municipal Income Fund | A1 | B1 | C1 | D7 | E2 | F1 | G1 | H1 | I1 | — |
Strategic NY Municipal Income Fund | A7 | B10 | — | D15 | E5 | F6 | G4 | H3 | I6 | — |
Tax-Exempt Fund | A7 | B10 | C7 | D15 | E12 | F6 | G4 | H3 | I6 | — |
Total Return Bond Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
U.S. Social Bond Fund | A6 | B12 | C6 | D17 | — | F5 | G6 | H5 | I5 | — |
U.S. Treasury Index Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
Ultra Short Term Bond Fund | A7 | B10 | C7 | D15 | — | F6 | G4 | H3 | I6 | — |
VA Intermediate Municipal Bond Fund | A4 | B5 | C2 | D6 | E3 | F3 | G3 | H2 | I3 | — |
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 – April 27, 2023 | 14 |
A3 – | The Fund will not purchase or hold any real estate, except that a Fund may invest in securities secured by real estate or interests therein or issued by persons (other than real estate investment trusts) which deal in real estate or interests therein. |
A4 – | The Fund may not purchase or sell real estate, except the Fund may purchase securities of issuers which deal or invest in real estate and may purchase securities which are secured by real estate or interests in real estate. |
A5 – | The Fund may not purchase or sell real estate, except the Fund may: (i) purchase securities of issuers which deal or invest in real estate, (ii) purchase securities which are secured by real estate or interests in real estate and (iii) hold and dispose of real estate or interests in real estate acquired through the exercise of its rights as a holder of securities which are secured by real estate or interests therein. |
A6 – | 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. |
A7 – | The Fund may not purchase or sell real estate, except each Fund may: (i) purchase securities of issuers which deal or invest in real estate, (ii) purchase securities which are secured by real estate or interests in real estate and (iii) hold and dispose of real estate or interests in real estate acquired through the exercise of its rights as a holder of securities which are secured by real estate or interests therein. |
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 (and, in the case of Mortgage Opportunities Fund, swaps) 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 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. |
B4 – | 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. |
B5 – | The Fund may not purchase or sell commodities, except that the Fund may, to the extent consistent with its investment objective, 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. This limitation does not apply to foreign currency transactions, including, without limitation, forward currency contracts. |
B6 – | The Fund may not purchase or sell commodities, except that the Fund may to the extent consistent with its investment objective: (i) invest in securities of companies that purchase or sell commodities or which invest in such programs, (ii) purchase and sell options, forward contracts, futures contracts, and options on futures contracts and (iii) enter into swap contracts and other financial transactions relating to commodities. This limitation does not apply to foreign currency transactions including without limitation forward currency contracts. |
B7 – | 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. |
B8 – | The Fund will not buy or sell physical 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 commodities contracts or which invest in such programs, and the Fund may, without limitation by this restriction, purchase and sell options, forward contracts, commodities futures contracts, commodity-linked notes, and options on futures contracts and enter into swap contracts and other financial transactions relating to, or that are secured by, physical commodities or commodity indices. This restriction does not apply to foreign currency transactions including |
Statement of Additional Information – April 27, 2023 | 15 |
* | For purposes of the fundamental investment policy on buying and selling physical commodities above, at the time of the establishment of the restriction for Funds that began investment operations before July 21, 2010, 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. For tax-exempt Funds, for purposes of this policy, the terms of a municipal security determine the issuer. The Fund will not invest more than 5% of its total assets in securities of any company, government, or political subdivision thereof, except the limitation will not apply to investments in securities issued or guaranteed by the U.S. government, its agencies, or instrumentalities, or other investment companies, and except that up to 25% of the Fund’s total assets may be invested without regard to this 5% limitation. For tax-exempt Funds, for purposes of this policy, the terms of a municipal security determine the issuer. |
C2 – | The Fund may not purchase securities (except securities issued or guaranteed by the U.S. Government, its agencies or instrumentalities) of any one issuer if, as a result, more than 5% of its total assets will be invested in the securities of such issuer or it would own more than 10% of the voting securities of such issuer, except that: (i) up to 25% of its total assets may be invested without regard to these limitations; and (ii) a Fund’s assets may be invested in the securities of one or more management investment companies to the extent permitted by the 1940 Act, the rules and regulations thereunder, and any exemptive relief obtained by the Fund. |
C3 – | The Fund will not make any investment inconsistent with its classification as a diversified company under the 1940 Act. |
C4 – | The Fund may not purchase securities (except securities issued or guaranteed by the U.S. Government, its agencies or instrumentalities) of any one issuer if, as a result, more than 5% of its total assets will be invested in the securities of such issuer or it would own more than 10% of the voting securities of such issuer, except that: (a) up to 25% of its total assets may be invested without regard to these limitations; and (b) the Fund’s assets may be invested in the securities of one or more management investment companies to the extent permitted by the 1940 Act, the rules and regulations thereunder, or any applicable exemptive relief obtained by the Fund. |
C5 – | The Fund will not purchase securities (except securities issued or guaranteed by the U.S. Government, its agencies or instrumentalities) of any one issuer if, as a result, more than 5% of its total assets will be invested in the securities of such issuer or it would own more than 10% of the voting securities of such issuer, except that: (a) up to 25% of its total assets may be invested without regard to these limitations; and (b) a Fund’s assets may be invested in the securities of one or more management investment companies to the extent permitted by the 1940 Act, the rules and regulations thereunder, or any applicable exemptive relief. |
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C6 – | The Fund operates as a diversified company under the 1940 Act. |
C7 – | The Fund may not purchase securities (except securities issued or guaranteed by the U.S. Government, its agencies or instrumentalities) of any one issuer if, as a result, more than 5% of its total assets will be invested in the securities of such issuer or it would own more than 10% of the voting securities of such issuer, except that: (i) up to 25% of its total assets may be invested without regard to these limitations and (ii) a Fund’s assets may be invested in the securities of one or more management investment companies to the extent permitted by the 1940 Act, the rules and regulations thereunder, or any applicable exemptive relief. |
C8 – | The Fund may not, as a matter of fundamental policy, purchase securities (except securities issued or guaranteed by the U.S. Government, its agencies or instrumentalities) of any one issuer if, as a result, more than 5% of its total assets will be invested in the securities of such issuer or it would own more than 10% of the voting securities of such issuer, except that: (i) up to 50% of its total assets may be invested without regard to these limitations and (ii) the Fund’s assets may be invested in the securities of one or more management investment companies to the extent permitted by the 1940 Act, the rules and regulations thereunder, or any applicable exemptive relief. |
* | 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. |
† | For purposes of applying the limitation set forth in its issuer diversification policy, under certain circumstances, a Fund may treat an investment, if any, in a municipal bond refunded with escrowed U.S. Government securities as an investment in U.S. Government securities. |
D. | Concentration* |
D1 – | 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. |
D2 – | 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. The Fund itself does not intend to concentrate, however, the aggregation of holdings of the underlying funds may result in the Fund indirectly investing more than 25% of its assets in a particular industry. The Fund does not control the investments of the underlying funds and any indirect concentration will occur only as a result of the Fund following its investment objectives by investing in the underlying funds.(a) |
D3 – | 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. |
D4 – | 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. For purposes of this restriction, loans will be considered investments in the industry of the underlying borrower, rather than that of the seller of the loan. |
D5 – | 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, Commodity Strategy Fund’s counterparties in commodities-related transactions. |
D6 – | The Fund may not purchase any securities which would cause 25% or more of the value of its total assets at the time of purchase to be invested in the securities of one or more issuers conducting their principal business activities in the same industry, provided that: a) 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 b) 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 exemptive relief obtained by the Fund. |
D7 – | The Fund will not invest more than 25% of total assets, at market value, in any one industry; except that municipal securities and securities of the U.S. Government, its agencies and instrumentalities are not considered an industry for purposes of this limitation. |
D8 – | 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 |
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* | For purposes of applying the limitation set forth in its concentration policy above, a Fund will generally use the industry classifications provided by GICS for classification of issuers of equity securities and the classifications provided by the Bloomberg U.S. Aggregate Bond Index for classification of issues of fixed-income securities. A Fund considers the investments of any underlying funds in which it invests, and will consider the portfolio positions applying the Time of Purchase Standard, which in the case of unaffiliated underlying funds is based on portfolio information made publicly available by them. A Fund does not consider futures or swaps clearinghouses or securities clearinghouses, where the Fund has exposure to such clearinghouses in the course of making investments in futures and securities, to be part of any industry. |
(a) | Capital Allocation Aggressive Portfolio considers the concentration policies of any underlying funds in which it invests and will consider the portfolio positions at the time of purchase, which in the case of unaffiliated underlying funds is based on portfolio information made publicly available by each underlying fund. |
(b) | For purposes of applying the limitation set forth in its concentration policy above, applying the Global Industry Classification Standard (GICS) sector classifications, as may be amended from time to time, Seligman Technology and Information Fund invests in companies operating in the information technology and communications services sectors, which sectors may be changed without Fund shareholder approval. |
E. | Invest 80% |
E1 – | The Fund will not under normal market conditions, invest less than 80% of its net assets in municipal obligations that are generally exempt from federal income tax as well as respective state and local income tax. |
E2 – | The Fund will not under normal market conditions, invest less than 80% of its net assets in bonds and other debt securities issued by or on behalf of state or local governmental units whose interest, in the opinion of counsel for the issuer, is exempt from federal income tax. |
E3 – | The Fund will invest at least 80% of its net assets in securities that pay interest exempt from federal income tax, other than the federal alternative minimum tax, and state individual income tax. |
E4 – | The Fund will invest at least 80% of its net assets in securities that pay interest exempt from federal income tax, other than the federal alternative minimum tax |
E5 – | The Fund will, under normal circumstances, invest at least 80% of its total assets in state bonds, subject to applicable state requirements. |
E6 – | Under normal circumstances, the Fund invests at least 80% of net assets in municipal securities that pay interest exempt from federal income tax (including the federal alternative minimum tax) and Connecticut individual income tax. These securities are issued by the State of Connecticut and its political subdivisions, agencies, authorities and instrumentalities, by other qualified issuers (such as Guam, Puerto Rico and the U.S. Virgin Islands) and by mutual funds that invest in such securities. Dividends derived from interest on municipal securities other than such securities will generally be exempt from regular federal income tax (including the federal alternative minimum tax) but subject to Connecticut personal income tax. The Fund may comply with this 80% policy by investing in a partnership, trust or regulated investment company which invests in such securities, in which case the Fund’s investment in such entity shall be deemed to be an investment in the underlying securities in the same proportion as such entity’s investment in such securities bears to its net assets. |
E7 – | As a matter of fundamental policy, under normal circumstances, the Fund invests at least 80% of net assets in municipal securities that pay interest exempt from federal income tax (including the federal alternative minimum tax). These securities are issued by states and their political subdivisions, agencies, authorities and instrumentalities, by other qualified issuers (such as Guam, Puerto Rico and the U.S. Virgin Islands) and by mutual funds that invest in such securities. The Fund may comply with this 80% policy by investing in a partnership, trust, or regulated investment company which invests in such securities, in which case the Fund’s investment in such entity shall be deemed to be an investment in the underlying securities in the same proportion as such entity’s investment in such securities bears to its net assets. |
E8 – | Under normal circumstances, the Fund invests at least 80% of net assets in municipal securities that pay interest exempt from federal income tax (including the federal alternative minimum tax) and Massachusetts individual income tax. These securities are issued by the Commonwealth of Massachusetts and its political subdivisions, agencies, authorities and instrumentalities, by other qualified issuers (such as Guam, Puerto Rico and the U.S. Virgin Islands) and by mutual funds that invest in such securities. Dividends derived from interest on municipal securities other than such securities will generally be exempt from regular federal income tax (including the federal alternative minimum tax) but may be subject to Massachusetts personal income tax. The Fund may comply with this 80% policy by investing in a partnership, trust, or regulated investment company which invests in such securities, in which case the Fund’s investment in such entity shall be deemed to be an investment in the underlying securities in the same proportion as such entity’s investment in such securities bears to its net assets. |
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F. | Act as an underwriter |
F1 – | 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. |
F2 – | 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. |
F3 – | The Fund may not underwrite any issue of securities within the meaning of the 1933 Act except when it might technically be deemed to be an underwriter either: (i) in connection with the disposition of a portfolio security; or (ii) in connection with the purchase of securities directly from the issuer thereof in accordance with its investment objective. This restriction shall not limit the Fund’s ability to invest in securities issued by other registered management investment companies. |
F4 – | The Fund may not underwrite any issue of securities issued by other persons within the meaning of the 1933 Act except when it might be deemed to be an underwriter either: (i) in connection with the disposition of a portfolio security; or (ii) in connection with the purchase of securities directly from the issuer thereof in accordance with its investment objective. This restriction shall not limit the Fund’s ability to invest in securities issued by other registered investment companies. |
F5 – | 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. |
F6 – | The Fund may not underwrite any issue of securities issued by other persons within the meaning of the 1933 Act except when it might be deemed to be an underwriter either: (i) in connection with the disposition of a portfolio security; or (ii) in connection with the purchase of securities directly from the issuer thereof in accordance with the Fund’s investment objective. This restriction shall not limit the Fund’s ability to invest in securities issued by other registered investment companies. |
G. | Lending |
G1 – | 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. For funds-of-funds – equity, under current Board policy, the Fund has no current intention to borrow to a material extent. |
G2 – | 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. |
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G3 – | The Fund may not make loans, except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any exemptive relief obtained by the Fund. |
G4 – | The Fund may not make loans, except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
G5 – | 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. |
G6 – | The Fund will not make loans, except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief, as interpreted or modified by regulatory authority having jurisdiction, from time to time. |
H. | Borrowing* |
H1 – | 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. For funds-of-funds – equity, under current Board policy, the Fund has no current intention to borrow to a material extent. |
H2 – | The Fund may not borrow money except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any exemptive relief obtained by the Fund. |
H3 – | The Fund may not borrow money except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
H4 – | 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. |
H5 – | The Fund will not borrow money except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief, as interpreted or modified by regulatory authority having jurisdiction, from time to time. |
* | For purposes of the policies described herein, this restriction shall not prevent the Funds from engaging in derivatives, short sales or other portfolio transactions that create leverage, as allowed by each Fund’s investment policies. |
I. | Issue senior securities |
I1 – | The Fund will not issue senior securities, except as permitted under the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
I2 – | The Fund will not issue senior securities or borrow money, 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. |
I3 – | The Fund may not issue senior securities except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any exemptive relief obtained by the Fund. |
I4 – | The Fund may not issue senior securities except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
I5 – | The Fund will not issue senior securities, except as permitted under the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief, as interpreted or modified by regulatory authority having jurisdiction, from time to time. |
I6 – | The Fund may not issue senior securities, except as permitted under the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
J. | Buy on margin/sell short |
J1 – | The Fund will not buy on margin or sell short or deal in options to buy or sell securities. |
J2 – | The Fund will not purchase securities on margin 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. |
■ | Purchase common stocks, preferred stocks, warrants, other equity securities, corporate bonds or debentures, state bonds, municipal bonds, or industrial revenue bonds. |
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■ | Purchase or hold the securities of any issuer, if to its knowledge, directors or officers of the Fund and, only in the case of Seligman Global Technology Fund, the directors and officers of the Fund’s Investment Manager, individually owning beneficially more than 0.5% of the outstanding securities of that issuer own in the aggregate more than 5% of such securities. |
■ | Enter into repurchase agreements of more than one week’s duration if more than 10% of the Fund’s net assets would be so invested. |
■ | Up to 25% of the Fund’s net assets may be invested in foreign investments. |
■ | Up to 15% of the Fund’s total assets may be invested in Eurodollar convertible securities and up to an additional 20% of its total assets in foreign securities. |
■ | Up to 20% of the Fund’s total assets may be invested in foreign securities. |
■ | Up to 20% of the Fund’s net assets may be invested in foreign investments. |
■ | Up to 25% of the Fund’s assets may be invested in dollar-denominated debt securities issued by foreign governments, companies or other entities. |
■ | Up to 20% of the Fund’s net assets may be invested in foreign securities. |
■ | Up to 25% of the Fund’s net assets of may be invested in foreign investments, which may include investments in non-U.S. dollar denominated securities, as well as investments in emerging markets securities. |
■ | Up to 20% of the Fund’s total assets may be invested in dollar-denominated foreign debt securities. |
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■ | Under normal circumstances, the Fund invests at least 80% of its net assets in equity securities. |
■ | 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 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, under normal market conditions, the Fund will invest at least 80% of its net assets (including the amount of any borrowings for investment purposes) in government securities and/or repurchase securities that are collateralized by government securities; 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 Funds may not sell securities short, except as permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
■ | The Funds may not sell securities short, except as permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
■ | The Funds may not sell securities short. |
■ | The Fund may not have a short position, unless the Fund owns, or owns rights (exercisable without payment) to acquire, an equal amount of such securities. |
■ | The Fund may not purchase securities on margin, but may receive short-term credit to clear securities transactions and may make initial or maintenance margin deposits in connection with futures transactions. |
■ | The Fund may not purchase securities of any one issuer (other than U.S. Government Obligations and securities of other investment companies) if, immediately after such purchase, more than 25% of the value of the Fund’s total assets would be invested in the securities of one issuer, and with respect to 50% of the Fund’s total assets, more than 5% of its assets would be invested in the securities of one issuer. |
■ | The Funds have adopted a policy to not concentrate their investments in any particular industry or group of industries. However, because these Funds invest principally in underlying funds, they may indirectly concentrate in a particular industry or group of industries through investments in the underlying funds. |
■ | The Funds may indirectly concentrate in a particular industry or group of industries through investments in underlying funds. |
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Type of Investment | Alternative and Fund-of-Funds – Alternative | Equity and Flexible |
Funds-of-Funds – Equity and Fixed Income |
Taxable Fixed Income(i) |
Taxable Money Market |
Tax-Exempt Fixed Income |
Asset-Backed Securities | • | • | • | • | • | • |
Bank Obligations (Domestic and Foreign) | • | • | • | • | • | • |
Collateralized Bond Obligations | • | • | • | • | • | • |
Commercial Paper | • | • | • | • | • | • |
Common Stock | • | • | • | •A | — | — |
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Type of Investment | Alternative and Fund-of-Funds – Alternative | Equity and Flexible |
Funds-of-Funds – Equity and Fixed Income |
Taxable Fixed Income(i) |
Taxable Money Market |
Tax-Exempt Fixed Income |
Convertible Securities | • | •B | • | •C | — | • |
Corporate Debt Securities | • | • | • | • | •D | • |
Custody Receipts and Trust Certificates | • | •E | • | •E | • | •E |
Debt Obligations | • | • | • | • | • | • |
Depositary Receipts | • | • | • | • | — | — |
Derivatives | • | • | • | • | — | • |
Dollar Rolls | • | •F | • | • | — | • |
Exchange-Traded Notes | • | • | • | • | — | • |
Foreign Currency Transactions | • | • | • | • | — | •G |
Foreign Securities | • | • | • | • | • | • |
Guaranteed Investment Contracts (Funding Agreements) | • | • | • | • | • | • |
High-Yield Securities | • | • | • | • | — | • |
Illiquid Investments | • | • | • | • | • | • |
Inflation Protected Securities | • | • | • | • | — | • |
Initial Public Offerings | • | • | • | • | • | • |
Inverse Floaters | • | •H | • | • | — | • |
Investments in Other Investment Companies (Including ETFs) | • | • | • | • | • | • |
Listed Private Equity Funds | • | • | • | • | — | • |
Money Market Instruments | • | • | • | • | • | • |
Mortgage-Backed Securities | • | • | • | • | • | • |
Municipal Securities | • | • | • | • | • | •K |
Participation Interests | • | • | • | • | — | • |
Partnership Securities | • | • | • | • | — | • |
Preferred Stock | • | • | • | •I | — | •I |
Private Placement and Other Restricted Securities | • | • | • | • | • | • |
Real Estate Investment Trusts | • | • | • | • | — | • |
Repurchase Agreements | • | • | • | • | • | • |
Reverse Repurchase Agreements | • | • | • | • | • | • |
Short Sales(ii) | • | • | • | • | — | • |
Sovereign Debt | • | • | • | • | • | • |
Standby Commitments | • | • | • | • | • | • |
U.S. Government and Related Obligations | • | • | • | • | • | • |
Variable and Floating Rate Obligations | • | •J | • | • | •J | •J |
Warrants and Rights | • | • | • | • | — | • |
(i) | Total Return Bond Fund is not authorized to purchase common stock or bank obligations. U.S. Treasury Index Fund is not authorized to purchase asset-backed securities, bank obligations, convertible securities, corporate debt obligations (other than money market instruments), depositary receipts, dollar rolls, foreign currency transactions, foreign securities, guaranteed investment contracts, inverse floaters, high-yield securities, mortgage-backed securities, municipal securities, participation interests, partnership securities, REITs, reverse repurchase agreements, short sales, sovereign debt and standby commitments. Ultra Short Term Bond Fund is not authorized to purchase common stock, foreign currency transactions and short sales. |
(ii) | See Fundamental and Non-Fundamental Investment Policies for Funds that are not permitted to sell securities short. |
A. | The following Fund is not authorized to invest in common stock: Quality Income Fund. |
B. | The following Fund is not authorized to invest in convertible securities: Commodity Strategy Fund. |
C. | The following Fund is not authorized to invest in convertible securities: Quality Income Fund. |
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D. | 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. |
E. | The following equity, flexible, taxable fixed income and tax-exempt fixed income Funds are not authorized to invest in Custody Receipts and Trust Certificates: each series of CFST. |
F. | The following Funds are authorized to invest in Dollar Rolls: Commodity Strategy Fund, Flexible Capital Income Fund, Global Opportunities Fund, MM Value Strategies Fund, Overseas Core Fund and each series of CFST. |
G. | The following Funds are not authorized to invest in Foreign Currency Transactions: CA Intermediate Municipal Bond Fund, MN Tax-Exempt Fund, NC Intermediate Municipal Bond Fund, SC Intermediate Municipal Bond Fund and VA Intermediate Municipal Bond Fund. |
H. | The following Funds are authorized to invest in inverse floaters: Commodity Strategy Fund, Flexible Capital Income Fund, Global Opportunities Fund, MM Value Strategies Fund, Overseas Core Fund and each series of CFST. |
I. | The following taxable fixed income Fund is not authorized to invest in preferred stock: Quality Income Fund. |
J. | The following equity, flexible, taxable money market and tax-exempt fixed income Funds are authorized to invest in Floating Rate Loans: Commodity Strategy Fund, Flexible Capital Income Fund, Global Opportunities Fund, MM Value Strategies Fund, Overseas Core Fund and each series of CFST. |
K. | The following tax-exempt fixed income Funds use effective duration to measure duration for purposes of their principal investment strategies: Intermediate Duration Municipal Bond Fund and Short Duration Municipal Bond Fund. Effective Duration is a duration calculation for bonds with embedded options and takes into account that expected cash flows will fluctuate as interest rates change. It measures the sensitivity of a bond's price to a change in interest rates. The higher the duration, the more sensitive a bond's price will be to interest rate changes. |
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■ | Contingent Convertible Securities Risk. Contingent convertible securities, also known as contingent capital securities or “CoCos,” are hybrid securities that are typically issued by non-U.S. banks. CoCos have characteristics of both debt and equity instruments, although they are generally treated by the Funds as debt investments. If certain “trigger events” occur, CoCos either convert into equity or undergo a principal write-down or write-off. Trigger events, which are defined by the documents governing the CoCo, may include a decline in the issuer’s capital ratio below a specified trigger level, the share price of the issuer falling to a particular level for a certain period of time, other events indicating an increase in the issuer’s risk of insolvency, and/or certain regulatory events, including changes in regulatory capital requirements or regulatory actions related to the issuer’s solvency prospects. |
The value of CoCos may be influenced by the creditworthiness of the issuer and/or fluctuations in such issuer’s applicable capital ratios; supply and demand for CoCos; general market conditions and available liquidity; and economic, financial or political events impacting the issuer, its particular market or the financial markets more broadly. Due to the contingent conversion or principal write-down or write-off features, CoCos may have substantially greater risk than other securities in times of financial stress. The occurrence of an automatic conversion or write-down or write-off event may be unpredictable and the potential effects of such event could cause a Fund’s shares to lose value. The coupon payments offered by CoCos are discretionary and may be cancelled or adjusted downward by the issuer or at the request of the relevant regulatory authority at any point, for any reason, and for any length of time. As a result of the uncertainty with respect to coupon payments, the value of CoCos may be volatile and their price may decline rapidly if coupon payments are suspended. CoCos are typically structurally subordinated to traditional convertible bonds in the issuer’s capital structure. There may be circumstances under which investors in CoCos may suffer a capital loss ahead of equity holders or when equity holders do not. | |
Although one or more of the other risks described in this SAI may also apply, the risks typically associated with CoCos include: Convertible Securities Risk, Credit Risk, Foreign Securities Risk, High-Yield Investments Risk, Interest Rate Risk, Issuer Risk, and Market Risk. |
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■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). The effectiveness of any currency hedging strategy by a Fund may be reduced by the Fund’s inability to precisely match forward contract amounts and the value of securities involved. Forward foreign currency contracts used for hedging may also limit any potential gain that might result from an increase or decrease in the value of the currency. The Fund may use these instruments to gain leveraged exposure to currencies, which is a speculative investment practice that increases the Fund's risk exposure and the possibility of losses. Unanticipated changes |
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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. |
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■ | A commodity-linked structured note is a derivative (structured investment) that has principal and/or interest payments based on the market price of one or more particular commodities (such as crude oil, gasoline and natural gas), a basket of commodities, indices of commodity futures or other economic variable. If payment of interest on a commodity-linked structured note is linked to the value of a particular commodity, basket of commodities, commodity index or other economic variable, the Fund might receive lower interest payments (or not receive any of the interest due) on its investments if there is a loss of value in the underlying reference. Further, to the extent that the amount of principal to be repaid upon maturity is linked to the value of a particular commodity, basket of commodities, commodity index or other economic variable, the Fund might not receive a portion (or any) of the principal at maturity of the investment or upon earlier exchange. At any time, the risk of loss associated with a particular structured note in the Fund’s portfolio may be significantly higher than the value of the note. A liquid secondary market may not exist for the commodity-linked structured notes held in the Fund’s portfolio, which may make it difficult for the notes to be sold at a price acceptable to the portfolio managers or for the Fund to accurately value them. |
■ | An equity-linked note (ELN) is a derivative (structured investment) that has principal and/or interest payments based on the value of a single equity security, a basket of equity securities or an index of equity securities, and generally has risks similar to these underlying equity securities. ELNs may be leveraged or unleveraged. An ELN typically provides interest income, thereby offering a yield advantage over investing directly in an underlying equity. The Fund may purchase ELNs that trade on a securities exchange or those that trade on the over-the-counter markets, as well as in privately negotiated transactions with the issuer of the ELN. Investments in ELNs are also subject to liquidity risk, which may make ELNs difficult to sell and value. The liquidity of unlisted ELNs is normally determined by the willingness of the issuer to make a market in the ELN. While the Fund will seek to purchase ELNs only from issuers that it believes to be willing and able to repurchase the ELN at a reasonable price, there can be no assurance that the Fund will be able to sell at such a price. Furthermore, such inability to sell may impair the Fund’s ability to enter into other transactions at a time when doing so might be advantageous. The Fund’s investments in ELNs have the potential to lead to significant losses, including the amount the Fund invested in the ELN, because ELNs are subject to the market and volatility risks associated with their underlying equity. In addition, because ELNs |
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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 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. |
■ | Contracts for differences are swap arrangements in which the parties agree that their return (or loss) will be based on the relative performance of two different groups or baskets of securities or other instruments. Often, one or both baskets will be an established securities index. The Fund’s return will be based on changes in value of theoretical long futures positions in the securities comprising one basket (with an aggregate face value equal to the notional amount of the contract for differences) and theoretical short futures positions in the securities comprising the other basket. The Fund also may use actual long and short futures positions and achieve similar market exposure by netting the payment obligations of the two contracts. If the short basket outperforms the long basket, the Fund will realize a loss – even in circumstances when the securities in both the long and short baskets appreciate in value. |
■ | 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 swap rates, treasury rates, foreign interest rates and other reference 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. |
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■ | A Municipal Market Data (MMD) Rate Lock permits a Fund to lock in a specific municipal interest rate for a portion of its portfolio to preserve a return on a particular investment or a portion of its portfolio, which in turn protects against any increase in the price of securities to be purchased at a later date. By using an MMD Rate Lock, the Fund can create a synthetic long or short duration position. A Fund will ordinarily use these transactions as a hedge or for duration or risk management, which may not be successful. An MMD Rate Lock is a contract between a Fund and an MMD Rate Lock provider pursuant to which the parties agree to make a net settlement payment to each other on a notional and duration amount, contingent upon whether the Municipal Market Data AAA General Obligation Scale is above or below a specified level on the expiration date of the contract. For example, if a Fund buys an MMD Rate Lock and the Municipal Market Data AAA General Obligation Scale is below the specified level on the expiration date, the counterparty to the contract will make a payment to a Fund equal to the specified level minus the actual level, multiplied by the notional amount of the contract. If the Municipal Market Data AAA General Obligation Scale is above the specified level on the expiration date, a Fund will make a payment to the counterparty equal to the actual level minus the specified level, multiplied by the notional amount of the contract. In connection with investments in MMD Rate Locks, there is a risk that municipal yields will move in the opposite direction than anticipated by a Fund, which would cause the Fund to make payments to its counterparty in the transaction that could adversely affect the Fund’s performance. |
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■ | Asia Pacific Region. A number of countries in the Asia Pacific region are considered underdeveloped or developing, including from a political, economic and/or social perspective, and may have relatively unstable governments and economies based on limited business, industries and/or natural resources or commodities. Events in any one country within the region may impact that country, other countries in the region or the region as a whole. As a result, events in the region will generally have a greater effect on the Fund than if the Fund were more geographically diversified in a region with more developed countries and economies. This could result in increased volatility in the value of the Fund’s investments and losses for the Fund. Continued growth of economies and securities markets in the region will require sustained economic and fiscal discipline, as well as continued commitment to governmental and regulatory reforms. Development also may be influenced by international economic conditions, including those in the United States and Japan, and by world demand for goods or natural resources produced in countries in the Asia Pacific region. Securities markets in the region are generally smaller and have a lower trading volume than those in the United States, which may result in the securities of some companies in the region being less liquid than U.S. or other foreign securities. Some currencies, inflation rates or interest rates in the Asia Pacific region are or can be volatile, and some countries in the region may restrict the flow of money in and out of the country. The risks described under “Emerging Market Securities Risk,” “Frontier Market Risk,” and “Foreign Securities Risk” may be more pronounced due to the Fund’s focus on investments in the region. |
■ | Europe. The Fund is particularly susceptible to risks related to economic, political, regulatory or other events or conditions, including acts of war or other conflicts in the region, affecting issuers and countries in Europe. Countries in Europe are often closely connected and interdependent, and events in one European country can have an adverse impact on, and potentially spread to, other European countries. Most developed countries in Western Europe are members of the EU, and many are also members of the European Economic and Monetary Union (EMU). European countries can be significantly affected by the tight fiscal and monetary controls that the EMU imposes on its members and with which candidates for EMU membership are required to comply. In addition, significant private or public debt problems in a single EU country can pose economic risks to the EU as a whole. Unemployment in Europe has historically been higher than in the United States and public deficits are an ongoing concern in many European countries. As a result, the Fund’s NAV may be more volatile than the NAV of a more geographically diversified fund. If securities of issuers in Europe fall out of favor, it may cause the Fund to underperform other funds that do not focus their investments in this region of the world. Any uncertainty caused by the departure of the UK from the EU, which occurred in January 2020, could have negative impacts on the UK and EU, as well as other European economies and the broader global economy. These could include negative impacts on currencies and financial markets as well as increased volatility and illiquidity, and potentially lower economic growth in markets in the UK, Europe and globally, which could adversely affect the value of your investment in the Fund. Any attempt by the Fund to hedge against or otherwise protect its portfolio or to profit from such circumstances may fail and, accordingly, an investment in the Fund could lose money over short or long periods. |
■ | Greater China. The Greater China region consists of Hong Kong, The People's Republic of China and Taiwan, among other countries, and the Fund's investments in the region are particularly susceptible to risks in that region. The Hong Kong, Taiwanese, and Chinese economies are dependent on the economies of other countries and can be significantly affected by |
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currency fluctuations and increasing competition from other emerging economies in Asia with lower costs. Adverse events in any one country within the region may impact the other countries in the region or Asia as a whole. As a result, adverse events in the region will generally have a greater effect on the Fund than if the Fund were more geographically diversified, which could result in greater volatility in the Fund’s NAV and losses. Markets in the Greater China region can experience significant volatility due to social, economic, regulatory and political uncertainties. Changes in Chinese government policy and economic growth rates could significantly affect local markets and the entire Greater China region. China has yet to develop comprehensive securities, corporate, or commercial laws, its market is relatively new and less developed, and its economy is experiencing a relative slowdown. Export growth continues to be a major driver of China’s economic growth. As a result, a reduction in spending on Chinese products and services, the institution of additional tariffs or other trade barriers, including as a result of heightened trade tensions between China and the United States, or a downturn in any of the economies of China’s key trading partners may have an adverse impact on the Chinese economy. The risks described under “Emerging Market Securities Risk,” “Frontier Market Risk,” and “Foreign Securities Risk” may be more pronounced due to the Fund’s focus on investments in the region. Many Chinese companies to which the Fund seeks investment exposure use a structure known as a variable interest entity (a VIE) to address Chinese restrictions on direct foreign investment in Chinese companies operating in certain sectors. The Fund’s investment exposure to VIEs may pose additional risks because the Fund’s investment is not made directly in the VIE (the actual Chinese operating company), but rather in a holding company domiciled outside of China (a Holding Company) whose interests in the business of the underlying Chinese operating company (the VIE) are established through contracts rather than through equity ownership. The VIE (which the Fund is restricted from owning under Chinese law) is generally owned by Chinese nationals, and the Holding Company (in which the Fund invests) holds only contractual rights (rather than equity ownership) relating to the VIE, typically including a contractual claim on the VIE's profits. Shares of the Holding Company, in turn, are traded on exchanges outside of China and are available to non-Chinese investors such as the Fund. The VIE structure is a longstanding practice in China that, until recently, was not acknowledged by the Chinese government, creating uncertainty over the possibility that the Chinese government might cease to tolerate VIE structures at any time or impose new restrictions on the structure. In such a scenario, the Chinese operating company could be subject to penalties, including revocation of its business and operating license, or the Holding Company could forfeit its interest in the business of the Chinese operating company. Further, in case of a dispute, the remedies and rights of the Fund may be limited, and such legal uncertainty may be exploited against the interests of the Fund. Control over a VIE may also be jeopardized if a natural person who holds the equity interest in the VIE breaches the terms of the contractual arrangements, is subject to legal proceedings, or if any physical instruments or property of the VIE, such as seals, business registration certificates, financial data and licensing arrangements (sometimes referred to as “chops”), are used without authorization. In the event of such an occurrence, the Fund, as a foreign investor, may have little or no legal recourse. In addition to the risk of government intervention, investments through a VIE structure are subject to the risk that the China-based company (or its officers, directors, or Chinese equity owners) may breach the contractual arrangements, that Chinese law changes in a way that adversely affects the enforceability of the arrangements, or that the contracts are otherwise not enforceable under Chinese law. In any of these cases, a Fund may suffer significant losses on its investments through a VIE structure with little or no recourse available. The Fund will typically have little or no ability to influence the VIE through proxy voting or other means because it is not a VIE owner/shareholder. Foreign companies listed on stock exchanges in the United States, including companies using the VIE structure, could also face delisting or other ramifications for failure to meet the expectations and/or requirements of the SEC, the Public Company Accounting Oversight Board, or other U.S. regulators. Recently, China has proposed the adoption of rules which would affirm that VIEs are legally permissible, though there remains significant uncertainty over how these rules will operate. Any of these risks could reduce the liquidity and value of the Fund’s investments in Holding Companies or render them valueless. |
■ | Japan. The Fund is particularly susceptible to the social, political, economic, regulatory and other conditions or events that may affect Japan’s economy. The Japanese economy is heavily dependent upon international trade, including, among other things, the export of finished goods and the import of oil and other commodities and raw materials. Because of its trade dependence, the Japanese economy is particularly exposed to the risks of currency fluctuation, foreign trade policy and regional and global economic disruption, including the risk of increased tariffs, embargoes, and other trade limitations or factors. Strained relationships between Japan and its neighboring countries, including China, South Korea and North Korea, based on historical grievances, territorial disputes, and defense concerns, may also cause uncertainty in Japanese markets. As a result, additional tariffs, other trade barriers, or boycotts may have an adverse impact on the Japanese economy. Japanese government policy has been characterized by economic regulation, intervention, protectionism and large government deficits. The Japanese economy is also challenged by an unstable financial services sector, highly leveraged corporate balance sheets and extensive cross-ownership among major corporations. Structural social and labor market changes, including an aging workforce, population decline and traditional aversion to labor mobility may adversely affect Japan’s economic competitiveness and growth potential. The potential for natural disasters, such as earthquakes, volcanic eruptions, typhoons and tsunamis, could also have significant negative effects on Japan’s economy. A significant portion of Japan's trade is conducted with developing nations in East and Southeast Asia and its economy can be affected by conditions and currency |
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fluctuations in these and other countries. For a number of years, Japan’s economic growth rate has remained relatively low, and it may remain low in the future. Securities in Japan are denominated and quoted in yen. As a result, the value of the Fund's Japanese securities as measured in U.S. dollars may be affected by fluctuations in the value of the Japanese yen relative to the U.S. dollar. Securities traded on Japanese stock exchanges have exhibited significant volatility in recent years. As a result of the Fund’s investment in Japanese securities, the Fund’s NAV may be more volatile than the NAV of a more geographically diversified fund. If securities of issuers in Japan fall out of favor, it may cause the Fund to underperform other funds that do not focus their investments in Japan. |
■ | Latin America Region. The Fund is particularly susceptible to risks related to economic, political, regulatory, legal, social or other events or conditions affecting issuers in, or those that have investment exposure to, the Latin America region. The economies of many Latin American countries have experienced elevated and volatile interest rates, inflation rates and unemployment rates. Currency devaluations and exchange rate volatility have also been common among Latin American economies. Relatively high dependence upon commodities, such as petroleum, minerals, metals and agricultural products, amongst others, may cause certain Latin American economies to be particularly sensitive to fluctuations in commodity prices. International economic conditions, trade arrangements and flow of international capital may have significant impact on Latin American economies due to their relatively heavy reliance upon international trade. Latin American economies may also be susceptible to adverse government regulatory and economic intervention and controls which may negatively impact economic growth. Limitations in the ability to repatriate investment income, capital or the proceeds of the sale of securities from Latin American countries could adversely affect the Fund. Other risks associated with investments in Latin American economies may include inadequate investor protections, less developed custody, settlement, regulatory, accounting, auditing and financial standards, unfavorable changes in laws or regulations, natural disasters, corruption and military activity. The risks described under “Emerging Market Securities Risk,” “Frontier Market Risk,” and “Foreign Securities Risk” may be more pronounced due to the Fund’s focus on investments in the region. |
■ | Middle East and North Africa Region. The Fund is particularly susceptible to risks related to economic, political, regulatory, legal, social or other events or conditions affecting issuers in, or those that have investment exposure to, the Middle East and North Africa region. The economies of many Middle Eastern and North African countries have experienced local and regional conflicts including terrorist activity, religious, ethnic and/or socio-economic unrest, acts of war or other conflicts in the region, as well as elevated and volatile interest rates, inflation rates and unemployment rates. Currency devaluations and exchange rate volatility have also been common among Middle Eastern and North African economies. Relatively high dependence upon commodities, such as petroleum and minerals amongst others, may cause certain Middle Eastern and North African economies to be particularly sensitive to fluctuations in commodity prices. International economic conditions, trade arrangements and flow of international capital may have a significant impact on Middle Eastern and North African economies due to their relatively heavy reliance upon international trade. Middle Eastern and North African economies may also be susceptible to adverse government regulatory and economic intervention and controls which may negatively impact economic growth. Limitations in the ability to repatriate investment income, capital or the proceeds of the sale of securities from Middle Eastern and North African countries could adversely affect the Fund. Other risks associated with investments in Middle Eastern and North African economies may include inadequate investor protections, less developed custody, settlement, regulatory, accounting, auditing and financial standards, unfavorable changes in laws or regulations, natural disasters, corruption and military activity. The risks described under “Emerging Market Securities Risk,” “Frontier Market Risk,” and “Foreign Securities Risk” may be more pronounced due to the Fund’s focus on investments in the region. |
■ | India. The Fund is particularly susceptible to risks related to economic, political, regulatory or other events or conditions affecting issuers in India. Because the Fund invests predominantly in Indian securities, its NAV will be much more sensitive to changes in economic, political and other factors within India than would a fund that invested in a variety of countries. Special risks include, among others, political and legal uncertainty, persistent religious, ethnic and border disputes, greater government control over the economy, currency fluctuations or blockage and the risk of nationalization or expropriation of assets. Uncertainty regarding inflation and currency exchange rates, fiscal policy, credit ratings and the possibility that future harmful political actions will be taken by the Indian government, could negatively impact the Indian economy and securities markets, and thus adversely affect the Fund’s performance. The risks described under “Emerging Market Securities Risk,” “Frontier Market Risk,” and “Foreign Securities Risk” may be more pronounced due to the Fund’s focus on investments in the region. |
The Indian government has exercised, and continues to exercise, significant influence over many aspects of the economy, and the number of public sector enterprises in India is substantial. Accordingly, Indian government actions in the future could have a significant effect on the Indian economy, which could affect private sector companies, market conditions, and prices and yields of securities in the Fund’s portfolio. The Fund’s performance will also be affected by changes in value of the Indian rupee versus the U.S. dollar. For example, if the value of the U.S. dollar goes up compared to the Indian rupee, an investment traded in the rupee will go down in value because it will be worth fewer U.S. dollars. Furthermore, the Fund may incur costs |
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in connection with conversions between U.S. dollars and rupees. | |
Indian issuers are subject to less regulation and scrutiny with regard to financial reporting, accounting and auditing than U.S. companies. Information regarding Indian corporations may be less reliable and all material information may not be available to the Fund. Securities laws in India are relatively new and unsettled and, consequently, there is a risk of rapid and unpredictable change in laws regarding foreign investment, securities regulation, title to securities and shareholder rights. Accordingly, foreign investors may be adversely affected by new or amended laws and regulations. In addition, it may be difficult to obtain and enforce a judgment in a court in India. It may not be possible for the Fund to effect service of process in India, and if the Fund obtains a judgment in a U.S. court, it may be difficult to enforce such judgment in India. The stock markets in the region are undergoing a period of growth and change, which may result in trading or price volatility and difficulties in the settlement and recording of transactions, and in interpreting and applying the relevant laws and regulations. The securities industries in India are comparatively underdeveloped, and stockbrokers and other intermediaries may not perform as well as their counterparts in the United States and other more developed securities markets and which may impose additional costs on investment. | |
The Indian population is comprised of diverse religious, linguistic, ethnic and religious groups. India has, from time to time, experienced civil unrest and hostility with neighboring countries such as Pakistan. Violence and disruption associated with these tensions could have a negative effect on the economy and, consequently, adversely affect the Fund. Agriculture occupies a prominent position in the Indian economy, alongside India’s service and industrial sectors. Adverse changes in weather, including monsoons, and other natural disasters in India and surrounding regions can have a significant adverse effect on the Indian economy, which could adversely affect the Fund. |
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■ | Large-Cap Stock Risk. Investments in larger, more established companies (larger companies) may involve certain risks associated with their larger size. For instance, larger companies may be less able to respond quickly to new competitive challenges, such as changes in consumer tastes or innovation from smaller competitors. Also, larger companies are sometimes less able to achieve as high growth rates as successful smaller companies, especially during extended periods of economic expansion. |
■ | Small- and Mid-Cap Stock Risk. Securities of small- and mid-cap companies can, in certain circumstances, have a higher potential for gains than securities of larger companies but are more likely to have more risk than larger companies. For example, small- and mid-cap companies may be more vulnerable to market downturns and adverse business or economic events than larger companies because they may have more limited financial resources and business operations. Small- and mid-cap companies are also more likely than larger companies to have more limited product lines and operating histories and to depend on smaller and generally less experienced management teams. Securities of small- and mid-cap companies may trade less frequently and in smaller volumes and may be less liquid and fluctuate more sharply in value than securities of larger companies. When the Fund takes significant positions in small- and mid-cap companies with limited trading volumes, the liquidation of those positions, particularly in a distressed market, could be prolonged and result in Fund investment losses that would affect the value of your investment in the Fund. In addition, some small- and mid-cap companies may not be widely followed by the investment community, which can lower the demand for their stocks. |
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Fund | Assets (millions) |
Annual rate at each asset level |
Balanced Fund(a) | $0 - $500 | 0.7200% |
>$500 - $1,000 | 0.6700% | |
>$1,000 - $1,500 | 0.6200% | |
>$1,500 - $3,000 | 0.5700% | |
>$3,000 - $6,000 | 0.5500% | |
>$6,000 - $12,000 | 0.5300% | |
>$12,000 - $15,600 | 0.5200% | |
>$15,600 - $20,300 | 0.5175% | |
>$20,300 - $26,400 | 0.5150% | |
>$26,400 - $34,300 | 0.5125% | |
>$34,300 - $44,600 | 0.5100% | |
>$44,600 | 0.5075% | |
Bond Fund | $0 - $500 | 0.500% |
Corporate Income Fund | >$500 - $1,000 | 0.495% |
MM Total Return Bond Strategies Fund | >$1,000 - $2,000 | 0.480% |
Quality Income Fund | >$2,000 - $3,000 | 0.460% |
Total Return Bond Fund | >$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% | |
CA Intermediate Municipal Bond Fund | $0 - $250 | 0.470% |
NC Intermediate Municipal Bond Fund | >$250 - $500 | 0.465% |
SC Intermediate Municipal Bond Fund | >$500 - $1,000 | 0.415% |
VA Intermediate Municipal Bond Fund | >$1,000 - $1,500 | 0.380% |
>$1,500 - $3,000 | 0.350% | |
>$3,000 - $6,000 | 0.330% | |
>$6,000 - $12,000 | 0.320% | |
>$12,000 | 0.310% | |
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% | |
Contrarian Core Fund(g) | $0 - $500 | 0.7700% |
>$500 - $1,000 | 0.7200% | |
>$1,000 - $1,500 | 0.6700% | |
>$1,500 - $3,000 | 0.6200% | |
>$3,000 - $6,000 | 0.6000% | |
>$6,000 - $12,000 | 0.5800% | |
>$12,000 - $15,600 | 0.5700% | |
>$15,600 - $20,300 | 0.5675% | |
>$20,300 - $26,400 | 0.5650% | |
>$26,400 - $34,300 | 0.5625% | |
>$34,300 - $44,600 | 0.5600% | |
>$44,600 - $58,000 | 0.5575% | |
>$58,000 | 0.5550% | |
Convertible Securities Fund(g) | $0 - $500 | 0.820% |
Select Mid Cap Growth Fund | >$500 - $1,000 | 0.770% |
Select Mid Cap Value Fund | >$1,000 - $1,500 | 0.720% |
>$1,500 - $3,000 | 0.670% | |
>$3,000 - $12,000 | 0.660% | |
>$12,000 | 0.650% |
Statement of Additional Information – April 27, 2023 | 104 |
Fund | Assets (millions) |
Annual rate at each asset level |
CT Intermediate Municipal Bond Fund | $0 - $250 | 0.470% |
MA Intermediate Municipal Bond Fund | >$250 - $500 | 0.465% |
MN Tax-Exempt Fund | >$500 - $1,000 | 0.415% |
NY Intermediate Municipal Bond Fund | >$1,000 - $3,000 | 0.380% |
OR Intermediate Municipal Bond Fund | >$3,000 - $6,000 | 0.340% |
Strategic CA Municipal Income Fund | >$6,000 - $7,500 | 0.330% |
Strategic NY Municipal Income Fund | >$7,500 - $12,000 | 0.320% |
>$12,000 | 0.310% | |
Disciplined Core Fund | $0 - $500 | 0.750% |
Disciplined Growth Fund | >$500 - $1,000 | 0.700% |
Disciplined Value Fund | >$1,000 - $1,500 | 0.650% |
Large Cap Enhanced Core Fund | >$1,500 - $3,000 | 0.600% |
>$3,000 - $6,000 | 0.580% | |
>$6,000 - $12,000 | 0.560% | |
>$12,000 | 0.550% | |
Dividend Income Fund(a) | $0 - $500 | 0.7200% |
>$500 - $1,000 | 0.6700% | |
>$1,000 - $1,500 | 0.6200% | |
>$1,500 - $3,000 | 0.5700% | |
>$3,000 - $6,000 | 0.5500% | |
>$6,000 - $12,000 | 0.5300% | |
>$12,000 - $15,600 | 0.5200% | |
>$15,600 - $20,300 | 0.5175% | |
>$20,300 - $26,400 | 0.5150% | |
>$26,400 - $34,300 | 0.5125% | |
>$34,300 - $44,600 | 0.5100% | |
>$44,600 - $58,000 | 0.5075% | |
>$58,000 - $75,400 | 0.5050% | |
>$75,400 | 0.5025% | |
Dividend Opportunity Fund | $0 - $500 | 0.720% |
Global Opportunities Fund(c) | >$500 - $1,000 | 0.670% |
Global Value Fund | >$1,000 - $1,500 | 0.620% |
Large Cap Value Fund | >$1,500 - $3,000 | 0.570% |
MM Value Strategies Fund | >$3,000 - $6,000 | 0.550% |
>$6,000 - $12,000 | 0.530% | |
>$12,000 | 0.520% | |
Emerging Markets Bond Fund | $0 - $500 | 0.600% |
Strategic Income Fund | >$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% | |
Emerging Markets Fund | $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% | |
Flexible Capital Income Fund | $0 - $500 | 0.650% |
>$500 - $1,000 | 0.630% | |
>$1,000 - $3,000 | 0.610% | |
>$3,000 - $6,000 | 0.570% | |
>$6,000 | 0.540% |
Statement of Additional Information – April 27, 2023 | 105 |
Fund | Assets (millions) |
Annual rate at each asset level |
Floating Rate Fund | $0 - $250 | 0.660% |
High Yield Bond Fund | >$250 - $500 | 0.645% |
Income Opportunities Fund | >$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% | |
Global Technology Growth Fund(g) | $0 - $500 | 0.870% |
MM Small Cap Equity Strategies Fund | >$500 - $1,000 | 0.820% |
Select Small Cap Value Fund | >$1,000 - $3,000 | 0.770% |
Small Cap Growth Fund | >$3,000 - $12,000 | 0.760% |
Small Cap Value Fund II | >$12,000 | 0.750% |
Government Money Market Fund(i) | $0 - $500 | 0.330% |
>$500 - $1,000 | 0.325% | |
>$1,000 - $1,500 | 0.303% | |
>$1,500 - $2,000 | 0.285% | |
>$2,000 - $2,500 | 0.268% | |
>$2,500 - $3,000 | 0.250% | |
>$3,000 - $5,000 | 0.240% | |
>$5,000 - $6,000 | 0.220% | |
>$6,000 - $7,500 | 0.200% | |
>$7,500 - $9,000 | 0.195% | |
>$9,000 - $10,000 | 0.170% | |
>$10,000 - $12,000 | 0.160% | |
>$12,000 - $15,000 | 0.150% | |
>$15,000 - $20,000 | 0.140% | |
>$20,000 - $24,000 | 0.130% | |
>$24,000 | 0.120% | |
Greater China Fund | $0 - $1,000 | 0.950% |
>$1,000 - $1,500 | 0.870% | |
>$1,500 - $3,000 | 0.820% | |
>$3,000 - $6,000 | 0.770% | |
>$6,000 | 0.720% | |
High Yield Municipal Fund | $0 - $500 | 0.540% |
>$500 - $1,000 | 0.535% | |
>$1,000 - $2,000 | 0.505% | |
>$2,000 - $3,000 | 0.480% | |
>$3,000 - $6,000 | 0.445% | |
>$6,000 - $7,500 | 0.420% | |
>$7,500 - $10,000 | 0.410% | |
>$10,000 - $12,000 | 0.400% | |
>$12,000 - $15,000 | 0.390% | |
>$15,000 - $24,000 | 0.380% | |
>$24,000 - $50,000 | 0.360% | |
>$50,000 | 0.340% |
Statement of Additional Information – April 27, 2023 | 106 |
Fund | Assets (millions) |
Annual rate at each asset level |
Intermediate Duration Municipal Bond Fund | $0 - $500 | 0.480% |
Tax-Exempt Fund | >$500 - $1,000 | 0.475% |
U.S. Social Bond Fund | >$1,000 - $2,000 | 0.445% |
>$2,000 - $3,000 | 0.420% | |
>$3,000 - $6,000 | 0.385% | |
>$6,000 - $9,000 | 0.360% | |
>$9,000 - $10,000 | 0.350% | |
>$10,000 - $12,000 | 0.340% | |
>$12,000 - $15,000 | 0.330% | |
>$15,000 - $24,000 | 0.320% | |
>$24,000 - $50,000 | 0.300% | |
>$50,000 | 0.290% | |
International Dividend Income Fund | $0 - $500 | 0.770% |
Large Cap Growth Fund | >$500 - $1,000 | 0.720% |
Large Cap Growth Opportunity Fund | >$1,000 - $1,500 | 0.670% |
MM Growth Strategies Fund | >$1,500 - $3,000 | 0.620% |
Select Large Cap Equity Fund | >$3,000 - $6,000 | 0.600% |
Select Large Cap Growth Fund | >$6,000 - $12,000 | 0.580% |
>$12,000 | 0.570% | |
Large Cap Index Fund(h) | All assets | 0.200% |
Mid Cap Index Fund | ||
Small Cap Index Fund(h) | ||
Limited Duration Credit Fund | $0 - $500 | 0.430% |
Short Duration Municipal Bond Fund | >$500 - $1,000 | 0.425% |
Short Term Bond Fund | >$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% | |
MM Alternative Strategies Fund(b) | $0 - $500 | 1.100% |
>$500 - $1,000 | 1.050% | |
>$1,000 - $3,000 | 1.020% | |
>$3,000 - $6,000 | 0.990% | |
>$6,000 - $12,000 | 0.960% | |
>$12,000 | 0.950% | |
MM Directional Alternative Strategies Fund | All assets | 1.60% |
MM International Equity Strategies Fund | $0 - $500 | 0.870% |
Overseas Value Fund | >$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% | |
Mortgage Opportunities Fund | $0 - $500 | 0.650% |
>$500 - $1,000 | 0.645% | |
>$1,000 - $2,000 | 0.630% | |
>$2,000 - $3,000 | 0.620% | |
>$3,000 - $6,000 | 0.595% | |
>$6,000 - $7,500 | 0.580% | |
>$7,500 - $9,000 | 0.565% | |
>$9,000 - $10,000 | 0.555% | |
>$10,000 - $12,000 | 0.545% | |
>$12,000 | 0.535% |
Statement of Additional Information – April 27, 2023 | 107 |
Fund | Assets (millions) |
Annual rate at each asset level |
Multi Strategy Alternatives Fund(b) | $0 - $500 | 0.960% |
>$500 - $1,000 | 0.955% | |
>$1,000 - $3,000 | 0.950% | |
>$3,000 - $12,000 | 0.940% | |
>$12,000 | 0.930% | |
Multisector Bond SMA Completion Portfolio | All assets | 0.00% |
Overseas SMA Completion Portfolio | ||
Solutions Aggressive Portfolio | ||
Solutions Conservative Portfolio | ||
Overseas Core Fund(d) | $0 - $250 | 0.870% |
Select Global Equity Fund(e) | >$250 - $500 | 0.855% |
>$500 - $750 | 0.820% | |
>$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% | |
Real Estate Equity 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% | |
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% | |
Seligman Global Technology Fund(a) | $0 - $500 | 0.9150% |
Seligman Technology and Information Fund(a) | >$500 - $1,000 | 0.9100% |
>$1,000 - $3,000 | 0.9050% | |
>$3,000 - $4,000 | 0.8650% | |
>$4,000 - $6,000 | 0.8150% | |
>$6,000 - $12,000 | 0.7650% | |
>$12,000 - $20,000 | 0.7550% | |
>$20,000 - $24,000 | 0.7450% | |
>$24,000 - $50,000 | 0.7350% | |
>$50,000 | 0.7050% | |
Small Cap Value Fund I(f) | $0 - $500 | 0.850% |
>$500 - $1,000 | 0.800% | |
>$1,000 - $3,000 | 0.750% | |
>$3,000 - $12,000 | 0.740% | |
>$12,000 | 0.730% | |
Strategic Municipal Income Fund | $0 - $500 | 0.480% |
>$500 - $1,000 | 0.475% | |
>$1,000 - $2,000 | 0.445% | |
>$2,000 - $3,000 | 0.420% | |
>$3,000 - $6,000 | 0.385% | |
>$6,000 - $7,500 | 0.360% | |
>$7,500 - $10,000 | 0.350% | |
>$10,000 - $12,000 | 0.340% | |
>$12,000 - $15,000 | 0.330% | |
>$15,000 - $24,000 | 0.320% | |
>$24,000 - $50,000 | 0.300% | |
>$50,000 | 0.290% | |
U.S. Treasury Index Fund(h) | All assets | 0.400% |
Ultra Short Term Bond Fund | All assets | 0.210% |
Statement of Additional Information – April 27, 2023 | 108 |
(a) | Effective July 1, 2022, the management fee schedule changed resulting in a fee rate decrease for certain 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) | This fee applies to assets invested in securities, other than underlying funds (including any exchange-traded funds (ETFs)) that pay a management services fee (or an investment advisory services fee, as applicable) to the Investment Manager, including other funds advised by the Investment Manager that do not pay a management services fee (or an investment advisory services fee, as applicable), derivatives and individual securities. The Fund does not pay a management services fee on assets that are invested in underlying funds, including any ETFs, that pay a management services fee (or an investment advisory services fee, as applicable) to the Investment Manager. |
(d) | Effective July 1, 2020, the management fee schedule changed resulting in a fee rate decrease for certain asset levels. |
(e) | Effective July 8, 2020, the management fee schedule changed resulting in a fee rate decrease for certain asset levels. |
(f) | Effective July 8, 2020, the management fee schedule changed resulting in a fee rate decrease for all asset levels. |
(g) | Effective July 1, 2021, the management fee schedule changed resulting in a fee rate decrease for certain asset levels. |
(h) | The Investment Manager, from the management services fee it receives from the Fund, pays all operating expenses of the Fund, with the exception of brokerage fees and commissions, taxes, interest, fees and expenses of Trustees who are not officers, directors or employees of the Investment Manager or its affiliates, Rule 12b-1 and/or shareholder servicing fees and any extraordinary non-recurring expenses that may arise, including litigation expenses. |
(i) | Effective July 1, 2022, the management fee schedule changed resulting in a fee rate decrease for all asset levels. |
Asset Category | Assets (millions) |
Annual rate at each asset level |
Category 1: Assets invested in affiliated mutual funds, exchange- traded funds and closed-end funds that pay a management services fee (or an investment management services fee, as applicable) to the Investment Manager. | $0 - $500 | 0.060% |
>$500 - $1,000 | 0.055% | |
>$1,000 - $3,000 | 0.050% | |
>$3,000 - $12,000 | 0.040% | |
>$12,000 | 0.030% | |
Category 2: Assets invested in exchange-traded funds and mutual funds that are not managed by the Investment Manager or its affiliates. | $0 - $500 | 0.160% |
>$500 - $1,000 | 0.155% | |
>$1,000 - $3,000 | 0.150% | |
>$3,000 - $12,000 | 0.140% | |
>$12,000 | 0.130% | |
Category 3: Securities, instruments and other assets not described above, including without limitation affiliated mutual funds, exchange-traded funds and closed-end funds that do not pay a management services fee (or an investment management services fee, as applicable) to the Investment Manager, third party closed-end funds, derivatives and individual securities. | $0 - $500 | 0.760% |
>$500 - $1,000 | 0.745% | |
>$1,000 - $1,500 | 0.730% | |
>$1,500 - $3,000 | 0.720% | |
>$3,000 - $6,000 | 0.690% | |
>$6,000 - $12,000 | 0.665% | |
>$12,000 | 0.630% |
Statement of Additional Information – April 27, 2023 | 109 |
Management Services Fees | |||
2022 | 2021 | 2020 | |
For Funds with fiscal period ending January 31 | |||
Capital Allocation Aggressive Portfolio | $542,608 | $510,838 | $606,356 |
Capital Allocation Conservative Portfolio | 171,901 | 258,667 | 262,717 |
Capital Allocation Moderate Aggressive Portfolio | 767,200 | 2,229,560 | 2,335,770 |
Capital Allocation Moderate Conservative Portfolio | 225,492 | 524,962 | 537,654 |
Capital Allocation Moderate Portfolio | 557,146 | 986,753 | 1,145,529 |
Income Builder Fund | 333,998 | 270,353 | 263,691 |
For Funds with fiscal period ending February 28/29 | |||
Convertible Securities Fund | 18,506,296 | 14,178,875 | 9,961,757 |
Global Value Fund | 7,076,763 | 5,420,431 | 5,244,230 |
Large Cap Enhanced Core Fund | 3,444,662 | 3,271,689 | 3,964,615 |
Large Cap Growth Opportunity Fund | 13,400,347 | 11,585,002 | 10,978,248 |
Large Cap Index Fund | 7,592,485 | 6,712,893 | 6,735,646 |
Mid Cap Index Fund | 6,746,461 | 6,055,023 | 7,922,667 |
Overseas Core Fund | 8,289,849 | 4,529,021 | 2,202,791 |
Overseas Value Fund | 20,379,104 | 12,831,802 | 14,663,603 |
Select Large Cap Equity Fund | 10,024,393 | 6,482,430 | 5,442,592 |
Select Mid Cap Value Fund | 19,191,348 | 13,047,043 | 11,879,635 |
Small Cap Index Fund | 8,941,618 | 6,406,653 | 7,989,133 |
Small Cap Value Fund II | 12,213,435 | 8,808,325 | 10,746,861 |
For Funds with fiscal period ending March 31 | |||
Adaptive Retirement 2020 Fund | 8,770 | 29,267 | 35,388 |
Adaptive Retirement 2025 Fund | 6,425 | 14,415 | 16,525 |
Adaptive Retirement 2030 Fund | 13,727 | 11,375 | 7,865 |
Adaptive Retirement 2035 Fund | 8,709 | 7,447 | 5,832 |
Adaptive Retirement 2040 Fund | 8,824 | 6,647 | 5,185 |
Adaptive Retirement 2045 Fund | 8,133 | 5,749 | 4,791 |
Adaptive Retirement 2050 Fund | 8,456 | 6,138 | 4,828 |
Adaptive Retirement 2055 Fund | 9,035 | 5,461 | 4,800 |
Adaptive Retirement 2060 Fund | 9,332 | 5,588 | 4,878 |
MM Growth Strategies Fund | 27,059,592 | 22,408,065 | 15,155,032 |
Select Large Cap Growth Fund | 14,323,957 | 14,558,858 | 15,837,381 |
Statement of Additional Information – April 27, 2023 | 110 |
Management Services Fees | |||
2022 | 2021 | 2020 | |
Short Term Bond Fund | $5,055,151 | $4,430,574 | $4,852,495 |
Solutions Aggressive Portfolio(a) | N/A | N/A | N/A |
Solutions Conservative Portfolio(a) | N/A | N/A | N/A |
For Funds with fiscal period ending April 30 | |||
Bond Fund | 5,680,830 | 3,993,853 | 2,052,692 |
CA Intermediate Municipal Bond Fund | 2,094,548 | 2,147,926 | 2,061,046 |
Corporate Income Fund | 7,895,106 | 6,218,370 | 5,701,960 |
MM Directional Alternative Strategies Fund | 4,300,211 | 3,897,950 | 3,943,529 |
NC Intermediate Municipal Bond Fund | 887,868 | 948,029 | 873,346 |
SC Intermediate Municipal Bond Fund | 546,952 | 559,928 | 521,691 |
Short Duration Municipal Bond Fund | 3,328,375 | 3,108,739 | 3,511,060 |
Small Cap Value Fund I | 9,303,647 | 5,982,116 | 4,579,241 |
Total Return Bond Fund | 15,626,595 | 11,286,582 | 10,060,113 |
U.S. Treasury Index Fund | 5,973,899 | 4,744,922 | 3,827,947 |
VA Intermediate Municipal Bond Fund | 613,778 | 682,392 | 669,613 |
For Funds with fiscal period ending May 31 | |||
Adaptive Risk Allocation Fund | 29,704,707 | 25,630,626 | 20,458,219 |
Commodity Strategy Fund | 2,732,246 | 2,176,511 | 1,934,695 |
Dividend Income Fund | 200,847,639 | 144,330,100 | 94,042,167 |
Dividend Opportunity Fund | 15,680,027 | 14,186,003 | 16,104,550 |
Flexible Capital Income Fund | 8,999,769 | 6,536,423 | 6,175,965 |
High Yield Bond Fund | 11,041,103 | 9,989,557 | 9,018,272 |
High Yield Municipal Fund | 4,108,904 | 3,940,655 | 4,277,480 |
Large Cap Value Fund | 17,262,181 | 13,600,050 | 12,117,312 |
MM Value Strategies Fund | 30,835,150 | 25,398,786 | 19,095,284 |
Mortgage Opportunities Fund | 26,779,541 | 14,245,789 | 10,789,319 |
Multi Strategy Alternatives Fund | 8,136,161 | 7,038,981 | 5,339,531 |
Quality Income Fund | 10,559,660 | 9,340,388 | 9,447,617 |
Select Large Cap Value Fund | 13,836,159 | 8,563,579 | 7,726,928 |
Select Small Cap Value Fund | 4,953,850 | 3,921,737 | 3,837,748 |
Seligman Technology and Information Fund | 89,255,818 | 71,805,854 | 54,491,686 |
For Funds with fiscal period ending July 31 | |||
Disciplined Core Fund | 29,279,467 | 28,285,302 | 26,833,909 |
Disciplined Growth Fund | 1,970,655 | 2,612,749 | 3,426,367 |
Disciplined Value Fund | 1,512,249 | 2,623,540 | 4,698,252 |
Floating Rate Fund | 5,627,756 | 4,241,794 | 5,195,218 |
Global Opportunities Fund | 3,492,229 | 3,877,653 | 3,644,588 |
Government Money Market Fund | 2,080,553 | 2,187,014 | 2,155,703 |
Income Opportunities Fund | 5,589,627 | 8,341,964 | 8,445,517 |
Large Cap Growth Fund | 32,952,655 | 31,137,330 | 23,896,337 |
Limited Duration Credit Fund | 4,309,472 | 4,175,452 | 3,027,073 |
MN Tax-Exempt Fund | 3,457,396 | 3,411,848 | 3,134,173 |
OR Intermediate Municipal Bond Fund | 1,640,959 | 1,668,598 | 1,650,284 |
Statement of Additional Information – April 27, 2023 | 111 |
Management Services Fees | |||
2022 | 2021 | 2020 | |
Strategic Municipal Income Fund | $12,118,281 | $11,629,815 | $10,034,164 |
Tax-Exempt Fund | 13,414,917 | 14,470,072 | 14,649,409 |
U.S. Social Bond Fund | 343,254 | 322,080 | 265,837 |
Ultra Short Term Bond Fund | 7,738,672 | 6,755,596 | 2,767,563 |
For Funds with fiscal period ending August 31 | |||
Balanced Fund | 49,506,664 | 47,511,078 | 39,932,542 |
Contrarian Core Fund | 73,066,834 | 71,031,504 | 59,086,521 |
Emerging Markets Bond Fund | 2,029,712 | 2,139,819 | 2,225,520 |
Emerging Markets Fund | 19,068,491 | 19,076,185 | 13,690,857 |
Global Technology Growth Fund | 21,893,401 | 22,485,851 | 14,948,888 |
Greater China Fund | 1,508,633 | 1,974,572 | 1,181,954 |
International Dividend Income Fund | 3,772,810 | 3,667,047 | 3,566,817 |
MM Alternative Strategies Fund | 5,796,605 | 5,432,519 | 5,185,136 |
MM International Equity Strategies Fund | 19,924,955 | 17,093,958 | 16,057,841 |
MM Small Cap Equity Strategies Fund | 11,665,000 | 10,905,194 | 12,819,923 |
MM Total Return Bond Strategies Fund | 46,955,056 | 45,359,904 | 38,877,170 |
Multisector Bond SMA Completion Portfolio(a) | N/A | N/A | N/A |
Overseas SMA Completion Portfolio(a) | N/A | N/A | N/A |
Select Mid Cap Growth Fund | 13,959,543 | 15,489,355 | 12,708,878 |
Small Cap Growth Fund | 18,758,335 | 21,574,770 | 8,018,595 |
Strategic Income Fund | 35,741,762 | 32,466,253 | 28,899,179 |
For Funds with fiscal period ending October 31 | |||
CT Intermediate Municipal Bond Fund | 383,819 | 452,491 | 465,339 |
Intermediate Duration Municipal Bond Fund | 8,757,991 | 5,258,981 | 5,537,465 |
MA Intermediate Municipal Bond Fund | 856,719 | 1,041,601 | 1,077,751 |
NY Intermediate Municipal Bond Fund | 870,240 | 1,044,472 | 1,082,482 |
Select Global Equity Fund | 6,074,722 | 6,566,989 | 4,733,259 |
Seligman Global Technology Fund | 16,750,008 | 16,590,135 | 11,495,912 |
Strategic CA Municipal Income Fund | 2,746,640 | 3,108,218 | 2,762,671 |
Strategic NY Municipal Income Fund | 819,579 | 933,745 | 922,358 |
For Funds with fiscal period ending December 31 | |||
Real Estate Equity Fund | 2,084,936 | 2,215,205 | 1,981,442 |
(a) | The Solution Series Funds do not pay a management services fee. |
Statement of Additional Information – April 27, 2023 | 112 |
Statement of Additional Information – April 27, 2023 | 113 |
Fund | Current Subadvisers | Parent Company/Other Information |
Fee Schedule or Aggregate Effective Fee Rate |
For Funds with fiscal period ending March 31 | |||
MM Growth Strategies Fund | JPMIM (effective October 3, 2022) Loomis Sayles (effective December 11, 2013) Los Angeles Capital (effective February 7, 2017) |
S A B |
0.218%(a) |
For Funds with fiscal period ending April 30 | |||
MM Directional Alternative Strategies Fund | Boston Partners (since commencement of operations) JPMIM (effective February 17, 2022) Allspring (since November 1, 2018) |
C S E |
0.856% |
For Funds with fiscal period ending May 31 | |||
Commodity Strategy Fund | Threadneedle (effective July 19, 2011) |
F | 0.250% on all assets |
MM Value Strategies Fund | DFA (effective December 11, 2013) Diamond Hill (effective September 14, 2016) |
G H |
0.117%(b) |
Multi Strategy Alternatives Fund | AQR (since September 24, 2019) PGIM Quantitative Solutions (since September 24, 2019) |
D I |
0.297% |
Statement of Additional Information – April 27, 2023 | 114 |
Fund | Current Subadvisers | Parent Company/Other Information |
Fee Schedule or Aggregate Effective Fee Rate |
For Funds with fiscal period ending August 31 | |||
MM Alternative Strategies Fund | AlphaSimplex (effective May 23, 2018) Crabel (effective January 12, 2022) Manulife (effective September 13, 2017) TCW (effective March 29, 2017) Water Island (since commencement of operations) |
J V K L M |
0.470% |
MM International Equity Strategies Fund | Arrowstreet (since commencement of operations) Baillie Gifford (since commencement of operations) Causeway (since commencement of operations) |
N O P |
0.393%(c) |
MM Small Cap Equity Strategies Fund | Conestoga (effective October 1, 2012) Hotchkis & Wiley (effective February 13, 2019) Jacobs Levy (effective July 18, 2022) JPMIM (effective December 19, 2018) |
Q R W S |
0.293%(d) |
MM Total Return Bond Strategies Fund | Loomis Sayles (effective April 11, 2016) PGIM (effective May 16, 2016) TCW (since commencement of operations) Voya (effective December 6, 2018) |
A T L U |
0.087%(e) |
For Funds with fiscal period ending October 31 | |||
Select Global Equity Fund | Threadneedle (effective July 9, 2004) |
F | 0.350% on all assets |
(a) | The rate shown is the estimated aggregate effective fee rate that will be paid by the Investment Manager to the subadvisers for the Fund beginning October 3, 2022. |
(b) | Effective on December 1, 2022, the subadvisory services fee rate for Diamond Hill changed. The rate shown is the estimated aggregate effective fee rate that will be paid by the Investment Manager to the subadvisers for the Fund beginning December 1, 2022. |
(c) | Effective on March 1, 2023, the subadvisory services fee rate for Causeway changed. The rate shown is the estimated aggregate effective fee rate that will be paid by the Investment Manager to the subadvisers for the Fund beginning March 1, 2023. |
Statement of Additional Information – April 27, 2023 | 115 |
(d) | Effective on November 1, 2020, the subadvisory services fee rate for Hotchkis & Wiley changed. The aggregate subadvisory services fee rate paid as of the Fund’s most recent fiscal year also includes fees paid to former subadviser, BMO Asset Management Corp. (BMO). BMO served as a subadviser to the Fund until December 16, 2021. |
(e) | Effective on November 1, 2022, the subadvisory services fee rate for PGIM and Voya changed. The rate shown is the estimated aggregate effective fee rate that will be paid by the Investment Manager to the subadvisers for the Fund beginning November 1, 2022. |
Statement of Additional Information – April 27, 2023 | 116 |
(a) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2020, 2021 and 2022, which amounted to 0.146%, 0.143% and 0.150%, respectively, of the Fund’s daily net assets during the applicable fiscal year. |
Statement of Additional Information – April 27, 2023 | 117 |
(b) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2020, 2021, and 2022 which amounted to 0.860%, 0.852%, and 0.856% respectively, of the Fund’s daily net assets during the applicable fiscal year. |
(c) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2020, 2021, and 2022 which amounted to 0.133%, 0.130%, and 0.127% respectively, of the Fund’s daily net assets during the applicable fiscal year. |
(d) | The fee shown represents the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers, which amounted to 0.202%, of the Fund’s daily net assets from September 24, 2019, when subadvisers began managing the Fund, to May 31, 2020, and 0.296% and 0.297% of the Fund’s daily net assets during the 2021 and 2022 fiscal year, respectively. |
(e) | Threadneedle provided services to the Fund pursuant to the subadvisory agreement through December 9, 2019. Accordingly, the amount shown is for the period from June 1, 2019 to December 9, 2019. |
(f) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2020, 2021, and 2022 which amounted to 0.477%, 0.475%, and 0.470% respectively, of the Fund’s daily net assets during the applicable fiscal year. |
(g) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2020, 2021, and 2022 which amounted to 0.326%, 0.323%, and 0.293% respectively, of the Fund’s daily net assets during the applicable fiscal year. |
(h) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2020, 2021, and 2022 which amounted to 0.094%, 0.091%, and 0.091% respectively, of the Fund’s daily net assets during the applicable fiscal year. |
(i) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2020, 2021, and 2022 which amounted to 0.409%, 0.405%, and 0.398% respectively, of the Fund’s daily net assets during the applicable fiscal year. |
(j) | Threadneedle provided services to the Fund pursuant to the subadvisory agreement through December 14, 2020. Accordingly, the amount shown is for the period from November 1, 2020 to December 14, 2020. |
Statement of Additional Information – April 27, 2023 | 118 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Capital Allocation Moderate Portfolio |
Dan Boncarosky | 6 RICs 3 PIVs 28 other accounts |
$4.99 billion $0.20 million $32.14 million |
None | None | Columbia Management – FoF |
Columbia Management |
Thomas Nakamura(g) | 3 other accounts |
$0.46 million | None | None | |||
Income Builder Fund |
Alex Christensen | 6 RICs 2 PIVs 121 other accounts |
$16.39 billion $182.79 million $1.31 billion |
None | None | Columbia Management – IB |
Columbia Management |
Gene Tannuzzo | 7 RICs 2 PIVs 63 other accounts |
$17.56 billion $182.79 million $1.82 billion |
None | $100,001 – $500,000(a) | |||
For Funds with fiscal year ending February 28/29 – Information is as of February 28, 2022, unless otherwise noted | |||||||
Convertible Securities Fund |
Yan Jin | 4 RICs 12 other accounts |
$6.73 billion $34.40 million |
None | Over $1,000,000(a) $50,001 – $100,000(b) |
Columbia Management | Columbia Management |
David King | 4 RICs 8 other accounts |
$6.73 billion $59.92 million |
None | Over $1,000,000(a) $100,001 – $500,000(b) | |||
Grace Lee | 4 RICs 10 other accounts |
$6.73 billion $31.22 million |
None | $50,001 – $100,000(a) $10,001 – $50,000(b) | |||
Global Value Fund |
Fred Copper | 6 RICs 1 PIV 21 other accounts |
$8.15 billion $103.62 million $192.21 million |
None | $50,001 – $100,000(b) |
Columbia Management | Columbia Management |
Melda Mergen | 5 RICs 1 PIV 16 other accounts |
$12.52 billion $30.55 million $748.13 million |
None | None | |||
Peter Schroeder | 5 other accounts |
$1.00 million | None | $50,001 – $100,000(b) | |||
Large Cap Enhanced Core Fund |
Oleg Nusinzon | 6 RICs 22 other accounts |
$11.59 billion $7.19 billion |
None | None | Columbia Management | Columbia Management |
Raghavendran Sivaraman | 6 RICs 18 other accounts |
$11.59 billion $7.20 billion |
1 other account ($322.46 M) |
None | |||
Large Cap Growth Opportunity Fund |
Nicolas Janvier | 1 RIC 10 PIVs 16 other accounts |
$32.64 million $8.41 billion $5.11 billion |
1 PIV ($24.99 M) 4 other accounts ($556.90 M) |
None(c) | Columbia Management/ Threadneedle |
Threadneedle |
Statement of Additional Information – April 27, 2023 | 119 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Large Cap Index Fund |
Christopher Lo | 10 RICs 1 PIV 30 other accounts |
$9.23 billion $10.58 million $2.32 billion |
None | $50,001 – $100,000(b) |
Columbia Management | Columbia Management |
Kaiyu Zhao | 3 RICs 1 PIV 4 other accounts |
$8.84 billion $10.58 million $0.20 million |
None | None | |||
Mid Cap Index Fund |
Christopher Lo | 10 RICs 1 PIV 30 other accounts |
$9.70 billion $10.58 million $2.32 billion |
None | $10,001 – $50,000(b) |
Columbia Management | Columbia Management |
Kaiyu Zhao | 3 RICs 1 PIV 4 other accounts |
$9.31 billion $10.58 million $0.20 million |
None | None | |||
Overseas Core Fund |
Fred Copper | 6 RICs 1 PIV 21 other accounts |
$8.13 billion $103.62 million $192.21 million |
None | $10,001 – $50,000(b) |
Columbia Management | Columbia Management |
Daisuke Nomoto | 5 RICs 2 PIVs 15 other accounts |
$7.14 billion $1.28 billion $23.08 million |
None | $100,001 – $500,000(b) | |||
Overseas Value Fund |
Fred Copper | 6 RICs 1 PIV 21 other accounts |
$6.39 billion $103.62 million $192.21 million |
None | $100,001 – $500,000(b) |
Columbia Management | Columbia Management |
Daisuke Nomoto | 5 RICs 2 PIVs 15 other accounts |
$5.41 billion $1.28 billion $23.08 million |
None | None | |||
Select Large Cap Equity Fund |
Melda Mergen | 5 RICs 1 PIV 16 other accounts |
$12.13 billion $30.55 million $748.13 million |
None | $500,001 – $1,000,000(a) $100,001 – $500,000(b) |
Columbia Management | Columbia Management |
Tiffany Wade | 4 RICs 1 PIV 17 other accounts |
$11.16 billion $30.55 million $744.31 million |
None | $10,001 – $50,000(b) | |||
Select Mid Cap Value Fund |
Kari Montanus | 3 RICs 12 other accounts |
$1.01 billion $8.06 million |
None | $1 – $10,000(a) $10,001 – $50,000(b) |
Columbia Management | Columbia Management |
Jonas Patrikson | 3 RICs 14 other accounts |
$1.01 billion $6.49 million |
None | $10,001 – $50,000(a) $10,001 – $50,000(b) | |||
Small Cap Index Fund |
Christopher Lo | 10 RICs 1 PIV 30 other accounts |
$8.59 billion $10.58 million $2.32 billion |
None | $10,001 – $50,000(b) |
Columbia Management | Columbia Management |
Kaiyu Zhao | 3 RICs 1 PIV 4 other accounts |
$8.19 billion $10.58 million $0.20 million |
None | None |
Statement of Additional Information – April 27, 2023 | 120 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Small Cap Value Fund II |
Jarl Ginsberg | 2 RICs 1 PIV 87 other accounts |
$517.55 million $117.92 million $70.08 million |
None | $1 – $10,000(a) $100,001 – $500,000(b) |
Columbia Management | Columbia Management |
Christian Stadlinger | 2 RICs 1 PIV 86 other accounts |
$517.55 million $117.92 million $78.94 million |
None | Over $1,000,000(a) | |||
For Funds with fiscal year ending March 31 – Information is as of March 31, 2022, unless otherwise noted | |||||||
Adaptive Retirement 2020 Fund |
Joshua Kutin | 32 RICs 6 PIVs 29 other accounts |
$73.19 billion $0.38 million $6.73 million |
None | $100,001 – $500,000(a) |
Columbia Management | Columbia Management |
Alexander Wilkinson | 11 RICs 3 PIVs 4 other accounts |
$4.41 billion $0.18 million $0.11 million |
None | None | |||
Adaptive Retirement 2025 Fund |
Joshua Kutin | 32 RICs 6 PIVs 29 other accounts |
$73.19 billion $0.38 million $6.73 million |
None | $100,001 – $500,000(a) |
Columbia Management | Columbia Management |
Alexander Wilkinson | 11 RICs 3 PIVs 4 other accounts |
$4.41 billion $0.18 million $0.11 million |
None | None | |||
Adaptive Retirement 2030 Fund |
Joshua Kutin | 32 RICs 6 PIVs 29 other accounts |
$73.18 billion $0.38 million $6.73 million |
None | None | Columbia Management | Columbia Management |
Alexander Wilkinson | 11 RICs 3 PIVs 4 other accounts |
$4.41 billion $0.18 million $0.11 million |
None | None | |||
Adaptive Retirement 2035 Fund |
Joshua Kutin | 32 RICs 6 PIVs 29 other accounts |
$73.19 billion $0.38 million $6.73 million |
None | None | Columbia Management | Columbia Management |
Alexander Wilkinson | 11 RICs 3 PIVs 4 other accounts |
$4.41 billion $0.18 million $0.11 million |
None | None | |||
Adaptive Retirement 2040 Fund |
Joshua Kutin | 32 RICs 6 PIVs 29 other accounts |
$73.19 billion $0.38 million $6.73 million |
None | None | Columbia Management | Columbia Management |
Alexander Wilkinson | 11 RICs 3 PIVs 4 other accounts |
$4.41 billion $0.18 million $0.11 million |
None | None |
Statement of Additional Information – April 27, 2023 | 121 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Adaptive Retirement 2045 Fund |
Joshua Kutin | 32 RICs 6 PIVs 29 other accounts |
$73.19 billion $0.38 million $6.73 million |
None | $100,001 – $500,000(a) |
Columbia Management | Columbia Management |
Alexander Wilkinson | 11 RICs 3 PIVs 4 other accounts |
$4.41 billion $0.18 million $0.11 million |
None | None | |||
Adaptive Retirement 2050 Fund |
Joshua Kutin | 32 RICs 6 PIVs 29 other accounts |
$73.19 billion $0.38 million $6.73 million |
None | None | Columbia Management | Columbia Management |
Alexander Wilkinson | 11 RICs 3 PIVs 4 other accounts |
$4.41 billion $0.18 million $0.11 million |
None | None | |||
Adaptive Retirement 2055 Fund |
Joshua Kutin | 32 RICs 6 PIVs 29 other accounts |
$73.19 billion $0.38 million $6.73 million |
None | $100,001 – $500,000(a) |
Columbia Management | Columbia Management |
Alexander Wilkinson | 11 RICs 3 PIVs 4 other accounts |
$4.41 billion $0.18 million $0.11 million |
None | None | |||
Adaptive Retirement 2060 Fund |
Joshua Kutin | 32 RICs 6 PIVs 29 other accounts |
$73.19 billion $0.38 million $6.73 million |
None | $100,001 – $500,000(a) |
Columbia Management | Columbia Management |
Alexander Wilkinson | 11 RICs 3 PIVs 4 other accounts |
$4.41 billion $0.18 million $0.11 million |
None | $1 – $10,000(a) | |||
MM Growth Strategies Fund |
JPMIM: Giri Devulapally(g) |
5 RICs 6 PIVs 26 other accounts |
$36.53 billion $3.14 billion $9.63 billion |
None |
None |
JPMIM |
JPMIM |
Holly Fleiss(g) | 4 RICs 3 PIVs 22 other accounts |
$36.17 billion $6.43 billion $7.95 billion |
1 other account ($1.56 B) |
None | |||
Larry Lee(g) | 5 RICs 2 PIVs 22 other accounts |
$49.80 billion $3.08 billion $7.95 billion |
None | None | |||
Robert Maloney(h) | None | None | None | None | |||
Joseph Wilson(g) | 4 RICs 3 PIVs 27 other accounts |
$36.17 billion $8.09 billion $10.71 billion |
None | None |
Statement of Additional Information – April 27, 2023 | 122 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Loomis Sayles: Aziz Hamzaogullari |
32 RICs 20 PIVs 137 other accounts |
$30.61 billion $13.66 billion $32.07 billion |
2 PIVs ($430.75 M) 1 other account ($350.77 M) |
None |
Loomis Sayles |
Loomis Sayles | |
Los Angeles Capital: Daniel Allen |
11 RICs 19 PIVs 34 other accounts |
$1.22 billion $12.69 billion $14.13 billion |
4 PIVs ($1.05 B) 7 other accounts ($9.32 B) |
None |
Los Angeles Capital |
Los Angeles Capital | |
Daniel Arche | 6 RICs 5 PIVs 12 other accounts |
$472.17 million $1.90 billion $2.13 billion |
2 PIVs ($585.37 M) |
None | |||
Hal Reynolds | 15 RICs 19 PIVs 42 other accounts |
$6.30 billion $12.69 billion $14.15 billion |
1 RIC (4.19 B) 4 PIVs ($1.05 B) 7 other accounts ($9.32 B) |
None | |||
Thomas Stevens | 10 RICs 19 PIVs 31 other accounts |
$5.55 billion $12.69 billion $14.13 billion |
1 RIC ($4.19 B) 4 PIVs ($1.05 B) 7 other accounts ($9.32 B) |
None | |||
Select Large Cap Growth Fund |
Richard Carter | 3 RICs 1 PIV 1,007 other accounts |
$2.27 billion $457.47 million $1.34 billion |
None | $100,001 – $500,000(a) $50,001 – $100,000(b) |
Columbia Management | Columbia Management |
Thomas Galvin | 3 RICs 1 PIV 1,008 other accounts |
$2.27 billion $457.47 million $1.37 billion |
None | Over $1,000,000(a) $50,001 – $100,000(b) | |||
Todd Herget | 3 RICs 1 PIV 1,010 other accounts |
$2.27 billion $457.47 million $1.34 billion |
None | $100,001 – $500,000(b) | |||
Short Term Bond Fund |
Gregory Liechty | 6 RICs 8 PIVs 58 other accounts |
$7.44 billion $2.07 billion $6.20 billion |
None | $50,001 – $100,000(b) |
Columbia Management | Columbia Management |
Ronald Stahl | 6 RICs 8 PIVs 55 other accounts |
$7.44 billion $2.07 billion $6.49 billion |
None | $50,001 – $100,000(a) $1 – $10,000(b) |
Statement of Additional Information – April 27, 2023 | 123 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Solutions Aggressive Portfolio |
Joshua Kutin | 32 RICs 6 PIVs 29 other accounts |
$73.18 billion $0.38 million $6.73 million |
None | None | Columbia Management | Columbia Management |
Alexander Wilkinson | 11 RICs 3 PIVs 4 other accounts |
$4.40 billion $0.18 million $0.11 million |
None | None | |||
Solutions Conservative Portfolio |
Joshua Kutin | 32 RICs 6 PIVs 29 other accounts |
$73.18 billion $0.38 million $6.73 million |
None | None | Columbia Management | Columbia Management |
Alexander Wilkinson | 11 RICs 3 PIVs 4 other accounts |
$4.40 billion $0.18 million $0.11 million |
None | None | |||
For Funds with fiscal year ending April 30 – Information is as of April 30, 2022, unless otherwise noted | |||||||
Bond Fund | Jason Callan | 13 RICs 10 PIVs 74 other accounts |
$24.56 billion $18.15 billion $1.61 billion |
None | None | Columbia Management | Columbia Management |
Alex Christensen | 6 RICs 2 PIVs 133 other accounts |
$15.00 billion $200.61 million $1.25 billion |
None | None | |||
Gene Tannuzzo | 7 RICs 2 PIVs 76 other accounts |
$15.89 billion $200.61 million $1.70 billion |
None | None | |||
CA Intermediate Municipal Bond Fund |
Paul Fuchs | 8 RICs 6 other accounts |
$3.07 billion $12.40 million |
None | None | Columbia Management | Columbia Management |
Douglas Rangel(f) | 4 other accounts |
$0.21 million | None | None | |||
Corporate Income Fund |
John Dawson | 7 RICs 1 PIV 25 other accounts |
$4.12 billion $38.34 million $2.93 billion |
None | $10,001 – $50,000(a) |
Columbia Management | Columbia Management |
Tom Murphy | 9 RICs 16 PIVs 31 other accounts |
$4.21 billion $15.55 billion $2.94 billion |
None | $100,001 – $500,000(a) |
|||
Shannon Rinehart | 3 RICs 1 PIV 26 other accounts |
$4.08 billion $38.34 million $2.93 billion |
None | $1– $10,000(b) |
|||
Royce Wilson | 7 RICs 1 PIV 22 other accounts |
$4.12 billion $38.34 million $2.93 billion |
None | $50,001 – $100,000(b) |
|||
MM Directional Alternative Strategies Fund |
JPMIM: Rick Singh |
3 RICs 1 PIV 2 other accounts |
$637.60 million $0.04 million $337.20 million |
1 PIV (426.10 M) |
None |
JPMIM |
JPMIM |
Statement of Additional Information – April 27, 2023 | 124 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Boston Partners: Scott Burgess(j) |
1 RIC |
$774.6 million |
None |
None |
Boston Partners |
Boston Partners | |
Joseph Feeney, Jr. | 6 RICs 12 PIVs 16 other accounts |
$1.27 billion $7.19 billion $1.74 billion |
None | None | |||
Allspring: Harindra de Silva |
14 RICs 17 PIVs 14 other accounts |
$4.69 billion $928.65 million $3.23 billion |
3 PIVs ($38.01 M) 1 other account ($18.89 M) |
None |
Allspring |
Allspring | |
David Krider | 5 RICs 10 PIVs 4 other accounts |
$1.58 billion $648.96 million $826.54 million |
3 PIVs ($38.01 M) 1 other account ($18.89 M) |
None | |||
NC Intermediate Municipal Bond Fund |
Paul Fuchs | 8 RICs 6 other accounts |
$3.32 billion $12.40 million |
None | None | Columbia Management | Columbia Management |
Douglas Rangel(f) | 4 other accounts |
$0.21 million | None | None | |||
SC Intermediate Municipal Bond Fund |
Paul Fuchs | 8 RICs 6 other accounts |
$3.38 billion $12.40 million |
None | None | Columbia Management | Columbia Management |
Douglas Rangel(f) | 4 other accounts |
$0.21 million | None | None | |||
Short Duration Municipal Bond Fund |
Douglas Rangel(f) | 4 other accounts |
$0.21 million | None | $10,001 – $50,000(b) |
Columbia Management | Columbia Management |
Catherine Stienstra | 8 RICs 3 other accounts |
$7.67 billion $1.47 million |
None | None | |||
Small Cap Value Fund I |
Jeremy Javidi | 1 RIC 1 PIV 10 other accounts |
$562.34 million $405.58 million $25.53 million |
None | Over $1,000,000(a) |
Columbia Management | Columbia Management |
Total Return Bond Fund |
Jason Callan | 13 RICs 10 PIVs 74 other accounts |
$22.36 billion $18.15 billion $1.61 billion |
None | $50,001 – $100,000(a) |
Columbia Management | Columbia Management |
Alex Christensen | 6 RICs 2 PIVs 133 other accounts |
$12.81 billion $200.61 million $1.25 billion |
None | $50,001 – $100,000(a) |
|||
Gene Tannuzzo | 7 RICs 2 PIVs 76 other accounts |
$13.69 billion $200.61 billion $1.70 billion |
None | $100,001 – $500,000(a) $100,001 – $500,000(b) |
|||
U.S. Treasury Index Fund |
Alan Erickson | 38 other accounts |
$2.30 billion | None | $10,001 – $50,000(b) |
Columbia Management | Columbia Management |
VA Intermediate Municipal Bond Fund |
Paul Fuchs | 8 RICs 6 other accounts |
$3.37 billion $12.40 million |
None | None | Columbia Management | Columbia Management |
Douglas Rangel(f) | 4 other accounts |
$0.21 million | None | None |
Statement of Additional Information – April 27, 2023 | 125 |
Statement of Additional Information – April 27, 2023 | 126 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Flexible Capital Income Fund |
Yan Jin | 4 RICs 12 other accounts |
$7.01 billion $26.68 million |
None | $500,001 – $1,000,000(a) $50,001 – $100,000(b) |
Columbia Management | Columbia Management |
David King | 4 RICs 8 other accounts |
$7.01 billion $50.95 million |
None | Over $1,000,000(a) $100,001 – $500,000(b) | |||
Grace Lee | 4 RICs 10 other accounts |
$7.01 billion $24.07 million |
None | $50,001 – $100,000(a) $50,001 – $100,000(b) | |||
High Yield Bond Fund |
Daniel DeYoung | 4 RICs 2 PIVs 10 other accounts |
$2.28 billion $7.37 billion $774.37 million |
None | $100,001 – $500,000(a) $1 – $10,000(b) |
Columbia Management | Columbia Management |
Brian Lavin | 5 RICs 1 PIV 18 other accounts |
$1.26 billion $130.04 million $2.92 billion |
None | $100,001 – $500,000(b) | |||
High Yield Municipal Fund |
Catherine Stienstra | 9 RICs 3 other accounts |
$7.68 billion $1.68 million |
None | $10,001 – $50,000(a) $10,001 – $50,000(b) |
Columbia Management | Columbia Management |
Douglas White | 5 RICs 8 other accounts |
$6.33 billion $9.33 million |
None | $50,001 – $100,000(a) $50,001 – $100,000(b) | |||
Large Cap Value Fund |
Hugh Mullin | 7 other accounts |
$8.45 million | None | $100,001 – $500,000(b) |
Columbia Management | Columbia Management |
MM Value Strategies Fund |
Columbia Management: Michael Barclay |
3 RICs 1 PIV 136 other accounts |
$37.78 billion $1.32 billion $2.62 billion |
None |
None |
Columbia Management |
Columbia Management |
Scott Davis(e) | 1 RIC 1 PIV 137 other accounts |
$37.75 billion $1.32 billion $2.58 billion |
None | None | |||
Tara Gately | 1 RIC 1 PIV 34 other accounts |
$37.75 billion $1.32 billion $2.42 billion |
None | None | |||
DFA: Jed Fogdall |
119 RICs 28 PIVs 313 other accounts |
$432.22 billion $22.26 billion $26.69 billion |
1 PIV ($194.77 M) 4 other accounts ($2.01 B) |
None |
DFA |
DFA | |
John Hertzer | 24 RICs 3 PIVs 6 other accounts |
$157.20 billion $3.99 billion $9.61 billion |
None | None |
Statement of Additional Information – April 27, 2023 | 127 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Joel Schneider | 54 RICs 7 PIVs 1 other account |
$141.22 billion $1.22 billion $241.41 million |
None | None | |||
Diamond Hill: Charles Bath |
3 RICs 2 PIVs 106 other accounts |
$11.06 billion $823.00 million $5.40 billion |
1 other account ($479.00 M) |
None |
Diamond Hill |
Diamond Hill | |
Austin Hawley | 4 RICs 2 PIVs 114 other accounts |
$11.47 billion $823.00 million $5.46 billion |
1 other account ($479.00 M) |
None | |||
Mortgage Opportunities Fund |
Jason Callan | 13 RICs 10 PIVs 74 other accounts |
$20.30 billion $18.38 billion $1.61 billion |
None | $100,001 – $500,000(a) Over $1,000,000(b) |
Columbia Management | Columbia Management |
Tom Heuer | 3 RICs 5 other accounts |
$2.98 billion $5.52 million |
None | $100,001 – $500,000(a) $100,001 – $500,000(b) |
|||
Ryan Osborn | 3 RICs 6 other accounts |
$2.98 billion $3.53 million |
None | $500,001 – $1,000,000(a) $50,001 – $100,000(b) |
|||
Multi Strategy Alternatives Fund |
Dan Boncarosky | 6 RICs 3 PIVs 28 other accounts |
$5.66 billion $0.19 million $28.96 million |
None | None | Columbia Management | Columbia Management |
Jason Callan | 13 RICs 10 PIVs 74 other accounts |
$23.94 billion $18.38 billion $1.61 billion |
None | None | |||
Matthew Ferrelli | 2 RICs 4 other accounts |
$607.61 million $156.29 million |
None | $1– $10,000(b) |
|||
Tom Heuer | 3 RICs 5 other accounts |
$6.62 billion $5.52 million |
None | None | |||
Marc Khalamayzer | 2 RICs 9 other accounts |
$607.61 million $156.63 million |
None | $10,001 – $50,000(b) |
|||
Joshua Kutin | 34 RICs 6 PIVs 29 other accounts |
$66.19 billion $0.37 million $6.37 million |
None | None | |||
Corey Lorenzen | 1 RIC 8 other accounts |
$0.00 $0.98 million |
None | None | |||
Ryan Osborn | 3 RICs 6 other accounts |
$6.62 billion $3.53 million |
None | None | |||
Brian Virginia | 15 RICs 9 other accounts |
$61.84 billion $3.63 million |
None | None |
Statement of Additional Information – April 27, 2023 | 128 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
AQR: Jordan Brooks |
1 RIC 1 PIV |
$56.26 million $42.53 million |
1 PIV ($42.53 M) |
None |
AQR |
AQR | |
Jonathan Fader | 2 PIVs | $776.45 million | 2 PIVs ($776.45 M) |
None | |||
Lars Nielsen | 26 RICs 24 PIVs 19 other accounts |
$15.40 billion $8.58 billion $9.69 billion |
1 RIC ($129.03 M) 21 PIVs ($6.92 B) 8 other accounts ($5.11 B) |
None | |||
Yao Hua Ooi | 8 RICs 21 PIVs |
$4.73 billion $8.57 billion |
19 PIVs ($8.18 B) |
None | |||
PGIM Quantitative Solutions: Marco Aiolfi |
35 RICs 7 PIVs 11 other accounts |
$58.88 billion $2.31 billion $788.56 million |
None |
None |
PGIM Quantitative Solutions |
PGIM Quantitative Solutions | |
Edward Tostanoski III(g) | 38 RICs 7 PIVs 12 other accounts |
$60.93 billion $2.32 billion $850.46 million |
None | None | |||
Quality Income Fund |
Jason Callan | 13 RICs 10 PIVs 74 other accounts |
$22.50 billion $18.38 billion $1.61 billion |
None | None | Columbia Management | Columbia Management |
Tom Heuer | 3 RICs 5 other accounts |
$5.17 billion $5.52 million |
None | $100,001 – $500,000(a) $50,001 – $100,000(b) | |||
Ryan Osborn | 3 RICs 6 other accounts |
$5.17 billion $3.53 million |
None | $50,001 – $100,000(b) | |||
Select Large Cap Value Fund |
Richard Rosen | 2 RICs 1 PIV 396 other accounts |
$2.71 billion $145.24 million $3.78 billion |
None | $100,001 – $500,000(a) |
Columbia Management | Columbia Management |
Richard Taft | 2 RICs 1 PIV 398 other accounts |
$2.71 billion $145.24 million $3.77 billion |
None | $100,001 – $500,000(a) $10,001 – $50,000(b) | |||
Select Small Cap Value Fund |
Kari Montanus | 3 RICs 12 other accounts |
$3.16 billion $7.76 million |
None | None | Columbia Management | Columbia Management |
Jonas Patrikson | 3 RICs 14 other accounts |
$3.16 billion $6.27 million |
None | $10,001 – $50,000(b) | |||
Seligman Technology and Information Fund |
Sanjay Devgan | 3 RICs 4 other accounts |
$1.91 billion $6.53 million |
None | $500,001 – $1,000,000(a) |
Columbia Management | Columbia Management– Tech Team |
Israel Hernandez | 4 other accounts |
$0.39 million | None | None |
Statement of Additional Information – April 27, 2023 | 129 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Jeetil Patel | 1 RIC 8 other accounts |
$459.86 million $6.26 million |
None | None | |||
Vimal Patel | 3 RICs 8 other accounts |
$2.36 billion $9.07 million |
None | $100,001 – $500,000(a) |
|||
Shekhar Pramanick | 4 RICs 6 other accounts |
$2.37 billion $11.33 million |
None | Over $1,000,000(a) |
|||
Paul Wick | 4 RICs 3 PIVs 7 other accounts |
$2.37 billion $2.03 billion $608.76 million |
2 PIVs ($1.45 B) 1 other account ($169.62 M) |
Over $1,000,000(a) |
|||
For Funds with fiscal year ending July 31 – Information is as of July 31, 2022, unless otherwise noted | |||||||
Disciplined Core Fund |
Oleg Nusinzon | 6 RICs 22 other accounts |
$6.65 billion $6.76 billion |
None | $10,001 – $50,000(b) |
Columbia Management | Columbia Management |
Raghavendran Sivaraman | 6 RICs 17 other accounts |
$6.65 billion $6.76 billion |
1 other account ($297.81 M) |
$10,001 – $50,000(b) | |||
Disciplined Growth Fund |
Oleg Nusinzon | 6 RICs 22 other accounts |
$10.68 billion $6.76 billion |
None | None | Columbia Management | Columbia Management |
Raghavendran Sivaraman | 6 RICs 17 other accounts |
$10.68 billion $6.76 billion |
1 other account ($297.81 M) |
None | |||
Disciplined Value Fund |
Oleg Nusinzon | 6 RICs 22 other accounts |
$10.70 billion $6.76 billion |
None | None | Columbia Management | Columbia Management |
Raghavendran Sivaraman | 6 RICs 17 other accounts |
$10.70 billion $6.76 billion |
1 other account ($297.81 M) |
$10,001 – $50,000(b) | |||
Floating Rate Fund |
Daniel DeYoung | 4 RICs 2 PIVs 9 other accounts |
$2.67 billion $7.93 billion $751.00 million |
None | $10,001 – $50,000(b) |
Columbia Management | Columbia Management |
Vesa Tontti | 10 other accounts |
$3.35 million | None | $10,001 – $50,000(a) $10,001 – $50,000(b) | |||
Global Opportunities Fund |
Dan Boncarosky | 6 RICs 3 PIVs 38 other accounts |
$5.09 billion $0.19 million $139.02 million |
None | $1 – $10,000(b) |
Columbia Management | Columbia Management |
Thomas Nakamura(d) | 3 other accounts |
$0.46 million | None | None | |||
Income Opportunities Fund |
Daniel DeYoung | 4 RICs 2 PIVs 9 other accounts |
$2.85 billion $7.93 billion $751.00 million |
None | None | Columbia Management | Columbia Management |
Brian Lavin | 5 RICs 19 other accounts |
$1.91 billion $2.88 billion |
None | $100,001 – $500,000(a) $10,001 – $50,000(b) |
Statement of Additional Information – April 27, 2023 | 130 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Large Cap Growth Fund |
Melda Mergen | 5 RICs 1 PIV 16 other accounts |
$7.78 billion $28.48 million $605.64 million |
None | $100,001 – $500,000(a) |
Columbia Management | Columbia Management |
Tiffany Wade | 4 RICs 1 PIV 17 other accounts |
$6.90 billion $28.48 million $602.24 million |
None | $50,001 – $100,000(b) | |||
Limited Duration Credit Fund |
John Dawson | 7 RICs 1 PIV 24 other accounts |
$4.48 billion $44.72 million $2.67 billion |
None | $10,001 – $50,000(a) $100,001 – $500,000(b) |
Columbia Management | Columbia Management |
Tom Murphy | 9 RICs 17 PIVs 31 other accounts |
$4.57 billion $21.70 billion $2.69 billion |
None | Over $1,000,000(a) Over $1,000,000(b) |
|||
Shannon Rinehart | 3 RICs 1 PIV 26 other accounts |
$4.43 billion $44.72 million $2.67 billion |
None | $10,001 – $50,000(b) |
|||
Royce Wilson | 7 RICs 1 PIV 22 other accounts |
$4.48 billion $44.72 million $2.67 billion |
None | $50,001 – $100,000(a) $10,001 – $50,000(b) |
|||
MN Tax-Exempt Fund |
Catherine Stienstra | 9 RICs 3 other accounts |
$7.47 billion $1.67 million |
None | None | Columbia Management | Columbia Management |
Douglas White | 5 RICs 11 other accounts |
$6.13 billion $147.07 million |
None | $50,001 – $100,000(a) | |||
OR Intermediate Municipal Bond Fund |
Paul Fuchs | 8 RICs 7 other accounts |
$2.88 billion $12.59 million |
None | None | Columbia Management | Columbia Management |
Douglas Rangel | 11 RICs 5 other accounts |
$4.15 billion $84.62 million |
None | None | |||
Strategic Municipal Income Fund |
Catherine Stienstra | 9 RICs 3 other accounts |
$5.97 billion $1.67 million |
None | $100,001 – $500,000(a) $50,001 – $100,000(b) |
Columbia Management | Columbia Management |
Douglas White | 5 RICs 11 other accounts |
$4.63 billion $147.07 million |
None | $50,001 – $100,000(b) | |||
Tax-Exempt Fund |
Catherine Stienstra | 9 RICs 3 other accounts |
$5.47 billion $1.67 million |
None | $100,001 – $500,000(a) $10,001 – $50,000(b) |
Columbia Management | Columbia Management |
Douglas White | 5 RICs 11 other accounts |
$4.13 billion $147.07 million |
None | None |
Statement of Additional Information – April 27, 2023 | 131 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
U.S. Social Bond Fund |
Tom Murphy | 9 RICs 17 PIVs 31 other accounts |
$5.21 billion $21.70 billion $2.69 billion |
None | None | Columbia Management | Columbia Management |
Catherine Stienstra | 9 RICs 3 other accounts |
$8.06 billion $1.67 million |
None | None | |||
Ultra Short Term Bond Fund |
Gregory Liechty | 6 RICs 8 PIVs 57 other accounts |
$4.94 billion $1.98 billion $5.07 billion |
None | $50,001– $100,000(b) |
Columbia Management | Columbia Management |
Ronald Stahl | 6 RICs 8 PIVs 60 other accounts |
$4.94 billion $1.98 billion $5.35 billion |
None | $100,001 – $500,000 (a) $1 – $10,000(b) | |||
For Funds with fiscal year ending August 31 – Information is as of August 31, 2022, unless otherwise noted | |||||||
Balanced Fund |
Jason Callan | 13 RICs 10 PIVs 12 other accounts |
$19.82 billion $21.92 billion $1.51 billion |
None | None | Columbia Management | Columbia Management |
Gregory Liechty | 6 RICs 8 PIVs 57 other accounts |
$4.70 billion $1.95 billion $4.99 billion |
None | None | |||
Guy Pope | 8 RICs 7 PIVs 87 other accounts |
$12.92 billion $1.08 billion $3.52 billion |
None | $100,001 – $500,000(a) |
|||
Ronald Stahl | 6 RICs 8 PIVs 60 other accounts |
$4.70 billion $1.95 billion $5.28 billion |
None | $100,001 – $500,000(a) $10,001 – $50,000(b) |
|||
Contrarian Core Fund |
Guy Pope | 8 RICs 7 PIVs 87 other accounts |
$6.95 billion $1.08 billion $3.52 billion |
None | Over $1,000,000(a) |
Columbia Management | Columbia Management |
Emerging Markets Bond Fund |
Christopher Cooke | 1 RIC 5 PIVs 15 other accounts |
$417.83 million $2.53 billion $717.93 million |
None | None(c) | Columbia Management/ Threadneedle |
Threadneedle |
Adrian Hilton | 2 RICs 5 PIVs 18 other accounts |
$502.50 million $2.53 billion $717.93 million |
None | None(c) | |||
Emerging Markets Fund |
Robert Cameron | 2 RICs 7 PIVs 19 other accounts |
$292.02 million $2.02 billion $1.32 billion |
None | $10,001 – $50,000(b) |
Columbia Management | Columbia Management |
Derek Lin | 3 RICs 7 PIVs 18 other accounts |
$425.37 million $2.02 billion $1.32 billion |
None | $10,001 – $50,000(a) $10,001 – $50,000(b) |
|||
Darren Powell | 2 RICs 7 PIVs 12 other accounts |
$292.02 million $2.02 billion $1.32 billion |
None | $50,001 – $100,000(b) |
Statement of Additional Information – April 27, 2023 | 132 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Perry Vickery | 2 RICs 7 PIVs 20 other accounts |
$292.02 million $2.02 billion $1.68 billion |
None | $50,001 – $100,000(a) $50,001 – $100,000(b) |
|||
Dara White | 3 RICs 7 PIVs 14 other accounts |
$425.37 million $2.02 billion $1.32 billion |
None | $500,001 – $1,000,000(a) $100,001 – $500,000(b) |
|||
Global Technology Growth Fund |
Rahul Narang | 8 other accounts |
$237.44 million | None | $100,001 – $500,000(b) |
Columbia Management | Columbia Management |
Greater China Fund |
Derek Lin | 3 RICs 7 PIVs 18 other accounts |
$1.81 billion $2.02 billion $1.32 billion |
None | $10,001 – $50,000(a) $10,001 – $50,000(b) |
Columbia Management | Columbia Management |
Dara White | 3 RICs 7 PIVs 14 other accounts |
$1.81 billion $2.02 billion $1.32 billion |
None | $100,001 – $500,000(a) $50,001 – $100,000(b) | |||
International Dividend Income Fund |
Jonathan Crown | 1 PIV 5 other accounts |
$175.44 million $8.58 billion |
None | None(c) | Columbia Management/ Threadneedle |
Threadneedle |
Georgina Hellyer | 1 PIV 3 other accounts |
$175.44 million $660.26 million |
None | None(c) | |||
MM Alternative Strategies Fund |
AlphaSimplex: Alexander Healy |
3 RICs 2 PIVs 8 other accounts |
$3.60 billion $922.49 million $1.70 billion |
1 PIV ($780.00 M) |
None |
AlphaSimplex |
AlphaSimplex |
Kathryn Kaminski | 3 RICs 2 PIVs 5 other accounts |
$3.60 billion $922.49 million $1.61 billion |
1 PIV ($780.00 M) |
None | |||
Philippe Lüdi | 3 RICs 2 PIVs 5 other accounts |
$3.60 billion $922.49 million $1.61 billion |
1 PIV ($780.00 M) |
None | |||
John Perry | 2 RICs 2 PIVs 5 other accounts |
$3.37 billion $922.49 million $1.61 billion |
1 PIV ($780.00 M) |
None | |||
Robert Rickard | 3 RICs 2 PIVs 1 other account |
$3.60 billion $922.49 million $168.63 million |
1 PIV ($780.00 M) |
None | |||
Crabel: Michael Pomada |
6 RICs 17 PIVs 26 other accounts |
$410.26 million $2.64 billion $4.23 billion |
6 PIVs ($1.89 B) 12 other accounts ($3.02 B) |
None |
Crabel |
Crabel | |
Grant Jaffarian | 4 RICs 4 PIVs 12 other accounts |
$323.70 million $385.39 million $975.13 million |
1 other accounts ($40.50 M) |
None |
Statement of Additional Information – April 27, 2023 | 133 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Manulife: Christopher Chapman |
4 RICs 52 PIVs 13 other accounts |
$6.28 billion $18.32 billion $2.96 billion |
None |
None |
Manulife |
Manulife | |
Thomas Goggins | 4 RICs 52 PIVs 13 other accounts |
$6.28 billion $18.32 billion $2.96 billion |
None | None | |||
Bradley Lutz | 10 RICs 50 PIVs 16 other accounts |
$10.74 billion $18.29 billion $3.27 billion |
None | None | |||
Kisoo Park | 4 RICs 51 PIVs 13 other accounts |
$6.28 billion $18.31 billion $2.96 billion |
None | None | |||
TCW: Stephen Kane |
33 RICs 19 PIVs 182 other accounts |
$103.96 billion $12.18 billion $43.57 billion |
3 PIVs ($499.31 M) 10 other accounts ($5.41 B) |
None |
TCW |
TCW | |
Laird Landmann | 30 RICs 44 PIVs 198 other accounts |
$107.82 billion $16.24 billion $52.59 billion |
25 PIVs ($3.89 B) 10 other accounts ($7.69 B) |
None | |||
Bryan Whalen | 30 RICs 40 PIVs 205 other accounts |
$106.85 billion $14.99 billion $54.08 billion |
18 PIVs ($882.79 M) 13 other accounts ($8.67 B) |
None | |||
Water Island: Roger Foltynowicz |
4 RICs 1 PIV |
$2.01 billion $77.00 million |
None |
None |
Water Island |
Water Island | |
Gregory Loprete | 3 RICs | $504.00 million | None | None | |||
Todd Munn | 4 RICs 1 PIV |
$2.01 billion $77.00 million |
None | None | |||
MM International Equity Strategies Fund |
Arrowstreet: John Campbell |
3 RICs 105 PIVs 29 other accounts |
$2.39 billion $86.37 billion $43.81 billion |
1 RIC ($152.83 M) 40 PIVs ($41.11 B) 8 other accounts ($7.34 B) |
None |
Arrowstreet |
Arrowstreet |
Manolis Liodakis | 3 RICs 105 PIVs 29 other accounts |
$2.39 billion $86.37 billion $43.81 billion |
1 RIC ($152.83 M) 40 PIVs ($41.11 B) 8 other accounts ($7.34 B) |
None |
Statement of Additional Information – April 27, 2023 | 134 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Christopher Malloy | 3 RICs 105 PIVs 29 other accounts |
$2.39 billion $86.37 billion $43.81 billion |
1 RIC ($152.83 M) 40 PIVs ($41.11 B) 8 other accounts ($7.34 B) |
None | |||
Peter Rathjens | 3 RICs 105 PIVs 29 other accounts |
$2.39 billion $86.37 billion $43.81 billion |
1 RIC ($152.83 M) 40 PIVs ($41.11 B) 8 other accounts ($7.34 B) |
None | |||
Derek Vance | 3 RICs 105 PIVs 29 other accounts |
$2.39 billion $86.37 billion $43.81 billion |
1 RIC ($152.83 M) 40 PIVs ($41.11 B) 8 other accounts ($7.34 B) |
None | |||
Baillie Gifford: Chris Davies |
3 RICs 5 PIVs 31 other accounts |
$4.33 billion $2.55 billion $7.61 billion |
4 other accounts ($1.93 B) |
None |
Baillie Gifford |
Baillie Gifford | |
Jenny Davis | 3 RICs 1 PIV 30 other accounts |
$4.33 billion $693.00 million $7.48 billion |
4 other accounts ($1.93 B) |
None | |||
Donald Farquharson | 3 RICs 2 PIVs 34 other accounts |
$4.33 billion $1.17 billion $9.80 billion |
5 other accounts ($2.17 B) |
None | |||
Andrew Stobart | 5 RICs 5 PIVs 44 other accounts |
$8.99 billion $2.81 billion $13.47 billion |
1 RIC ($177.00 M) 1 PIV ($103.00 M) 4 other accounts ($1.93 B) |
None | |||
Steve Vaughan(d) | 5 RICs 2 PIVs 31 other account |
$4.53 billion $760.00 million $7.53 billion |
1 RIC ($157.00 M) 4 other accounts ($1.93 B) |
None | |||
Tom Walsh | 3 RICs 1 PIV 30 other accounts |
$4.33 billion $693.00 million $7.48 billion |
4 other accounts ($1.93 B) |
None | |||
Causeway: Jonathan Eng |
14 RICs 17 PIVs 83 other accounts |
$11.35 billion $3.38 billion $16.92 billion |
3 other accounts ($1.28 B) |
None |
Causeway |
Causeway |
Statement of Additional Information – April 27, 2023 | 135 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Harry Hartford | 14 RICs 17 PIVs 91 other accounts |
$11.35 billion $3.38 billion $16.93 billion |
3 other accounts ($1.28 B) |
None | |||
Sarah Ketterer | 14 RICs 17 PIVs 141 other accounts |
$11.35 billion $3.38 billion $17.15 billion |
3 other accounts ($1.28 B) |
None | |||
Ellen Lee | 14 RICs 17 PIVs 82 other accounts |
$11.35 billion $3.38 billion $16.91 billion |
3 other accounts ($1.28 B) |
None | |||
Conor Muldoon | 14 RICs 17 PIVs 87 other accounts |
$11.35 billion $3.38 billion $16.91 billion |
3 other accounts ($1.28 B) |
None | |||
Alessandro Valentini | 14 RICs 17 PIVs 82 other accounts |
$11.35 billion $3.38 billion $16.91 billion |
3 other accounts ($1.28 B) |
None | |||
MM Small Cap Equity Strategies Fund |
Columbia Management: Jarl Ginsberg |
2 RICs 1 PIV 95 other accounts |
$1.59 billion $133.27 million $78.81 million |
None |
None |
Columbia Management |
Columbia Management |
Christian Stadlinger | 2 RICs 1 PIV 97 other accounts |
$1.59 billion $133.27 million $88.14 million |
None | None | |||
Conestoga: Robert Mitchell |
4 RICs 2 PIVs 249 other accounts |
$3.62 billion $424.33 million $2.20 billion |
None |
None |
Conestoga |
Conestoga | |
Joseph Monahan | 3 RICs 1 PIV 173 other accounts |
$3.62 billion $394.54 million $1.38 billion |
None | None | |||
Hotchkis & Wiley: Judd Peters |
22 RICs 10 PIVs 49 other accounts |
$17.96 billion $2.04 billion $6.84 billion |
2 RICs ($11.69 B) 1 PIV ($42.80 M) 3 other accounts ($694.00 M) |
None |
Hotchkis & Wiley |
Hotchkis & Wiley | |
Ryan Thomes | 22 RICs 10 PIVs 49 other accounts |
$17.96 billion $2.04 billion $6.84 billion |
2 RICs ($11.69 B) 1 PIV ($42.80 M) 3 other accounts ($694.00 M) |
None |
Statement of Additional Information – April 27, 2023 | 136 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Jacobs Levy: Bruce Jacobs |
10 RICs 13 PIVs 93 other accounts |
$2.18 billion $2.44 billion $8.13 billion |
1 PIV ($209.63 M) 8 other accounts ($4.15 B) |
None |
Jacobs Levy |
Jacobs Levy | |
Kenneth Levy | 10 RICs 13 PIVs 93 other accounts |
$2.18 billion $2.44 billion $8.13 billion |
1 PIV ($209.63 M) 8 other accounts ($4.15 B) |
None | |||
JPMIM: Matthew Cohen |
4 RICs 5 PIVs |
$5.54 billion $6.28 billion |
1 other account ($1.34 B) |
None |
JPMIM |
JPMIM | |
Eytan Shapiro | 4 RICs 4 PIVs 1 other account |
$6.15 billion $3.11 billion $324.00 million |
None | None | |||
MM Total Return Bond Strategies Fund |
Loomis Sayles: Daniel Conklin |
7 RICs 11 PIVs 190 other accounts |
$2.24 billion $8.84 billion $20.90 billion |
None |
None |
Loomis Sayles |
Loomis Sayles |
Christopher Harms | 18 RICs 11 PIVs 226 other accounts |
$2.25 billion $8.84 billion $21.36 billion |
None | None | |||
Clifton Rowe | 7 RICs 11 PIVs 193 other accounts |
$2.24 billion $8.84 billion $20.91 billion |
None | None | |||
PGIM: Michael Collins |
28 RICs 15 PIVs 102 other accounts |
$71.12 billion $25.87 billion $53.62 billion |
4 other accounts ($1.19 B) |
None |
PGIM |
PGIM | |
Gregory Peters | 54 RICs 24 PIVs 141 other accounts |
$89.80 billion $38.49 billion $77.90 billion |
1 PIV ($51.13 M) 8 other accounts ($4.92 B) |
None | |||
Richard Piccirillo | 41 RICs 16 PIVs 102 other accounts |
$81.14 billion $25.99 billion $53.62 billion |
1 PIV ($51.13 M) 4 other accounts ($1.19 B) |
None | |||
Lindsay Rosner(i) | 41 RICs 16 PIVs 104 other accounts |
$84.34 billion $23.80 billion $50.78 billion |
4 other accounts ($1.11 B) |
None | |||
Robert Tipp | 47 RICs 19 PIVs 99 other accounts |
$80.54 billion $26.94 billion $58.14 billion |
8 other accounts ($4.92 B) |
None |
Statement of Additional Information – April 27, 2023 | 137 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
TCW: Stephen Kane |
33 RICs 19 PIVs 182 other accounts |
$101.24 billion $12.18 billion $43.57 billion |
3 PIVs ($499.31 M) 10 other accounts ($5.41 B) |
None |
TCW |
TCW | |
Laird Landmann | 30 RICs 44 PIVs 198 other accounts |
$105.10 billion $16.24 billion $52.59 billion |
25 PIVs ($3.89 B) 10 other accounts ($7.69 B) |
None | |||
Bryan Whalen | 30 RICs 40 PIVs 205 other accounts |
$104.13 billion $14.99 billion $54.08 billion |
18 PIVs ($882.79 M) 13 other accounts ($8.67 B) |
None | |||
Voya: David Goodson |
5 RICs 71 PIVs 72 other accounts |
$12.58 billion $3.42 billion $19.38 billion |
None |
None |
Voya |
Voya | |
Randall Parish | 6 RICs 71 PIVs 57 other accounts |
$12.52 billion $3.31 billion $13.43 billion |
1 PIV ($97.00 M) |
None | |||
Matthew Toms | 8 RICs 114 PIVs 105 other accounts |
$17.25 billion $6.24 billion $23.72 billion |
1 other account ($245.00 M) |
None | |||
Multisector Bond SMA Completion Portfolio |
Jason Callan | 13 RICs 10 PIVs 12 other accounts |
$22.63 billion $21.92 billion $1.51 billion |
None | None | Columbia Management | Columbia Management |
Alex Christensen | 6 RICs 2 PIVs 67 other accounts |
$14.53 billion $189.51 million $1.16 billion |
None | None | |||
Gene Tannuzzo | 7 RICs 2 PIVs 14 other accounts |
$15.23 billion $189.51 million $1.59 billion |
None | None | |||
Overseas SMA Completion Portfolio |
Fred Copper | 6 RICs 1 PIV 23 other accounts |
$7.84 billion $91.92 million $164.60 million |
None | None | Columbia Management | Columbia Management |
Daisuke Nomoto | 5 RICs 2 PIVs 21 other accounts |
$7.02 billion $978.37 million $14.93 million |
None | None |
Statement of Additional Information – April 27, 2023 | 138 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
Select Mid Cap Growth Fund |
Daniel Cole | 7 RICs 2 PIVs 154 other accounts |
$5.84 billion $100.99 million $41.85 million |
None | $100,001 – $500,000(a) $100,001 – $500,000(b) |
Columbia Management | Columbia Management |
Wayne Collette(j) | 2 RICs 1 PIV 135 Other accounts |
$1.81 billion $106.82 million $22.91 million |
None | None | |||
Dana Kelley(j) | 2 RICs 1 PIV 129 Other accounts |
$1.81 billion $106.82 million $17.37 million |
None | $1 – $10,000(b) | |||
Small Cap Growth Fund |
Daniel Cole | 7 RICs 2 PIVs 154 other accounts |
$5.70 billion $100.99 million $41.85 million |
None | $100,001 – $500,000(a) $100,001 – $500,000(b) |
Columbia Management | Columbia Management |
Wayne Collette | 1 RIC 1 PIV 155 other accounts |
$272.55 million $96.74 million $26.94 million |
None | $100,001 – $500,000(a) $100,001 – $500,000(b) | |||
Dana Kelley(h) | 5 other accounts |
$1.30 million | None | $50,001 – $100,000(b) | |||
Strategic Income Fund |
Jason Callan | 13 RICs 10 PIVs 12 other accounts |
$16.95 billion $21.92 billion $1.51 billion |
None | None | Columbia Management | Columbia Management |
Alex Christensen | 6 RICs 2 PIVs 67 other accounts |
$8.84 billion $189.51 million $1.16 billion |
None | $50,001 – $100,000(a) $50,001 – $100,000(b) | |||
Gene Tannuzzo | 7 RICs 2 PIVs 14 other accounts |
$9.54 billion $189.51 million $1.59 billion |
None | $500,001 – $1,000,000(a) $100,001 – $500,000(b) | |||
For Funds with fiscal year ending October 31 – Information is as of October 31, 2022, unless otherwise noted | |||||||
CT Intermediate Municipal Bond Fund |
Paul Fuchs | 8 RICs 7 other accounts |
$2.80 billion $11.66 million |
None | None | Columbia Management | Columbia Management |
Douglas Rangel | 11 RICs 5 other accounts |
$3.93 billion $71.80 million |
None | None | |||
Intermediate Duration Municipal Bond Fund | Paul Fuchs | 8 RICs 7 other accounts |
$1.24 billion $11.66 million |
None | $10,001 – $50,000(a) $10,001 – $50,000(b) |
Columbia Management | Columbia Management |
Douglas Rangel | 11 RICs 5 other accounts |
$2.37 billion $71.80 million |
None | None | |||
MA Intermediate Municipal Bond Fund |
Paul Fuchs | 8 RICs 7 other accounts |
$2.73 billion $11.66 million |
None | $10,001 – $50,000(a) |
Columbia Management | Columbia Management |
Douglas Rangel | 11 RICs 5 other accounts |
$3.86 billion $71.80 million |
None | None |
Statement of Additional Information – April 27, 2023 | 139 |
Other Accounts Managed (Excluding the Fund) | Ownership of Fund Shares |
Potential Conflicts of Interest |
Structure of Compensation | ||||
Fund | Portfolio Manager | Number and Type of Account* |
Approximate Total Net Assets |
Performance- Based Accounts** | |||
NY Intermediate Municipal Bond Fund |
Paul Fuchs | 8 RICs 7 other accounts |
$2.73 billion $11.66 million |
None | None | Columbia Management | Columbia Management |
Douglas Rangel | 11 RICs 5 other accounts |
$3.86 billion $71.80 million |
None | None | |||
Select Global Equity Fund |
David Dudding | 2 PIVs 17 other accounts |
$3.05 billion $3.09 billion |
1 other account ($1.19 B) |
None(c) | Columbia Management/ Threadneedle |
Threadneedle |
Alex Lee | 2 PIVs 15 other accounts |
$1.80 billion $1.45 billion |
1 other account ($64.16 M) |
None(c) | |||
Seligman Global Technology Fund |
Christopher Boova | 2 RICs 7 other accounts |
$492.89 million $6.61 million |
None | None | Columbia Management | Columbia Management– Tech Team |
Sanjay Devgan | 3 RICs 4 other accounts |
$8.17 billion $6.06 million |
None | $1 – $10,000(a) |
|||
Vimal Patel | 3 RICs 8 other accounts |
$8.54 billion $8.52 million |
None | $10,001 – $50,000(a) |
|||
Shekhar Pramanick | 4 RICs 6 other accounts |
$8.56 billion $12.07 million |
None | None | |||
Sanjiv Wadhwani | 1 RIC 5 other accounts |
$103.49 million $2.14 million |
None | None | |||
Paul Wick | 4 RICs 3 PIVs 7 other accounts |
$8.56 billion $1.78 billion $516.40 million |
2 PIVs ($1.23 B) 1 other account ($134.38 M) |
Over $1,000,000(a) |
|||
Strategic CA Municipal Income Fund |
Catherine Stienstra | 9 RICs 3 other accounts |
$6.36 billion $1.54 million |
None | None | Columbia Management | Columbia Management |
Douglas White | 5 RICs 10 other accounts |
$5.16 billion $74.05 million |
None | None | |||
Strategic NY Municipal Income Fund |
Catherine Stienstra | 9 RICs 3 other accounts |
$6.65 billion $1.54 million |
None | None | Columbia Management | Columbia Management |
Douglas White | 5 RICs 10 other accounts |
$5.45 billion $74.05 million |
None | None | |||
For Funds with fiscal year ending December 31 – Information is as of December 31, 2022, unless otherwise noted | |||||||
Real Estate Equity Fund |
Arthur Hurley | 1 RIC 13 other accounts |
$74.43 million $2.40 million |
None | $10,001 – $50,000(a) $50,001 – $100,000(b) |
Columbia Management | Columbia Management |
* | RIC refers to a Registered Investment Company; PIV refers to a Pooled Investment Vehicle. |
** | Number and type of accounts for which the advisory fee paid is based in part or wholly on performance and the aggregate net assets in those accounts. |
(a) | Excludes any notional investments. |
(b) | Notional investments through a deferred compensation account. |
Statement of Additional Information – April 27, 2023 | 140 |
(c) | The Fund is available for sale only in the U.S. The portfolio manager does not reside in the U.S. and therefore does not hold any shares of the Fund. |
(d) | The portfolio manager began managing the Fund after its last fiscal year end. |
(e) | Mr. Davis is expected to retire effective June 30, 2023 and, as of such date, he will cease to serve as portfolio manager of the Fund. |
(f) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of May 31, 2022. |
(g) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of July 31, 2022. |
(h) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of September 30, 2022. |
(i) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of October 31, 2022. |
(j) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of January 31, 2023. |
AlphaSimplex: AlphaSimplex and its investment personnel provide investment management services to multiple portfolios for multiple clients. AlphaSimplex may purchase or sell securities for one client portfolio and not another client portfolio, and the performance of securities purchased for one portfolio may vary from the performance of securities purchased for other portfolios. In addition, client account structures may have fee structures, such as performance-based fees, that differ. The firm has adopted and implemented a Statement of Policy and Procedures Regarding Allocation Among Investment Advisory Clients intended to address conflicts of interest relating to the management of multiple accounts, including accounts with multiple fee arrangements, and the allocation of investment opportunities. AlphaSimplex reviews investment decisions for the purpose of ensuring that all accounts with substantially similar investment objectives are treated equitably. The performance of similarly managed accounts is also regularly compared to determine whether there are any unexplained significant discrepancies. Finally, AlphaSimplex has adopted trade allocation procedures that require equitable allocation of trade orders for a particular security among participating accounts. The implementation of these procedures is monitored by AlphaSimplex’s Chief Compliance Officer. |
In addition, AlphaSimplex is aware of the potential for a conflict of interest in cases where AlphaSimplex, a related person or any of their employees, buys or sells securities recommended by AlphaSimplex to the clients. AlphaSimplex, in recognition of its fiduciary obligations to its clients and its desire to maintain its high ethical standards, has adopted a Code of Ethics containing provisions designed to prevent improper personal trading, identify conflicts of interest and provide a means to resolve any actual or potential conflict in favor of the client. AlphaSimplex requires all employees to obtain preclearance of personal securities transactions (other than certain exempted transactions as set forth in the Code of Ethics). |
AQR: Each of the portfolio managers is also responsible for managing other accounts in addition to the respective Funds the portfolio manager manages, including other accounts of AQR, or its affiliates. Other accounts may include, without limitation, separately managed accounts for foundations, endowments, pension plans, and high net-worth families; registered investment companies; unregistered investment companies relying on either Section 3(c)(1) or Section 3(c)(7) of |
Statement of Additional Information – April 27, 2023 | 141 |
the 1940 Act (such companies are commonly referred to as “hedge funds”); foreign investment companies; and may also include accounts or investments managed or made by the portfolio managers in a personal or other capacity (“Proprietary Accounts”). Management of other accounts in addition to the Funds can present certain conflicts of interest, as described below. |
From time to time, potential conflicts of interest may arise between a portfolio manager’s management of the investments of the Funds, on the one hand, and the management of other accounts (including for the purposes of this discussion, Proprietary Accounts), on the other. The other accounts might have similar investment objectives or strategies as the Funds, or otherwise hold, purchase, or sell securities that are eligible to be held, purchased or sold by the Funds. Because of their positions with the Funds, the portfolio managers know the size, timing and possible market impact of the Funds' trades. A potential conflict of interest exists where portfolio managers could use this information to the advantage of other accounts they manage and to the possible detriment of the Funds. |
A number of potential conflicts of interest may arise as a result of AQR’s or the portfolio manager’s management of a number of accounts with similar investment strategies. Often, an investment opportunity may be suitable for both the Funds and other accounts, but may not be available in sufficient quantities for both the Funds and the other accounts to participate fully. Similarly, there may be limited opportunity to sell an investment held by the Funds and another account. In circumstances where the amount of total exposure to a strategy or investment type across accounts is, in the opinion of AQR, capacity constrained, the availability of the strategy or investment type for the Funds and other accounts may be reduced in AQR’s discretion. The Funds may therefore have reduced exposure to a capacity constrained strategy or investment type, which could adversely affect the Funds' return. AQR is not obligated to allocate capacity pro rata and may take its financial interests into account when allocating capacity among the Funds and other accounts. Among other things, capacity constraints in a particular strategy or investment type could cause the Fund to close to all or certain new investors |
Another conflict could arise where different account guidelines and/or differences within particular investment strategies may lead to the use of different investment practices for portfolios with a similar investment strategy. AQR will not necessarily purchase or sell the same instruments at the same time or in the same direction (particularly if different accounts have different strategies), or in the same proportionate amounts for all eligible accounts (particularly if different accounts have materially different amounts of capital under management, different amounts of investable cash available, different investment restrictions, or different risk tolerances). As a result, although AQR manages numerous accounts and/or portfolios with similar or identical investment objectives, or may manage accounts with different objectives that trade in the same instruments, the portfolio decisions relating to these accounts, and the performance resulting from such decisions, may differ from account to account. AQR may, from time to time, implement new trading strategies or participate in new trading strategies for some but not all accounts, including the Funds. Strategies may not be implemented in the same manner among accounts where they are employed, even if the strategy is consistent with the objectives of such accounts. In certain circumstances, investment opportunities that are in limited supply and/or have limited return potential in light of administrative costs of pursuing such investments (e.g., IPOS) are only allocated to accounts where the given opportunity is more closely aligned with the applicable strategy and/or trading approach. |
Whenever decisions are made to buy or sell investments by the Funds and one or more other accounts simultaneously, AQR or the portfolio manager may aggregate the purchases and sales of the investments and will allocate the transactions in a manner that it believes to be equitable under the circumstances. To this end, AQR has adopted policies and procedures that are intended to assure that investment opportunities are allocated equitably among accounts over time. As a result of the allocations, there may be instances where the Funds will not participate in a transaction that is allocated among other accounts or the Funds may not be allocated the full amount of the investments sought to be traded. These aggregation and allocation policies could have a detrimental effect on the price or amount of the investments available to the Funds from time to time. Subject to applicable laws and/or account restrictions, AQR may buy, sell or hold securities for other accounts while entering into a different or opposite investment decision for one or more funds. |
To the extent that the Funds holds interests in an issuer that are different (or more senior or junior) than, or potentially adverse to, those held by other accounts, AQR may be presented with investment decisions where the outcome would benefit one account and would not benefit or would harm the other account. This may include, but is not limited to, an account investing in a different security of an issuer’s capital structure than another account, an account investing in the same security but on different terms than another account, an account obtaining exposure to an investment using different types of securities or instruments than another account, an account engaging in short selling of securities that another account holds long, an account voting securities in a different manner than another account, and/or an account acquiring or disposing of its interests at different times than another account. This could have a material adverse effect on, or in some instances could benefit, one or more of such accounts, including accounts that are affiliates of AQR, accounts in which AQR has an interest, or accounts which pay AQR higher fees or a performance fee. These transactions or investments by one or more accounts could dilute or otherwise disadvantage the values, prices, or investment strategies of such accounts. When |
Statement of Additional Information – April 27, 2023 | 142 |
AQR, on behalf of an account, manages or implements a portfolio decision ahead of, or contemporaneously with, portfolio decisions of another account, market impact, liquidity constraints, or other factors could result in such other account receiving less favorable pricing or trading results, paying higher transaction costs, or being otherwise disadvantaged. In addition, in connection with the foregoing, AQR, on behalf of an account, is permitted to pursue or enforce rights or actions, or refrain from pursuing or enforcing rights or actions, with respect to a particular issuer in which action could materially adversely affect such other account. |
In addition, when the Funds and other accounts hold investments in the same issuer (including at the same place in the capital structure), the Funds may be prohibited by applicable law from participating in restructurings, work-outs or other activities related to its investment in the issuer. As a result, the Funds may not be permitted by law to make the same investment decisions as other accounts in the same or similar situations even if AQR believes it would be in the Funds' best economic interests to do so. The Funds may be prohibited by applicable law from investing in an issuer (or an affiliate) that other accounts are also investing in or currently invest in even if AQR believes it would be in the best economic interests of the Funds to do so. Furthermore, entering into certain transactions that are not deemed prohibited by law when made may potentially lead to a condition that raises regulatory or legal concerns in the future. This may be the case, for example, with issuers that AQR considers to be at risk of default and restructuring or work-outs with debt holders, which may include the Funds and other accounts. In some cases, to avoid the potential of future prohibited transactions, AQR may avoid allocating an investment opportunity to the Funds that it would otherwise recommend, subject to the AQR’s then- current allocation policy and any applicable exemptions. |
In certain circumstances, AQR may be restricted from transacting in a security or instrument because of material nonpublic information received in connection with an investment opportunity that is offered to AQR. In other circumstances, AQR will not participate in an investment opportunity to avoid receiving material nonpublic information that would restrict AQR from transacting in a security or instrument. These restrictions may adversely impact the Funds' performance. |
AQR and the Funds' portfolio managers may also face a conflict of interest where some accounts pay higher fees to AQR than others, as they may have an incentive to favor accounts with the potential for greater fees. For instance, the entitlement to a performance fee in managing one or more accounts may create an incentive for AQR to take risks in managing assets that it would not otherwise take in the absence of such arrangements. Additionally, since performance fees reward AQR for performance in accounts which are subject to such fees, AQR may have an incentive to favor these accounts over those that have only fixed asset-based fees, such as the Funds, with respect to areas such as trading opportunities, trade allocation, and allocation of new investment opportunities. |
AQR has implemented specific policies and procedures (e.g., a code of ethics and trade allocation policies) that seek to address potential conflicts of interest that may arise in connection with the management of the Funds and other accounts and that are designed to ensure that all accounts, including the Funds, are treated fairly and equitably over time. |
Arrowstreet: Arrowstreet offers institutional investors a select range of equity investment strategies: long-only, alpha extension and long/short. |
Arrowstreet’s investment strategies are managed by a cohesive investment team. Individual strategies are not managed by individual investment professionals but rather all strategies are managed by the same team of investment professionals. This team approach to trading is designed to ensure that all research ideas and opinions are shared at the same time among all accounts without systematically favoring any one account over another. Arrowstreet manages a large number of client accounts and, as a result, potential conflicts of interest may arise from time to time. As a result, Arrowstreet has established a number of policies and procedures designed to mitigate and/or eliminate potential conflicts. Arrowstreet has established policies and procedures with respect to trade execution, aggregation and allocation. In addition, Arrowstreet maintains a comprehensive code of ethics addressing potential conflicts that could arise between Arrowstreet and its employees and its clients. |
Arrowstreet believes that its policies and procedures are reasonably designed to address potential conflicts of interest. |
Baillie Gifford: In addition to managing the Fund, individual portfolio managers are commonly responsible for managing other registered investment companies, other pooled investment vehicles and/or other accounts. These other accounts may have similar investment strategies to the Fund. Potential conflicts between the portfolio management of the Fund and the portfolio manager’s other accounts are managed by Baillie Gifford using allocation policies and procedures, and internal review processes. Baillie Gifford has developed trade allocation systems and controls to ensure that no one client, regardless of type, is intentionally favored at the expense of another. Allocation policies are designed to address potential conflicts in situations where two or more funds or accounts participate in investment decisions involving the same securities. |
Statement of Additional Information – April 27, 2023 | 143 |
Boston Partners: Boston Partners owes its clients a duty of loyalty and monitors situations in which the interests of its advisory clients may be in conflict with its own interests. Boston Partners identifies business practices that may cause a conflict of interest between it and its clients, discloses such conflicts of interest to clients and develops reasonable procedures to mitigate such conflicts. |
Boston Partners has identified the following potential conflicts of interest and the measures it uses to address these matters: |
Equitable Treatment of Accounts Boston Partners recognizes that potential conflicts may arise from the side-by-side management of registered investment companies and “investment accounts,” which include privately offered funds and separately managed accounts of individuals and institutional investors. Where Boston Partners’ separately managed accounts are charged performance fees, portfolio managers may be inclined to take investment risks that are outside the scope of such client’s investment objectives and strategy. In addition, since Boston Partners’ private investment funds charge performance fees and share those fees with portfolio managers, such portfolio managers may also be inclined to take additional investment risks. Boston Partners maintains a Trade Allocation and Aggregation Policy as well as a Simultaneous Management Policy to ensure that client accounts are treated equitably. The Compliance Department (“CD”) reviews allocations and dispersion regularly, and accounts within the same strategy are precluded from simultaneously holding a security long and short. There are certain circumstances that would permit a long/short portfolio to take a contra position in a security that is held in another strategy. This happens very infrequently and the contra position is generally not related to the fundamental views of the security (i.e. – initiating a long position in a security at year-end to take advantage of tax-loss selling as a short term investment, or initiating a position based solely on its relative weight in the benchmark to manage investment risk). However in certain situations, the investment constraints of a strategy, including but not limited to country, region, industry or benchmark, may result in a different investment thesis for the same security. Each situation is fully vetted and approved by the firm’s Chief Investment Officer or his designee. Risk Management performs periodic reviews to ensure the product complies with the investment strategy and defined risk parameters. |
Furthermore, since Boston Partners charges a performance fee on certain accounts, and in particular these accounts may receive “new issues” allocations, Boston Partners has a conflict of interest in allocating new issues to these accounts. Boston Partners maintains an IPO Allocation Policy and the CD assists in, and/or reviews, the allocation of new issues to ensure that IPOS are being allocated among all eligible accounts in an equitable manner. |
Utilizing Brokerage to Advantage Boston Partners Boston Partners does not place trades through affiliated brokers. Securities trades are executed through brokerage firms with which Boston Partners maintains other advantageous relationships, such as soft dollars. In these cases, the broker may expect commission business in return. Boston Partners has established a Trade Management Oversight Committee to evaluate brokerage services and to review commissions paid to brokers. In addition, Boston Partners maintains a Best Execution Policy and a Soft Dollar Policy to assist in its monitoring efforts. Boston Partners also identifies affiliates of the investment companies for which it acts as investment adviser or sub adviser to ensure it is trading in accordance with applicable rules and regulations. |
Directed Brokerage Boston Partners faces an inherent conflict since it is in a position to direct client transactions to a broker or dealer in exchange for distribution capacity. Boston Partners maintains policies which prohibit its traders from considering a broker-dealer’s distribution capacity for promoting or selling Boston Partners’ separate account services, mutual funds, or proprietary funds (collectively “Boston Partners’ Services”) during the broker selection process. Nor will Boston Partners compensate any broker either directly or indirectly by directing brokerage transactions to that broker for consideration in selling Boston Partners’ Services. |
Mixed Use Allocations and Use of Soft Dollars to Benefit Adviser Soft dollar services which have a “mixed use” allocation present a conflict of interest when determining the allocation between those services that primarily benefit Boston Partners’ clients and those that primarily benefit Boston Partners. In addition, a conflict of interest exists when Boston Partners uses soft dollars to pay expenses that would normally be paid by Boston Partners. Boston Partners has developed soft dollar policies which require it to make a good faith allocation of “mixed use” services and to document its analysis. In addition, the CD reviews all requests for soft dollars to ensure inclusion under the safe harbor of Section 28 (e) of the Exchange Act. |
Trade Errors A conflict arises when an investment adviser requests a broker/dealer to absorb the cost of a trade error in return for increased trading and/or commissions. Boston Partners prohibits correcting a trade error for any quid pro quo with a broker and has procedures for the proper correction of trade errors. |
Statement of Additional Information – April 27, 2023 | 144 |
Principal Transactions A principal transaction occurs when an investment adviser, acting for the account of itself or an affiliate buys a security from, or sells a security to a client. An inherent conflict of interest exists since an adviser has an opportunity to transfer unwanted securities from its account to a client's account, sell securities to a client’s account at prices above the market, or transfer more favorably priced securities from a client account to its account. Boston Partners generally does not permit the selling of a security from one client account and the purchasing of the same security in another client account if Boston Partners has a principal interest in one of the accounts at the time of the transaction. Additionally, Boston Partners requires that clients give consent by signing subscription agreements to purchase a pooled investment vehicle in which Boston Partners or a related entity has an interest. |
Cross Trades Cross transactions between clients create an inherent conflict of interest because Boston Partners has a duty to obtain the most favorable price for both the selling client and the purchasing client. Boston Partners generally does not engage in cross trading, however Boston Partners has procedures to ensure that any cross trade is in the best interests of all clients. |
Affiliated Investments Potential conflicts exist if Boston Partners directs client investments into affiliated vehicles in order to increase the size of these vehicles and thereby increase its compensation by (a) lowering overall expenses of the vehicle, some of which Boston Partners may have responsibility for; (b) permitting greater marketing of the vehicle which will generate greater fee revenue for Boston Partners; or (c) allowing Boston Partners or an affiliate to redeem its investment capital in such vehicle. To mitigate any detriment to the client, Boston Partners has product suitability procedures and will obtain a client’s consent prior to investing client assets in an affiliated vehicle. |
Proprietary Trading Opportunities Employees are in a position to take investment opportunities for themselves or Boston Partners before such opportunities are executed on behalf of clients. Employees have a duty to advance Boston Partners’ client interests before Boston Partners interests or their personal interests. Boston Partners must assure that employees do not favor their own or Boston Partners’ accounts. The Code of Ethics (“the Code”) includes procedures on ethical conduct and personal trading, including preclearance and blackout procedures, to which all employees are subject. |
Insider Trading/Non-Public Information Employees are in a position to learn material nonpublic information. Such employees are in a position to trade in their personal accounts on such information, to the potential disadvantage of client accounts. The Code addresses insider trading including permissible activities. Employees certify, at least annually, that they are in compliance with the Code. |
Boston Partners periodically discusses securities which may be held in client accounts with external investment professionals when sourcing and analyzing investment ideas. These discussions may include but are not limited to economic factors, market outlook, sector and industry views, and general and/or specific information regarding securities. Discussion of specific securities creates a conflict which could disadvantage Boston Partners’ clients if the external parties were to act upon this information, including but not limited to front-running and scalping either particular securities or numerous securities in a similar sector to the extent such information is known about Boston Partners’ holdings. Boston Partners has policies prohibiting discussion of client investments for non-business purposes and has outlined permissible activities as well as certain other prohibitions when sourcing investment ideas for business purposes. |
Value-Added Investors A senior executive from a public company or a private company that is a hedge fund, broker-dealer, investment adviser, or investment bank, (collectively “VAIs”), may invest in Boston Partners’ private funds. A conflict exists if Boston Partners invests in companies affiliated with a VAI or if a VAI who works at a private company provide material non-public information to Boston Partners or vice versa. Both of these conflicts raise issues with respect to information sharing. Boston Partners has procedures to: i) identify these individuals through its annual outside businesses questionnaire, its annual compliance questionnaire, review of new account start-up documents, and its 5130 and 5131 questionnaires, and ii) monitor conflicts these persons present through its pre-trade compliance system and/or email surveillance. |
Selective Disclosure Selective disclosure occurs when material information is given to a single investor, or a limited group of investors, and not to all investors at the same time. This practice may allow one set of investors to profit on undisclosed information prior to giving others the same opportunity. In order to prevent this conflict of interest, Boston Partners has procedures regarding the dissemination of account holdings. |
Valuation of Client Accounts Because Boston Partners calculates its own advisory fees, it has an incentive to over-value such accounts to either increase the fees payable by the client, or to conceal poor performance for an incentive fee. Boston Partners has several safeguards in |
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place to mitigate this conflict. Boston Partners has a policy for the valuation of securities. Boston Partners’ Operations Department (“Operations”) reconciles cash, assets, and prices for all client accounts with the client’s custodian bank’s records on a monthly basis. Finally, as part of Boston Partners annual financial review, external auditors review a sample of client fee invoices. |
Representing Clients At times, clients may request Boston Partners represent their interests in class action litigation, bankruptcies or other matters. Boston Partners’ expertise lies in investment management and has an inherent conflict of interest if cast in any other role. When possible, Boston Partners’ investment management agreements include provisions that Boston Partners will not act on behalf of the client in class actions, bankruptcies or matters of litigation. |
Outside Business Activities An employee’s outside business activities may conflict with the employee’s duties to Boston Partners and its clients. Boston Partners requires all employees to disclose any outside employment to the CD, who, in conjunction with the employee’s supervisor and the Director of HR, will identify any potential conflicts. In the event that a resolution to the conflict cannot be reached, the employee may be asked to terminate either his outside employment or his position with Boston Partners. |
Business Gifts and Entertainment Boston Partners employees periodically give or receive gifts from clients. Boston Partners employees host clients or receive entertainment provided by a client. Such gifts or entertainment may be considered efforts to gain unfair advantage. Boston Partners maintains a gifts and entertainment policy and has developed a “Q&A” guide for employees regarding certain types of gifts and entertainment. Generally, employees are not permitted to give or receive gifts of more than $100 in value, per person, per year. Entertainment that is normal or customary in the industry is considered appropriate. Employees should consult the CD if they are unsure about a particular gift or value of entertainment. |
Illegal or Unethical Behavior Unethical or illegal conduct by employees damages Boston Partners’ ability to meet its fiduciary duties to clients. Employees are required to report to management any actual or suspected illegal or unethical conduct on the part of other employees of which they become aware or any situations in which they are concerned about the “best course of action.” In addition, employees are required to certify annually that they are in compliance with this Manual. Regardless of whether a government inquiry occurs, Boston Partners views seriously any violation of this Manual. Disciplinary sanctions may be imposed on any employee committing a violation of this Manual. |
Proxy Voting Boston Partners’ proxy voting authority for its clients, puts it in a position where its interests may conflict with the best interests of its clients when determining how to vote. Boston Partners has a proxy voting policy and has engaged an outside vendor to execute proxies according to this policy. Boston Partners has a procedure to handle conflicts of interest which may arise in voting client securities. |
Consulting Relationships Boston Partners may purchase software, educational programs and peer group information from consulting firms that represent Boston Partners clients. Due to the lack of payment transparency, these relationships could give rise to improper activity on the part of the investment adviser or the consultant. Products purchased from consultants must serve a legitimate need for Boston Partners’ business and may not be acquired to influence a consultant’s recommendation of Boston Partners. |
Causeway: The portfolio managers who subadvise a portion of the assets of the Fund also manage their own personal accounts and other accounts, including accounts for corporations, pension plans, public retirement plans, sovereign wealth funds, superannuation funds, Taft-Hartley pension plans, endowments and foundations, mutual funds and other collective investment vehicles, charities, private trusts and funds, wrap fee programs, and other institutions (collectively, “Other Accounts”). In managing certain of the Other Accounts, the portfolio managers employ investment strategies similar to those used in subadvising a portion of the Fund, subject to certain variations in investment restrictions. The portfolio managers purchase and sell securities for the Fund that they also recommend to Other Accounts. The portfolio managers at times give advice or take action with respect to certain accounts that differs from the advice given other accounts with similar investment strategies. Certain of the Other Accounts may pay higher or lower management fee rates than the Fund or pay performance-based fees to Causeway. Causeway is the investment adviser and sponsor of a number of mutual funds: Causeway International Value Fund, Causeway Global Value Fund, Causeway Emerging Markets Fund, Causeway International Opportunities Fund, Causeway International Small Cap Fund, and Causeway Concentrated Equity Fund (together, the “Causeway Mutual Funds”). Causeway also sponsors and manages certain other comingled vehicles in its international value equity strategy that are offered to institutional investors. Most of the portfolio managers have personal investments in one or more Causeway Funds. Ms. Ketterer and Mr. Hartford each holds (through estate planning vehicles) a controlling voting interest in Causeway’s parent holding company and Messrs. Eng, Muldoon, Valentini, and Ms. Lee (directly or through estate planning vehicles) have minority ownership interests in Causeway’s parent holding company. |
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Actual or potential conflicts of interest arise from the portfolio managers’ management responsibilities with respect to the Other Accounts and their own personal accounts. These responsibilities may cause portfolio managers to devote unequal time and attention across client accounts and the differing fees, incentives and relationships with the various accounts provide incentives to favor certain accounts. Causeway has written compliance policies and procedures designed to mitigate or manage these conflicts of interest. These include policies and procedures to seek fair and equitable allocation of investment opportunities (including IPOs and new issues) and trade allocations among all client accounts and policies and procedures concerning the disclosure and use of portfolio transaction information. Causeway also has a Code of Ethics which, among other things, limits personal trading by portfolio managers and other employees of Causeway. There is no guarantee that any such policies or procedures will cover every situation in which a conflict of interest arises. |
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 funds or other accounts with different advisory fee rates and/or fee structures, including accounts, such as the Investment Manager’s hedge funds, 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 accounts that pay higher fees, including performance fee accounts, such that the portfolio manager may have an incentive to allocate attractive investments disproportionately to performance fee accounts. | |
Similar 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. When the Investment Manager determines it necessary or appropriate in order to ensure compliance with restrictions on joint transactions under the 1940 Act, a Fund may not be able to invest in privately-placed securities in which other accounts advised by the Investment Manager using a similar style, including performance fee accounts, are able to invest, even when the Investment Manager believes such securities would otherwise represent attractive investment opportunities. As a general matter and subject to the Investment Manager’s Code of Ethics and certain limited exceptions, including for investments in the Investment Manager’s hedge funds, 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. | |
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 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. |
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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 – IB: Management of the Income Builder Fund-of-Funds differs from that of the other Funds. The portfolio management process is set forth generally below and in more detail in the Fund’s prospectus. | |
The Investment Manager uses quantitative models combined with qualitative factors to determine the Fund’s allocations to the underlying funds. Using these methodologies, a group of the Investment Manager’s investment professionals allocates the Fund’s assets within and across different asset classes in an effort to achieve the Fund’s objective of providing a high level of current income and growth of capital. The Fund will typically be rebalanced monthly in an effort to maximize the level of income and capital growth, incorporating various measures of relative value subject to constraints that set minimum or maximum exposure within asset classes, as set forth in the prospectus. Within the equity and fixed income asset classes, the Investment Manager establishes allocations for the Fund, seeking to achieve each Fund’s objective by investing in defined investment categories. The target allocation range constraints are intended, in part, to promote diversification within the asset classes. | |
Because of the structure of 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. These potential conflicts of interest include: |
■ | In certain cases, the portfolio managers of the underlying funds are the same as the portfolio managers of the Income Builder Fund-of-Funds, and could influence the allocation of fund-of-funds assets to or away from the underlying funds that they manage. |
■ | The Investment Manager and its affiliates may receive higher compensation as a result of allocations to underlying funds with higher fees. |
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. |
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■ | 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. |
Conestoga: Like other investment professionals with multiple clients, portfolio managers may face certain potential conflicts of interest in connection with managing both the portion of the Fund’s assets allocated to Conestoga (Conestoga’s Sleeve) and other accounts at the same time. Conestoga has adopted compliance policies and procedures that attempt to address certain of the potential conflicts that Conestoga’s portfolio managers face in this regard. Certain of those conflicts of interest are summarized below. | |
The management of accounts with different advisory or sub-advisory fee rates and/or fee and expense structures may raise certain potential conflicts of interest for a portfolio manager by creating an incentive to favor higher fee, or higher profit margin accounts. | |
Potential conflicts of interest also may arise when a portfolio manager has personal investments in other accounts that may create an incentive to favor those accounts. A portfolio manager who is responsible for managing multiple funds and/or accounts may devote unequal time and attention to the management of those funds and/or accounts. The effects of this potential conflict may be more pronounced where funds and/or accounts managed by a particular portfolio manager have different investment strategies. | |
A portfolio manager may be able to select or influence the selection of the broker-dealers that are used to execute securities transactions for a fund. A portfolio manager’s decision as to the selection of broker-dealers could produce disproportionate costs and benefits among Conestoga’s Sleeve and the other accounts the portfolio manager manages. | |
A potential conflict of interest may arise when a portfolio manager buys or sells the same securities for the Conestoga’s Sleeve and other accounts. On occasions when a portfolio manager considers the purchase or sale of a security to be in the best interests of Conestoga’s Sleeve as well as other accounts, the Conestoga’s trading desk may, to the extent consistent with applicable laws and regulations, aggregate the securities to be sold or bought in order to obtain the best execution and lower brokerage commissions, if any. Aggregation of trades may create the potential for unfairness to Conestoga’s Sleeve or the Fund or another account if a portfolio manager favors one account over another in allocating the securities bought or sold. | |
“Cross trades,” in which a portfolio manager sells a particular security held by Conestoga’s Sleeve to another account (potentially saving transaction costs for both accounts), could involve a potential conflict of interest if, for example, a portfolio manager is permitted to sell a security from one account to another account at a higher price than an independent third party would pay. Conestoga has adopted compliance procedures that provide that any transactions between the Fund and another account managed by Conestoga are to be made at a current market price, consistent with applicable laws and regulations. | |
Another potential conflict of interest may arise based on the different investment objectives and strategies of Conestoga’s Sleeve and other accounts managed by its portfolio manager(s). Depending on another account’s objectives and other factors, a portfolio manager may give advice to and make decisions for Conestoga’s Sleeve that may differ from advice given, or the timing or nature of decisions made, with respect to another account. A portfolio manager’s investment decisions are the product of many factors in addition to basic suitability for the particular account involved. Thus, a portfolio manager may buy or sell a particular security for certain accounts, and not for Conestoga’s Sleeve, even though it could have been bought or sold for Conestoga’s Sleeve at the same time. A portfolio manager also may buy a particular |
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security for one or more accounts when one or more other accounts are selling the security. There may be circumstances when a portfolio manager’s purchases or sales of portfolio securities for one or more accounts may have an adverse effect on other accounts, including the Fund. | |
The portfolio manager(s) also may have other potential conflicts of interest in managing Conestoga’s Sleeve, and the description above is not a complete description of every conflict that could exist in managing Conestoga’s Sleeve and other accounts. Many of the potential conflicts of interest to which the Conestoga’s portfolio managers are subject are essentially the same or similar to the potential conflicts of interest related to the investment management activities of Conestoga or other subadvisers of the Fund. |
Crabel: Crabel provides investment management services to multiple clients across multiple trading programs. The firm’s clients include commodity pools, registered investment companies, separately managed accounts, and other pooled investment vehicles. Crabel employees may also trade for their own personal trading accounts. A fundamental policy of the firm is to identify and mitigate conflicts that impact Crabel’s business, with a guiding principle that the firm owes a fiduciary duty to act in the best interests of its clients. There are a variety of conflicts of interest in operating its business, which Crabel addresses in its adopted Compliance Manual and a variety of policy statements. Crabel believes its adopted policies and procedures (e.g., code of ethics, valuation, trade allocation, and privacy) are reasonably designed to provide oversight when acting on behalf of multiple clients. Oversight is provided by the firm’s Compliance department, as well as senior management, various business departments, internal committees, and the firm’s Executive Committee. |
With respect to the allocation of investment opportunities, Crabel adopted a trade allocation policy reasonably designed to ensure the allocation of fills is fair and equitable across multiple clients that trade the same investment strategy. There is no discretion on a trade by trade basis to decide how a trade is allocated; rather Crabel’s system utilizes a random allocation algorithm to allocate fills to accounts based on account size. |
As a systematic, algorithmic trading firm, Crabel has implemented various internal controls that are designed to prevent Crabel’s employees from taking inappropriate risk. Trading models are systematically implemented through Crabel’s algorithmic execution platform, with the majority of Crabel’s trading being automated. Only a limited number of senior staff in the Research department are authorized to add a trading model. No discretion is taken with the firm’s systematic trading approach. Crabel’s automated trading platform was designed with multiple redundancies to prevent errant trade executions and limits are set with brokers to provide initial oversight of trade activity. Oversight of performance, slippage, and trading models is intended to minimize the risk of employees acting outside of their given latitude. | |
DFA: Actual or apparent conflicts of interest may arise when a portfolio manager has the primary day-to-day responsibilities with respect to a mutual fund and other accounts. Other accounts include registered mutual funds (including proprietary mutual funds advised by DFA or its affiliates), other unregistered pooled investment vehicles, and other accounts managed for organizations and individuals (“Accounts”). An Account may have similar investment objectives to the Fund, or may purchase, sell or hold securities that are eligible to be purchased, sold or held by the Fund. Actual or apparent conflicts of interest include: |
■ | 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. Most Accounts managed by a portfolio manager are managed using the same investment approaches that are used in connection with the management of the Fund. |
■ | 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 choose to hold its investment 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 deal with 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 separate 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. |
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■ | 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. |
Hotchkis & Wiley: The Portfolio is managed by Hotchkis & Wiley’s investment team (Investment Team). The Investment Team also manages institutional accounts and other mutual funds in several different investment strategies. The portfolios within an investment strategy are managed using a target portfolio; however, each portfolio may have different restrictions, |
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cash flows, tax and other relevant considerations which may preclude a portfolio from participating in certain transactions for that investment strategy. Consequently, the performance of portfolios may vary due to these different considerations. The Investment Team may place transactions for one investment strategy that are directly or indirectly contrary to investment decisions made on behalf of another investment strategy. Hotchkis & Wiley also provides model portfolio investment recommendations to sponsors without execution or additional services. The timing of model delivery recommendations will vary depending on the contractual arrangement with the program Sponsor. As a result, depending on the program arrangement and circumstances surrounding a trade order, Hotchkis & Wiley’s discretionary clients may receive prices that are more favorable than those received by a client of a program Sponsor or vice versa. |
Hotchkis & Wiley may be restricted from purchasing more than a limited percentage of the outstanding shares of a company or otherwise restricted from trading in a company’s securities due to other regulatory limitations. If a company is a viable investment for more than one investment strategy, Hotchkis & Wiley has adopted policies and procedures reasonably designed to ensure that all of its clients are treated fairly and equitably. Additionally, potential and actual conflicts of interest may also arise as a result of Hotchkis & Wiley’s other business activities and Hotchkis & Wiley’s possession of material non-public information about an issuer, which may have an adverse impact on one group of clients while benefiting another group. In certain situations, Hotchkis & Wiley will purchase different classes of securities of the same company (e.g. senior debt, subordinated debt, and or equity) in different investment strategies which can give rise to conflicts where Hotchkis & Wiley may advocate for the benefit of one class of security which may be adverse to another security that is held by clients of a different strategy. Hotchkis & Wiley seeks to mitigate the impact of these conflicts on a case by case basis. Hotchkis & Wiley utilizes soft dollars to obtain brokerage and research services, which may create a conflict of interest in allocating clients’ brokerage business. Research services may be used in servicing any or all of Hotchkis & Wiley’s clients (including model portfolio delivery clients) across all of the firm’s investment strategies, and may benefit certain client accounts more than others. Certain discretionary client accounts may also pay a less proportionate amount of commissions for research services. If a research product provides both a research and a non-research function, Hotchkis & Wiley will make a reasonable allocation of the use and pay for the non-research portion with hard dollars. Hotchkis & Wiley will make decisions involving soft dollars in a manner that satisfies the requirements of Section 28(e) of the Securities Exchange Act of 1934. |
Different types of accounts and investment strategies may have different fee structures. Additionally, certain accounts pay Hotchkis & Wiley performance-based fees, which may vary depending on how well the account performs compared to a benchmark. Because such fee arrangements have the potential to create an incentive for Hotchkis & Wiley to favor such accounts in making investment decisions and allocations, Hotchkis & Wiley has adopted policies and procedures reasonably designed to ensure that all of its clients are treated fairly and equitably, including in respect of allocation decisions, such as initial public offerings. Since accounts are managed to a target portfolio by the Investment Team, adequate time and resources are consistently applied to all accounts in the same investment strategy. Investment personnel of the firm 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 Conduct. | |
Jacobs Levy: Jacobs Levy and its investment personnel provide investment management services to multiple accounts, including the Fund’s account. The portfolio managers, Bruce Jacobs and Kenneth Levy, jointly manage all Jacobs Levy-managed accounts with the support of the firm’s other investment professionals. Providing investment management services to multiple accounts simultaneously may give rise to certain potential conflicts of interest because accounts may have investment objectives and/or strategies that are similar to or different from those of the Fund. Jacobs Levy may make investment decisions for certain accounts that are not necessarily consistent with the decisions made for other accounts. As such, performance among accounts (including the Fund’s account) may differ. Conflicts may also arise in the allocation of transactions among client accounts with different fee arrangements and accounts in which the firm or the portfolio managers may have an ownership or financial interest. | |
Jacobs Levy is entitled to be paid performance-based compensation by certain accounts it manages. Jacobs Levy’s revenue may be increased by its receipt of performance-based fees. In addition, certain client accounts may have higher asset-based fees or more favorable performance-based compensation arrangements than other accounts. Jacobs Levy and the portfolio managers, whose compensation is derived primarily through their equity share in Jacobs Levy, may have an incentive to favor client accounts that pay the firm performance-based compensation or higher fees. | |
Jacobs Levy manages a number of proprietary accounts alongside client accounts. These proprietary accounts may invest in the same securities that Jacobs Levy recommends to or buys or sells for client accounts (including the Fund’s account). Jacobs Levy typically aggregates trades for proprietary and client accounts. These proprietary accounts may have investment objectives and/or strategies which are similar to or different from those of the Fund. Jacobs Levy may make investment |
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decisions for proprietary accounts that are not necessarily consistent with the decisions made regarding client investments (including investments for the Fund). As such, the performance of these proprietary accounts may differ from the performance of client accounts (including the Fund’s account). | |
Jacobs Levy has adopted and implemented policies and procedures intended to address conflicts of interest relating to the management of multiple accounts. Jacobs Levy reviews statistical allocation reports periodically to determine whether accounts are treated, in its view, fairly. The performance of similarly managed accounts is also compared periodically to determine whether there are any unexplained significant discrepancies. In addition, Jacobs Levy has adopted procedures, which, in its view, are reasonably designed to create a fair and equitable allocation of investment opportunities over time among accounts. | |
Jacobs Levy provides model portfolios to one or more of its clients for which Jacobs Levy does not have investment discretion. Jacobs Levy may execute trades for other clients whose accounts utilize the same investment strategy as the model(s). Since Jacobs Levy does not have discretion to execute trades for its model portfolio client(s), it is possible that trading based on the model portfolio will occur at the same or different times for Jacobs Levy’s discretionary clients and for its model portfolio client(s), and therefore that trading conducted for one client will impact the value at which the relevant securities trade for another client. | |
JPMIM: The potential for conflicts of interest exists when portfolio managers manage other accounts with similar investment objectives and strategies as the Fund (“Similar Accounts”). Potential conflicts may include, for example, conflicts between investment strategies and conflicts in the allocation of investment opportunities. | |
Responsibility for managing JPMorgan’s and its affiliates’ clients’ portfolios is organized according to investment strategies within asset classes. Generally, client portfolios with similar strategies are managed by portfolio managers in the same portfolio management group using the same objectives, approach and philosophy. Underlying sectors or strategy allocations within a larger portfolio are likewise managed by portfolio managers who use the same approach and philosophy as similarly managed portfolios. Therefore, portfolio holdings, relative position sizes and industry and sector exposures tend to be similar across similar portfolios and strategies, which minimizes the potential for conflicts of interest. | |
JPMorgan and/or its affiliates (“JPMorgan Chase”) perform investment services, including rendering investment advice, to varied clients. JPMorgan, JPMorgan Chase and its or their directors, officers, agents, and/or employees may render similar or differing investment advisory services to clients and may give advice or exercise investment responsibility and take such other action with respect to any of its other clients that differs from the advice given or the timing or nature of action taken with respect to another client or group of clients. It is JPMorgan’s policy, to the extent practicable, to allocate, within its reasonable discretion, investment opportunities among clients over a period of time on a fair and equitable basis. One or more of JPMorgan’s other client accounts may at any time hold, acquire, increase, decrease, dispose, or otherwise deal with positions in investments in which another client account may have an interest from time-to-time. | |
JPMorgan, JPMorgan Chase, and any of its or their directors, partners, officers, agents or employees, may also buy, sell, or trade securities for their own accounts or the proprietary accounts of JPMorgan and/or JPMorgan Chase. JPMorgan and/or JPMorgan Chase, within their discretion, may make different investment decisions and other actions with respect to their own proprietary accounts than those made for client accounts, including the timing or nature of such investment decisions or actions. Further, JPMorgan is not required to purchase or sell for any client account securities that it, JPMorgan Chase, and any of its or their employees, principals, or agents may purchase or sell for their own accounts or the proprietary accounts of JPMorgan, or JPMorgan Chase or its clients. | |
JPMorgan and/or its affiliates may receive more compensation with respect to certain Similar Accounts than that received with respect to the Fund or may receive compensation based in part on the performance of certain Similar Accounts. This may create a potential conflict of interest for JPMorgan and its affiliates or the portfolio managers by providing an incentive to favor these Similar Accounts when, for example, placing securities transactions. In addition, JPMorgan or its affiliates could be viewed as having a conflict of interest to the extent that JPMorgan or an affiliate has a proprietary investment in Similar Accounts, the portfolio managers have personal investments in Similar Accounts or the Similar Accounts are investment options in JPMorgan’s or its affiliates’ employee benefit plans. Potential conflicts of interest may arise with both the aggregation and allocation of securities transactions and allocation of investment opportunities because of market factors or investment restrictions imposed upon JPMorgan and its affiliates by law, regulation, contract or internal policies. Allocations of aggregated trades, particularly trade orders that were only partially completed due to limited availability and allocation of investment opportunities generally, could raise a potential conflict of interest, as JPMorgan or its affiliates may have an incentive to allocate securities that are expected to increase in value to favored accounts. Initial public offerings, in particular, are frequently of very limited availability. JPMorgan and its affiliates may be perceived as causing accounts they manage to participate in an offering to increase JPMorgan’s and its affiliates’ overall allocation of securities in that offering. A potential conflict of interest also may be perceived to arise if transactions in one account closely follow related transactions in a different account, such as when a purchase increases the value of securities previously purchased by |
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another account, or when a sale in one account lowers the sale price received in a sale by a second account. If JPMorgan or its affiliates manage accounts that engage in short sales of securities of the type in which the Fund invests, JPMorgan or its affiliates 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. | |
As an internal policy matter, JPMorgan or its affiliates may from time to time maintain certain overall investment limitations on the securities positions or positions in other financial instruments JPMorgan or its affiliates will take on behalf of its various clients due to, among other things, liquidity concerns and regulatory restrictions. Such policies may preclude the Fund from purchasing particular securities or financial instruments, even if such securities or financial instruments would otherwise meet the Fund’s objectives. | |
The goal of JPMorgan and its affiliates is to meet their fiduciary obligation with respect to all clients. JPMorgan and its affiliates have policies and procedures that seek to manage conflicts. JPMorgan and its affiliates monitor a variety of areas, including compliance with fund guidelines, review of allocation decisions and compliance with JPMorgan’s Codes of Ethics and JPMorgan Chase and Co.’s Code of Conduct. With respect to the allocation of investment opportunities, JPMorgan and its affiliates also have certain policies designed to achieve fair and equitable allocation of investment opportunities among its clients over time. For example: Orders for the same equity security traded through a single trading desk or system are aggregated on a continual basis throughout each trading day consistent with JPMorgan’s and its affiliates’ duty of best execution for their clients. If aggregated trades are fully executed, accounts participating in the trade will be allocated their pro rata share on an average price basis. Partially completed orders generally will be allocated among the participating accounts on a pro-rata average price basis, subject to certain limited exceptions. For example, accounts that would receive a de minimis allocation relative to their size may be excluded from the order. Another exception may occur when thin markets or price volatility require that an aggregated order be completed in multiple executions over several days. If partial completion of the order would result in an uneconomic allocation to an account due to fixed transaction or custody costs, JPMorgan and its affiliates may exclude small orders until 50% of the total order is completed. Then the small orders will be executed. Following this procedure, small orders will lag in the early execution of the order, but will be completed before completion of the total order. | |
Purchases of money market instruments and fixed income securities cannot always be allocated pro-rata across the accounts with the same investment strategy and objective. However, JPMIM and its affiliates attempt to mitigate any potential unfairness by basing non-pro rata allocations traded through a single trading desk or system upon objective predetermined criteria for the selection of investments and a disciplined process for allocating securities with similar duration, credit quality and liquidity in the good faith judgment of JPMIM or its affiliates so that fair and equitable allocation will occur over time. | |
Loomis Sayles: Conflicts of interest may arise in the allocation of investment opportunities and the allocation of aggregated orders among the Funds and other accounts managed by the portfolio managers. A portfolio manager potentially could give favorable treatment to some accounts for a variety of reasons, including favoring larger accounts, accounts that pay higher fees, accounts that pay performance-based fees, accounts of affiliated companies and accounts in which the portfolio manager has an interest. Such favorable treatment could lead to more favorable investment opportunities or allocations for some accounts. Loomis Sayles makes investment decisions for all accounts (including institutional accounts, mutual funds, hedge funds and affiliated accounts) based on each account’s availability of other comparable investment opportunities and Loomis Sayles’ desire to treat all accounts fairly and equitably over time. Loomis Sayles maintains trade allocation and aggregation policies and procedures to address these potential conflicts. Conflicts of interest also arise to the extent a portfolio manager short sells a stock in one client account but holds that stock long in other accounts, including the Funds, or sells a stock for some accounts while buying the stock for others, and through the use of “soft dollar arrangements,” which are discussed in Loomis Sayles’ Brokerage Allocation Policies and Procedures and Loomis Sayles’ Trade Aggregation and Allocation Policies and Procedures. |
Los Angeles Capital: Los Angeles Capital has implemented policies and procedures, including brokerage and trade allocation policies and procedures, which the firm believes are reasonably designed to address the potential for conflicts of interest associated with managing portfolios for multiple clients and that seek to treat all clients fairly and equally over time and to mitigate conflicts among accounts. Client accounts are managed independent of one another in accordance with client specific mandates, restrictions, and instructions as outlined in the investment management agreement, and such restrictions and instructions are monitored for compliance with the client’s investment guidelines. Side-by-side management can result in investment positions or actions taken for one client account that differ from those taken in another client account. Accordingly, one client account can engage in short sales of or take a short position in an investment that at the same time is owned or being purchased long by another client account. These positions and actions can adversely affect or benefit different clients at different times. |
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The firm manages client accounts that have different investment strategies, objectives, restrictions, constraints, launch dates, and overlapping benchmark constituents. Given these customizations and differences, it is possible that Los Angeles Capital may be purchasing or holding a security for one account and simultaneously selling the same security for another account. However, simultaneously purchasing and selling the same security in the same account (“wash trades”) is prohibited. |
The decision as to which accounts participate in an investment opportunity will take into account, among other things, the quantitative model’s outlook on the account’s strategy, the account’s investment guidelines, and the account’s risk metrics. Global accounts’ orders are sent to the market simultaneously subject to prevailing market conditions, client flows, and liquidity. Emerging markets account orders are typically aggregated during account rebalances, but the firm is not required to do so. |
Los Angeles Capital’s proprietary optimization-based technology for trading client portfolios complements the firm’s approach to stock selection and uses real-time market prices to parse the master (“parent”) order lists into a sub-list or “child” order lists, for execution by agency brokers. For accounts traded using the firm’s trade optimization technology, real-time market prices are the primary creation determinant in each child order. Therefore, names traded for one account (or group of accounts) may result in different execution prices than a name traded for another account (or group of accounts). The firm’s trade optimization technology is primarily used for U.S. market accounts. As the firm’s trade optimization trading technology is dependent upon robust and consistent market data, Los Angeles Capital does not currently utilize this technology in Developed Asia and Emerging Markets. |
While each client account is managed individually, Los Angeles Capital may, at any given time, purchase and/or sell the same security in a block that is allocated among multiple accounts. There are a number of variables that can influence a decision to aggregate purchases or sales into a block, including but not limited to, order size, liquidity, client trading directives, regulatory limitations, round lot requirements, and cash flows. The firm allocates trades that are submitted in a block prior to placing the trade with the broker. When there is decision making on whether to include or exclude certain accounts from a block transaction, there is always the potential for conflicts of interest. Furthermore, the effect of trade aggregation may work on some occasions to the account’s disadvantage. Los Angeles Capital’s policies and procedures in allocating trades are structured to treat all clients fairly. Los Angeles Capital is not required to aggregate any particular trade. For example, an account with directed brokerage may not participate in certain block trades. |
The firm’s strategies predominantly invest in liquid common stocks. Based on a variety of factors including the strategy, guidelines, and turnover goals, Los Angeles Capital determines the trading frequency for each account. Most accounts currently trade at least semi-monthly and others may trade more or less frequently depending on turnover goals, market conditions and other factors unique to the strategy or markets in which they are invested. An account’s rebalance cycle is dependent on the account’s strategy. Los Angeles Capital has designed a proprietary Brokerage Allocation Randomization system for objectively pairing which broker to use when executing an account’s transactions based on regional market eligibility/suitability characteristics, as well as perceived execution capability of the broker in such regional markets. This system is not used for Emerging Markets-only strategies. The firm’s proprietary accounts, which are invested in liquid, benchmark securities, may be traded in rotation with client accounts or on a particular day of the week depending on liquidity, size, model constraints, and resource constraints. The order of account rebalances may work on some occasions to the account’s advantage or disadvantage. |
Los Angeles Capital’s portfolio managers manage accounts that are charged a performance-based fee alongside accounts in the same strategy with 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. Management and performance fees inure to the benefit of the firm as a whole and not to specific individuals or groups of individuals. Further, Los Angeles Capital employs a quantitative investment process which utilizes the firm’s proprietary investment model technology to identify securities and construct portfolios. |
Los Angeles Capital has adopted a Code of Ethics that includes procedures on ethical conduct and personal trading and requires pre-clearance authorization from both the Trading and Compliance and Regulatory Risk Departments for certain personal security transactions. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is monitored under the Code of Ethics, and is designed to reasonably identify and prevent conflicts of interest between the firm and its clients. |
Investment personnel of Los Angeles Capital or its affiliate may be permitted to be commercially or professionally involved with an issuer of securities. There is a potential risk that Los Angeles Capital personnel may place their own interests (resulting from outside employment/directorships) ahead of the interests of Los Angeles Capital clients. Before engaging in |
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any outside business activity, employees must obtain approval of the CCO as well as other personnel. Any potential conflicts of interest from such involvement are monitored for compliance with Los Angeles Capital’s Code of Ethics. The Code of Ethics also governs employees giving or accepting gifts and entertainment. |
Manulife: When a portfolio manager is responsible for the management of more than one account, the potential arises for the portfolio manager to favor one account over another. The principal types of potential conflicts of interest that may arise are discussed below. For the reasons outlined below, the Fund does not believe that any material conflicts are likely to arise out of a portfolio manager‘s responsibility for the management of the Fund as well as one or more other accounts. Manulife has adopted procedures that are intended to monitor compliance with the policies referred to in the following paragraphs. Generally, the risks of such conflicts of interests are increased to the extent that a portfolio manager has a financial incentive to favor one account over another. Manulife has structured their compensation arrangements in a manner that is intended to limit such potential for conflicts of interests. See ―Compensation of Portfolio Managers below. | |
A portfolio manager could favor one account over another in allocating new investment opportunities that have limited supply, such as initial public offerings and private placements. If, for example, an initial public offering that was expected to appreciate in value significantly shortly after the offering was allocated to a single account, that account may be expected to have better investment performance than other accounts that did not receive an allocation on the initial public offering. Manulife has policies that require a portfolio manager to allocate such investment opportunities in an equitable manner and generally to allocate such investments proportionately among all accounts with similar investment objectives. | |
A portfolio manager could favor one account over another in the order in which trades for the accounts are placed. If a portfolio manager determines to purchase a security for more than one account in an aggregate amount that may influence the market price of the security, accounts that purchased or sold the security first may receive a more favorable price than accounts that made subsequent transactions. The less liquid the market for the security or the greater the percentage that the proposed aggregate purchases or sales represent of average daily trading volume, the greater the potential for accounts that make subsequent purchases or sales to receive a less favorable price. When a portfolio manager intends to trade the same security for more than one account, the policies of Manulife generally require that such trades be “bunched”, which means that the trades for the individual accounts are aggregated and each account receives the same price. There are some types of accounts as to which bunching may not be possible for contractual reasons (such as directed brokerage arrangements). Circumstances may also arise where the trader believes that bunching the orders may not result in the best possible price. Where those accounts or circumstances are involved, Manulife will place the order in a manner intended to result in as favorable a price as possible for such client. | |
A portfolio manager could favor an account if the portfolio manager‘s compensation is tied to the performance of that account rather than all accounts managed by the portfolio manager. If, for example, the portfolio manager receives a bonus based upon the performance of certain accounts relative to a benchmark while other accounts are disregarded for this purpose, the portfolio manager will have a financial incentive to seek to have the accounts that determine the portfolio manager‘s bonus achieve the best possible performance to the possible detriment of other accounts. Similarly, if Manulife receives a performance-based advisory fee, the portfolio manager may favor that account, whether or not the performance of that account directly determines the portfolio manager‘s compensation. The investment performance on specific accounts is not a factor in determining the portfolio manager‘s compensation. Neither the advisor nor Manulife receives a performance-based fee with respect to any of the accounts managed by the portfolio managers. | |
A portfolio manager could favor an account if the portfolio manager has a beneficial interest in the account, in order to benefit a large client or to compensate a client that had poor returns. For example, if the portfolio manager held an interest in an investment partnership that was one of the accounts managed by the portfolio manager, the portfolio manager would have an economic incentive to favor the account in which the portfolio manager held an interest. Manulife imposes certain trading restrictions and reporting requirements for accounts in which a portfolio manager or certain family members have a personal interest in order to confirm that such accounts are not favored over other accounts. | |
If the different accounts have materially and potentially conflicting investment objectives or strategies, a conflict of interest may arise. For example, if a portfolio manager purchases a security for one account and sells the same security short for another account, such trading pattern could disadvantage either the account that is long or short. In making portfolio manager assignments, Manulife seeks to avoid such potentially conflicting situations. However, where a portfolio manager is responsible for accounts with differing investment objectives and policies, it is possible that the portfolio manager will conclude that it is in the best interest of one account to sell a portfolio security while another account continues to hold or increase the holding in such security. |
PGIM: Like other investment advisers, PGIM Fixed Income is subject to various conflicts of interest in the ordinary course of its business. PGIM Fixed Income strives to identify potential risks, including conflicts of interest, that are inherent in its |
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business, and PGIM Fixed Income conducts annual conflict of interest reviews. However, it is not possible to identify every potential conflict that can arise. When actual or potential conflicts of interest are identified, PGIM Fixed Income seeks to address such conflicts through one or more of the following methods: |
■ | elimination of the conflict; |
■ | disclosure of the conflict; or |
■ | management of the conflict through the adoption of appropriate policies, procedures or other mitigants. |
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■ | it provides advisory services to the proprietary accounts of investment consultants and/or their affiliates, and advisory services to funds offered by investment consultants and/or their affiliates; |
■ | it invites investment consultants to events or other entertainment hosted by PGIM Fixed Income; |
■ | it purchases software applications, market data, access to databases, technology services and other products or services from certain investment consultants; and |
■ | it sometimes pays for the opportunity to participate in conferences organized by investment consultants. |
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■ | Elimination of the conflict; |
■ | Disclosure of the conflict; or |
■ | Management of the conflict through the adoption of appropriate policies and procedures. |
■ | Asset-Based Fees vs. Performance-Based Fees; Other Fee Considerations. PGIM Quantitative Solutions manages accounts with asset-based fees alongside accounts with performance-based fees. Asset-based fees are calculated based on the value of a client’s portfolio at periodic measurement dates or over specified periods of time. Performance-based fees are generally based on a share of the total return of a portfolio, and may offer greater upside potential to PGIM Quantitative Solutions than asset-based fees, depending on how the fees are structured. This side-by-side management could create an incentive for PGIM Quantitative Solutions to favor one account over another. Specifically, PGIM Quantitative Solutions could have the incentive to favor accounts for which it receives performance fees, and possibly take greater investment risks in those accounts, in order to bolster performance and increase its fees. In addition, since fees are negotiable, one client may be paying a higher fee than another client with similar investment objectives or goals. In negotiating fees, PGIM Quantitative Solutions takes into account a number of factors including, but not limited to, the |
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investment strategy, the size of a portfolio being managed, the relationship with the client, and the required level of service. Fees may also differ based on account type. For example, fees for commingled vehicles, including those that PGIM Quantitative Solutions subadvises, may differ from fees charged for single client accounts. | |
■ | Long Only/Long-Short Accounts. PGIM Quantitative Solutions manages accounts that only allow it to hold securities long as well as accounts that permit short selling. PGIM Quantitative Solutions may, therefore, sell a security short in some client accounts while holding the same security long in other client accounts, creating the possibility that PGIM Quantitative Solutions is taking inconsistent positions with respect to a particular security in different client accounts. |
■ | Compensation/Benefit Plan Accounts/Other Investments by Investment Professionals. PGIM Quantitative Solutions manages certain funds and strategies whose performance is considered in determining long-term incentive plan benefits for certain investment professionals. Investment professionals involved in the management of accounts in these strategies have an incentive to favor them over other accounts they manage in order to increase their compensation. Additionally, PGIM Quantitative Solutions’ investment professionals may have an interest in those strategies if the funds are chosen as options in their 401(k) or deferred compensation plans offered by Prudential or if they otherwise invest in those funds directly. |
■ | Affiliated Accounts. PGIM Quantitative Solutions manages accounts on behalf of its affiliates as well as unaffiliated accounts. PGIM Quantitative Solutions could have an incentive to favor accounts of affiliates over others. |
■ | Non-Discretionary Accounts or Model Portfolios. PGIM Quantitative Solutions provides non-discretionary model portfolios to some clients and manages other portfolios on a discretionary basis. When PGIM Quantitative Solutions manages accounts on a non-discretionary basis, the investment team will typically deliver a model portfolio to a non-discretionary client at or around the same time as executing discretionary trades in the same strategy. The non-discretionary clients may be disadvantaged if PGIM Quantitative Solutions delivers the model investment portfolio to them after it initiates trading for the discretionary clients, or vice versa. |
■ | Large Accounts/Higher Fee Strategies. Large accounts typically generate more revenue than do smaller accounts and certain strategies have higher fees than others. As a result, a portfolio manager has an incentive when allocating scarce investment opportunities to favor accounts that pay a higher fee or generate more income for PGIM Quantitative Solutions. |
■ | Securities of the Same Kind or Class. PGIM Quantitative Solutions sometimes buys or sells, or directs or recommends that one client buy or sell, securities of the same kind or class that are purchased or sold for another client, at prices that may be different. PGIM Quantitative Solutions may also, at any time, execute trades of securities of the same kind or class in one direction for an account and in the opposite direction for another account, due to differences in investment strategy or client direction. Different strategies effecting trading in the same securities or types of securities can appear as inconsistencies in PGIM Quantitative Solutions’ management of multiple accounts side-by-side. |
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■ | Conflicts Arising Out of Legal Restrictions. PGIM Quantitative Solutions may be restricted by law, regulation, contract or other constraints as to how much, if any, of a particular security it may purchase or sell on behalf of a client, and as to the timing of such purchase or sale. Sometimes, these restrictions apply as a result of PGIM Quantitative Solutions’ relationship with Prudential Financial and its other affiliates. For example, PGIM Quantitative Solutions’ holdings of a security on behalf of its clients are required, under certain regulations, to be aggregated with the holdings of that security by other Prudential Financial affiliates. These holdings could, on an aggregate basis, exceed certain reporting or ownership thresholds. PGIM Quantitative Solutions tracks these aggregate holdings and may restrict purchases to avoid crossing such thresholds because of the potential consequences to Prudential if such thresholds are exceeded. In addition, PGIM Quantitative Solutions could receive material, non-public information with respect to a particular issuer from an affiliate and, as a result, be unable to execute purchase or sale transactions in securities of that issuer for its clients. PGIM Quantitative Solutions is generally able to avoid receiving material, non-public information from its affiliates by maintaining information barriers to prevent the transfer of information between affiliates. |
■ | PGIM Quantitative Solutions, Prudential Financial, Inc., The Prudential Insurance Company of America (PICA) and other affiliates of PGIM Quantitative Solutions have financial interests in, or relationships with, companies whose securities PGIM Quantitative Solutions holds, purchases or sells in its client accounts. Certain of these interests and relationships are material to PGIM Quantitative Solutions or to the Prudential enterprise. At any time, these interests and relationships could be inconsistent or in potential or actual conflict with positions held or actions taken by PGIM Quantitative Solutions on behalf of its client accounts. For example, PGIM Quantitative Solutions invests in the securities of one or more clients for the accounts of other clients. PGIM Quantitative Solutions’ affiliates sell various products and/or services to certain companies whose securities PGIM Quantitative Solutions purchases and sells for its clients. PGIM Quantitative Solutions’ affiliates hold public and private debt and equity securities of a large number of issuers. PGIM Quantitative Solutions invests in some of the same issuers for its client accounts but at different levels in the capital structure. For instance, PGIM Quantitative Solutions may invest client assets in the equity of companies whose debt is held by an affiliate. Certain of PGIM Quantitative Solutions’ affiliates (as well as directors of PGIM Quantitative Solutions’ affiliates) are officers or directors of issuers in which PGIM Quantitative Solutions invests from time to time. These issuers may also be service providers to PGIM Quantitative Solutions or its affiliates. In general, conflicts related to the financial interests described above are addressed by the fact that PGIM Quantitative Solutions makes investment decisions for each client independently considering the best economic interests of such client. |
■ | Certain of PGIM Quantitative Solutions’ employees may offer and sell securities of, and interests in, commingled funds that PGIM Quantitative Solutions manages or subadvises. Employees may offer and sell securities in connection with their roles as registered representatives of Prudential Investment Management Services LLC (a broker-dealer affiliate), or as officers, agents, or approved persons of other affiliates. There is an incentive for PGIM Quantitative Solutions’ employees to offer these securities to investors regardless of whether the investment is appropriate for such investor since |
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increased assets in these vehicles will result in increased advisory fees to PGIM Quantitative Solutions. In addition, although sales commissions are not paid for such activities, such sales could result in increased compensation to the employee. To mitigate this conflict, PGIM Quantitative Solutions performs suitability checks on new clients as well as on an annual basis with respect to all clients. | |
■ | A portion of the long-term incentive grant of some of PGIM Quantitative Solutions’ investment professionals will increase or decrease based on the performance of several of PGIM Quantitative Solutions’ strategies over defined time periods. Consequently, some of PGIM Quantitative Solutions’ portfolio managers from time to time have financial interests in the accounts they advise. To address potential conflicts related to these financial interests, PGIM Quantitative Solutions has procedures, including supervisory review procedures, designed to verify that each of its accounts is managed in a manner that is consistent with PGIM Quantitative Solutions’ fiduciary obligations, as well as with the account’s investment objectives, investment strategies and restrictions. Specifically, PGIM Quantitative Solutions’ chief investment officer will perform a comparison of trading costs between accounts in the strategies whose performance is considered in connection with the long-term incentive grant and other accounts, to verify that such costs are consistent with each other or otherwise in line with expectations. The results of the analysis are discussed at a meeting of PGIM Quantitative Solutions’ Trade Management Oversight Committee. |
■ | PGIM Quantitative Solutions and its affiliates, from time to time, have service agreements with various vendors that are also investment consultants. Under these agreements, PGIM Quantitative Solutions or its affiliates compensate the vendors for certain services, including software, market data and technology services. PGIM Quantitative Solutions’s clients may also retain these vendors as investment consultants. The existence of service agreements between these consultants and PGIM Quantitative Solutions may provide an incentive for the investment consultants to favor PGIM Quantitative Solutions when they advise their clients. PGIM Quantitative Solutions does not, however, condition its purchase of services from consultants upon their recommending PGIM Quantitative Solutions to their clients. PGIM Quantitative Solutions will provide clients with information about services that PGIM Quantitative Solutions or its affiliates obtain from these consultants upon request. PGIM Quantitative Solutions retains third party advisors and other service providers to provide various services for PGIM Quantitative Solutions as well as for funds that PGIM Quantitative Solutions manages or subadvises. A service provider may provide services to PGIM Quantitative Solutions or one of its funds while also providing services to PGIM, Inc. (PGIM), other PGIM-advised funds, or affiliates of PGIM, and may negotiate rates in the context of the overall relationship. PGIM Quantitative Solutions may benefit from negotiated fee rates offered to its funds and vice-versa. There is no assurance that PGIM Quantitative Solutions will be able to obtain advantageous fee rates from a given service provider negotiated by its affiliates based on their relationship with the service provider, or that it will know of such negotiated fee rates. |
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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 and its affiliate Columbia Management have 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. |
Voya: A portfolio manager may be subject to potential conflicts of interest because the portfolio manager is responsible for other accounts in addition to the Funds. These other accounts may include, among others, other mutual funds, separately managed advisory accounts, commingled trust accounts, insurance separate accounts, wrap fee programs, and hedge funds. Potential conflicts may arise out of the implementation of differing investment strategies for the portfolio manager’s various accounts, the allocation of investment opportunities among those accounts or differences in the advisory fees paid by the portfolio manager’s accounts. | |
A potential conflict of interest may arise as a result of the portfolio manager’s responsibility for multiple accounts with similar investment guidelines. Under these circumstances, a potential investment may be suitable for more than one of the portfolio manager’s accounts, but the quantity of the investment available for purchase is less than the aggregate amount the accounts would ideally devote to the opportunity. Similar conflicts may arise when multiple accounts seek to dispose of the same investment. | |
A portfolio manager may also manage accounts whose objectives and policies differ from those of the Funds. These differences may be such that under certain circumstances, trading activity appropriate for one account managed by the portfolio manager may have adverse consequences for another account managed by the portfolio manager. For example, if an account were to sell a significant position in a security, which could cause the market price of that security to decrease, while a Fund maintained its position in that security. | |
A potential conflict may arise when a portfolio manager is responsible for accounts that have different advisory fees – the difference in the fees may create an incentive for the portfolio manager to favor one account over another, for example, in terms of access to particularly appealing investment opportunities. This conflict may be heightened where an account is subject to a performance-based fee. As part of its compliance program, Voya IM has adopted policies and procedures reasonably designed to address the potential conflicts of interest described above. | |
Finally, a potential conflict of interest may arise because the investment mandates for certain other accounts, such as hedge funds, may allow extensive use of short sales which, in theory, could allow them to enter into short positions in securities where other accounts hold long positions. Voya IM has policies and procedures reasonably designed to limit and monitor short sales by the other accounts to avoid harm to the Funds. |
Water Island: Water Island maintains policies and procedures reasonably designed to detect and minimize potential conflicts of interest inherent in circumstances when a portfolio manager has day-to-day responsibilities for managing multiple portfolios. Other portfolios managed by Water Island may include, without limitation: separately managed accounts, registered investment companies, unregistered investment companies such as pooled investment vehicles and hedge funds, and proprietary accounts. However, no set of policies and procedures can possibly anticipate or relieve all potential conflicts of interest. These conflicts may be real, potential, or perceived. Certain of these conflicts are described below. |
Allocation of Limited Investment Opportunities – If a portfolio manager identifies a limited investment opportunity (including initial public offerings and private placement securities) that may be suitable for multiple funds and/or accounts, |
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the investment opportunity may be allocated among these multiple funds or accounts, which may limit a client’s ability to take full advantage of the investment opportunity, due to liquidity constraints or other factors. Water Island has adopted trade aggregation and allocation procedures designed to ensure that allocations of limited investment opportunities are conducted in a fair and equitable manner among client accounts, including the Fund. Nevertheless, investment opportunities may be allocated differently among client accounts due to the characteristics of an account, such as the size of the account, cash position, investment guidelines and restrictions, or risk controls. |
Similar Investment Strategies – Water Island and its portfolio management team may manage multiple portfolios with similar investment strategies. Investment decisions for each portfolio are generally made based on each portfolio’s investment objectives and guidelines, cash availability, current holdings, and risk controls. Purchases or sales of securities for a portfolio may be appropriate for other portfolios with like objectives and may be bought or sold in different amounts and at different times in multiple portfolios. In these cases, transactions are allocated to portfolios in a manner believed fair and equitable across client account portfolios by Water Island’s allocation methodology. Purchase and sale orders for a portfolio may be combined with those of other portfolios in the interest of achieving the most favorable net results for all portfolios. |
Different Investment Strategies – Water Island and its portfolio management team may manage multiple portfolios with different investment strategies. As such, the potential exists for short sales of securities in certain portfolios while the same security is held long in one or more other portfolios. In an attempt to mitigate the inherent risks of simultaneous management of portfolios with different investment strategies, Water Island has established and implemented procedures to promote fair and equitable treatment of all portfolios. The procedures include monitoring and surveillance of trading activity and supervisory reviews of accounts. Any proposed cross trades must be reviewed and approved by Water Island’s compliance department prior to execution and must comply with Rule 17a-7 under the 1940 Act. |
Differences in Financial Incentives - A conflict of interest may arise where the financial or other benefits available to a portfolio manager or an investment adviser differ among the funds and/or accounts under management. For example, when the structure of an investment adviser’s management fee differs among the funds and/or accounts under its management (such as where certain funds or accounts pay higher management fees or performance-based management fees), a portfolio manager might be motivated to favor certain funds and/or accounts over others. Performance-based fees could also create an incentive for an investment adviser to make investments that are riskier or more speculative. In addition, a portfolio manager might be motivated to favor funds and/or accounts in which the portfolio manager or Water Island has a financial interest. For instance, Water Island may from time to time establish “pilot” or “incubator” funds for the purpose of testing proposed investment strategies or products prior to accepting assets from outside investors. Typically, Water Island or an affiliate supplies the funding for these accounts. Employees of Water Island, including the Fund’s portfolio managers, may also invest in certain pilot accounts. Water Island may also manage certain pooled investment vehicles whereby Water Island provides principal protection for investors. Water Island may be motivated to favor such funds to minimize the likelihood of losses. Similarly, the desire to maintain or raise assets under management or to enhance the portfolio manager’s performance record in a particular investment strategy or to derive other rewards, financial or otherwise, could influence a portfolio manager to lend preferential treatment to those funds and/or accounts that could most significantly benefit Water Island or the portfolio manager. As described above, it is Water Island’s policy that investment opportunities and trades are allocated fairly and equitably among client accounts, taking into consideration the objectives, restrictions, investment strategy, asset allocation and benchmarks of each client. To manage conflicts that arise from management of portfolios that may have differences in financial incentives, performance in portfolios with like strategies is regularly reviewed by management. Moreover, Water Island has adopted a policy to treat pilot accounts in the same manner as other client accounts, including the Fund, for purposes of trade aggregation and allocation -- neither favoring nor disfavoring them (except that pilot accounts do not receive allocations of initial public offerings or private placement securities unless other accounts receive a full allocation first). |
Selection of Brokers/Dealers - A portfolio manager may be able to select or influence the selection of the brokers/dealers that are used to execute securities transactions. In addition to executing trades, some brokers/dealers provide Water Island with brokerage and research services (as those terms are defined in Section 28(e) of the Exchange Act), which may result in the payment of higher brokerage fees than might have otherwise been available. These services may be more beneficial to certain accounts than to others. To be assured of continuing to receive services considered of value to the Fund and its other clients, Water Island has adopted a brokerage allocation policy embodying the concepts of Section 28(e) of the Exchange Act. A portfolio manager’s decision as to the selection of brokers and dealers could yield disproportionate costs and benefits among the accounts that they manage, although the payment of brokerage commissions is always subject to the requirement that Water Island determines in good faith that the commissions are reasonable in relation to the value of the brokerage and research services received. Firms that provide brokerage or research services to the Fund and Water Island may also promote the sale of investment companies or pooled investment vehicles advised by Water Island, and Water Island and/or |
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its affiliates may separately compensate them for doing so. Such brokerage business is placed on the basis of the brokerage and research services provided by the firm and is not based on any sales of the investment companies or pooled investment vehicles advised by Water Island. |
Personal Holdings and Transactions – Water Island’s portfolio managers and other employees may have beneficial ownership of holdings in personal accounts that are the same or similar to those held in client accounts, including the Fund. Under limited circumstances, Water Island allows its employees to trade in securities that it recommends to advisory clients, and the actions taken by such individuals on a personal basis may differ from, or be inconsistent with, the nature and timing of advice or actions taken by Water Island for its client accounts. Water Island and its employees may also invest in registered investment companies and other pooled investment vehicles that are managed by Water Island. This may result in a potential conflict of interest since Water Island’s employees have knowledge of such funds’ investment holdings, which is non-public information. Water Island has implemented a Code of Ethics which is designed to address and mitigate the possibility that these professionals could place their own interests ahead of those of clients. The Code of Ethics addresses this potential conflict of interest by imposing preclearance and reporting requirements, trading blackout periods, a minimum holding period, supervisory oversight, and other measures designed to reduce conflicts of interest. |
Water Island and the Fund’s portfolio managers may also face other potential conflicts of interest in the management of the Fund and other client accounts, and the examples above are not intended to provide an exhaustive list or complete description of every conflict that may arise. |
AlphaSimplex: All AlphaSimplex investment professionals receive compensation according to a merit-based incentives structure. In addition to receiving competitive base salaries, employees are eligible for performance bonuses, which are based on both individual and firm performance. Performance is assessed on an annual basis by department heads. AlphaSimplex considers a number of factors—including risk-adjusted performance and intellectual contribution—when determining the bonus compensation of its investment professionals. Key professionals who have made significant and lasting contributions to the firm are invited to participate in a supplemental bonus pool reserved for partners of the firm. Partners are awarded claims on specific percentages of the firm’s annual profits. |
The Compensation Committee of the AlphaSimplex Board of Directors approves all bonus and partnership awards based on the recommendations of management. The total bonus pool is comprised of a staff bonus pool, which is generally set at 100% of base salaries, and a separate pool for partners, which is funded with any remainder and allocated among the partners based on their partnership interests. Accordingly, variable compensation makes up a significant portion of total remuneration, particularly for senior managers, whose bonuses can amount to between 100% and 600% of base compensation. To retain talent, AlphaSimplex defers a significant portion of bonus amounts for key professionals for up to three years. The deferred portion of bonuses is invested across all the strategies managed by AlphaSimplex. Finally, as a condition of employment, all AlphaSimplex employees agree to abide by non-compete/non-solicit/non-disclosure agreements. These agreements provide for a 12–36 month non-compete period in the event an employee leaves the firm. |
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Portfolio manager compensation is a function of firm-wide profitability. Since AlphaSimplex’s approach to investment management is quantitative and systematic, Fund shareholder interests are less dependent on day-to-day portfolio manager decisions, but more a function of overall model performance over longer time periods. Therefore, strong long-term Fund performance goes hand-in-hand with long-term firm profitability and portfolio manager compensation. |
AQR: The compensation for each of the portfolio managers that is a Principal of AQR is in the form of distributions based on the net income generated by AQR and each Principal’s relative ownership in AQR. A Principal’s relative ownership in AQR is based on a number of factors including contribution to the research process, leadership and other contributions to AQR. There is no direct linkage between assets under management, Fund performance and compensation. However, there is an indirect linkage in that superior performance tends to attract assets and thus increase revenues and presumably net income. |
The compensation for the portfolio managers that are not Principals of AQR primarily consists of a fixed base salary and a discretionary bonus (Total Compensation). Total Compensation is reviewed at least annually under a formal review program and changes are made based on a number of factors including firm performance, market rates for specific roles and an individual’s performance. Job performance contributes significantly to the determination of any Total Compensation increase; other factors, such as seniority are also considered. A portfolio manager’s Total Compensation is not based on any specific fund’s or strategy’s assets under management or performance, but is affected by the overall performance of the firm. |
Each portfolio manager is also eligible to participate in AQR’s 401(k) retirement plan which is offered to all employees of AQR. |
Arrowstreet: Arrowstreet’s compensation system is designed to attract, motivate and retain talented professionals. Arrowstreet’s compensation structure for investment professionals consists of a competitive base salary and bonus. Bonuses are paid on an annual basis. Bonus targets are set for each individual at each review period, typically the start of every year. | |
Baillie Gifford: Compensation arrangements within Baillie Gifford vary depending upon whether the individual is an employee or partner of Baillie Gifford & Co. | |
Baillie Gifford’s compensation package for staff is oriented towards rewarding long term contributions to both investment performance and the business overall. The partners are the sole owners of the firm and share directly in its profits. In this respect, the compensation and incentive package of senior executives is directly related to both performance and retention of existing clients, achieved through providing excellent investment service. | |
Baillie Gifford’s remuneration approach emphasises the importance of client outcomes and aligns more closely with its long-term investment approach. | |
A firm-wide bonus may be paid annually. Additionally, staff may receive a bonus through the Long-Term Profit Award scheme, sharing in the firm’s long-term performance. | |
The remuneration for non-partner staff at Baillie Gifford has three key elements: (i) base salary, (ii) an Annual Performance Award and (iii) a Long-Term Profit Award. In addition, staff are eligible for the firm’s health and welfare benefits available to all Baillie Gifford employees. | |
Annual Performance Award (APA) | |
All members of staff participate in the APA arrangement and are allocated to a level within the APA in line with the size, scope, and function of their role. There are five levels for the annual performance award, each with a different level of maximum award, relevant to the area of the business that each member is part of. | |
The APA calculation is determined based on the business area that the staff member is aligned to. | |
Long Term Profit Award (LTPA) | |
In addition to the annual performance award, all members of staff have the opportunity to participate in the LTPA. This award provides an annual payment to staff determined by the firm’s profitability, enabling staff to share in, and have a direct link to, the long-term prosperity of the firm. | |
The LTPA calculation is determined by the firm’s profitability and staff are aligned to one of ten levels. | |
Deferral | |
All staff defer between 10% and 40% of their total annual variable remuneration (both APA and LTPA elements). Awards deferred are held for a period of three years and are invested in a range of funds managed by Baillie Gifford that broadly reflect the firm’s investment policy. | |
Partners of Baillie Gifford & Co. Donald Farquharson, Tom Walsh and Jenny Davis are partners of Baillie Gifford & Co. | |
The remuneration of Baillie Gifford & Co. partners comprises Baillie Gifford & Co. partnership profits, which are distributed as: |
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base salary; and | |
a share of the partnership profits. | |
The profit share is calculated as a percentage of total partnership profits based on seniority and role within Baillie Gifford & Co. The basis for the profit share is detailed in the Baillie Gifford & Co. Partnership Agreement. The main staff benefits such as pension schemes are not available to partners and therefore partners provide for benefits from their own personal funds. Partners in their first few years additionally receive a bonus. The bonuses are calculated in the same way as those for staff but exclude the deferred element. A proportion of the bonus paid will be retained to be used to buy capital shares in the partnership. |
Boston Partners: All investment professionals receive a compensation package comprised of an industry competitive base salary and a discretionary bonus and long-term incentives. Through our bonus program, key investment professionals are rewarded primarily for strong investment performance. |
Typically, bonuses are based upon a combination of one or more of the following four criteria: |
1. Individual Contribution: an evaluation of the professional’s individual contribution based on the expectations established at the beginning of each year; |
2. Product Investment Performance: performance of the investment product(s) with which the individual is involved versus the pre-designed index, based on the excess return; |
3. Investment Team Performance: the financial results of the investment group; and |
4. Firm-wide Performance: the overall financial performance of Boston Partners. |
Boston Partners professional compensation consultants with asset management expertise to annually review our practices to ensure that they remain highly competitive. |
Causeway: Ms. Ketterer and Mr. Hartford, the chief executive officer and president of Causeway, respectively, receive annual salary and are entitled, as controlling owners of the firm’s parent holding company, to distributions of the holding company’s profits based on their ownership interests. They do not receive incentive compensation. The other portfolio managers receive salary and may receive incentive compensation (including potential cash, awards of growth units, or awards of equity units). Portfolio managers also receive, directly or through estate planning vehicles, distributions of profits based on their minority ownership interests in the firm’s parent holding company. Causeway’s Compensation Committee, weighing a variety of objective and subjective factors, determines salary and incentive compensation and, subject to approval of the holding company’s Board of Managers, may award equity units. Portfolios are team-managed and salary and incentive compensation are not based on the specific performance the Fund or any single client account managed by Causeway but take into account the performance of the individual portfolio manager, the relevant team and Causeway’s overall performance and financial results. The performance of stocks selected for Fund and client portfolios within a particular industry or sector over a multi-year period relative to appropriate benchmarks will be relevant for portfolio managers assigned to that industry or sector. Causeway takes into account both quantitative and qualitative factors when determining the amount of incentive compensation awarded, including the following factors: individual research contribution, portfolio and team management contribution, group research contribution, client service and recruiting contribution, and other contributions to client satisfaction and firm development. The assessment of these factors takes into account both current and future risks and different factors can be weighed differently. | |
Columbia Management: Portfolio manager direct compensation is typically comprised of a base salary, and an annual incentive award that is paid either in the form of a cash bonus if the size of the award is under a specified threshold, or, if the size of the award is over a specified threshold, the award is paid in a combination of a cash bonus, an equity incentive award, and deferred compensation. Equity incentive awards are made in the form of Ameriprise Financial restricted stock or, for more senior employees, both Ameriprise Financial restricted stock and stock options. The investment return credited on deferred compensation is based on the performance of specified Columbia Funds, in most cases including the Columbia Funds the portfolio manager manages. | |
Base salary is typically determined based on market data relevant to the employee’s position, as well as other factors including internal equity. Base salaries are reviewed annually, and increases are typically given as promotional increases, internal equity adjustments, or market adjustments. | |
Under the Columbia Management annual incentive plan for investment professionals, awards are discretionary, and the amount of incentive awards for investment team members is variable based on (1) an evaluation of the investment performance of the investment team of which the investment professional is a member, reflecting the performance (and client experience) of the funds or accounts the investment professional manages and, if applicable, reflecting the individual’s work as an investment research analyst, (2) the results of a peer and/or management review of the individual, taking into account attributes such as team participation, investment process followed, communications, and leadership, and (3) the |
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amount of aggregate funding of the plan determined by senior management of Columbia Threadneedle Investments and Ameriprise Financial, which takes into account Columbia Threadneedle Investments revenues and profitability, as well as Ameriprise Financial profitability, historical plan funding levels and other factors. Columbia Threadneedle Investments revenues and profitability are largely determined by assets under management. In determining the allocation of incentive compensation to investment teams, the amount of assets and related revenues managed by the team is also considered, alongside investment performance. Individual awards are subject to a comprehensive risk adjustment review process to ensure proper reflection in remuneration of adherence to our controls and Code of Conduct. | |
Investment performance for a fund or other account is measured using a scorecard that compares account performance against benchmarks, custom indexes and/or peer groups. Account performance may also be compared to unaffiliated passively managed ETFs, taking into consideration the management fees of comparable passively managed ETFs, when available and as determined by the Investment Manager. Consideration is given to relative performance over the one-, three- and five-year periods, with the largest weighting on the three-year comparison. For individuals and teams that manage multiple strategies and accounts, relative asset size is a key determinant in calculating the aggregate score, with weighting typically proportionate to actual assets. For investment leaders who have group management responsibilities, another factor in their evaluation is an assessment of the group’s overall investment performance. Exceptions to this general approach to bonuses exist for certain teams and individuals. | |
Equity incentive awards are designed to align participants’ interests with those of the shareholders of Ameriprise Financial. Equity incentive awards vest over multiple years, so they help retain employees. | |
Deferred compensation awards are designed to align participants’ interests with the investors in the Columbia Funds and other accounts they manage. The value of the deferral account is based on the performance of Columbia Funds. Employees have the option of selecting from various Columbia Funds for their deferral account, however portfolio managers must (other than by strict exception) allocate a minimum of 25% of their incentive awarded through the deferral program to the Columbia Fund(s) they manage. Deferrals vest over multiple years, so they help retain employees. | |
For all employees the benefit programs generally are the same and are competitive within the financial services industry. Employees participate in a wide variety of plans, including options in Medical, Dental, Vision, Health Care and Dependent Spending Accounts, Life Insurance, Long Term Disability Insurance, 401(k), and a cash balance pension plan. | |
Columbia Management – Tech Team: Portfolio manager compensation is typically comprised of (i) a base salary and (ii) an annual cash bonus. The annual cash bonus, and in most instances the base salary, are paid from a team compensation pool that is based on fees and performance of the accounts managed by the portfolio management team, which include mutual funds, wrap accounts, institutional portfolios and hedge funds. | |
The percentage of management fees on mutual funds that fund the bonus pool is based on the short term (typically one-year) and long-term (typically three-year and five-year) performance of those accounts in relation to the relevant peer group universe. | |
The pool is also funded by a percentage of the management fees on long-only institutional separate accounts, that percentage being based on the source of the account in question, and by a fixed percentage of management fees on hedge funds and separately managed accounts that follow a hedge fund mandate. | |
The percentage of performance fees on hedge funds and separately managed accounts that follow a hedge fund mandate that fund the bonus pool is based on the absolute level of each hedge fund’s current year investment return. | |
For all employees, the benefit programs generally are the same and are competitive within the financial services industry. Employees participate in a wide variety of plans, including options in Medical, Dental, Vision, Health Care and Dependent Spending Accounts, Life Insurance, Long Term Disability Insurance, 401(k), and a cash balance pension plan. |
Conestoga: Each of the Fund’s portfolio managers is a partner of Conestoga. As such, each portfolio manager receives a share of Conestoga’s annual profits, as specified in the manager’s partnership agreement with Conestoga, from Conestoga’s management of the Fund and all other accounts. |
Crabel: Crabel employees are compensated with a competitive salary and have the opportunity for a discretionary bonus. An employee’s individual performance and the performance of the firm are factors considered when determining the bonus amount. Certain senior executives participate as profits interest owners of the firm. Portfolio manager compensation related to individual strategy performance is variable, generally determined based on a percentage of the fees earned from the aggregate assets of each strategy. Managers are not compensated if they meet or exceed an index or other performance target or based on the performance of a strategy. Each strategy is designed to achieve a specific volatility target, which an investor expects to achieve. Due to the systematic nature of Crabel’s trading, managers do not have sole discretion to modify strategy parameters or to enter discretionary trades as a way to influence performance of the strategy. In any year that the firm receives performance-based fees, a portfolio manager, along with all other firm employees, may receive higher total |
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compensation based on the firm’s overall profitability in such year. Compensation is reviewed periodically to ensure all employee compensation is competitive and reflects the role of the individual employee including responsibility, job complexity, performance, and job market conditions. | |
DFA: Portfolio managers receive a base salary and bonus. Compensation of a portfolio manager is determined at the discretion of DFA and is based on a portfolio manager’s experience, responsibilities, the perception of the quality of his or her work efforts and other subjective factors. The compensation of portfolio managers is not directly based upon the performance of the mutual funds or other accounts that the portfolio managers manage. DFA reviews the compensation of each portfolio manager annually and may make modifications in compensation as its Compensation Committee deems necessary to reflect changes in the market. Each portfolio manager’s compensation consists of the following: |
■ | 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. |
■ | The long-term pre-tax investment performance of the fund(s) that they manage, |
■ | Diamond Hill’s assessment of the investment contribution they make to strategies they do not manage, |
■ | Diamond Hill’s assessment of each portfolio manager’s overall contribution to the development of the investment team through ongoing discussion, interaction, feedback and collaboration, and |
■ | Diamond Hill’s assessment of each portfolio manager’s contribution to client service, marketing to prospective clients and investment communication activities. Long-term performance is defined as the trailing five years (performance of less than five years is judged on a subjective basis). |
Hotchkis & Wiley: Hotchkis & Wiley’s investment team, including portfolio managers, is compensated in various forms, which may include a base salary, bonus, profit sharing, and equity ownership. Compensation is used to reward, attract , and retain high- quality investment professionals. The Investment team is evaluated and accountable at three levels. The first level is individual contribution to the research and decision-making process, including the quality and quantity of work achieved. The second level is teamwork, generally evaluated through contribution within sector teams. The third level pertains to overall portfolio and firm performance. |
Fixed salaries and discretionary bonuses for investment professionals are determined by the Chief Executive Officer of Hotchkis & Wiley using tools which may include annual evaluations, compensation surveys, feedback from other employees, and advice from members of Hotchkis & Wiley’s Executive and Compensation Committees. The amount of the bonus is determined by the total amount of Hotchkis & Wiley’s bonus pool available for the year, which is generally a function of revenues. No investment professional receives a bonus that is a pre-determined percentage of revenues or net income. Compensation is thus subjective rather than formulaic. The portfolio managers of the Fund own equity in Hotchkis |
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& Wiley. Hotchkis & Wiley believes that the employee ownership structure of the firm will be a significant factor in ensuring a motivated and stable employee base going forward. Hotchkis & Wiley believes that the combination of competitive compensation levels and equity ownership provides Hotchkis & Wiley with a demonstrable advantage in the retention and motivation of employees. Portfolio managers who own equity in Hotchkis & Wiley receive their pro rata share of Hotchkis & Wiley’s profits. Investment professionals may also receive contributions under Hotchkis & Wiley’s profit sharing/401(k) plan. | |
Jacobs Levy: Each portfolio manager receives a fixed salary and a percentage of the profits of Jacobs Levy, which is based upon the portfolio manager’s ownership interest in the firm. Jacobs Levy’s profits are derived from the fees the firm receives from managing client accounts. For most client accounts, the firm receives a fee based upon a percentage of assets under management (the “basic fee”). For some accounts, the firm receives a fee that is adjusted based upon the performance of the account compared to a benchmark. The type of performance adjusted fee, the measurement period for the fee and the benchmark vary by client. In some cases, the basic fee is adjusted based upon the trailing returns (e.g., annualized trailing 12 quarter returns) of the account relative to an annualized benchmark return plus a specified number of basis points. In other cases, the firm receives the basic fee and a percentage of the profits in excess of a benchmark. | |
JPMIM: JPMorgan’s compensation programs are designed to align the behavior of employees with the achievement of its short- and long-term strategic goals, which revolve around client investment objectives. This is accomplished, in part, through a balanced performance assessment process and total compensation program, as well as a clearly defined culture that rigorously and consistently promotes adherence to the highest ethical standards. | |
In determining portfolio manager compensation, JPMorgan uses a balanced discretionary approach to assess performance against four broad categories: (1) business results; (2) risk and control; (3) customers and clients; and (4) people and leadership. | |
These performance categories consider short-, medium- and long-term goals that drive sustained value for clients, while accounting for risk and control objectives. Specifically, portfolio manager performance is evaluated against various factors including the following: (1) blended pre-tax investment performance relative to competitive indices, generally weighted more to the long-term; (2) individual contribution relative to the client’s risk/return objectives; and (3) adherence with JPMorgan’s compliance, risk and regulatory procedures. | |
Feedback from JPMorgan’s risk and control professionals is considered in assessing performance. | |
JPMorgan maintains a balanced total compensation program comprised of a mix of fixed compensation (including a competitive base salary and, for certain employees, a fixed cash allowance), variable compensation in the form of cash incentives, and long-term incentives in the form of equity based and/or fund-tracking incentives that vest over time. Long-term awards comprise of up to 60% of overall incentive compensation, depending on an employee’s pay level. | |
Long-term awards are generally in the form of time-vested JPMC Restricted Stock Units (“RSUs”). However, portfolio managers are subject to a mandatory deferral of long-term incentive compensation under JPMorgan’s Mandatory Investor Plan (“MIP”). The MIP provides for a rate of return equal to that of the Fund(s) that the portfolio managers manage, thereby aligning portfolio managers’ pay with that of their client’s experience/return. 100% of the portfolio managers’ long-term incentive compensation is eligible for MIP with 50% allocated to the specific Fund(s) they manage, as determined by their respective manager. The remaining portion of the overall amount is electable and may be treated as if invested in any of the other Funds available in the plan or can take the form of RSUs. |
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. Although portfolio manager compensation is not directly tied to assets under management, a portfolio manager’s base salary and/or bonus potential may reflect the amount of assets for which the manager is responsible relative to other portfolio managers. The annual bonus is incentive-based and generally represents a significant multiple of base salary. The bonus is based on three factors: investment performance, profit growth of the firm, and personal conduct. Investment performance is the primary component of the annual bonus and generally represents at least 60% of the total for fixed-income managers. The other factors are used to determine the remainder of the annual incentive bonus, subject to the discretion of the Chief Investment Officer (“CIO”) and senior management. The CIO and senior management evaluate these other factors annually. |
The investment performance component of the annual incentive bonus depends primarily on investment performance against benchmark and/or against peers within similar disciplines. The score is based upon the product’s institutional composite performance; however, adjustments may be made if there is significant dispersion among the returns of the composite and accounts not included in the composite. For most products, the product investment score compares the product’s rolling three year performance over the past nine quarters (a five year view) against both a benchmark and a peer group established by the CIO. The scoring rewards both the aggregate excess performance of the product against a benchmark and the product’s relative rank within a peer group. In addition, for fixed income products, the performance |
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score rewards for the consistency of that outperformance and is enhanced if over the past five years it has kept its rolling three-year performance ahead of its benchmark. Managers working on several product teams receive a final score based on the relative revenue weight of each product. |
Portfolio managers may also participate in the three segments of the long-term incentive program. The amount of the awards for each segment are dependent upon role, industry experience, team and firm profitability, and/or investment performance. |
General |
The core elements of the Loomis Sayles compensation plan include a base salary, an annual incentive bonus, and, for senior investor and leadership roles, a long-term incentive bonus. The base salary is a fixed amount based on a combination of factors, including industry experience, firm experience, job performance and market considerations. The annual incentive bonus and long term incentive bonus is driven by a variety of factors depending upon the specific role. Factors include investment performance, individual performance, team and firm profitability, role, and industry experience. Both the annual and long term bonus have a deferral component. Loomis Sayles has developed and implemented three long-term incentive plan segments to attract and retain investment talent. |
For the senior-most investment roles, a Long Term Incentive Plan provides annual grants relative to the role, and includes a post retirement payment feature to incentivize effective succession management. Participation is contingent upon signing an award agreement, which includes a non-compete covenant. The second and third Long Term Incentive Plans are constructed to create mid-term alignment for key positions, including a two year deferral feature. The second plan is role based, and the third is team based which is more specifically dependent upon team profitability and/or investment performance. |
In addition, Loomis Sayles also offers a profit sharing plan for all employees and a defined benefit plan for employees who joined the firm prior to May 3, 2003. The profit sharing contribution to the retirement plan of each employee is based on a percentage of base salary (up to a maximum amount). The defined benefit plan is based on years of service and base compensation (up to a maximum amount). |
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. |
Manulife: Manulife Asset Management has designed its compensation plan to effectively attract, retain and reward top investment talent. The incentive plan is designed to align and reward investment teams that deliver consistent value added performance for the company’s client and partners through world-class investment strategies and solutions. | |
Investment professionals are compensated with a combination of base salary and incentives as detailed below. | |
Base salaries | |
Base salaries are market-based and salary ranges are periodically reviewed. Individual salary adjustments are based on individual performance against mutually-agreed-upon objectives and development of technical skills. | |
Incentives — Short- and Long-Term | |
All investment professionals (including portfolio managers, analysts and traders) are eligible for participation in a short and long term investment incentive plan. These incentives are tied to performance against various objective and subjective measures, including: | |
Investment Performance — Performance of portfolios managed by the investment team. This is the most heavily weighted factor and it is measured relative to an appropriate benchmark or universe over established time periods. | |
Financial Performance — Performance of Manulife Asset Management and its parent corporation. | |
Non-Investment Performance — Derived from the contributions an investment professional brings to Manulife Asset Management. | |
Awards under this plan include: | |
Annual Cash Awards |
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Deferred Incentives — One hundred percent of this portion of the award is invested in strategies managed by the team/individual as well as other Manulife Asset Management strategies. | |
Manulife equity awards — Investment professionals that are considered officers of Manulife receive a portion of their award in Manulife Restricted Share Units (RSUs) or stock options. This plan is based on the value of the underlying common shares of Manulife. |
PGIM: The base salary of an investment professional in the PGIM Fixed Income unit of PGIM is primarily based on market data relative to similar positions as well as the past performance, years of experience and scope of responsibility of the individual. PGIM Fixed Income is allocated an overall incentive pool based on the investment and financial performance of the business. Incentive compensation for investment professionals, including the annual cash bonus, the long-term equity grant and grants under PGIM Fixed Income’s long-term incentive plans, is primarily based on such person’s contribution to PGIM Fixed Income’s goal of providing investment performance to clients consistent with portfolio objectives, guidelines, risk parameters, and its compliance risk management and other policies, as well as market-based data such as compensation trends and levels of overall compensation for similar positions in the asset management industry. In addition, an investment professional’s qualitative contributions to the organization and its commercial success are considered in determining incentive compensation. Incentive compensation is not solely based on the performance of, or value of assets in, any single account or group of client accounts. |
The PGIM Fixed Income unit within PGIM Limited (PGIM Fixed Income (U.K.)) has adopted a remuneration policy in relation to activities conducted through the entities authorized and regulated by the FCA in the United Kingdom. The remuneration policy is intended to be compliant with the United Kingdom’s Investment Firms Prudential Regime (IFPR) and governs the remuneration of PGIM Fixed Income (U.K.) staff and “material risk takers” of PGIM Fixed Income (U.K.) including those that are based outside the United Kingdom. | |
An investment professional’s annual cash bonus is paid from an annual incentive pool. The pool is developed as a percentage of PGIM Fixed Income’s operating income and the percentage used to calculate the pool may be refined by factors such as: | |
- business initiatives; | |
- the number of investment professionals receiving a bonus and related peer group compensation; | |
- financial metrics of the business relative to those of appropriate peer groups; and | |
- investment performance of portfolios: (i) relative to appropriate peer groups and/or (ii) as measured against relevant investment indices. | |
Long-term compensation consists of Prudential Financial, Inc. restricted stock and grants under the long-term incentive plan and targeted long-term incentive plan. The long-term incentive plan is intended to align compensation with investment performance. The targeted long-term incentive plan is intended to align the interests of certain of PGIM Fixed Income’s investment professionals with the performance of the particular alternative investment strategies or commingled investment vehicles they manage. Grants under the long-term incentive plan and targeted long-term incentive plan are participation interests in notional accounts with a beginning value of a specified dollar amount. For the long-term incentive plan, the value attributed to these notional accounts increases or decreases over a defined period of time based on the performance of investment composites representing a number of PGIM Fixed Income’s investment strategies. With respect to targeted long-term incentive awards, the value attributed to the notional accounts increases or decreases over a defined period of time based (as applicable) on the performance of either (i) a composite of particular alternative investment strategies or (ii) a commingled investment vehicle. An investment composite is an aggregation of accounts with similar investment strategies. The head of PGIM Fixed Income also receives performance shares which represent the right to receive shares of Prudential Financial, Inc. common stock conditioned upon, and subject to, the achievement of specified financial performance goals by Prudential Financial, Inc. Each of the restricted stock, grants under the long-term incentive plans, and performance shares is subject to vesting requirements. | |
PGIM Quantitative Solutions: PGIM Quantitative Solutions’ investment professionals are compensated through a combination of base salary, a performance-based annual cash incentive bonus and an annual long-term incentive grant. PGIM Quantitative Solutions regularly utilizes third party surveys to compare its compensation program against leading asset management firms to monitor competitiveness. An investment professional’s incentive compensation, including both the annual cash bonus and long-term incentive grant, is largely driven by a person’s contribution to PGIM Quantitative Solutions’ goal of providing investment performance to clients consistent with portfolio objectives, guidelines and risk parameters, as well as such person’s qualitative contributions to the organization. An investment professional’s long-term incentive grant is currently divided into two components: (i) 80% of the value of the grant is subject to increase or decrease based on the performance of certain PGIM Quantitative Solutions strategies, and (ii) 20% of the value of the grant consists of restricted stock of Prudential Financial, Inc. (PGIM Quantitative Solutions’ ultimate parent company). The long-term |
Statement of Additional Information – April 27, 2023 | 175 |
incentive grants are subject to vesting requirements. The incentive compensation of each investment professional is not based solely or directly on the performance of the Fund (or any other individual account managed by PGIM Quantitative Solutions) or the value of the assets of the Fund (or any other individual account managed by PGIM Quantitative Solutions). | |
The annual cash bonus pool is determined quantitatively based on two primary factors: 1) investment performance of composites representing PGIM Quantitative Solutions’ various investment strategies on a 1-year and 3-year basis relative to appropriate market peer groups and the indices against which PGIM Quantitative Solutions’ strategies are managed, and 2) business results as measured by PGIM Quantitative Solutions’ pretax income. | |
TCW: The overall objective of TCW’s compensation program for portfolio managers is to attract experienced and expert investment professionals and to retain them over the long-term. Compensation is comprised of several components which, in the aggregate, are designed to achieve these objectives and to reward the portfolio managers for their contributions to the successful performance of the accounts they manage. Portfolio managers are compensated through a combination of base salary, fee sharing based compensation (“fee sharing”), bonus and equity incentive participation in TCW’s parent company (“equity incentives”). Fee sharing and equity incentives generally represent most of the portfolio managers’ compensation. In some cases, portfolio managers are eligible for discretionary bonuses. | |
Salary. Salary is agreed to with portfolio managers at the time of employment and is reviewed from time to time. It does not change significantly and often does not constitute a significant part of a portfolio manager’s compensation. | |
Fee Sharing. Fee sharing for investment professionals is based on revenues generated by accounts in the investment strategy area for which the investment professionals are responsible. In most cases, revenues are allocated to a pool and fee sharing compensation is allocated among members of the investment team after the deduction of certain expenses (including compensation over a threshold level) related to the strategy group. The allocations are based on the investment professionals’ contribution to TCW and its clients, including qualitative and quantitative contributions. | |
In general, the same fee sharing percentage is used to compensate a portfolio manager for investment services related to a Fund as that used to compensate portfolio managers for other client accounts in the same strategy managed by TCW or an affiliate of TCW (collectively, “the TCW Group”). In some cases, the fee sharing pool includes revenues related to more than one product, in which case each participant in the pool is entitled to fee sharing derived from his or her contributions to all the included products. | |
Investment professionals are not directly compensated for generating performance fees. In some cases, the overall fee sharing pool is subject to fluctuation based on the relative pre-tax performance of the investment strategy composite returns, net of fees and expenses, to that of the benchmark. The measurement of performance relative to the benchmark can be based on single year or multiple year metrics, or a combination thereof. The benchmark used is the one associated with the Fund managed by the portfolio manager as disclosed in the prospectus. Benchmarks vary from strategy to strategy but, within a given strategy, the same benchmark applies to all accounts, including the Funds. | |
Discretionary Bonus/Guaranteed Minimums. Discretionary bonuses may be paid out of an investment team’s fee sharing pool, as determined by the supervisor(s) in the department. In other cases where portfolio managers do not receive fee sharing or where it is determined that the combination of salary and fee sharing does not adequately compensate the portfolio manager, discretionary bonuses may be paid by the applicable TCW entity. Also, pursuant to contractual arrangements, some portfolio managers received minimum bonuses. | |
Equity Incentives. Management believes that equity ownership aligns the interests of portfolio managers with the interests of the firm and its clients. Accordingly, TCW Group’s key investment professionals participate in equity incentives through ownership or participation in restricted unit plans that vest over time or unit appreciation plans of TCW’s parent company. The plans include the Fixed Income Retention Plan, Restricted Unit Plan and 2013 Equity Unit Incentive Plan. | |
Under the Fixed Income Retention Plan, certain portfolio managers in the fixed income area were awarded cash and/or partnership units in TCW’s parent company, either on a contractually-determined basis or on a discretionary basis. Awards under this plan were made in 2010 that vest over time. | |
Under the Restricted Unit Plan, certain portfolio managers in the fixed income and equity areas may be awarded partnership units in TCW’s parent company. Awards under this plan have vested over time, subject to satisfaction of performance criteria. | |
Under the 2013 Equity Unit Incentive Plan, certain portfolio managers in the fixed income and equity areas may be awarded options to acquire partnership units in TCW’s parent company with a strike price equal to the fair market value of the option at the date of grant. The options granted under this plan are subject to vesting and other conditions. | |
Other Plans and Compensation Vehicles. Portfolio managers may also elect to participate in the applicable TCW Group’s 401(k) plan, to which they may contribute a portion of their pre- and post-tax compensation to the plan for investment on a tax-deferred basis. |
Statement of Additional Information – April 27, 2023 | 176 |
Threadneedle: Direct compensation is typically comprised of a base salary, a fixed role-based allowance paid monthly alongside 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 fund-linked deferred compensation compliant with European regulatory requirements in its structure and delivery vehicles. Equity incentive awards are made in the form of Ameriprise Financial restricted stock, or for senior employees outside our fund management teams 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, compliant with local regulation in particular the UCITS V requirements |
■ | Team cooperation and values |
Statement of Additional Information – April 27, 2023 | 177 |
Water Island: Investment professionals are compensated with salary and a bonus based on individual performance, both relative and absolute fund performance, and profitability of Water Island. Profit sharing in Water Island may also be included as potential compensation. In addition, Water Island believes employee ownership and the opportunity for all employees to hold ownership interests in Water Island fosters teamwork and encourages longevity in tenure. Ownership shares may be issued to employees based on tenure, position, and contribution to Water Island. Water Island’s policies help ensure that the financial interests of its key investment personnel are aligned with its clients’ financial interests. Water Island also expends efforts to help ensure it attracts and retains key investment talent. Its goal is to focus its employees on long-term rather than short-term performance and to encourage employee retention. |
Statement of Additional Information – April 27, 2023 | 178 |
Statement of Additional Information – April 27, 2023 | 179 |
Sales Charges Paid to Distributor | Amount Retained by Distributor After Paying Commissions | |||||
Fund | 2022 | 2021 | 2020 | 2022 | 2021 | 2020 |
For Funds with fiscal period ending May 31 | ||||||
Adaptive Risk Allocation Fund | $328,356 | $468,295 | $540,863 | $54,990 | $70,960 | $85,809 |
Commodity Strategy Fund | 137,250 | 21,154 | 4,897 | 19,975 | 2,894 | 646 |
Dividend Income Fund | 4,680,369 | 5,272,863 | 6,748,595 | 797,392 | 809,764 | 1,178,972 |
Dividend Opportunity Fund | 617,734 | 484,557 | 659,661 | 92,768 | 78,161 | 102,667 |
Flexible Capital Income Fund | 1,107,048 | 733,893 | 1,120,990 | 171,267 | 111,732 | 191,177 |
High Yield Bond Fund | 183,368 | 257,470 | 321,145 | 36,594 | 40,845 | 53,296 |
High Yield Municipal Fund | 152,005 | 109,765 | 224,428 | 34,061 | 25,380 | 60,236 |
Large Cap Value Fund | 414,458 | 322,449 | 384,175 | 59,293 | 46,249 | 56,695 |
Mortgage Opportunities Fund | 370,654 | 272,086 | 311,274 | 88,887 | 43,202 | 64,304 |
Multi Strategy Alternatives Fund | 2,303 | 1,445 | 3,128 | 321 | 199 | 477 |
Quality Income Fund | 89,126 | 174,283 | 111,905 | 22,191 | 28,462 | 17,852 |
Select Large Cap Value Fund | 433,000 | 206,095 | 87,633 | 68,515 | 30,043 | 18,978 |
Select Small Cap Value Fund | 95,175 | 69,551 | 71,257 | 15,115 | 10,129 | 11,146 |
Seligman Technology and Information Fund | 2,552,324 | 2,291,960 | 2,321,259 | 377,188 | 333,969 | 356,451 |
For Funds with fiscal period ending July 31 | ||||||
Disciplined Core Fund | 633,612 | 638,753 | 787,456 | 93,016 | 92,340 | 116,819 |
Disciplined Growth Fund | 116,270 | 103,678 | 127,227 | 16,817 | 15,443 | 19,786 |
Disciplined Value Fund | 58,131 | 41,448 | 26,341 | 10,702 | 5,976 | 10,425 |
Floating Rate Fund | 289,730 | 113,614 | 127,784 | 49,448 | 18,166 | 32,582 |
Global Opportunities Fund | 90,687 | 109,856 | 120,987 | 14,128 | 14,771 | 18,338 |
Government Money Market Fund | 4,087 | 1,435 | 6,298 | 4,087 | 1,435 | 6,298 |
Income Opportunities Fund | 48,900 | 82,228 | 132,413 | 10,507 | 13,573 | 22,398 |
Large Cap Growth Fund | 868,387 | 722,035 | 715,316 | 133,398 | 105,545 | 108,868 |
Limited Duration Credit Fund | 130,458 | 286,266 | 185,335 | 35,567 | 52,298 | 37,444 |
MN Tax-Exempt Fund | 225,052 | 347,475 | 386,251 | 44,882 | 55,598 | 78,188 |
OR Intermediate Municipal Bond Fund | 47,807 | 46,020 | 38,196 | 13,929 | 3,956 | 6,335 |
Strategic Municipal Income Fund | 399,574 | 612,436 | 610,829 | 92,342 | 115,996 | 149,549 |
Tax-Exempt Fund | 464,113 | 521,730 | 898,384 | 92,300 | 87,993 | 159,243 |
U.S. Social Bond Fund | 4,336 | 15,291 | 19,097 | 751 | 3,565 | 3,140 |
Ultra Short Term Bond Fund | 0 | 2,080 | 0 | 0 | 2,080 | 0 |
For Funds with fiscal period ending August 31 | ||||||
Balanced Fund | 4,324,897 | 5,372,688 | 4,260,418 | 724,607 | 815,927 | 671,363 |
Contrarian Core Fund | 1,463,636 | 1,520,330 | 1,179,153 | 224,384 | 224,239 | 187,929 |
Emerging Markets Bond Fund | 2,547 | 20,722 | 19,558 | 447 | 3,172 | 3,566 |
Emerging Markets Fund | 150,791 | 367,712 | 125,742 | 25,201 | 52,987 | 20,089 |
Global Technology Growth Fund | 899,544 | 1,427,993 | 1,850,556 | 138,558 | 211,735 | 285,413 |
Greater China Fund | 66,900 | 125,921 | 44,178 | 12,102 | 18,338 | 6,497 |
International Dividend Income Fund | 88,971 | 26,960 | 21,348 | 13,824 | 3,818 | 3,200 |
Select Mid Cap Growth Fund | 193,524 | 224,109 | 223,782 | 27,621 | 31,690 | 46,623 |
Small Cap Growth Fund | 372,618 | 1,204,813 | 572,766 | 74,826 | 174,457 | 84,165 |
Strategic Income Fund | 824,172 | 1,166,660 | 1,224,978 | 179,755 | 193,452 | 216,783 |
Statement of Additional Information – April 27, 2023 | 180 |
Distribution Fee* | Service Fee* | Combined Total* | |
Class A | up to 0.25% | 0.25%(c) | Up to 0.35%(a)(c)(d) |
Class Adv | None | None | None |
Class C | 0.75%(b)(d) | 0.25%(c) | 1.00%(c)(d) |
Class Inst | None | None | None |
Class Inst2 | None | None | None |
Class Inst3 | None | None | None |
Class E | 0.10% | 0.25% | 0.35% |
Class R (series of CFST and CFST I) | 0.50% | —(e) | 0.50% |
Class R (series of CFST II) | up to 0.50% | up to 0.25% | 0.50%(d)(e) |
Class V | None | 0.50%(f) | Up to 0.50%(f) |
(a) | The maximum distribution and service fees for Class A shares varies among the Funds, as shown in the table below: |
Funds | Maximum Class A Distribution Fee |
Maximum Class A Service Fee |
Maximum Class A Combined Total |
Series of CFST and CFST II (other than Government Money Market Fund) |
— | — | 0.25%; these Funds pay a combined distribution and service fee |
Government Money Market Fund | — | — | 0.10% |
Ultra Short Term Bond Fund | up to 0.15% | up to 0.15% | 0.15% |
Statement of Additional Information – April 27, 2023 | 181 |
Funds | Maximum Class A Distribution Fee |
Maximum Class A Service Fee |
Maximum Class A Combined Total |
Balanced Fund, Contrarian Core Fund, Dividend Income Fund, Global Technology Growth Fund, Large Cap Growth Fund, OR Intermediate Municipal Bond Fund, Real Estate Equity Fund, Select Mid Cap Growth Fund, Small Cap Growth Fund, Total Return Bond Fund |
up to 0.10% | up to 0.25% | up to 0.35%; these Funds may pay distribution and service fees up to a maximum of 0.35% of their average daily net assets attributable to Class A shares (comprised of up to 0.10% for distribution services and up to 0.25% for shareholder liaison services) but currently limit such fees to an aggregate fee of not more than 0.25% for Class A shares |
Adaptive Risk Allocation Fund, Bond Fund, CT Intermediate Municipal Bond Fund, Corporate Income Fund, Emerging Markets Fund, Greater China Fund, International Dividend Income Fund, MA Intermediate Municipal Bond Fund, Multi Strategy Alternatives Fund, NY Intermediate Municipal Bond Fund, Select Large Cap Growth Fund, Small Cap Value Fund I, Strategic Income Fund, Strategic NY Municipal Income Fund, U.S. Social Bond Fund |
— | 0.25% | 0.25% |
High Yield Municipal Fund, Intermediate Duration Municipal Bond Fund, Tax- Exempt Fund, Strategic CA Municipal Income Fund |
— | 0.20% | 0.20% |
U.S. Treasury Index Fund | — | 0.15% | 0.15% |
(b) | The distribution fee for Class C shares of certain Funds varies. The annual distribution fee for Class C shares shall be 0.45% for CT Intermediate Municipal Bond Fund, MA Intermediate Municipal Bond Fund, NY Intermediate Municipal Bond Fund, OR Intermediate Municipal Bond Fund, Strategic CA Municipal Income Fund, and Strategic NY Municipal Income Fund, 0.55% for Short Term Bond Fund and Corporate Income Fund, 0.60% for High Yield Municipal Fund, Intermediate Duration Municipal Bond Fund and Tax-Exempt Fund, and 0.65% for U.S. Treasury Index Fund, of the average daily net assets of the Fund’s Class C shares. |
(c) | The service fees for Class A and Class C shares of certain Funds vary. The annual service fee for Class A and Class C shares of High Yield Municipal Fund, Intermediate Duration Municipal Bond Fund, Tax-Exempt Fund and Class A shares of Strategic CA Municipal Income Fund may equal up to 0.20% of the average daily NAV of all shares of such Fund class. The service fee for Class A and Class C shares of U.S. Treasury Index Fund shall equal up to 0.15% annually of the average daily NAV of all shares of such Fund class. |
(d) | Fee amounts noted apply to all Funds other than Government Money Market Fund, which, for Class A shares, pays distribution and service fees of 0.10%, and for Class C shares pays distribution fees of 0.75%. The payment of the distribution and/or service fees payable by Government Money Market Fund under its Plan of Distribution has been suspended through November 30, 2023, or such earlier date as may be determined at the sole discretion of Government Money Market Fund’s Board. Compensation paid to financial intermediaries is suspended for the duration of the suspension of payments under Government Money Market Fund’s Plan of Distribution. |
(e) | Class R shares of series of CFST and CFST I pay a distribution fee pursuant to a Rule 12b-1 plan. The Funds do not have a shareholder service plan for Class R shares. Series of CFST II have a distribution and shareholder service plan for Class R shares. For Class R shares of series of CFST II, the maximum fee under the plan reimbursed for distribution expenses is equal on an annual basis to 0.50% of the average daily net assets of the Fund attributable to Class R shares. Of that amount, up to 0.25% may be reimbursed for shareholder service expenses. |
(f) | The shareholder servicing fees for Class V shares are up to 0.50% of average daily net assets attributable to Class V shares for equity Funds and 0.40% for fixed income Funds. In general, the Funds currently limit such fees to a maximum of 0.25% for equity Funds and 0.15% for fixed-income Funds. These fees for Class V shares are not paid pursuant to a Rule 12b-1 plan. See Class V Shareholder Service Fees below for more information. |
* | For Multisector Bond SMA Completion Portfolio and Overseas SMA Completion Portfolio, the Funds may pay at an annual rate a distribution fee of up to 0.25% and a shareholder servicing fee of up to 0.25%, provided that the combined distribution and servicing fee does not exceed a combined total of 0.25% of average daily net assets, pursuant to Rule 12b-1 under the 1940 Act. No distribution or service fees are |
Statement of Additional Information – April 27, 2023 | 182 |
currently paid by the Funds under the distribution and/or shareholder servicing plans, however, and there are no current plans to impose these fees. Future payments may be made under the distribution and/or shareholder servicing plans without any further shareholder approval. In the event Rule 12b-fees are charged, over time they would increase the cost of an investment in the Funds. |
Statement of Additional Information – April 27, 2023 | 183 |
Fund | Class A | Class C | Class R | Class V |
For Funds with fiscal period ending January 31 | ||||
Capital Allocation Aggressive Portfolio | $3,271,406 | $897,418 | $18,130 | N/A |
Capital Allocation Conservative Portfolio | 511,252 | 191,207 | 1,670 | N/A |
Capital Allocation Moderate Aggressive Portfolio | 4,445,278 | 1,135,556 | 29,552 | $220,882 |
Capital Allocation Moderate Conservative Portfolio | 1,129,322 | 425,687 | 8,566 | N/A |
Capital Allocation Moderate Portfolio | 3,417,501 | 1,083,928 | 15,432 | N/A |
Income Builder Fund | 2,385,806 | 1,931,741 | 54,114 | N/A |
For Funds with fiscal period ending February 28/29 | ||||
Convertible Securities Fund | 1,307,706 | 936,648 | 8,620 | N/A |
Global Value Fund | 1,877,322 | 136,108 | 41,724 | N/A |
Large Cap Enhanced Core Fund | 160,911 | N/A | 292,241 | N/A |
Large Cap Growth Opportunity Fund | 3,136,823 | 213,843 | 124,945 | N/A |
Large Cap Index Fund | 1,500,439 | N/A | N/A | N/A |
Mid Cap Index Fund | 2,147,729 | N/A | N/A | N/A |
Overseas Core Fund | 151,568 | 34,771 | 18 | N/A |
Overseas Value Fund | 857,120 | 209,200 | 70,322 | N/A |
Select Large Cap Equity Fund | 607,933 | 85,054 | N/A | N/A |
Select Mid Cap Value Fund | 2,753,034 | 127,939 | 150,660 | N/A |
Small Cap Index Fund | 2,943,484 | N/A | N/A | N/A |
Small Cap Value Fund II | 208,858 | 10,166 | 19,183 | N/A |
For Funds with fiscal period ending March 31 | ||||
Select Large Cap Growth Fund | 622,181 | 503,278 | 57,618 | N/A |
Short Term Bond Fund | 602,100 | 115,168 | 5,822 | N/A |
For Funds with fiscal period ending April 30 | ||||
Bond Fund | 240,062 | 66,494 | 4,188 | 10,713 |
CA Intermediate Municipal Bond Fund | 113,583 | 57,964 | N/A | N/A |
Corporate Income Fund | 246,785 | 32,379 | N/A | N/A |
NC Intermediate Municipal Bond Fund | 42,805 | 23,769 | N/A | N/A |
SC Intermediate Municipal Bond Fund | 75,591 | 27,480 | N/A | N/A |
Short Duration Municipal Bond Fund | 189,619 | 15,999 | N/A | N/A |
Small Cap Value Fund I | 698,947 | 87,269 | 12,488 | N/A |
Statement of Additional Information – April 27, 2023 | 184 |
Fund | Class A | Class C | Class R | Class V |
Total Return Bond Fund | $1,989,544 | $199,653 | $31,492 | N/A |
U.S. Treasury Index Fund | 61,638 | 35,758 | N/A | N/A |
VA Intermediate Municipal Bond Fund | 73,094 | 17,200 | N/A | N/A |
For Funds with fiscal period ending May 31 | ||||
Adaptive Risk Allocation Fund | 470,177 | 1,122,719 | 4,031 | N/A |
Commodity Strategy Fund | 26,861 | 22,111 | 5,967 | N/A |
Dividend Income Fund | 11,159,672 | 13,656,007 | 1,169,371 | $238,284 |
Dividend Opportunity Fund | 3,459,186 | 979,182 | 198,848 | N/A |
Flexible Capital Income Fund | 904,902 | 2,543,989 | 5,940 | N/A |
High Yield Bond Fund | 1,505,383 | 169,395 | 78,595 | N/A |
High Yield Municipal Fund | 372,147 | 296,402 | N/A | N/A |
Large Cap Value Fund | 4,498,993 | 126,622 | 15,626 | N/A |
Mortgage Opportunities Fund | 841,869 | 827,057 | N/A | N/A |
Multi Strategy Alternatives Fund | 4,430 | 12,604 | 36 | N/A |
Quality Income Fund | 977,869 | 170,835 | 23,290 | N/A |
Select Large Cap Value Fund | 793,966 | 471,083 | 147,641 | N/A |
Select Small Cap Value Fund | 998,021 | 46,441 | 11,081 | N/A |
Seligman Technology and Information Fund | 18,283,697 | 4,227,166 | 452,866 | N/A |
For Funds with fiscal period ending July 31 | ||||
Disciplined Core Fund | 10,470,506 | 362,309 | 13,838 | N/A |
Disciplined Growth Fund | 380,939 | 138,829 | 2,912 | N/A |
Disciplined Value Fund | 140,238 | 84,063 | 6,621 | 202,722 |
Floating Rate Fund | 573,129 | 307,356 | 6,578 | N/A |
Global Opportunities Fund | 1,136,232 | 61,623 | 7,544 | N/A |
Government Money Market Fund | 0 | 0 | 0 | N/A |
Income Opportunities Fund | 660,760 | 103,849 | 1,987 | N/A |
Large Cap Growth Fund(a) | 6,534,287 | 658,348 | 46,578 | 700,906 |
Limited Duration Credit Fund | 549,390 | 184,978 | N/A | N/A |
MN Tax-Exempt Fund | 1,054,296 | 455,757 | N/A | N/A |
OR Intermediate Municipal Bond Fund | 104,321 | 28,692 | N/A | N/A |
Strategic Municipal Income Fund | 2,128,617 | 815,541 | N/A | N/A |
Tax-Exempt Fund | 4,601,635 | 308,040 | N/A | N/A |
U.S. Social Bond Fund | 35,650 | 13,041 | N/A | N/A |
Ultra Short Term Bond Fund | 1,287,607 | N/A | N/A | N/A |
For Funds with fiscal period ending August 31 | ||||
Balanced Fund | 8,391,921 | 14,448,053 | 654,613 | N/A |
Contrarian Core Fund | 4,746,205 | 4,700,353 | 652,043 | 484,102 |
Emerging Markets Bond Fund | 92,731 | 29,862 | 93,224 | N/A |
Emerging Markets Fund | 685,862 | 157,106 | 28,748 | N/A |
Global Technology Growth Fund | 1,602,302 | 2,009,686 | N/A | N/A |
Greater China Fund | 153,223 | 24,005 | N/A | N/A |
International Dividend Income Fund | 199,738 | 13,737 | 543 | N/A |
Select Mid Cap Growth Fund | 2,255,430 | 78,273 | 37,168 | 63,949 |
Small Cap Growth Fund | 1,180,752 | 376,933 | 48,978 | N/A |
Statement of Additional Information – April 27, 2023 | 185 |
(a) | The Fund paid distribution and/or service fees of $63,370 for Class E shares for the fiscal year ended 2022. |
Fund | Class C | Percentage of Class C net assets |
Capital Allocation Aggressive Portfolio | $1,937,000 | 3.05% |
Capital Allocation Conservative Portfolio | 307,000 | 2.15% |
Capital Allocation Moderate Portfolio | 1,471,000 | 1.93% |
Commodity Strategy Fund | 61,000 | 1.02% |
Disciplined Core Fund | 1,064,000 | 3.69% |
Disciplined Growth Fund | 29,000 | 0.30% |
Disciplined Value Fund | 52,000 | 0.61% |
Dividend Opportunity Fund | 857,000 | 0.97% |
Emerging Markets Bond Fund | 311,000 | 15.75% |
Flexible Capital Income Fund | 1,147,000 | 0.52% |
Floating Rate Fund | 946,000 | 3.04% |
Global Opportunities Fund | 368,000 | 8.42% |
Global Value Fund | 811,000 | 8.58% |
Government Money Market Fund | 433,000 | 2.54% |
High Yield Bond Fund | 6,107,000 | 47.72% |
Income Builder Fund | 1,586,000 | 1.01% |
Income Opportunities Fund | 884,000 | 10.90% |
Large Cap Value Fund | 596,000 | 5.54% |
Limited Duration Credit Fund | 495,000 | 4.42% |
MN Tax-Exempt Fund | 457,000 | 1.16% |
Mortgage Opportunities Fund | 293,000 | 0.41% |
Overseas Core Fund | 195,000 | 9.80% |
Quality Income Fund | 413,000 | 3.44% |
Statement of Additional Information – April 27, 2023 | 186 |
Fund | Class C | Percentage of Class C net assets |
Select Global Equity Fund | $1,196,000 | 8.46% |
Select Large Cap Value Fund | 2,682,000 | 5.33% |
Select Small Cap Value Fund | 2,119,000 | 60.70% |
Seligman Global Technology Fund | 3,699,000 | 5.73% |
Seligman Technology and Information Fund | 14,067,000 | 4.57% |
Strategic Municipal Income Fund | 348,000 | 0.51% |
Statement of Additional Information – April 27, 2023 | 187 |
Amounts Reimbursed | |||
2022 | 2021 | 2020 | |
For Funds with fiscal period ending January 31 | |||
Capital Allocation Aggressive Portfolio | $0 | $0 | $0 |
Capital Allocation Conservative Portfolio | 0 | 0 | 0 |
Capital Allocation Moderate Aggressive Portfolio | 0 | 0 | 0 |
Capital Allocation Moderate Conservative Portfolio | 0 | 0 | 0 |
Capital Allocation Moderate Portfolio | 0 | 0 | 0 |
Income Builder Fund | 0 | 0 | 0 |
For Funds with fiscal period ending February 28/29 | |||
Convertible Securities Fund | 0 | 8,924 | 660,488 |
Global Value Fund | 0 | 0 | 0 |
Large Cap Enhanced Core Fund | 1,834,770 | 1,711,083 | 1,665,918 |
Large Cap Growth Opportunity Fund | 745,606 | 1,049,983 | 1,155,543 |
Large Cap Index Fund | 100,580 | 81,075 | 116,212 |
Mid Cap Index Fund | 3,771,140 | 3,633,370 | 4,723,607 |
Overseas Core Fund | 469,589 | 535,040 | 329,617 |
Overseas Value Fund | 1,611,875 | 1,492,415 | 464,931 |
Select Large Cap Equity Fund | 4,584,489 | 3,242,272 | 2,717,031 |
Select Mid Cap Value Fund | 192,449 | 614,756 | 696,721 |
Small Cap Index Fund | 107,374 | 78,023 | 132,424 |
Small Cap Value Fund II | 588,235 | 567,977 | 690,475 |
For Funds with fiscal period ending March 31 | |||
Adaptive Retirement 2020 Fund | 95,350 | 84,206 | 85,954 |
Adaptive Retirement 2025 Fund | 94,865 | 84,105 | 86,669 |
Adaptive Retirement 2030 Fund | 96,033 | 83,255 | 83,692 |
Adaptive Retirement 2035 Fund | 95,441 | 83,751 | 83,969 |
Adaptive Retirement 2040 Fund | 95,499 | 83,457 | 85,306 |
Adaptive Retirement 2045 Fund | 95,437 | 83,615 | 83,706 |
Statement of Additional Information – April 27, 2023 | 188 |
Amounts Reimbursed | |||
2022 | 2021 | 2020 | |
Adaptive Retirement 2050 Fund | $95,551 | $83,198 | $83,043 |
Adaptive Retirement 2055 Fund | 95,546 | 83,415 | 83,657 |
Adaptive Retirement 2060 Fund | 95,679 | 83,130 | 83,131 |
MM Growth Strategies Fund | 759,933 | 3,026,878 | 2,238,091 |
Select Large Cap Growth Fund | 803,047 | 671,919 | 0 |
Short Term Bond Fund | 1,101,028 | 879,384 | 787,097 |
Solutions Aggressive Portfolio | 103,713 | 92,178 | 92,597 |
Solutions Conservative Portfolio | 103,885 | 92,128 | 91,936 |
For Funds with fiscal period ending April 30 | |||
Bond Fund | 1,452,619 | 1,175,985 | 691,739 |
CA Intermediate Municipal Bond Fund | 490,887 | 555,285 | 507,174 |
Corporate Income Fund | 710,495 | 657,957 | 420,876 |
MM Directional Alternative Strategies Fund | 478,398 | 467,358 | 285,869 |
NC Intermediate Municipal Bond Fund | 110,976 | 143,028 | 76,868 |
SC Intermediate Municipal Bond Fund | 135,568 | 169,890 | 108,181 |
Short Duration Municipal Bond Fund | 1,159,421 | 1,092,263 | 1,121,225 |
Small Cap Value Fund I | 0 | 140,670 | 230,084 |
Total Return Bond Fund | 4,125,761 | 3,190,003 | 3,170,757 |
U.S. Treasury Index Fund | 3,466,656 | 2,758,251 | 2,144,375 |
VA Intermediate Municipal Bond Fund | 110,884 | 150,545 | 90,867 |
For Funds with fiscal period ending May 31 | |||
Adaptive Risk Allocation Fund | 0 | 0 | 0 |
Commodity Strategy Fund | 0 | 0 | 0 |
Dividend Income Fund | 0 | 0 | 0 |
Dividend Opportunity Fund | 0 | 0 | 0 |
Flexible Capital Income Fund | 0 | 0 | 0 |
High Yield Bond Fund | 419,330 | 433,824 | 71,162 |
High Yield Municipal Fund | 130,076 | 138,447 | 103,476 |
Large Cap Value Fund | 0 | 0 | 0 |
MM Value Strategies Fund | 0 | 0 | 464,184 |
Mortgage Opportunities Fund | 0 | 266,697 | 465,515 |
Multi Strategy Alternatives Fund | 982,907 | 977,377 | 594,465 |
Quality Income Fund | 0 | 97,217 | 306,918 |
Select Large Cap Value Fund | 5,782,175 | 3,910,918 | 3,511,498 |
Select Small Cap Value Fund | 89,354 | 192,873 | 0 |
Seligman Technology and Information Fund | 0 | 0 | 0 |
For Funds with fiscal period ending July 31 | |||
Disciplined Core Fund | 0 | 0 | 0 |
Disciplined Growth Fund | 260,001 | 214,530 | 57,123 |
Disciplined Value Fund | 405,628 | 660,054 | 731,414 |
Floating Rate Fund | 192,057 | 278,195 | 229,446 |
Global Opportunities Fund | 0 | 0 | 0 |
Government Money Market Fund | 1,077,766 | 1,032,646 | 916,555 |
Statement of Additional Information – April 27, 2023 | 189 |
(a) | For the period from October 29, 2019 (commencement of operations) to August 31, 2020. |
(b) | For the period from September 12, 2019 (commencement of operations) to August 31, 2020. |
Statement of Additional Information – April 27, 2023 | 190 |
Fees Waived | |||
2022 | 2021 | 2020 | |
For Funds with fiscal period ending February 28/29 | |||
Convertible Securities Fund | $45,650 | $29,641 | $4,781 |
Large Cap Enhanced Core Fund | 9,423 | 0 | 0 |
Overseas Core Fund | 32 | 0 | 0 |
Overseas Value Fund | 0 | 24,866 | 89,926 |
Select Mid Cap Value Fund | 42,303 | 26,468 | 3,088 |
Small Cap Value Fund II | 17,959 | 47,405 | 35,556 |
For Funds with fiscal period ending March 31 | |||
MM Growth Strategies Fund | 1 | 0 | 0 |
Select Large Cap Growth Fund | 26,233 | 27,079 | 87,164 |
Short Term Bond Fund | 24,056 | 34,951 | 34,429 |
For Funds with fiscal period ending April 30 | |||
Bond Fund | 32,638 | 9,329 | 13,763 |
Corporate Income Fund | 37,596 | 11,053 | 8,444 |
Short Duration Municipal Bond Fund | 25,202 | 38,433 | 31,310 |
Total Return Bond Fund | 38,702 | 22,799 | 0 |
U.S. Treasury Index Fund | 18,846 | 72,090 | 43,712 |
For Funds with fiscal period ending May 31 | |||
Dividend Opportunity Fund | 29,590 | 25,319 | 21,671 |
Flexible Capital Income Fund | 0 | 0 | 1,146 |
High Yield Bond Fund | 27,101 | 0 | 0 |
High Yield Municipal Fund | 19,939 | 56,598 | 49,761 |
Multi Strategy Alternatives Fund | 0 | 0 | 423,777 |
Quality Income Fund | 1,777 | 2,454 | 2,175 |
Select Large Cap Value Fund | 8,408 | 0 | 0 |
For Funds with fiscal period ending July 31 | |||
Disciplined Growth Fund | 0 | 0 | 245 |
Disciplined Value Fund | 607 | 0 | 0 |
Floating Rate Fund | 9,567 | 0 | 0 |
Government Money Market Fund | 1,185,640 | 1,965,110 | 405,644 |
Income Opportunities Fund | 12,529 | 0 | 0 |
OR Intermediate Municipal Bond Fund | 4,698 | 17,051 | 22,642 |
Strategic Municipal Income Fund | 29,198 | 58,684 | 39,986 |
Tax-Exempt Fund | 22,518 | 73,139 | 59,898 |
U.S. Social Bond Fund | 0 | 0 | 233 |
For Funds with fiscal period ending August 31 | |||
Emerging Markets Bond Fund | 3,246 | 0 | 0 |
Emerging Markets Fund | 0 | 13,635 | 0 |
Greater China Fund | 1,929 | 0 | 0 |
For Funds with fiscal period ending October 31 | |||
CT Intermediate Municipal Bond Fund | 1,625 | 5,054 | 5,462 |
Intermediate Duration Municipal Bond Fund | 0 | 8,005 | 1,748 |
Statement of Additional Information – April 27, 2023 | 191 |
Fees Waived | |||
2022 | 2021 | 2020 | |
MA Intermediate Municipal Bond Fund | $1,661 | $6,346 | $8,893 |
NY Intermediate Municipal Bond Fund | 4,031 | 15,236 | 25,327 |
Select Global Equity Fund | 0 | 0 | 10 |
Strategic CA Municipal Income Fund | 77,375 | 236,843 | 113,836 |
Strategic NY Municipal Income Fund | 12,043 | 40,915 | 53,359 |
Statement of Additional Information – April 27, 2023 | 192 |
Statement of Additional Information – April 27, 2023 | 193 |
Statement of Additional Information – April 27, 2023 | 194 |
Statement of Additional Information – April 27, 2023 | 195 |
Statement of Additional Information – April 27, 2023 | 196 |
Statement of Additional Information – April 27, 2023 | 197 |
Name, address, year of birth | Position held with Subsidiary and length of service |
Principal occupation during past five years |
Brian M. Engelking 5228 Ameriprise Financial Center Minneapolis, MN 55474-2405 Born 1979 |
Director since March 2020 |
Global Lead Financial Officer – Columbia Threadneedle Investments at Ameriprise Financial, Inc. since June 2020. Previously, Vice President – Finance, Ameriprise Financial, Inc. and served in various finance leadership roles with Ameriprise Financial, Inc. since 2000. |
Christopher O. Petersen 5228 Ameriprise Financial Center Minneapolis, MN 55474-2405 Born 1970 |
Director since January 2015 |
See Fund Governance – The Officers – Fund Officers. |
Statement of Additional Information – April 27, 2023 | 198 |
Subsidiary | Assets (millions) |
Annual rate at each asset level(a) |
ASGM Offshore Fund, Ltd. | $0 - $500 | 1.100% |
ASMF Offshore Fund, Ltd. | >$500 - $1,000 | 1.050% |
(Subsidiaries of MM Alternative Strategies Fund)(a) | >$1,000 - $3,000 | 1.020% |
>$3,000 - $6,000 | 0.990% | |
>$6,000 - $12,000 | 0.960% | |
>$12,000 | 0.950% | |
CCSF Offshore Fund, Ltd. | $0 - $500 | 0.630% |
(Subsidiary of Commodity Strategy Fund)(a) | >$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% | |
CMSAF1 Offshore Fund, Ltd. | $0 - $500 | 0.960% |
CMSAF2 Offshore Fund, Ltd. | >$500 - $1,000 | 0.955% |
CMSAF3 Offshore Fund, Ltd. | >$1,000 - $3,000 | 0.950% |
(Subsidiaries of Multi Strategy Alternatives Fund)(a) | >$3,000 - $12,000 | 0.940% |
>$12,000 | 0.930% |
(a) | When calculating asset levels for purposes of determining fee rate breakpoints, asset levels are based on aggregate net assets of the Subsidiary and its Fund. When calculating the fee payable under this agreement, the annual rates are based on a percentage of the daily net assets of the Subsidiary. |
Statement of Additional Information – April 27, 2023 | 199 |
Statement of Additional Information – April 27, 2023 | 200 |
Name, Address, Year of Birth | Position Held with the Columbia Funds and Length of Service | Principal Occupation(s) During the Past Five Years and Other Relevant Professional Experience |
Number of Funds in the Columbia Funds Complex* Overseen |
Other Directorships Held by Trustee During the Past Five Years and Other Relevant Board Experience |
Committee Assignments |
George S. Batejan c/o Columbia Management Investment Advisers, LLC, 290 Congress Street Boston, MA 02210 1954 |
Trustee since 2017 |
Executive Vice President, Global Head of Technology and Operations, Janus Capital Group, Inc., 2010-2016 | 177 | 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; former Advisory Board Member, University of Colorado Business School, 2015-2018; former Board Member, Chase Bank International, 1993-1994 | Compliance, Contracts, Investment Review Committee |
Statement of Additional Information – April 27, 2023 | 201 |
Name, Address, Year of Birth | Position Held with the Columbia Funds and Length of Service | Principal Occupation(s) During the Past Five Years and Other Relevant Professional Experience |
Number of Funds in the Columbia Funds Complex* Overseen |
Other Directorships Held by Trustee During the Past Five Years and Other Relevant Board Experience |
Committee Assignments |
Kathleen Blatz c/o Columbia Management Investment Advisers, LLC, 290 Congress Street Boston, MA 02210 1954 |
Trustee since 2006 |
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; Member and Interim Chair, Minnesota Sports Facilities Authority, January-July 2017; Interim President and Chief Executive Officer, Blue Cross Blue Shield of Minnesota (health care insurance), February-July 2018, April-October 2021 | 177 | Former Trustee, Blue Cross and Blue Shield of Minnesota, 2009-2021 (Chair of the Business Development Committee, 2014-2017; Chair of the Governance Committee, 2017-2019); former Member and Chair of the Board, Minnesota Sports Facilities Authority, January 2017-July 2017; former Director, Robina Foundation, 2009-2020 (Chair, 2014-2020); Director, Richard M. Schulze Family Foundation, since 2021 | Compliance, Contracts, Investment Review Committee |
Pamela G. Carlton c/o Columbia Management Investment Advisers, LLC, 290 Congress Street Boston, MA 02210 1954 |
Chair since 2023; Trustee since 2007 | 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, 1982-1991, Morgan Stanley; Attorney, Cleary Gottlieb Steen & Hamilton LLP, 1980-1982 | 177 | Trustee, New York Presbyterian Hospital Board, since 1996; Director, DR Bank (Audit Committee), since 2017; Director, Evercore Inc. (Audit Committee, Nominating and Governance Committee) (financial services), since 2019; Director, Apollo Commercial Real Estate Finance, Inc. (Chair, Nominating and Governance Committee), since 2021; the Governing Council of the Independent Directors Council (IDC), since 2021 | Contracts, Board Governance, Investment Review Committee |
Janet Langford Carrig c/o Columbia Management Investment Advisers, LLC, 290 Congress Street Boston, MA 02210 1957 |
Trustee since 1996 |
Senior Vice President, General Counsel and Corporate Secretary, ConocoPhillips (independent energy company), September 2007-October 2018 | 177 | Director, EQT Corporation (natural gas producer), since 2019; former Director, Whiting Petroleum Corporation (independent oil and gas company), 2020-2022 | Contracts, Board Governance, Investment Review Committee |
Statement of Additional Information – April 27, 2023 | 202 |
Name, Address, Year of Birth | Position Held with the Columbia Funds and Length of Service | Principal Occupation(s) During the Past Five Years and Other Relevant Professional Experience |
Number of Funds in the Columbia Funds Complex* Overseen |
Other Directorships Held by Trustee During the Past Five Years and Other Relevant Board Experience |
Committee Assignments |
J. Kevin Connaughton c/o Columbia Management Investment Advisers, LLC, 290 Congress Street Boston, MA 02210 1964 |
Trustee since 2020 |
CEO and President, RhodeWay Financial (non-profit financial planning firm), since December 2022; Member, FINRA National Adjudicatory Council since January 2020; Adjunct Professor of Finance, Bentley University, since January 2018; Consultant to Independent Trustees of CFVIT and CFST I from March 2016 to June 2020 with respect to CFVIT and to December 2020 with respect to CFST I; Managing Director and General Manager of Mutual Fund Products, Columbia Management Investment Advisers, LLC, May 2010-February 2015; President, Columbia Funds, 2008-2015; and senior officer of Columbia Funds and affiliated funds, 2003-2015 | 175 | Former Director, The Autism Project, March 2015-December 2021; former Member of the Investment Committee, St. Michael’s College, November 2015-February 2020; former Trustee, St. Michael’s College, June 2017-September 2019; former Trustee, New Century Portfolios (former mutual fund complex), January 2015-December 2017 | Audit, Contracts, Investment Review Committee |
Olive M. Darragh c/o Columbia Management Investment Advisers, LLC, 290 Congress Street Boston, MA 02210 1962 |
Trustee since 2020 |
Managing Director of Darragh Inc. (strategy and talent management consulting firm), since 2010; Founder and CEO, Zolio, Inc. (investment management talent identification platform), since 2004; Consultant to Independent Trustees of CFVIT and CFST I from June 2019 to June 2020 with respect to CFVIT and to December 2020 with respect to CFST I; Partner, Tudor Investments, 2004-2010; Senior Partner, McKinsey & Company (consulting), 1990-2004; Touche Ross CPA, 1985-1988 | 175 | Treasurer, Edinburgh University US Trust Board, since January 2023; Member, HBS Community Action Partners Board, since September 2022; former Director, University of Edinburgh Business School (Member of US Board), 2004-2019; former Director, Boston Public Library Foundation, 2008-2017 | Compliance, Contracts, Investment Review Committee |
Patricia M. Flynn c/o Columbia Management Investment Advisers, LLC, 290 Congress Street Boston, MA 02210 1950 |
Trustee since 2004 |
Professor of Economics and Management, Bentley University, since 2002; Dean, McCallum Graduate School of Business, Bentley University, 1992-2002 | 177 | Former Trustee, MA Taxpayers Foundation,1997-2022; former Director, The MA Business Roundtable, 2003-2019; former Chairperson, Innovation Index Advisory Committee, MA Technology Collaborative, 1997-2020 | Audit, Contracts, Investment Review Committee |
Brian J. Gallagher c/o Columbia Management Investment Advisers, LLC, 290 Congress Street Boston, MA 02210 1954 |
Trustee since 2017 |
Retired; Partner with Deloitte & Touche LLP and its predecessors, 1977-2016 | 177 | Trustee, Catholic Schools Foundation, since 2004 | Audit, Contracts, Investment Review Committee |
Statement of Additional Information – April 27, 2023 | 203 |
Name, Address, Year of Birth | Position Held with the Columbia Funds and Length of Service | Principal Occupation(s) During the Past Five Years and Other Relevant Professional Experience |
Number of Funds in the Columbia Funds Complex* Overseen |
Other Directorships Held by Trustee During the Past Five Years and Other Relevant Board Experience |
Committee Assignments |
Douglas A. Hacker c/o Columbia Management Investment Advisers, LLC, 290 Congress Street Boston, MA 02210 1955 |
Trustee since 1996 |
Independent business executive, since May 2006; Executive Vice President – Strategy of United Airlines, December 2002-May 2006; President of UAL Loyalty Services (airline marketing company), September 2001-December 2002; Executive Vice President and Chief Financial Officer of United Airlines, July 1999-September 2001 | 177 | Director, SpartanNash Company since November 2013 (Chair of the Board since May 2021) (food distributor); Director, Aircastle Limited (Chair of Audit Committee) (aircraft leasing), since August 2006; former Director, Nash Finch Company (food distributor), 2005-2013; former Director, SeaCube Container Leasing Ltd. (container leasing), 2010-2013; and former Director, Travelport Worldwide Limited (travel information technology), 2014-2019 | Audit, Contracts, Board Governance, Investment Review Committee |
Nancy T. Lukitsh c/o Columbia Management Investment Advisers, LLC, 290 Congress Street Boston, MA 02210 1956 |
Trustee since 2011 |
Senior Vice President, Partner and Director of Marketing, Wellington Management Company, LLP (investment adviser), 1997-2010; Chair, Wellington Management Portfolios (commingled non-U.S. investment pools), 2007 -2010; Director, Wellington Trust Company, NA and other Wellington affiliates, 1997-2010 | 175 | None | Contracts, Board Governance, Investment Review Committee |
David M. Moffett c/o Columbia Management Investment Advisers, LLC, 290 Congress Street Boston, MA 02210 1952 |
Trustee since 2011 |
Retired; former Chief Executive Officer of Freddie Mac and Chief Financial Officer of U.S. Bank | 175 | Director, CSX Corporation (transportation suppliers); Director, PayPal Holdings Inc. (payment and data processing services); Trustee, University of Oklahoma Foundation; former Director, eBay Inc. (online trading community), 2007-2015; and former Director, CIT Bank, CIT Group Inc. (commercial and consumer finance), 2010-2016; former Senior Adviser to The Carlyle Group (financial services), March 2008-September 2008; former Governance Consultant to Bridgewater Associates (investment company), January 2013-December 2015 | Audit, Contracts, Investment Review Committee |
Statement of Additional Information – April 27, 2023 | 204 |
Name, Address, Year of Birth | Position Held with the Columbia Funds and Length of Service | Principal Occupation(s) During the Past Five Years and Other Relevant Professional Experience |
Number of Funds in the Columbia Funds Complex* Overseen |
Other Directorships Held by Trustee During the Past Five Years and Other Relevant Board Experience |
Committee Assignments |
Catherine James Paglia c/o Columbia Management Investment Advisers, LLC, 290 Congress Street Boston, MA 02210 1952 |
Trustee since 2004 |
Director, Enterprise Asset Management, Inc. (private real estate and asset management company), since September 1998; Managing Director and Partner, Interlaken Capital, Inc., 1989-1997; Vice President, 1982-1985, Principal, 1985-1987, Managing Director, 1987-1989, Morgan Stanley; Vice President, Investment Banking, 1980-1982, Associate, Investment Banking, 1976-1980, Dean Witter Reynolds, Inc. | 177 | Director, Valmont Industries, Inc. (irrigation systems manufacturer), since 2012; Trustee, Carleton College (on the Investment Committee), since 1987; Trustee, Carnegie Endowment for International Peace (on the Investment Committee), since 2009 | Compliance, Contracts, Board Governance, Investment Review Committee |
Natalie A. Trunow c/o Columbia Management Investment Advisers, LLC, 290 Congress Street Boston, MA 02210 1967 |
Trustee since 2020 |
Chief Executive Officer, Millennial Portfolio Solutions LLC (asset management and consulting services) January 2016-January 2021; Non-executive Member of the Investment Committee and Valuation Committee, Sarona Asset Management Inc. (private equity firm) since September 2019; Advisor, Horizon Investments (asset management and consulting services), August 2018-January 2022; Advisor, Paradigm Asset Management, November 2016-January 2022; Consultant to Independent Trustees of CFVIT and CFST I from September 2016 to June 2020 with respect to CFVIT and to December 2020 with respect to CFST I; Director of Investments/Consultant, Casey Family Programs, April 2016-November 2016; Senior Vice President and Chief Investment Officer, Calvert Investments, August 2008-January 2016; Section Head and Portfolio Manager, General Motors Asset Management, June 1997-August 2008 | 175 | Independent Director, (Investment Committee), Health Services for Children with Special Needs, Inc., 2010-2021; Independent Director, (Executive Committee and Chair, Audit Committee), Consumer Credit Counseling Services (formerly Guidewell Financial Solutions), since 2016; Independent Director (Investment Committee), Sarona Asset Management, since 2019 | Compliance, Contracts, Investment Review Committee |
Sandra L. Yeager c/o Columbia Management Investment Advisers, LLC, 290 Congress Street Boston, MA 02210 1964 |
Trustee since 2017 |
Retired; President and founder, Hanoverian Capital, LLC (SEC registered investment advisor firm), 2008-2016; Managing Director, DuPont Capital, 2006-2008; Managing Director, Morgan Stanley Investment Management, 2004-2006; Senior Vice President, Alliance Bernstein, 1990-2004 | 177 | Former Director, NAPE (National Alliance for Partnerships in Equity) Education Foundation, October 2016-October 2020; Advisory Board, Jennersville YMCA, since 2022 | Audit, Contracts, Investment Review Committee |
Statement of Additional Information – April 27, 2023 | 205 |
Name, Address, Year of Birth |
Position Held with the Columbia Funds and Length of Service |
Principal Occupation(s) During the Past Five Years and Other Relevant Professional Experience |
Number of Funds in the Columbia Funds Complex* Overseen |
Other Directorships Held by Trustee During the Past Five Years and Other Relevant Board Experience | Committee Assignments |
Daniel J. Beckman c/o Columbia Management Investment Advisers, LLC 290 Congress Street Boston, MA 02210 1962 |
Trustee since November 2021 and President since June 2021 | Vice President – Head of North America Product, Columbia Management Investment Advisers, LLC, since April 2015; President and Principal Executive Officer of the Columbia Funds, since June 2021; officer of Columbia Funds and affiliated funds, 2020-2021 | 177 | Director, Ameriprise Trust Company, since October 2016; Director, Columbia Management Investment Distributors, Inc. since November 2018; Board of Governors, Columbia Wanger Asset Management, LLC since January 2022; Director, Columbia Threadneedle Canada, Inc., since December 2022 | None |
* | The term “Columbia Funds Complex” as used herein includes Columbia Seligman Premium Technology Growth Fund, Tri-Continental Corporation and each series of Columbia Funds Series Trust (CFST), Columbia Funds Series Trust I (CFST I), Columbia Funds Series Trust II (CFST II), Columbia ETF Trust I (CET I), Columbia ETF Trust II (CET II), Columbia Funds Variable Insurance Trust (CFVIT) and Columbia Funds Variable Series Trust II (CFVST II). Messrs. Batejan, Beckman, Gallagher and Hacker and Mses. Blatz, Carlton, Carrig, Flynn, Paglia and Yeager serve as directors of Columbia Seligman Premium Technology Growth Fund and Tri-Continental Corporation. |
** | 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. |
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 |
Michael G. Clarke 290 Congress Street Boston, MA 02210 1969 |
Chief Financial Officer and Principal Financial Officer (2009) and Senior Vice President (2019) | Senior Vice President and Head of Global Operations & Investor Services, Columbia Management Investment Advisers, LLC, since March 2022 (previously Vice President, Head of North American Operations, and Co-Head of Global Operations, June 2019 to February 2022 and Vice President – Accounting and Tax, May 2010 - May 2019); senior officer of Columbia Funds and affiliated funds, since 2002. |
Joseph Beranek 5890 Ameriprise Financial Center Minneapolis, MN 55474 1965 |
Treasurer and Chief Accounting Officer (Principal Accounting Officer) (2019) and Principal Financial Officer (2020), CFST, CFST I, CFST II, CFVIT and CFVST II; Assistant Treasurer, CET I and CET II | Vice President – Mutual Fund Accounting and Financial Reporting, Columbia Management Investment Advisers, LLC, since December 2018 and March 2017, respectively. |
Statement of Additional Information – April 27, 2023 | 206 |
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 |
Marybeth Pilat 290 Congress Street Boston, MA 02210 1968 |
Treasurer and Chief Accounting Officer (Principal Accounting Officer) and Principal Financial Officer (2020) for CET I and CET II; Assistant Treasurer, CFST, CFST I, CFST II, CFVIT and CFVST II | Vice President – Product Pricing and Administration, Columbia Management Investment Advisers, LLC, since May 2017. |
William F. Truscott 290 Congress Street Boston, MA 02210 1960 |
Senior Vice President (2001) | Formerly, Trustee/Director of Columbia Funds Complex or legacy funds, November 2001 – January 1, 2021; Chief Executive Officer, Global Asset Management, Ameriprise Financial, Inc., since September 2012; Chairman of the Board and President, Columbia Management Investment Advisers, LLC, since July 2004 and February 2012, respectively; Chairman of the Board and Chief Executive Officer, Columbia Management Investment Distributors, Inc., since November 2008 and February 2012, respectively; Chairman of the Board and Director, Threadneedle Asset Management Holdings, Sàrl, since March 2013 and December 2008, respectively; senior executive of various entities affiliated with Columbia Threadneedle Investments. |
Christopher O. Petersen 5228 Ameriprise Financial Center Minneapolis, MN 55474 1970 |
Senior Vice President and Assistant Secretary (2021) | Formerly, Trustee/Director of funds within the Columbia Funds Complex, July 1, 2020 - November 22, 2021; Senior Vice President and Assistant General Counsel, Ameriprise Financial, Inc., since September 2021 (previously Vice President and Lead Chief Counsel, January 2015 - September 2021); formerly, President and Principal Executive Officer of the Columbia Funds 2015 - 2021; officer of Columbia Funds and affiliated funds, since 2007. |
Thomas P. McGuire 290 Congress Street Boston, MA 02210 1972 |
Senior Vice President and Chief Compliance Officer (2012) | Vice President – Asset Management Compliance, Ameriprise Financial, Inc., since May 2010; Chief Compliance Officer, Columbia Acorn/Wanger Funds, since December 2015; formerly, Chief Compliance Officer, Ameriprise Certificate Company, September 2010 - September 2020. |
Ryan C. Larrenaga 290 Congress Street Boston, MA 02210 1970 |
Senior Vice President (2017), Chief Legal Officer (2017) and Secretary (2015) | Vice President and Chief Counsel, Ameriprise Financial, Inc. since August 2018 (previously Vice President and Group Counsel, August 2011 - August 2018); Chief Legal Officer, Columbia Acorn/Wanger Funds, since September 2020; officer of Columbia Funds and affiliated funds since 2005. |
Michael E. DeFao 290 Congress Street Boston, MA 02210 1968 |
Vice President (2011) and Assistant Secretary (2010) | Vice President and Chief Counsel, Ameriprise Financial, Inc., since May 2010; Vice President, Chief Legal Officer and Assistant Secretary, Columbia Management Investment Advisers, LLC, since October 2021 (previously Vice President and Assistant Secretary, May 2010 - September 2021). |
Lyn Kephart-Strong 5228 Ameriprise Financial Center Minneapolis, MN 55474 1960 |
Vice President (2015) | Vice President, Global Investment Operations Services, Columbia Management Investment Advisers, LLC, since 2010; President, Columbia Management Investment Services Corp. since October 2014; President, Ameriprise Trust Company, since January 2017. |
Statement of Additional Information – April 27, 2023 | 207 |
Statement of Additional Information – April 27, 2023 | 208 |
Statement of Additional Information – April 27, 2023 | 209 |
Statement of Additional Information – April 27, 2023 | 210 |
Statement of Additional Information – April 27, 2023 | 211 |
Fiscal Period | Audit Committee |
Compliance Committee |
Contracts Committee |
Board Governance Committee |
Investment Review Committee |
For the fiscal year ending January 31, 2022 |
5 | 4 | 5 | 5 | 4 |
For the fiscal year ending February 28, 2022 |
5 | 4 | 5 | 5 | 4 |
For the fiscal year ending March 31, 2022 |
6 | 4 | 6 | 5 | 4 |
For the fiscal year ending April 30, 2022 |
6 | 4 | 6 | 5 | 4 |
For the fiscal year ending May 31, 2022 |
6 | 4 | 6 | 3 | 4 |
For the fiscal year ending July 31, 2022 |
6 | 4 | 5 | 5 | 4 |
For the fiscal year ending August 31, 2022 |
6 | 4 | 6 | 5 | 4 |
For the fiscal year ending October 31, 2022 |
6 | 5 | 6 | 5 | 4 |
For the fiscal year ending December 31, 2022 |
5 | 4 | 6 | 6 | 4 |
Statement of Additional Information – April 27, 2023 | 212 |
Batejan | Blatz | Carlton | Carrig | Connaughton | Darragh | Flynn | |
Adaptive Retirement 2020 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2025 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2030 Fund | A | A | A | A | A | D(a) | A |
Adaptive Retirement 2035 Fund | A | A | A | A | A | D(a) | A |
Adaptive Retirement 2040 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2045 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2050 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2055 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2060 Fund | A | A | A | A | A | A | A |
Adaptive Risk Allocation Fund | A | A | A | A | C | A | A |
Balanced Fund | A | A | A | E(a) | C | A | A |
Bond Fund | A | A | A | A | C | A | A |
CA Intermediate Municipal Bond Fund | A | A | A | A | A | A | A |
Capital Allocation Aggressive Portfolio | A | A | A | A | A | A | A |
Capital Allocation Conservative Portfolio | A | A | A | A | A | A | A |
Capital Allocation Moderate Aggressive Portfolio | A | A | A | A | A | A | A |
Capital Allocation Moderate Conservative Portfolio | A | A | A | A | A | A | A |
Capital Allocation Moderate Portfolio | A | A | A | A | A | A | A |
Commodity Strategy Fund | A | A | A | A | A | A | A |
Contrarian Core Fund | A | A | A | E(a) | C | A | A |
Convertible Securities Fund | A | A | A | A | C | D(a) | A |
Corporate Income Fund | A | A | A | D(a) | A | D(a) | A |
CT Intermediate Municipal Bond Fund | A | A | A | A | A | A | A |
Disciplined Core Fund | A | A | A | A | A | A | E(a) |
Disciplined Growth Fund | A | A | A | A | A | A | A |
Disciplined Value Fund | A | A | A | A | A | A | A |
Dividend Income Fund | A | A | A | E(a) | D | E | A |
Dividend Opportunity Fund | E | E | A | E(a) | A | A | E(a) |
Emerging Markets Bond Fund | A | A | A | A | A | A | A |
Emerging Markets Fund | A | E | A | A | B | A | A |
Flexible Capital Income Fund | A | A | A | A | A | A | E(a) |
Floating Rate Fund | A | A | E(a) | A | A | A | A |
Global Opportunities Fund | A | A | A | A | A | A | C |
Global Technology Growth Fund | A | A | A | A | A | E | A |
Global Value Fund | A | C | A | A | A | A | A |
Government Money Market Fund | B(a) | A | E(a) | B(a) | A | B(a) | C(a) |
Statement of Additional Information – April 27, 2023 | 213 |
Batejan | Blatz | Carlton | Carrig | Connaughton | Darragh | Flynn | |
Greater China Fund | A | A | A | A | B | A | A |
High Yield Bond Fund | A | A | A | A | A | D(a) | A |
High Yield Municipal Fund | A | A | A | A | A | A | A |
Income Builder Fund | A | A | A | A | A | A | A |
Income Opportunities Fund | A | A | A | A | A | A | A |
Intermediate Duration Municipal Bond Fund | A | A | A | A | A | A | A |
International Dividend Income Fund | A | A | A | A | A | A | A |
Large Cap Enhanced Core Fund | A | A | A | A | A | A | A |
Large Cap Growth Fund | A | A | A | E | A | A | A |
Large Cap Growth Opportunity Fund | A | A | A | A | A | A | A |
Large Cap Index Fund | A | A | A | A | A | A | A |
Large Cap Value Fund | A | A | A | A | A | A | A |
Limited Duration Credit Fund | A | A | A | A | A | A | A |
MA Intermediate Municipal Bond Fund | A | A | A | A | A | A | A |
Mid Cap Index Fund | A | A | A | A | A | A | A |
MM Alternative Strategies Fund | A | A | A | A | A | A | A |
MM Directional Alternative Strategies Fund | A | A | A | A | A | A | A |
MM Growth Strategies Fund | A | A | A | A | A | A | A |
MM International Equity Strategies Fund | A | A | A | A | A | A | A |
MM Small Cap Equity Strategies Fund | A | A | A | A | A | A | A |
MM Total Return Bond Strategies Fund | A | A | E(a) | A | A | A | A |
MM Value Strategies Fund | A | A | A | A | A | A | A |
MN Tax-Exempt Fund | A | A | A | A | A | A | A |
Mortgage Opportunities Fund | A | A | A | A | A | A | A |
Multisector Bond SMA Completion Portfolio | A | A | A | A | A | A | A |
Multi Strategy Alternatives Fund | A | A | A | A | A | A | A |
NC Intermediate Municipal Bond Fund | A | A | A | A | A | A | A |
NY Intermediate Municipal Bond Fund | A | A | A | A | A | A | A |
OR Intermediate Municipal Bond Fund | A | A | A | A | A | A | A |
Overseas Core Fund | D | A | A | A | A | A | A |
Overseas SMA Completion Portfolio | A | A | A | A | A | A | A |
Overseas Value Fund | A | A | A | A | A | A | A |
Quality Income Fund | A | C | A | A | A | A | A |
Real Estate Equity Fund | A | A | A | A | A | A | A |
SC Intermediate Municipal Bond Fund | A | A | A | A | A | A | A |
Select Global Equity Fund | A | E | A | A | A | A | A |
Select Large Cap Equity Fund | A | A | A | A | A | A | A |
Select Large Cap Growth Fund | A | A | A | A | C | A | A |
Select Large Cap Value Fund | E | A | E(a) | A | A | A | E(a) |
Select Mid Cap Growth Fund | A | A | A | A | A | A | A |
Select Mid Cap Value Fund | A | A | A | A | C | A | A |
Select Small Cap Value Fund | E | A | E(a) | A | A | A | A |
Seligman Global Technology Fund | C(a) | B | A | A | A | A | E(a) |
Seligman Technology and Information Fund | A | E | E(a) | A | A | A | A |
Statement of Additional Information – April 27, 2023 | 214 |
Batejan | Blatz | Carlton | Carrig | Connaughton | Darragh | Flynn | |
Short Duration Municipal Bond Fund | A | A | A | A | A | A | A |
Short Term Bond Fund | A | A | A | A | A | A | A |
Small Cap Growth Fund | D | A | A | A | C | A | A |
Small Cap Index Fund | A | A | A | A | A | A | A |
Small Cap Value Fund I | C(a) | A | A | A | A | A | A |
Small Cap Value Fund II | A | A | A | A | C | A | A |
Solutions Aggressive Portfolio | A | A | A | A | A | A | A |
Solutions Conservative Portfolio | A | A | A | A | A | A | A |
Strategic CA Municipal Income Fund | A | A | A | A | A | A | A |
Strategic Income Fund | A | A | A | A | C | A | A |
Strategic Municipal Income Fund | A | A | A | A | A | A | A |
Strategic NY Municipal Income Fund | A | A | A | A | A | A | A |
Tax-Exempt Fund | A | B | A | A | A | A | A |
Total Return Bond Fund | A | A | E(a) | A | A | A | A |
U.S. Social Bond Fund | A | A | A | A | A | A | A |
U.S. Treasury Index Fund | A | A | A | A | A | A | A |
Ultra Short Term Bond Fund | A | A | A | A | A | A | A |
VA Intermediate Municipal Bond Fund | A | A | A | A | A | A | A |
Aggregate Dollar Range of Equity Securities in all Funds in the Columbia Funds Complex Overseen by the Trustee | E(a) | E | E(a) | E(a) | E | E(a) | E(a) |
(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. |
Statement of Additional Information – April 27, 2023 | 215 |
Gallagher | Hacker | Lukitsh | Moffett | Paglia | Trunow | Yeager | |
Adaptive Retirement 2020 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2025 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2030 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2035 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2040 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2045 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2050 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2055 Fund | A | A | A | A | A | A | A |
Adaptive Retirement 2060 Fund | A | A | A | A | A | A | A |
Adaptive Risk Allocation Fund | A | E | A | A | A | A | A |
Balanced Fund | D(a) | A | A | A | A | A | A |
Bond Fund | A | A | A | A | A | A | E(a) |
CA Intermediate Municipal Bond Fund | A | A | A | A | A | A | A |
Capital Allocation Aggressive Portfolio | A | A | A | A | A | A | A |
Capital Allocation Conservative Portfolio | A | A | A | A | A | A | A |
Capital Allocation Moderate Aggressive Portfolio | D | A | A | A | A | A | A |
Capital Allocation Moderate Conservative Portfolio | A | A | A | A | A | A | A |
Capital Allocation Moderate Portfolio | A | A | A | A | A | A | A |
Commodity Strategy Fund | A | A | A | A | A | A | A |
Contrarian Core Fund | A | A | A | A | E(a) | A | A |
Convertible Securities Fund | A | E | A | A | A | A | A |
Corporate Income Fund | A | A | A | A | A | A | A |
CT Intermediate Municipal Bond Fund | A | A | A | A | A | A | A |
Disciplined Core Fund | A | A | A | A | A | A | A |
Disciplined Growth Fund | A | A | A | A | A | A | A |
Disciplined Value Fund | A | A | A | A | A | A | A |
Dividend Income Fund | A | A | E | A | E(a) | A | E(a) |
Dividend Opportunity Fund | A | A | A | A | A | A | A |
Emerging Markets Bond Fund | A | A | A | A | A | A | A |
Emerging Markets Fund | E(a) | E | A | A | A | A | E(a) |
Flexible Capital Income Fund | A | A | A | A | E(a) | A | A |
Floating Rate Fund | D | A | A | A | A | A | A |
Global Opportunities Fund | D(a) | A | A | A | A | A | A |
Global Technology Growth Fund | A | A | E | E(a) | A | A | A |
Global Value Fund | E | A | A | A | A | A | A |
Government Money Market Fund | B(a) | A | A | B(a) | D(a) | E(a) | B(a) |
Greater China Fund | A | A | A | A | A | A | A |
High Yield Bond Fund | A | A | A | A | A | A | A |
High Yield Municipal Fund | A | A | A | A | A | A | A |
Income Builder Fund | E | A | A | A | A | A | A |
Income Opportunities Fund | A | A | A | A | A | A | A |
Intermediate Duration Municipal Bond Fund | A | A | A | A | A | A | A |
International Dividend Income Fund | A | A | A | A | A | A | A |
Large Cap Enhanced Core Fund | A | A | A | A | A | A | A |
Statement of Additional Information – April 27, 2023 | 216 |
Gallagher | Hacker | Lukitsh | Moffett | Paglia | Trunow | Yeager | |
Large Cap Growth Fund | A | A | A | A | A | A | A |
Large Cap Growth Opportunity Fund | A | A | A | A | A | A | A |
Large Cap Index Fund | A | A | A | A | A | E(a) | A |
Large Cap Value Fund | A | A | A | A | A | A | A |
Limited Duration Credit Fund | A | A | A | A | A | E(a) | A |
MA Intermediate Municipal Bond Fund | A | A | A | A | A | A | A |
Mid Cap Index Fund | A | A | A | A | A | E(a) | A |
MM Alternative Strategies Fund | A | A | A | A | A | A | A |
MM Directional Alternative Strategies Fund | A | A | A | A | A | A | A |
MM Growth Strategies Fund | A | A | A | A | A | A | A |
MM International Equity Strategies Fund | A | A | A | A | A | A | A |
MM Small Cap Equity Strategies Fund | E(a) | A | A | A | A | A | A |
MM Total Return Bond Strategies Fund | A | A | A | A | A | A | A |
MM Value Strategies Fund | E(a) | A | A | A | A | A | A |
MN Tax-Exempt Fund | A | A | A | A | A | A | A |
Mortgage Opportunities Fund | A | A | A | A | A | A | E(a) |
Multisector Bond SMA Completion Portfolio | A | A | A | A | A | A | A |
Multi Strategy Alternatives Fund | A | A | A | A | A | A | A |
NC Intermediate Municipal Bond Fund | A | A | A | A | A | A | A |
NY Intermediate Municipal Bond Fund | A | A | A | A | A | A | A |
OR Intermediate Municipal Bond Fund | A | A | A | A | A | A | A |
Overseas Core Fund | A | A | A | A | A | A | E(a) |
Overseas SMA Completion Portfolio | A | A | A | A | A | A | A |
Overseas Value Fund | D | A | A | A | A | A | A |
Quality Income Fund | A | A | A | A | A | A | A |
Real Estate Equity Fund | A | A | A | A | A | A | A |
SC Intermediate Municipal Bond Fund | A | A | A | A | A | A | A |
Select Global Equity Fund | A | A | A | A | A | A | A |
Select Large Cap Equity Fund | D(a) | A | A | A | A | A | A |
Select Large Cap Growth Fund | A | E | A | A | A | A | A |
Select Large Cap Value Fund | A | A | A | A | A | A | A |
Select Mid Cap Growth Fund | A | E | A | A | A | A | A |
Select Mid Cap Value Fund | A | A | A | A | A | A | E(a) |
Select Small Cap Value Fund | A | A | A | A | A | A | A |
Seligman Global Technology Fund | E(a) | A | A | A | A | A | A |
Seligman Technology and Information Fund | A | A | A | A | E(a) | A | A |
Short Duration Municipal Bond Fund | A | A | A | A | A | A | A |
Short Term Bond Fund | A | A | A | A | A | A | A |
Small Cap Growth Fund | E(a) | E | A | A | A | A | A |
Small Cap Index Fund | A | A | A | A | A | E(a) | A |
Small Cap Value Fund I | A | A | A | A | A | A | A |
Small Cap Value Fund II | A | A | A | A | A | A | A |
Solutions Aggressive Portfolio | A | A | A | A | A | A | A |
Solutions Conservative Portfolio | A | A | A | A | A | A | A |
Statement of Additional Information – April 27, 2023 | 217 |
Gallagher | Hacker | Lukitsh | Moffett | Paglia | Trunow | Yeager | |
Strategic CA Municipal Income Fund | A | A | A | A | A | A | A |
Strategic Income Fund | A | A | A | A | A | A | A |
Strategic Municipal Income Fund | A | A | A | A | A | A | A |
Strategic NY Municipal Income Fund | A | A | A | A | A | A | A |
Tax-Exempt Fund | A | A | A | A | A | A | A |
Total Return Bond Fund | A | A | A | A | A | A | A |
U.S. Social Bond Fund | A | A | A | A | A | A | A |
U.S. Treasury Index Fund | A | A | A | A | A | A | A |
Ultra Short Term Bond Fund | A | A | A | A | A | A | A |
VA Intermediate Municipal Bond Fund | A | A | A | A | A | A | A |
Aggregate Dollar Range of Equity Securities in all Funds in the Columbia Funds Complex Overseen by the Trustee | E(a) | E | E | E(a) | E(a) | E(a) | E(a) |
(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. |
Beckman | |
Adaptive Retirement 2020 Fund | A |
Adaptive Retirement 2025 Fund | A |
Adaptive Retirement 2030 Fund | E |
Adaptive Retirement 2035 Fund | A |
Adaptive Retirement 2040 Fund | A |
Adaptive Retirement 2045 Fund | A |
Adaptive Retirement 2050 Fund | A |
Adaptive Retirement 2055 Fund | A |
Adaptive Retirement 2060 Fund | A |
Adaptive Risk Allocation Fund | E |
Balanced Fund | A |
Bond Fund | A |
CA Intermediate Municipal Bond Fund | A |
Capital Allocation Aggressive Portfolio | A |
Capital Allocation Conservative Portfolio | A |
Capital Allocation Moderate Aggressive Portfolio | A |
Capital Allocation Moderate Conservative Portfolio | A |
Capital Allocation Moderate Portfolio | A |
Commodity Strategy Fund | A |
Contrarian Core Fund | C(a) |
Convertible Securities Fund | A |
Corporate Income Fund | B(a) |
CT Intermediate Municipal Bond Fund | A |
Disciplined Core Fund | A |
Disciplined Growth Fund | A |
Disciplined Value Fund | A |
Dividend Income Fund | A |
Dividend Opportunity Fund | A |
Statement of Additional Information – April 27, 2023 | 218 |
Beckman | |
Emerging Markets Bond Fund | A |
Emerging Markets Fund | B(a) |
Flexible Capital Income Fund | C |
Floating Rate Fund | A |
Global Opportunities Fund | A |
Global Technology Growth Fund | A |
Global Value Fund | C |
Government Money Market Fund | A |
Greater China Fund | A |
High Yield Bond Fund | A |
High Yield Municipal Fund | A |
Income Builder Fund | A |
Income Opportunities Fund | A |
Intermediate Duration Municipal Bond Fund | A |
International Dividend Income Fund | A |
Large Cap Enhanced Core Fund | A |
Large Cap Growth Fund | A |
Large Cap Growth Opportunity Fund | A |
Large Cap Index Fund | A |
Large Cap Value Fund | A |
Limited Duration Credit Fund | A |
MA Intermediate Municipal Bond Fund | C |
Mid Cap Index Fund | A |
MM Alternative Strategies Fund | A |
MM Directional Alternative Strategies Fund | A |
MM Growth Strategies Fund | A |
MM International Equity Strategies Fund | A |
MM Small Cap Equity Strategies Fund | A |
MM Total Return Bond Strategies Fund | A |
MM Value Strategies Fund | A |
MN Tax-Exempt Fund | A |
Mortgage Opportunities Fund | C |
Multisector Bond SMA Completion Portfolio | A |
Multi Strategy Alternatives Fund | C |
NC Intermediate Municipal Bond Fund | A |
NY Intermediate Municipal Bond Fund | A |
OR Intermediate Municipal Bond Fund | A |
Overseas Core Fund | A |
Overseas SMA Completion Portfolio | A |
Overseas Value Fund | A |
Quality Income Fund | A |
Real Estate Equity Fund | A |
SC Intermediate Municipal Bond Fund | A |
Select Global Equity Fund | C(a) |
Statement of Additional Information – April 27, 2023 | 219 |
Beckman | |
Select Large Cap Equity Fund | A |
Select Large Cap Growth Fund | C |
Select Large Cap Value Fund | B(a) |
Select Mid Cap Growth Fund | B(a) |
Select Mid Cap Value Fund | B |
Select Small Cap Value Fund | A |
Seligman Global Technology Fund | A |
Seligman Technology and Information Fund | A |
Short Duration Municipal Bond Fund | A |
Short Term Bond Fund | A |
Small Cap Growth Fund | B(a) |
Small Cap Index Fund | A |
Small Cap Value Fund I | A |
Small Cap Value Fund II | C |
Solutions Aggressive Portfolio | A |
Solutions Conservative Portfolio | A |
Strategic CA Municipal Income Fund | A |
Strategic Income Fund | B |
Strategic Municipal Income Fund | A |
Strategic NY Municipal Income Fund | A |
Tax-Exempt Fund | A |
Total Return Bond Fund | C(a) |
U.S. Social Bond Fund | A |
U.S. Treasury Index Fund | A |
Ultra Short Term Bond Fund | C |
VA Intermediate Municipal Bond Fund | A |
Aggregate Dollar Range of Equity Securities in all Funds in the Columbia Funds Complex Overseen by the Trustee |
E(a) |
(a) | With respect to Mr. Beckman, this amount includes compensation payable under a Deferred Compensation Plan administered by Ameriprise Financial. |
Statement of Additional Information – April 27, 2023 | 220 |
Trustees | Total Cash Compensation from the Columbia Funds Complex Paid to Trustee(a) |
Amount Deferred from Total Compensation(b) |
George S. Batejan | $481,000 | $24,050 |
Kathleen Blatz | $457,000 | 0 |
Pamela G. Carlton | $496,000 | $49,600 |
Janet Langford Carrig | $498,000 | $498,000 |
J. Kevin Connaughton | $501,000 | 0 |
Olive M. Darragh | $486,000 | $243,000 |
Patricia M. Flynn | $457,000 | 0 |
Brian J. Gallagher | $484,000 | $242,000 |
Douglas A. Hacker | $535,000 | 0 |
Nancy T. Lukitsh | $471,000 | 0 |
David M. Moffett | $444,000 | $444,000 |
Catherine James Paglia | $535,000 | $267,500 |
Minor M. Shaw(c) | $469,000 | $234,500 |
Natalie A. Trunow | $462,000 | $360,360 |
Sandra L. Yeager | $496,000 | $248,000 |
(a) | Includes any portion of cash compensation Trustees elected to defer during the fiscal period. |
(b) | The Trustees may elect to defer a portion of the total cash compensation payable. Additional information regarding the Deferred Compensation Plan is described below. |
(c) | Ms. Shaw served as Trustee until December 31, 2022, and stopped receiving compensation from the Funds and the Columbia Funds Complex as of such date. |
Statement of Additional Information – April 27, 2023 | 221 |
Statement of Additional Information – April 27, 2023 | 222 |
Fund | Aggregate Compensation from Fund Independent Trustees | |||||||
Batejan(a) | Blatz | Carlton(b) | Carrig(c) | Connaughton | Darragh(d) | Flynn(e) | Gallagher(f) | |
Amount Deferred | $11 | $0 | $277 | $879 | $0 | $414 | $638 | $428 |
Adaptive Retirement 2045 Fund | $852 | $790 | $855 | $879 | $873 | $828 | $841 | $855 |
Amount Deferred | $11 | $0 | $277 | $879 | $0 | $414 | $638 | $428 |
Adaptive Retirement 2050 Fund | $852 | $790 | $855 | $879 | $873 | $828 | $841 | $855 |
Amount Deferred | $11 | $0 | $277 | $879 | $0 | $414 | $638 | $428 |
Adaptive Retirement 2055 Fund | $852 | $790 | $855 | $879 | $873 | $828 | $841 | $855 |
Amount Deferred | $11 | $0 | $277 | $879 | $0 | $414 | $638 | $428 |
Adaptive Retirement 2060 Fund | $852 | $790 | $855 | $879 | $873 | $828 | $841 | $855 |
Amount Deferred | $11 | $0 | $277 | $879 | $0 | $414 | $638 | $428 |
MM Growth Strategies Fund | $4,015 | $3,723 | $4,030 | $4,141 | $4,108 | $3,897 | $3,965 | $4,030 |
Amount Deferred | $49 | $0 | $1,321 | $4,141 | $0 | $1,949 | $3,060 | $2,015 |
Short Term Bond Fund | $1,747 | $1,620 | $1,753 | $1,801 | $1,791 | $1,700 | $1,722 | $1,753 |
Amount Deferred | $24 | $0 | $560 | $1,801 | $0 | $850 | $1,284 | $877 |
Select Large Cap Growth Fund | $2,451 | $2,272 | $2,461 | $2,528 | $2,507 | $2,377 | $2,422 | $2,461 |
Amount Deferred | $29 | $0 | $813 | $2,528 | $0 | $1,189 | $1,887 | $1,230 |
Solutions Aggressive Portfolio | $859 | $796 | $862 | $886 | $879 | $834 | $847 | $862 |
Amount Deferred | $11 | $0 | $279 | $886 | $0 | $417 | $643 | $431 |
Solutions Conservative Portfolio | $860 | $797 | $863 | $887 | $881 | $836 | $848 | $863 |
Amount Deferred | $11 | $0 | $280 | $887 | $0 | $418 | $644 | $432 |
For Funds with fiscal period ending April 30 | ||||||||
Bond Fund | $1,781 | $1,653 | $1,785 | $1,794 | $1,793 | $1,706 | $1,746 | $1,785 |
Amount Deferred | $29 | $0 | $545 | $1,794 | $0 | $853 | $1,222 | $893 |
CA Intermediate Municipal Bond Fund | $1,228 | $1,140 | $1,231 | $1,236 | $1,235 | $1,175 | $1,204 | $1,231 |
Amount Deferred | $20 | $0 | $376 | $1,236 | $0 | $588 | $844 | $615 |
Corporate Income Fund | $2,133 | $1,979 | $2,136 | $2,147 | $2,150 | $2,047 | $2,088 | $2,137 |
Amount Deferred | $36 | $0 | $643 | $2,147 | $0 | $1,023 | $1,431 | $1,068 |
MM Directional Alternative Strategies Fund | $1,087 | $1,009 | $1,089 | $1,094 | $1,094 | $1,041 | $1,065 | $1,089 |
Amount Deferred | $18 | $0 | $332 | $1,094 | $0 | $520 | $742 | $545 |
NC Intermediate Municipal Bond Fund | $1,024 | $951 | $1,027 | $1,031 | $1,030 | $981 | $1,004 | $1,027 |
Amount Deferred | $16 | $0 | $314 | $1,031 | $0 | $490 | $704 | $513 |
SC Intermediate Municipal Bond Fund | $966 | $897 | $969 | $973 | $972 | $925 | $947 | $969 |
Amount Deferred | $15 | $0 | $296 | $973 | $0 | $463 | $664 | $484 |
Short Duration Municipal Bond Fund | $1,481 | $1,374 | $1,484 | $1,491 | $1,492 | $1,420 | $1,450 | $1,484 |
Amount Deferred | $25 | $0 | $448 | $1,491 | $0 | $710 | $998 | $742 |
Small Cap Value Fund I | $1,763 | $1,637 | $1,767 | $1,775 | $1,775 | $1,689 | $1,727 | $1,767 |
Amount Deferred | $29 | $0 | $537 | $1,775 | $0 | $845 | $1,200 | $884 |
Total Return Bond Fund | $3,396 | $3,151 | $3,399 | $3,419 | $3,434 | $3,271 | $3,316 | $3,402 |
Amount Deferred | $62 | $0 | $991 | $3,419 | $0 | $1,636 | $2,173 | $1,701 |
U.S. Treasury Index Fund | $2,044 | $1,897 | $2,048 | $2,057 | $2,057 | $1,958 | $2,004 | $2,049 |
Amount Deferred | $33 | $0 | $625 | $2,057 | $0 | $979 | $1,402 | $1,024 |
VA Intermediate Municipal Bond Fund | $979 | $908 | $981 | $985 | $984 | $937 | $959 | $981 |
Amount Deferred | $16 | $0 | $300 | $985 | $0 | $468 | $674 | $490 |
For Funds with fiscal period ending May 31 | ||||||||
Adaptive Risk Allocation Fund | $4,220 | $3,904 | $4,255 | $4,371 | $4,372 | $4,170 | $4,102 | $4,225 |
Amount Deferred | $85 | $0 | $1,182 | $4,371 | $0 | $2,085 | $2,550 | $2,112 |
Commodity Strategy Fund | $1,189 | $1,099 | $1,197 | $1,230 | $1,231 | $1,175 | $1,156 | $1,189 |
Amount Deferred | $24 | $0 | $334 | $1,230 | $0 | $587 | $724 | $595 |
Dividend Income Fund | $29,518 | $27,300 | $29,784 | $30,589 | $30,607 | $29,205 | $28,648 | $29,539 |
Amount Deferred | $615 | $0 | $8,145 | $30,589 | $0 | $14,602 | $17,421 | $14,769 |
Dividend Opportunity Fund | $2,749 | $2,543 | $2,772 | $2,848 | $2,847 | $2,715 | $2,672 | $2,751 |
Amount Deferred | $55 | $0 | $772 | $2,848 | $0 | $1,358 | $1,669 | $1,376 |
Statement of Additional Information – April 27, 2023 | 223 |
Fund | Aggregate Compensation from Fund Independent Trustees | |||||||
Batejan(a) | Blatz | Carlton(b) | Carrig(c) | Connaughton | Darragh(d) | Flynn(e) | Gallagher(f) | |
Flexible Capital Income Fund | $1,922 | $1,777 | $1,938 | $1,991 | $1,992 | $1,900 | $1,866 | $1,923 |
Amount Deferred | $39 | $0 | $534 | $1,991 | $0 | $950 | $1,146 | $962 |
High Yield Bond Fund | $2,211 | $2,046 | $2,228 | $2,290 | $2,289 | $2,183 | $2,152 | $2,214 |
Amount Deferred | $43 | $0 | $628 | $2,290 | $0 | $1,091 | $1,366 | $1,107 |
High Yield Municipal Fund | $1,440 | $1,333 | $1,451 | $1,491 | $1,491 | $1,422 | $1,401 | $1,442 |
Amount Deferred | $28 | $0 | $407 | $1,491 | $0 | $711 | $884 | $721 |
Large Cap Value Fund | $2,972 | $2,750 | $2,997 | $3,079 | $3,078 | $2,936 | $2,889 | $2,975 |
Amount Deferred | $59 | $0 | $835 | $3,079 | $0 | $1,468 | $1,805 | $1,487 |
MM Value Strategies Fund | $4,871 | $4,507 | $4,913 | $5,048 | $5,047 | $4,814 | $4,733 | $4,875 |
Amount Deferred | $99 | $0 | $1,360 | $5,048 | $0 | $2,407 | $2,930 | $2,438 |
Mortgage Opportunities Fund | $4,118 | $3,808 | $4,153 | $4,265 | $4,268 | $4,072 | $3,998 | $4,120 |
Amount Deferred | $85 | $0 | $1,141 | $4,265 | $0 | $2,036 | $2,447 | $2,060 |
Multi Strategy Alternatives Fund | $1,499 | $1,387 | $1,511 | $1,553 | $1,552 | $1,481 | $1,457 | $1,500 |
Amount Deferred | $30 | $0 | $421 | $1,553 | $0 | $740 | $911 | $750 |
Quality Income Fund | $2,540 | $2,351 | $2,558 | $2,629 | $2,628 | $2,506 | $2,473 | $2,544 |
Amount Deferred | $49 | $0 | $725 | $2,629 | $0 | $1,253 | $1,581 | $1,272 |
Select Large Cap Value Fund | $2,365 | $2,186 | $2,388 | $2,452 | $2,454 | $2,342 | $2,293 | $2,366 |
Amount Deferred | $50 | $0 | $645 | $2,452 | $0 | $1,171 | $1,371 | $1,183 |
Select Small Cap Value Fund | $1,294 | $1,197 | $1,304 | $1,340 | $1,339 | $1,277 | $1,258 | $1,295 |
Amount Deferred | $25 | $0 | $366 | $1,340 | $0 | $639 | $794 | $648 |
Seligman Technology and Information Fund | $9,129 | $8,446 | $9,201 | $9,450 | $9,458 | $9,020 | $8,875 | $9,141 |
Amount Deferred | $184 | $0 | $2,557 | $9,450 | $0 | $4,510 | $5,518 | $4,570 |
For Funds with fiscal period ending July 31 | ||||||||
Disciplined Core Fund | $4,661 | $4,340 | $4,719 | $4,845 | $4,876 | $4,674 | $4,503 | $4,687 |
Amount Deferred | $134 | $0 | $1,064 | $4,845 | $0 | $2,337 | $2,007 | $2,343 |
Disciplined Growth Fund | $1,078 | $1,003 | $1,091 | $1,120 | $1,127 | $1,080 | $1,042 | $1,084 |
Amount Deferred | $30 | $0 | $250 | $1,120 | $0 | $540 | $478 | $542 |
Disciplined Value Fund | $1,025 | $955 | $1,038 | $1,066 | $1,072 | $1,028 | $991 | $1,031 |
Amount Deferred | $29 | $0 | $235 | $1,066 | $0 | $514 | $446 | $516 |
Floating Rate Fund | $1,558 | $1,451 | $1,579 | $1,621 | $1,632 | $1,565 | $1,503 | $1,567 |
Amount Deferred | $47 | $0 | $344 | $1,621 | $0 | $783 | $629 | $783 |
Global Opportunities Fund | $1,268 | $1,181 | $1,284 | $1,318 | $1,326 | $1,271 | $1,227 | $1,276 |
Amount Deferred | $36 | $0 | $293 | $1,318 | $0 | $636 | $559 | $638 |
Government Money Market Fund | $1,293 | $1,204 | $1,310 | $1,345 | $1,353 | $1,297 | $1,249 | $1,300 |
Amount Deferred | $38 | $0 | $292 | $1,345 | $0 | $649 | $546 | $650 |
Income Opportunities Fund | $1,568 | $1,460 | $1,587 | $1,630 | $1,640 | $1,572 | $1,516 | $1,577 |
Amount Deferred | $45 | $0 | $361 | $1,630 | $0 | $786 | $686 | $789 |
Large Cap Growth Fund | $5,046 | $4,697 | $5,106 | $5,242 | $5,275 | $5,054 | $4,882 | $5,075 |
Amount Deferred | $141 | $0 | $1,179 | $5,242 | $0 | $2,527 | $2,265 | $2,537 |
Limited Duration Credit Fund | $1,691 | $1,575 | $1,711 | $1,757 | $1,768 | $1,695 | $1,635 | $1,701 |
Amount Deferred | $48 | $0 | $391 | $1,757 | $0 | $847 | $746 | $850 |
MN Tax-Exempt Fund | $1,487 | $1,385 | $1,505 | $1,546 | $1,556 | $1,491 | $1,437 | $1,496 |
Amount Deferred | $43 | $0 | $341 | $1,546 | $0 | $746 | $645 | $748 |
OR Intermediate Municipal Bond Fund | $1,144 | $1,065 | $1,158 | $1,189 | $1,197 | $1,147 | $1,106 | $1,151 |
Amount Deferred | $33 | $0 | $262 | $1,189 | $0 | $574 | $496 | $575 |
Strategic Municipal Income Fund | $3,058 | $2,846 | $3,093 | $3,175 | $3,198 | $3,066 | $2,955 | $3,074 |
Amount Deferred | $87 | $0 | $705 | $3,175 | $0 | $1,533 | $1,339 | $1,537 |
Tax-Exempt Fund | $3,308 | $3,080 | $3,347 | $3,437 | $3,459 | $3,316 | $3,198 | $3,327 |
Amount Deferred | $94 | $0 | $763 | $3,437 | $0 | $1,658 | $1,450 | $1,664 |
U.S. Social Bond Fund | $919 | $856 | $930 | $955 | $961 | $921 | $888 | $924 |
Amount Deferred | $26 | $0 | $211 | $955 | $0 | $461 | $399 | $462 |
Statement of Additional Information – April 27, 2023 | 224 |
Fund | Aggregate Compensation from Fund Independent Trustees | |||||||
Batejan(a) | Blatz | Carlton(b) | Carrig(c) | Connaughton | Darragh(d) | Flynn(e) | Gallagher(f) | |
Ultra Short Term Bond Fund | $3,870 | $3,603 | $3,914 | $4,020 | $4,047 | $3,878 | $3,742 | $3,892 |
Amount Deferred | $109 | $0 | $895 | $4,020 | $0 | $1,939 | $1,707 | $1,946 |
For Funds with fiscal period ending August 31 | ||||||||
Balanced Fund | $7,982 | $7,478 | $8,128 | $8,344 | $8,398 | $8,122 | $7,657 | $8,018 |
Amount Deferred | $259 | $0 | $1,652 | $8,344 | $0 | $4,061 | $2,850 | $4,009 |
Contrarian Core Fund | $10,713 | $10,034 | $10,908 | $11,198 | $11,268 | $10,895 | $10,280 | $10,762 |
Amount Deferred | $345 | $0 | $2,233 | $11,198 | $0 | $5,448 | $3,882 | $5,381 |
Emerging Markets Bond Fund | $1,136 | $1,064 | $1,157 | $1,187 | $1,195 | $1,156 | $1,090 | $1,141 |
Amount Deferred | $37 | $0 | $237 | $1,187 | $0 | $578 | $411 | $571 |
Emerging Markets Fund | $2,503 | $2,343 | $2,545 | $2,613 | $2,631 | $2,542 | $2,406 | $2,515 |
Amount Deferred | $79 | $0 | $534 | $2,613 | $0 | $1,271 | $950 | $1,258 |
Global Technology Growth Fund | $3,119 | $2,919 | $3,171 | $3,256 | $3,278 | $3,166 | $2,998 | $3,134 |
Amount Deferred | $98 | $0 | $668 | $3,256 | $0 | $1,583 | $1,191 | $1,567 |
Greater China Fund | $991 | $928 | $1,008 | $1,035 | $1,042 | $1,007 | $952 | $996 |
Amount Deferred | $31 | $0 | $210 | $1,035 | $0 | $503 | $370 | $498 |
International Dividend Income Fund | $1,259 | $1,180 | $1,282 | $1,316 | $1,325 | $1,281 | $1,208 | $1,265 |
Amount Deferred | $41 | $0 | $261 | $1,316 | $0 | $641 | $450 | $632 |
MM Alternative Strategies Fund | $1,287 | $1,205 | $1,310 | $1,345 | $1,354 | $1,309 | $1,234 | $1,292 |
Amount Deferred | $42 | $0 | $266 | $1,345 | $0 | $655 | $458 | $646 |
MM International Equity Strategies Fund | $2,933 | $2,746 | $2,986 | $3,064 | $3,087 | $2,986 | $2,809 | $2,945 |
Amount Deferred | $97 | $0 | $594 | $3,064 | $0 | $1,493 | $1,002 | $1,472 |
MM Small Cap Equity Strategies Fund | $2,005 | $1,878 | $2,042 | $2,096 | $2,109 | $2,039 | $1,923 | $2,014 |
Amount Deferred | $65 | $0 | $417 | $2,096 | $0 | $1,020 | $722 | $1,007 |
MM Total Return Bond Strategies Fund | $9,438 | $8,848 | $9,613 | $9,867 | $9,932 | $9,611 | $9,050 | $9,482 |
Amount Deferred | $309 | $0 | $1,937 | $9,867 | $0 | $4,806 | $3,314 | $4,741 |
Multisector Bond SMA Completion Portfolio | $878 | $822 | $893 | $917 | $923 | $892 | $842 | $882 |
Amount Deferred | $28 | $0 | $183 | $917 | $0 | $446 | $319 | $441 |
Overseas SMA Completion Portfolio | $865 | $810 | $880 | $904 | $909 | $879 | $830 | $869 |
Amount Deferred | $28 | $0 | $181 | $904 | $0 | $440 | $316 | $434 |
Select Mid Cap Growth Fund | $2,398 | $2,244 | $2,437 | $2,503 | $2,518 | $2,432 | $2,307 | $2,410 |
Amount Deferred | $73 | $0 | $523 | $2,503 | $0 | $1,216 | $949 | $1,205 |
Small Cap Growth Fund | $2,835 | $2,652 | $2,878 | $2,958 | $2,974 | $2,868 | $2,736 | $2,852 |
Amount Deferred | $82 | $0 | $644 | $2,958 | $0 | $1,434 | $1,210 | $1,426 |
Strategic Income Fund | $6,187 | $5,794 | $6,298 | $6,466 | $6,510 | $6,297 | $5,930 | $6,213 |
Amount Deferred | $203 | $0 | $1,267 | $6,466 | $0 | $3,148 | $2,166 | $3,106 |
For Funds with fiscal period ending October 31 | ||||||||
CT Intermediate Municipal Bond Fund | $971 | $911 | $979 | $1,010 | $1,023 | $988 | $921 | $967 |
Amount Deferred | $40 | $0 | $150 | $1,010 | $0 | $494 | $173 | $483 |
Intermediate Duration Municipal Bond Fund | $2,520 | $2,363 | $2,543 | $2,623 | $2,663 | $2,576 | $2,382 | $2,509 |
Amount Deferred | $110 | $0 | $348 | $2,623 | $0 | $1,288 | $312 | $1,254 |
MA Intermediate Municipal Bond Fund | $1,061 | $995 | $1,070 | $1,104 | $1,118 | $1,080 | $1,007 | $1,057 |
Amount Deferred | $44 | $0 | $164 | $1,104 | $0 | $540 | $189 | $528 |
NY Intermediate Municipal Bond Fund | $1,064 | $997 | $1,073 | $1,107 | $1,120 | $1,082 | $1,009 | $1,059 |
Amount Deferred | $44 | $0 | $164 | $1,107 | $0 | $541 | $190 | $529 |
Select Global Equity Fund | $1,537 | $1,441 | $1,550 | $1,599 | $1,618 | $1,563 | $1,458 | $1,530 |
Amount Deferred | $63 | $0 | $239 | $1,599 | $0 | $781 | $281 | $765 |
Seligman Global Technology Fund | $2,534 | $2,376 | $2,556 | $2,637 | $2,670 | $2,579 | $2,404 | $2,524 |
Amount Deferred | $104 | $0 | $390 | $2,637 | $0 | $1,289 | $448 | $1,262 |
Strategic CA Municipal Income Fund | $1,435 | $1,346 | $1,448 | $1,493 | $1,512 | $1,460 | $1,362 | $1,430 |
Amount Deferred | $59 | $0 | $224 | $1,493 | $0 | $730 | $265 | $715 |
Strategic NY Municipal Income Fund | $1,054 | $988 | $1,063 | $1,097 | $1,110 | $1,072 | $1,000 | $1,049 |
Statement of Additional Information – April 27, 2023 | 225 |
Fund | Aggregate Compensation from Fund Independent Trustees | |||||||
Batejan(a) | Blatz | Carlton(b) | Carrig(c) | Connaughton | Darragh(d) | Flynn(e) | Gallagher(f) | |
Amount Deferred | $43 | $0 | $163 | $1,097 | $0 | $536 | $188 | $525 |
For Funds with fiscal period ending December 31 | ||||||||
Real Estate Equity Fund | $1,166 | $1,106 | $1,203 | $1,233 | $1,240 | $1,203 | $1,106 | $1,173 |
Amount Deferred | $58 | $0 | $120 | $1,233 | $0 | $601 | $0 | $587 |
(a) | As of January 1, 2022, Mr. Batejan has elected to defer receipt of a portion of his compensation pursuant to the Deferred Compensation Plan. As of March 31, 2023, the value of Mr. Batejan’s account under the Deferred Compensation Plan was $31,098. |
(b) | As of March 31, 2023, the value of Ms. Carlton’s account under the Deferred Compensation Plan was $1,321,347. |
(c) | As of March 31, 2023, the value of Ms. Carrig’s account under the Deferred Compensation Plan was $4,963,739. |
(d) | As of March 31, 2023, the value of Ms. Darragh’s account under the Deferred Compensation Plan was $468,703. |
(e) | As of March 31, 2023, the value of Ms. Flynn’s account under the Deferred Compensation Plan was $3,216,164. |
(f) | As of March 31, 2023, the value of Mr. Gallagher’s account under the Deferred Compensation Plan was $1,012,501. |
Fund | Aggregate Compensation from Fund Independent Trustees | |||||||
Hacker | Lukitsh | Moffett(a) | Paglia(b) | Santomero(c) | Shaw(d) | Trunow(e) | Yeager(f) | |
For Funds with fiscal period ending January 31 | ||||||||
Capital Allocation Aggressive Portfolio | $2,307 | $1,977 | $1,952 | $2,307 | $1,748 | $1,930 | $1,852 | $1,879 |
Amount Deferred | $0 | $0 | $1,952 | $1,154 | $0 | $965 | $1,046 | $940 |
Capital Allocation Conservative Portfolio | $1,211 | $1,038 | $1,025 | $1,211 | $917 | $1,013 | $972 | $986 |
Amount Deferred | $0 | $0 | $1,025 | $606 | $0 | $506 | $549 | $493 |
Capital Allocation Moderate Aggressive Portfolio | $2,899 | $2,485 | $2,454 | $2,899 | $2,199 | $2,426 | $2,328 | $2,362 |
Amount Deferred | $0 | $0 | $2,454 | $1,450 | $0 | $1,213 | $1,314 | $1,181 |
Capital Allocation Moderate Conservative Portfolio | $1,466 | $1,256 | $1,240 | $1,466 | $1,111 | $1,226 | $1,177 | $1,194 |
Amount Deferred | $0 | $0 | $1,240 | $733 | $0 | $613 | $664 | $597 |
Capital Allocation Moderate Portfolio | $2,381 | $2,041 | $2,015 | $2,381 | $1,806 | $1,993 | $1,912 | $1,940 |
Amount Deferred | $0 | $0 | $2,015 | $1,191 | $0 | $996 | $1,079 | $970 |
Income Builder Fund | $2,458 | $2,105 | $2,077 | $2,458 | $1,856 | $2,054 | $1,972 | $2,002 |
Amount Deferred | $0 | $0 | $2,077 | $1,229 | $0 | $1,027 | $1,115 | $1,001 |
For Funds with fiscal period ending February 28/29 | ||||||||
Convertible Securities Fund | $3,297 | $2,836 | $2,786 | $3,297 | $2,337 | $2,762 | $2,662 | $2,700 |
Amount Deferred | $0 | $0 | $2,786 | $1,648 | $0 | $1,381 | $1,544 | $1,350 |
Global Value Fund | $1,896 | $1,626 | $1,596 | $1,896 | $1,322 | $1,583 | $1,526 | $1,549 |
Amount Deferred | $0 | $0 | $1,596 | $948 | $0 | $791 | $889 | $774 |
Large Cap Enhanced Core Fund | $1,408 | $1,208 | $1,186 | $1,408 | $986 | $1,176 | $1,134 | $1,150 |
Amount Deferred | $0 | $0 | $1,186 | $704 | $0 | $588 | $660 | $575 |
Large Cap Growth Opportunity Fund | $2,714 | $2,330 | $2,288 | $2,714 | $1,904 | $2,268 | $2,187 | $2,219 |
Amount Deferred | $0 | $0 | $2,288 | $1,357 | $0 | $1,134 | $1,272 | $1,110 |
Large Cap Index Fund | $4,385 | $3,764 | $3,695 | $4,386 | $3,071 | $3,664 | $3,533 | $3,584 |
Amount Deferred | $0 | $0 | $3,695 | $2,193 | $0 | $1,832 | $2,056 | $1,792 |
Mid Cap Index Fund | $4,028 | $3,463 | $3,400 | $4,028 | $2,843 | $3,372 | $3,250 | $3,295 |
Amount Deferred | $0 | $0 | $3,400 | $2,014 | $0 | $1,686 | $1,887 | $1,648 |
Overseas Core Fund | $1,860 | $1,594 | $1,564 | $1,860 | $1,295 | $1,551 | $1,497 | $1,519 |
Amount Deferred | $0 | $0 | $1,564 | $930 | $0 | $776 | $872 | $759 |
Overseas Value Fund | $3,258 | $2,784 | $2,731 | $3,258 | $2,242 | $2,710 | $2,615 | $2,655 |
Amount Deferred | $0 | $0 | $2,731 | $1,629 | $0 | $1,355 | $1,528 | $1,327 |
Select Large Cap Equity Fund | $2,212 | $1,895 | $1,860 | $2,212 | $1,536 | $1,844 | $1,779 | $1,806 |
Amount Deferred | $0 | $0 | $1,860 | $1,106 | $0 | $922 | $1,038 | $903 |
Select Mid Cap Value Fund | $3,307 | $2,830 | $2,776 | $3,307 | $2,286 | $2,755 | $2,657 | $2,696 |
Amount Deferred | $0 | $0 | $2,776 | $1,654 | $0 | $1,377 | $1,552 | $1,348 |
Small Cap Index Fund | $4,979 | $4,269 | $4,190 | $4,979 | $3,486 | $4,156 | $4,006 | $4,063 |
Amount Deferred | $0 | $0 | $4,190 | $2,489 | $0 | $2,078 | $2,330 | $2,031 |
Small Cap Value Fund II | $2,301 | $1,970 | $1,932 | $2,301 | $1,594 | $1,917 | $1,849 | $1,876 |
Statement of Additional Information – April 27, 2023 | 226 |
Fund | Aggregate Compensation from Fund Independent Trustees | |||||||
Hacker | Lukitsh | Moffett(a) | Paglia(b) | Santomero(c) | Shaw(d) | Trunow(e) | Yeager(f) | |
Amount Deferred | $0 | $0 | $1,932 | $1,151 | $0 | $959 | $1,079 | $938 |
For Funds with fiscal period ending March 31 | ||||||||
Adaptive Retirement 2020 Fund | $998 | $855 | $835 | $998 | $601 | $830 | $805 | $828 |
Amount Deferred | $0 | $0 | $835 | $499 | $0 | $415 | $491 | $414 |
Adaptive Retirement 2025 Fund | $997 | $855 | $835 | $997 | $601 | $830 | $805 | $828 |
Amount Deferred | $0 | $0 | $835 | $499 | $0 | $415 | $491 | $414 |
Adaptive Retirement 2030 Fund | $999 | $856 | $836 | $999 | $602 | $831 | $806 | $829 |
Amount Deferred | $0 | $0 | $836 | $499 | $0 | $416 | $491 | $415 |
Adaptive Retirement 2035 Fund | $998 | $855 | $835 | $998 | $601 | $830 | $805 | $828 |
Amount Deferred | $0 | $0 | $835 | $499 | $0 | $415 | $491 | $414 |
Adaptive Retirement 2040 Fund | $998 | $855 | $835 | $998 | $601 | $830 | $805 | $828 |
Amount Deferred | $0 | $0 | $835 | $499 | $0 | $415 | $491 | $414 |
Adaptive Retirement 2045 Fund | $998 | $855 | $835 | $998 | $601 | $830 | $805 | $828 |
Amount Deferred | $0 | $0 | $835 | $499 | $0 | $415 | $491 | $414 |
Adaptive Retirement 2050 Fund | $998 | $855 | $835 | $998 | $601 | $830 | $805 | $828 |
Amount Deferred | $0 | $0 | $835 | $499 | $0 | $415 | $491 | $414 |
Adaptive Retirement 2055 Fund | $998 | $855 | $835 | $998 | $601 | $830 | $805 | $828 |
Amount Deferred | $0 | $0 | $835 | $499 | $0 | $415 | $491 | $414 |
Adaptive Retirement 2060 Fund | $998 | $855 | $835 | $998 | $601 | $830 | $805 | $828 |
Amount Deferred | $0 | $0 | $835 | $499 | $0 | $415 | $491 | $414 |
MM Growth Strategies Fund | $4,698 | $4,029 | $3,936 | $4,698 | $2,881 | $3,908 | $3,791 | $3,897 |
Amount Deferred | $0 | $0 | $3,936 | $2,349 | $0 | $1,954 | $2,301 | $1,949 |
Short Term Bond Fund | $2,042 | $1,753 | $1,710 | $2,042 | $1,209 | $1,701 | $1,651 | $1,700 |
Amount Deferred | $0 | $0 | $1,710 | $1,021 | $0 | $851 | $1,012 | $850 |
Select Large Cap Growth Fund | $2,879 | $2,461 | $2,405 | $2,879 | $1,778 | $2,388 | $2,314 | $2,377 |
Amount Deferred | $0 | $0 | $2,405 | $1,439 | $0 | $1,194 | $1,400 | $1,189 |
Solutions Aggressive Portfolio | $1,005 | $862 | $841 | $1,005 | $606 | $836 | $811 | $834 |
Amount Deferred | $0 | $0 | $841 | $503 | $0 | $418 | $495 | $417 |
Solutions Conservative Portfolio | $1,007 | $863 | $843 | $1,007 | $607 | $838 | $812 | $836 |
Amount Deferred | $0 | $0 | $843 | $503 | $0 | $419 | $495 | $418 |
For Funds with fiscal period ending April 30 | ||||||||
Bond Fund | $2,033 | $1,733 | $1,682 | $2,073 | $1,142 | $1,717 | $1,647 | $1,746 |
Amount Deferred | $0 | $0 | $1,682 | $1,036 | $0 | $859 | $1,031 | $873 |
CA Intermediate Municipal Bond Fund | $1,402 | $1,195 | $1,159 | $1,430 | $790 | $1,184 | $1,135 | $1,203 |
Amount Deferred | $0 | $0 | $1,159 | $715 | $0 | $592 | $710 | $602 |
Corporate Income Fund | $2,429 | $2,075 | $2,013 | $2,476 | $1,338 | $2,055 | $1,972 | $2,093 |
Amount Deferred | $0 | $0 | $2,013 | $1,238 | $0 | $1,028 | $1,242 | $1,047 |
MM Directional Alternative Strategies Fund | $1,240 | $1,057 | $1,026 | $1,264 | $694 | $1,048 | $1,004 | $1,065 |
Amount Deferred | $0 | $0 | $1,026 | $632 | $0 | $524 | $629 | $533 |
NC Intermediate Municipal Bond Fund | $1,169 | $996 | $967 | $1,192 | $659 | $987 | $946 | $1,004 |
Amount Deferred | $0 | $0 | $967 | $596 | $0 | $494 | $592 | $502 |
SC Intermediate Municipal Bond Fund | $1,103 | $940 | $912 | $1,125 | $621 | $932 | $893 | $947 |
Amount Deferred | $0 | $0 | $912 | $562 | $0 | $466 | $559 | $474 |
Short Duration Municipal Bond Fund | $1,691 | $1,441 | $1,398 | $1,724 | $933 | $1,428 | $1,370 | $1,453 |
Amount Deferred | $0 | $0 | $1,398 | $862 | $0 | $714 | $861 | $727 |
Small Cap Value Fund I | $2,013 | $1,715 | $1,664 | $2,053 | $1,122 | $1,700 | $1,630 | $1,729 |
Amount Deferred | $0 | $0 | $1,664 | $1,027 | $0 | $850 | $1,022 | $865 |
Total Return Bond Fund | $3,887 | $3,309 | $3,203 | $3,958 | $2,032 | $3,274 | $3,147 | $3,343 |
Amount Deferred | $0 | $0 | $3,203 | $1,979 | $0 | $1,637 | $2,003 | $1,671 |
U.S. Treasury Index Fund | $2,329 | $1,989 | $1,931 | $2,376 | $1,311 | $1,971 | $1,889 | $2,004 |
Amount Deferred | $0 | $0 | $1,931 | $1,188 | $0 | $986 | $1,183 | $1,002 |
Statement of Additional Information – April 27, 2023 | 227 |
Statement of Additional Information – April 27, 2023 | 228 |
Fund | Aggregate Compensation from Fund Independent Trustees | |||||||
Hacker | Lukitsh | Moffett(a) | Paglia(b) | Santomero(c) | Shaw(d) | Trunow(e) | Yeager(f) | |
Amount Deferred | $0 | $0 | $1,623 | $980 | $0 | $816 | $1,101 | $847 |
MN Tax-Exempt Fund | $1,727 | $1,505 | $1,427 | $1,727 | $600 | $1,436 | $1,421 | $1,491 |
Amount Deferred | $0 | $0 | $1,427 | $864 | $0 | $718 | $970 | $746 |
OR Intermediate Municipal Bond Fund | $1,329 | $1,158 | $1,098 | $1,329 | $461 | $1,105 | $1,093 | $1,147 |
Amount Deferred | $0 | $0 | $1,098 | $664 | $0 | $552 | $747 | $574 |
Strategic Municipal Income Fund | $3,551 | $3,092 | $2,934 | $3,551 | $1,244 | $2,952 | $2,920 | $3,066 |
Amount Deferred | $0 | $0 | $2,934 | $1,775 | $0 | $1,476 | $1,992 | $1,533 |
Tax-Exempt Fund | $3,840 | $3,347 | $3,176 | $3,840 | $1,347 | $3,193 | $3,161 | $3,316 |
Amount Deferred | $0 | $0 | $3,176 | $1,920 | $0 | $1,597 | $2,155 | $1,658 |
U.S. Social Bond Fund | $1,067 | $930 | $882 | $1,067 | $371 | $887 | $878 | $921 |
Amount Deferred | $0 | $0 | $882 | $534 | $0 | $444 | $599 | $461 |
Ultra Short Term Bond Fund | $4,490 | $3,914 | $3,715 | $4,490 | $1,587 | $3,737 | $3,696 | $3,878 |
Amount Deferred | $0 | $0 | $3,715 | $2,245 | $0 | $1,869 | $2,518 | $1,939 |
For Funds with fiscal period ending August 31 | ||||||||
Balanced Fund | $9,320 | $8,073 | $7,603 | $9,320 | $2,647 | $7,784 | $7,689 | $8,067 |
Amount Deferred | $0 | $0 | $7,603 | $4,660 | $0 | $3,892 | $5,388 | $4,034 |
Contrarian Core Fund | $12,504 | $10,836 | $10,207 | $12,504 | $3,605 | $10,448 | $10,316 | $10,823 |
Amount Deferred | $0 | $0 | $10,207 | $6,252 | $0 | $5,224 | $7,217 | $5,412 |
Emerging Markets Bond Fund | $1,325 | $1,149 | $1,083 | $1,325 | $382 | $1,108 | $1,094 | $1,148 |
Amount Deferred | $0 | $0 | $1,083 | $663 | $0 | $554 | $766 | $574 |
Emerging Markets Fund | $2,914 | $2,529 | $2,388 | $2,914 | $882 | $2,443 | $2,408 | $2,526 |
Amount Deferred | $0 | $0 | $2,388 | $1,457 | $0 | $1,221 | $1,675 | $1,263 |
Global Technology Growth Fund | $3,640 | $3,152 | $2,975 | $3,640 | $1,106 | $3,043 | $3,000 | $3,147 |
Amount Deferred | $0 | $0 | $2,975 | $1,820 | $0 | $1,522 | $2,085 | $1,574 |
Greater China Fund | $1,156 | $1,002 | $945 | $1,156 | $344 | $967 | $954 | $1,000 |
Amount Deferred | $0 | $0 | $945 | $578 | $0 | $483 | $665 | $500 |
International Dividend Income Fund | $1,469 | $1,274 | $1,199 | $1,469 | $418 | $1,228 | $1,213 | $1,273 |
Amount Deferred | $0 | $0 | $1,199 | $735 | $0 | $614 | $850 | $636 |
MM Alternative Strategies Fund | $1,502 | $1,301 | $1,225 | $1,502 | $425 | $1,255 | $1,239 | $1,300 |
Amount Deferred | $0 | $0 | $1,225 | $751 | $0 | $627 | $869 | $650 |
MM International Equity Strategies Fund | $3,429 | $2,966 | $2,790 | $3,429 | $930 | $2,858 | $2,824 | $2,967 |
Amount Deferred | $0 | $0 | $2,790 | $1,714 | $0 | $1,429 | $1,989 | $1,483 |
MM Small Cap Equity Strategies Fund | $2,343 | $2,028 | $1,909 | $2,343 | $671 | $1,955 | $1,931 | $2,025 |
Amount Deferred | $0 | $0 | $1,909 | $1,172 | $0 | $977 | $1,352 | $1,013 |
MM Total Return Bond Strategies Fund | $11,033 | $9,544 | $8,987 | $11,033 | $3,077 | $9,204 | $9,099 | $9,542 |
Amount Deferred | $0 | $0 | $8,987 | $5,516 | $0 | $4,602 | $6,389 | $4,771 |
Multisector Bond SMA Completion Portfolio | $1,024 | $888 | $836 | $1,024 | $296 | $856 | $845 | $887 |
Amount Deferred | $0 | $0 | $836 | $512 | $0 | $428 | $591 | $443 |
Overseas SMA Completion Portfolio | $1,009 | $874 | $824 | $1,009 | $293 | $843 | $833 | $874 |
Amount Deferred | $0 | $0 | $824 | $504 | $0 | $422 | $582 | $437 |
Select Mid Cap Growth Fund | $2,795 | $2,423 | $2,289 | $2,795 | $881 | $2,341 | $2,305 | $2,417 |
Amount Deferred | $0 | $0 | $2,289 | $1,397 | $0 | $1,170 | $1,595 | $1,209 |
Small Cap Growth Fund | $3,292 | $2,863 | $2,713 | $3,292 | $1,123 | $2,771 | $2,723 | $2,853 |
Amount Deferred | $0 | $0 | $2,713 | $1,646 | $0 | $1,385 | $1,865 | $1,426 |
Strategic Income Fund | $7,221 | $6,257 | $5,888 | $7,221 | $2,011 | $6,030 | $5,959 | $6,255 |
Amount Deferred | $0 | $0 | $5,888 | $3,611 | $0 | $3,015 | $4,185 | $3,127 |
For Funds with fiscal period ending October 31 | ||||||||
CT Intermediate Municipal Bond Fund | $1,086 | $973 | $909 | $1,086 | $164 | $941 | $938 | $988 |
Amount Deferred | $0 | $0 | $909 | $543 | $0 | $470 | $694 | $494 |
Intermediate Duration Municipal Bond Fund | $2,834 | $2,526 | $2,353 | $2,834 | $296 | $2,437 | $2,438 | $2,576 |
Amount Deferred | $0 | $0 | $2,353 | $1,417 | $0 | $1,218 | $1,834 | $1,288 |
Statement of Additional Information – April 27, 2023 | 229 |
Fund | Aggregate Compensation from Fund Independent Trustees | |||||||
Hacker | Lukitsh | Moffett(a) | Paglia(b) | Santomero(c) | Shaw(d) | Trunow(e) | Yeager(f) | |
MA Intermediate Municipal Bond Fund | $1,187 | $1,063 | $993 | $1,187 | $179 | $1,028 | $1,025 | $1,080 |
Amount Deferred | $0 | $0 | $993 | $593 | $0 | $514 | $758 | $540 |
NY Intermediate Municipal Bond Fund | $1,190 | $1,066 | $995 | $1,190 | $180 | $1,031 | $1,028 | $1,082 |
Amount Deferred | $0 | $0 | $995 | $595 | $0 | $515 | $760 | $541 |
Select Global Equity Fund | $1,720 | $1,540 | $1,438 | $1,720 | $267 | $1,489 | $1,484 | $1,563 |
Amount Deferred | $0 | $0 | $1,438 | $860 | $0 | $745 | $1,097 | $782 |
Seligman Global Technology Fund | $2,838 | $2,541 | $2,372 | $2,838 | $425 | $2,456 | $2,448 | $2,579 |
Amount Deferred | $0 | $0 | $2,372 | $1,419 | $0 | $1,228 | $1,812 | $1,290 |
Strategic CA Municipal Income Fund | $1,608 | $1,439 | $1,343 | $1,608 | $251 | $1,391 | $1,387 | $1,460 |
Amount Deferred | $0 | $0 | $1,343 | $804 | $0 | $696 | $1,024 | $730 |
Strategic NY Municipal Income Fund | $1,179 | $1,056 | $986 | $1,179 | $178 | $1,021 | $1,018 | $1,072 |
Amount Deferred | $0 | $0 | $986 | $589 | $0 | $510 | $753 | $536 |
For Funds with fiscal period ending December 31 | ||||||||
Real Estate Equity Fund | $1,301 | $1,166 | $1,099 | $1,301 | $0 | $1,136 | $1,143 | $1,203 |
Amount Deferred | $0 | $0 | $1,099 | $650 | $0 | $568 | $892 | $601 |
(a) | As of March 31, 2023, the value of Mr. Moffett’s account under the Deferred Compensation Plan was $3,585,730. |
(b) | As of March 31, 2023, the value of Ms. Paglia’s account under the Deferred Compensation Plan was $5,173,049. |
(c) | As of March 31, 2023, the value of Mr. Santomero’s account under the Deferred Compensation Plan was $152,749. Mr. Santomero served as Trustee until December 31, 2021, and stopped receiving compensation from the Funds and the Columbia Funds Complex as of such date. |
(d) | As of March 31, 2023, the value of Ms. Shaw’s account under the Deferred Compensation Plan was $4,617,218. Ms. Shaw served as Trustee until December 31, 2022, and stopped receiving compensation from the Funds and the Columbia Funds Complex as of such date. |
(e) | As of March 31, 2023, the value of Ms. Trunow’s account under the Deferred Compensation Plan was $1,293,876. |
(f) | As of March 31, 2023, the value of Ms. Yeager’s account under the Deferred Compensation Plan was $1,099,842. |
Statement of Additional Information – April 27, 2023 | 230 |
Statement of Additional Information – April 27, 2023 | 231 |
Statement of Additional Information – April 27, 2023 | 232 |
Statement of Additional Information – April 27, 2023 | 233 |
Total Brokerage Commissions | |||
Fund | 2022 | 2021 | 2020 |
For Funds with fiscal period ending January 31 | |||
Capital Allocation Aggressive Portfolio | $23,866 | $62,262 | $61,664 |
Capital Allocation Conservative Portfolio | 5,336 | 18,717 | 15,310 |
Capital Allocation Moderate Aggressive Portfolio | 29,144 | 194,900 | 165,374 |
Capital Allocation Moderate Conservative Portfolio | 15,751 | 38,413 | 33,551 |
Capital Allocation Moderate Portfolio | 17,137 | 129,590 | 114,518 |
Income Builder Fund | 58,027 | 0 | 0 |
Statement of Additional Information – April 27, 2023 | 234 |
Total Brokerage Commissions | |||
Fund | 2022 | 2021 | 2020 |
For Funds with fiscal period ending February 28/29 | |||
Convertible Securities Fund | $34,331 | $59,652 | $12,162 |
Global Value Fund | 346,742 | 728,357 | 336,171 |
Large Cap Enhanced Core Fund | 176,263 | 254,715 | 285,048 |
Large Cap Growth Opportunity Fund | 632,962 | 356,422 | 313,545 |
Large Cap Index Fund | 64,591 | 94,380 | 90,203 |
Mid Cap Index Fund | 163,782 | 193,481 | 171,187 |
Overseas Core Fund | 953,263 | 589,928 | 262,521 |
Overseas Value Fund | 2,037,201 | 1,437,960 | 1,664,664 |
Select Large Cap Equity Fund | 309,490 | 396,167 | 271,833 |
Select Mid Cap Value Fund | 618,250 | 1,381,175 | 495,282 |
Small Cap Index Fund | 164,596 | 415,881 | 255,499 |
Small Cap Value Fund II | 1,046,623 | 1,403,634 | 830,549 |
For Funds with fiscal period ending March 31 | |||
Adaptive Retirement 2020 Fund | 138 | 403 | 363 |
Adaptive Retirement 2025 Fund | 88 | 179 | 173 |
Adaptive Retirement 2030 Fund | 201 | 75 | 118 |
Adaptive Retirement 2035 Fund | 130 | 52 | 78 |
Adaptive Retirement 2040 Fund | 135 | 50 | 56 |
Adaptive Retirement 2045 Fund | 129 | 38 | 55 |
Adaptive Retirement 2050 Fund | 142 | 51 | 55 |
Adaptive Retirement 2055 Fund | 147 | 37 | 56 |
Adaptive Retirement 2060 Fund | 149 | 39 | 56 |
MM Growth Strategies Fund | 661,924 | 430,008 | 405,033 |
Select Large Cap Growth Fund | 372,676 | 270,209 | 524,341 |
Short Term Bond Fund | 42,360 | 22,551 | 33,085 |
Solutions Aggressive Portfolio | 3,086 | 2,295 | 2,000 |
Solutions Conservative Portfolio | 1,640 | 1,225 | 1,301 |
For Funds with fiscal period ending April 30 | |||
Bond Fund | 93,702 | 33,214 | 21,784 |
CA Intermediate Municipal Bond Fund | 0 | 0 | 0 |
Corporate Income Fund | 82,899 | 54,548 | 74,328 |
MM Directional Alternative Strategies Fund | 593,459 | 454,304 | 423,285 |
NC Intermediate Municipal Bond Fund | 0 | 0 | 0 |
SC Intermediate Municipal Bond Fund | 0 | 0 | 0 |
Short Duration Municipal Bond Fund | 5,378 | 1,377 | 0 |
Small Cap Value Fund I | 1,498,530 | 833,963 | 1,031,945 |
Total Return Bond Fund | 304,703 | 88,241 | 206,857 |
U.S. Treasury Index Fund | 0 | 0 | 0 |
VA Intermediate Municipal Bond Fund | 0 | 0 | 0 |
For Funds with fiscal period ending May 31 | |||
Adaptive Risk Allocation Fund | 993,430 | 652,326 | 978,175 |
Commodity Strategy Fund | 350,792 | 378,693 | 630,687 |
Statement of Additional Information – April 27, 2023 | 235 |
Total Brokerage Commissions | |||
Fund | 2022 | 2021 | 2020 |
Dividend Income Fund | $2,860,537 | $3,148,410 | $3,435,678 |
Dividend Opportunity Fund | 531,661 | 983,559 | 1,012,666 |
Flexible Capital Income Fund | 228,731 | 198,842 | 294,806 |
High Yield Bond Fund | 12,032 | 17,388 | 0 |
High Yield Municipal Fund | 19,821 | 7,666 | 22,075 |
Large Cap Value Fund | 342,806 | 493,218 | 360,772 |
MM Value Strategies Fund | 444,953 | 493,606 | 467,118 |
Mortgage Opportunities Fund | 2,092,123 | 305,106 | 2,022,350 |
Multi Strategy Alternatives Fund | 814,943 | 788,358 | 577,333 |
Quality Income Fund | 203,593 | 96,911 | 286,615 |
Select Large Cap Value Fund | 517,742 | 513,470 | 288,668 |
Select Small Cap Value Fund | 68,755 | 197,169 | 238,106 |
Seligman Technology and Information Fund | 1,287,735 | 3,093,639 | 3,425,563 |
For Funds with fiscal period ending July 31 | |||
Disciplined Core Fund | 735,706 | 1,721,685 | 2,027,287 |
Disciplined Growth Fund | 71,620 | 159,582 | 208,454 |
Disciplined Value Fund | 62,289 | 259,505 | 491,007 |
Floating Rate Fund | 2,000 | 5,502 | 722 |
Global Opportunities Fund | 218,942 | 287,193 | 280,584 |
Government Money Market Fund | 0 | 0 | 0 |
Income Opportunities Fund | 0 | 10,680 | 0 |
Large Cap Growth Fund | 762,728 | 952,462 | 830,737 |
Limited Duration Credit Fund | 40,040 | 48,859 | 41,770 |
MN Tax-Exempt Fund | 21,525 | 10,830 | 636 |
OR Intermediate Municipal Bond Fund | 0 | 0 | 0 |
Strategic Municipal Income Fund | 142,591 | 148,140 | 82,396 |
Tax-Exempt Fund | 79,272 | 44,775 | 15,530 |
U.S. Social Bond Fund | 1,053 | 0 | 451 |
Ultra Short Term Bond Fund | 34,112 | 18,209 | 5,903 |
For Funds with fiscal period ending August 31 | |||
Balanced Fund | 1,855,467 | 1,608,476 | 1,714,703 |
Contrarian Core Fund | 3,640,258 | 3,116,106 | 3,630,303 |
Emerging Markets Bond Fund | 485 | 1,507 | 1,897 |
Emerging Markets Fund | 1,893,295 | 1,095,600 | 894,596 |
Global Technology Growth Fund | 247,291 | 440,234 | 253,132 |
Greater China Fund | 161,247 | 126,127 | 57,030 |
International Dividend Income Fund | 222,990 | 171,501 | 323,907 |
MM Alternative Strategies Fund | 432,169 | 517,898 | 534,594 |
MM International Equity Strategies Fund | 1,264,872 | 1,159,511 | 1,193,180 |
MM Small Cap Equity Strategies Fund | 972,574 | 1,149,005 | 2,282,379 |
MM Total Return Bond Strategies Fund | 335,727 | 307,030 | 380,866 |
Multisector Bond SMA Completion Portfolio | 1,795 | 188 | 205(a) |
Overseas SMA Completion Portfolio | 6,057 | 4,286 | 1,982(b) |
Statement of Additional Information – April 27, 2023 | 236 |
Total Brokerage Commissions | |||
Fund | 2022 | 2021 | 2020 |
Select Mid Cap Growth Fund | $644,507 | $754,019 | $607,000 |
Small Cap Growth Fund | 1,737,514 | 1,477,787 | 923,948 |
Strategic Income Fund | 823,108 | 415,459 | 358,470 |
For Funds with fiscal period ending October 31 | |||
CT Intermediate Municipal Bond Fund | 0 | 0 | 0 |
Intermediate Duration Municipal Bond Fund | 0 | 0 | 0 |
MA Intermediate Municipal Bond Fund | 0 | 0 | 0 |
NY Intermediate Municipal Bond Fund | 0 | 0 | 0 |
Select Global Equity Fund | 259,277 | 141,310 | 218,082 |
Seligman Global Technology Fund | 455,186 | 487,491 | 690,858 |
Strategic CA Municipal Income Fund | 25,632 | 22,312 | 3,082 |
Strategic NY Municipal Income Fund | 6,569 | 5,785 | 1,002 |
For Funds with fiscal period ending December 31 | |||
Real Estate Equity Fund | 85,080 | 21,626 | 79,301 |
(a) | For the period from October 29, 2019 (commencement of operations) to August 31, 2020. |
(b) | For the period from September 12, 2019 (commencement of operations) to August 31, 2020. |
Statement of Additional Information – April 27, 2023 | 237 |
Statement of Additional Information – April 27, 2023 | 238 |
Brokerage directed for research | ||
Fund | Amount of Transactions | Amount of Commissions Imputed or Paid |
For Funds with fiscal period ending January 31 | ||
Capital Allocation Aggressive Portfolio | $0(a) | $0(a) |
Capital Allocation Conservative Portfolio | 0(a) | 0(a) |
Capital Allocation Moderate Aggressive Portfolio | 0(a) | 0(a) |
Capital Allocation Moderate Conservative Portfolio | 0(a) | 0(a) |
Capital Allocation Moderate Portfolio | 0(a) | 0(a) |
Income Builder Fund | 0(a) | 0(a) |
For Funds with fiscal period ending February 28/29 | ||
Convertible Securities Fund | 0 | 0 |
Global Value Fund | 209,156,818 | 60,402 |
Large Cap Enhanced Core Fund | 405,170,528 | 77,921 |
Large Cap Growth Opportunity Fund | 2,062,954,935 | 197,715 |
Large Cap Index Fund | 0 | 0 |
Mid Cap Index Fund | 0 | 0 |
Overseas Core Fund | 319,807,775 | 212,739 |
Overseas Value Fund | 788,633,601 | 483,702 |
Select Large Cap Equity Fund | 652,585,712 | 74,136 |
Select Mid Cap Value Fund | 910,566,338 | 198,498 |
Small Cap Index Fund | 0 | 0 |
Small Cap Value Fund II | 800,858,620 | 351,794 |
Statement of Additional Information – April 27, 2023 | 239 |
Brokerage directed for research | ||
Fund | Amount of Transactions | Amount of Commissions Imputed or Paid |
For Funds with fiscal period ending March 31 | ||
Adaptive Retirement 2020 Fund | $0 | $0 |
Adaptive Retirement 2025 Fund | 0 | 0 |
Adaptive Retirement 2030 Fund | 0 | 0 |
Adaptive Retirement 2035 Fund | 0 | 0 |
Adaptive Retirement 2040 Fund | 0 | 0 |
Adaptive Retirement 2045 Fund | 0 | 0 |
Adaptive Retirement 2050 Fund | 0 | 0 |
Adaptive Retirement 2055 Fund | 0 | 0 |
Adaptive Retirement 2060 Fund | 0 | 0 |
MM Growth Strategies Fund | 4,302,998,367 | 365,575 |
Select Large Cap Growth Fund | 1,287,153,844 | 163,345 |
Short Term Bond Fund | 0 | 0 |
Solutions Aggressive Portfolio | 0 | 0 |
Solutions Conservative Portfolio | 0 | 0 |
For Funds with fiscal period ending April 30 | ||
Bond Fund | 0 | 0 |
CA Intermediate Municipal Bond Fund | 0 | 0 |
Corporate Income Fund | 0 | 0 |
MM Directional Alternative Strategies Fund | 769,870,969 | 169,119 |
NC Intermediate Municipal Bond Fund | 0 | 0 |
SC Intermediate Municipal Bond Fund | 0 | 0 |
Short Duration Municipal Bond Fund | 0 | 0 |
Small Cap Value Fund I | 582,902,980 | 784,479 |
Total Return Bond Fund | 0 | 0 |
U.S. Treasury Index Fund | 0 | 0 |
VA Intermediate Municipal Bond Fund | 0 | 0 |
For Funds with fiscal period ending May 31 | ||
Adaptive Risk Allocation Fund | 161,761,391 | 42,866 |
Commodity Strategy Fund | 0 | 0 |
Dividend Income Fund | 8,875,331,055 | 1,068,857 |
Dividend Opportunity Fund | 776,449,499 | 130,941 |
Flexible Capital Income Fund | 258,790,425 | 58,268 |
High Yield Bond Fund | 0 | 0 |
High Yield Municipal Fund | 0 | 0 |
Large Cap Value Fund | 781,459,105 | 119,419 |
MM Value Strategies Fund | 851,886,039 | 134,319 |
Mortgage Opportunities Fund | 0 | 0 |
Multi Strategy Alternatives Fund | 0 | 0 |
Quality Income Fund | 0 | 0 |
Select Large Cap Value Fund | 483,594,593 | 171,485 |
Select Small Cap Value Fund | 58,817,733 | 27,415 |
Statement of Additional Information – April 27, 2023 | 240 |
Brokerage directed for research | ||
Fund | Amount of Transactions | Amount of Commissions Imputed or Paid |
Seligman Technology and Information Fund | $1,411,207,360 | $305,151 |
For Funds with fiscal period ending July 31 | ||
Disciplined Core Fund | 590,204,458 | 76,890 |
Disciplined Growth Fund | 251,831,660 | 31,989 |
Disciplined Value Fund | 170,656,627 | 29,014 |
Floating Rate Fund | 0 | 0 |
Global Opportunities Fund | 115,569,849 | 30,740 |
Government Money Market Fund | 0 | 0 |
Income Opportunities Fund | 0 | 0 |
Large Cap Growth Fund | 2,105,204,434 | 234,175 |
Limited Duration Credit Fund | 0 | 0 |
MN Tax-Exempt Fund | 0 | 0 |
OR Intermediate Municipal Bond Fund | 0 | 0 |
Strategic Municipal Income Fund | 0 | 0 |
Tax-Exempt Fund | 0 | 0 |
U.S. Social Bond Fund | 0 | 0 |
Ultra Short Term Bond Fund | 0 | 0 |
For Funds with fiscal period ending August 31 | ||
Balanced Fund | 4,661,480,770 | 738,453 |
Contrarian Core Fund | 10,224,114,035 | 1,631,077 |
Emerging Markets Bond Fund | 0 | 0 |
Emerging Markets Fund | 267,706,245 | 346,279 |
Global Technology Growth Fund | 226,939,157 | 69,710 |
Greater China Fund | 56,889,567 | 63,519 |
International Dividend Income Fund | 23,015,880 | 24,908 |
MM Alternative Strategies Fund | 399,131,491 | 167,690 |
MM International Equity Strategies Fund | 51,916,169 | 51,916 |
MM Small Cap Equity Strategies Fund | 852,595,321 | 459,262 |
MM Total Return Bond Strategies Fund | 0 | 0 |
Multisector Bond SMA Completion Portfolio | 0 | 0 |
Overseas SMA Completion Portfolio | 1,821,042 | 1,857 |
Select Mid Cap Growth Fund | 2,106,175,101 | 252,791 |
Small Cap Growth Fund | 2,353,691,528 | 737,689 |
Strategic Income Fund | 0 | 0 |
For Funds with fiscal period ending October 31 | ||
CT Intermediate Municipal Bond Fund | 0 | 0 |
Intermediate Duration Municipal Bond Fund | 0 | 0 |
MA Intermediate Municipal Bond Fund | 0 | 0 |
NY Intermediate Municipal Bond Fund | 0 | 0 |
Select Global Equity Fund | 1,359,247 | 233 |
Seligman Global Technology Fund | 251,009,387 | 107,944 |
Strategic CA Municipal Income Fund | 0 | 0 |
Statement of Additional Information – April 27, 2023 | 241 |
Brokerage directed for research | ||
Fund | Amount of Transactions | Amount of Commissions Imputed or Paid |
Strategic NY Municipal Income Fund | $0 | $0 |
For Funds with fiscal period ending December 31 | ||
Real Estate Equity Fund | 63,681,308 | 18,627 |
(a) | The underlying funds may have directed transactions to firms in exchange for research services. |
Statement of Additional Information – April 27, 2023 | 242 |
Fund | Issuer | Value of securities owned at end of fiscal period |
Select Mid Cap Value Fund | None | N/A |
Small Cap Index Fund | NBT Bancorp, Inc. | $6,709,685 |
Piper Sandler Companies | $8,427,393 | |
Small Cap Value Fund II | Stifel Financial Corp. | $14,459,949 |
For Funds with fiscal period ending March 31, 2022 | ||
Adaptive Retirement 2020 Fund | N/A | N/A |
Adaptive Retirement 2025 Fund | N/A | N/A |
Adaptive Retirement 2030 Fund | N/A | N/A |
Adaptive Retirement 2035 Fund | N/A | N/A |
Adaptive Retirement 2040 Fund | N/A | N/A |
Adaptive Retirement 2045 Fund | N/A | N/A |
Adaptive Retirement 2050 Fund | N/A | N/A |
Adaptive Retirement 2055 Fund | N/A | N/A |
Adaptive Retirement 2060 Fund | N/A | N/A |
MM Growth Strategies Fund | None | N/A |
Select Large Cap Growth Fund | None | N/A |
Short Term Bond Fund | Citigroup, Inc. | $7,784,047 |
Credit Suisse Mortgage Trust | $26,203,459 | |
GS Mortgage-Backed Securities Trust | $1,595,308 | |
JPMorgan Chase & Co. | $11,978,521 | |
JPMorgan Mortgage Trust | $17,932 | |
Morgan Stanley | $8,854,692 | |
Morgan Stanley Capital I Trust | $3,424,546 | |
Morgan Stanley Mortgage Loan Trust | $56,898 | |
PNC Bank NA | $2,503,842 | |
The Goldman Sachs Group, Inc. | $8,823,096 | |
Solutions Aggressive Portfolio | N/A | N/A |
Solutions Conservative Portfolio | N/A | N/A |
For Funds with fiscal period ending April 30, 2022 | ||
Bond Fund | Citigroup Commercial Mortgage Trust | $1,842,718 |
Citigroup, Inc. | $5,588,004 | |
Credit Suisse Mortgage Capital Certificates | $608,989 | |
Credit Suisse Mortgage Capital Certificates OA LLC | $6,018,046 | |
Credit Suisse Mortgage Trust | $3,388,717 | |
GS Mortgage-Backed Securities Corp. Trust | $2,946,342 | |
Jefferies Financial Group, Inc. | $1,199 | |
JPMorgan Chase & Co. | $14,129,024 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $1,494,862 | |
Morgan Stanley | $5,889,871 | |
Morgan Stanley Capital I Trust | $1,107,297 | |
The Goldman Sachs Group, Inc. | $7,414,684 | |
CA Intermediate Municipal Bond Fund | None | N/A |
Corporate Income Fund | Citigroup, Inc. | $27,681,714 |
Goldman Sachs Group | $35,977,389 | |
JPMorgan Chase & Co. | $55,284,407 | |
Morgan Stanley | $29,370,253 |
Statement of Additional Information – April 27, 2023 | 243 |
Fund | Issuer | Value of securities owned at end of fiscal period |
MM Directional Alternative Strategies Fund | Franklin Resources, Inc. | $301,129 |
JPMorgan Chase & Co. | $717,234 | |
The Charles Schwab Corp. | $564,866 | |
The Goldman Sachs Group, Inc. | $421,576 | |
NC Intermediate Municipal Bond Fund | None | N/A |
SC Intermediate Municipal Bond Fund | None | N/A |
Short Duration Municipal Bond Fund | None | N/A |
Small Cap Value Fund I | None | N/A |
Total Return Bond Fund | Citigroup Mortgage Loan Trust, Inc. | $5,320,953 |
Citigroup, Inc. | $18,619,486 | |
Credit Suisse Mortgage Capital Certificates OA LLC | $13,447,832 | |
Credit Suisse Mortgage Trust | $2,240,752 | |
GS Mortgage Securities Trust | $12,438,269 | |
JPMorgan Chase & Co. | $45,940,179 | |
Morgan Stanley | $22,715,565 | |
Morgan Stanley Capital I Trust | $5,609,020 | |
The Goldman Sachs Group, Inc. | $31,673,550 | |
U.S. Treasury Index Fund | None | N/A |
VA Intermediate Municipal Bond Fund | None | N/A |
For Funds with fiscal period ending May 31, 2022 | ||
Adaptive Risk Allocation Fund | None | N/A |
Commodity Strategy Fund | Citigroup Commercial Mortgage Trust | $4,101,279 |
Citigroup, Inc. | $1,601,525 | |
JPMorgan Chase & Co. | $1,627,239 | |
JPMorgan Chase Bank NA | $2,859,703 | |
Morgan Stanley | $1,631,873 | |
PNC Bank NA | $800,179 | |
The Goldman Sachs Group, Inc. | $1,615,404 | |
Dividend Income Fund | JPMorgan Chase & Co. | $1,055,028,129 |
Morgan Stanley | $270,245,988 | |
PNC Financial Services Group, Inc. (The) | $423,929,134 | |
Dividend Opportunity Fund | JPMorgan Chase & Co. | $89,916,400 |
Morgan Stanley & Co. | $45,223,500 | |
PNC Financial Services Group, Inc. (The) | $30,696,750 | |
Flexible Capital Income Fund | Citigroup Capital XIII | $7,737,750 |
JPMorgan Chase & Co. | $15,206,450 | |
Morgan Stanley | $15,935,900 | |
PNC Financial Services Group, Inc. (The) | $14,909,850 | |
High Yield Bond Fund | None | N/A |
High Yield Municipal Fund | None | N/A |
Large Cap Value Fund | JPMorgan Chase & Co. | $78,068,592 |
Morgan Stanley | $48,135,032 | |
PNC Financial Services Group, Inc. (The) | $51,062,026 | |
MM Value Strategies Fund | Citigroup, Inc. | $12,943,540 |
Franklin Resources, Inc. | $2,579,614 | |
Jefferies Financial Group, Inc. | $437,713 | |
JPMorgan Chase & Co. | $99,858,906 | |
Morgan Stanley | $26,897,215 | |
PNC Financial Services Group, Inc. (The) | $22,259,529 | |
The Goldman Sachs Group, Inc. | $19,133,799 |
Statement of Additional Information – April 27, 2023 | 244 |
Fund | Issuer | Value of securities owned at end of fiscal period |
Mortgage Opportunities Fund | Credit Suisse Mortgage Capital Certificates OA LLC | $39,051,905 |
Credit Suisse Mortgage Trust | $33,883,231 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $15,828,649 | |
Morgan Stanley Capital I Trust | $4,929,983 | |
Morgan Stanley Resecuritization Pass-Through Trust | $1,757,500 | |
Multi Strategy Alternatives Fund | Credit Suisse Mortgage Capital Certificates | $4,249,868 |
Credit Suisse Mortgage Trust | $2,258,882 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $1,130,551 | |
Morgan Stanley Capital I Trust | $537,816 | |
Quality Income Fund | Citigroup Mortgage Loan Trust, Inc. | $4,653,776 |
Credit Suisse Mortgage Capital Certificates OA LLC | $15,825,434 | |
JPMorgan Commercial Mortgage Securities Trust | $6,606,380 | |
Morgan Stanley Capital I Trust | $5,036,292 | |
Select Large Cap Value Fund | Citigroup, Inc. | $46,540,139 |
JPMorgan Chase & Co. | $51,050,565 | |
Morgan Stanley | $54,927,774 | |
Select Small Cap Value Fund | None | N/A |
Seligman Technology and Information Fund | None | N/A |
For Funds with fiscal period ending July 31, 2022 | ||
Disciplined Core Fund | Morgan Stanley | $62,068,994 |
Disciplined Growth Fund | None | N/A |
Disciplined Value Fund | Citigroup, Inc. | $979,094 |
Goldman Sachs Group | $1,382,568 | |
JPMorgan Chase & Co. | $304,550 | |
Morgan Stanley | $4,385,708 | |
Floating Rate Fund | None | N/A |
Global Opportunities Fund | Morgan Stanley | $2,205,794 |
PT Bank BTPN Syariah Tbk | $271,930 | |
Government Money Market Fund | None | N/A |
Income Opportunities Fund | None | N/A |
Large Cap Growth Fund | None | N/A |
Limited Duration Credit Fund | JPMorgan Chase & Co. | $26,976,146 |
Morgan Stanley | $25,245,783 | |
MN Tax-Exempt Fund | None | N/A |
OR Intermediate Municipal Bond Fund | None | N/A |
Strategic Municipal Income Fund | None | N/A |
Tax-Exempt Fund | None | N/A |
U.S. Social Bond Fund | Morgan Stanley | $214,636 |
Ultra Short Term Bond Fund | Citigroup, Inc. | $27,845,310 |
JPMorgan Chase & Co. | $25,931,623 | |
Morgan Stanley | $25,999,390 | |
The Goldman Sachs Group, Inc. | $26,139,641 |
Statement of Additional Information – April 27, 2023 | 245 |
Statement of Additional Information – April 27, 2023 | 246 |
Fund | Issuer | Value of securities owned at end of fiscal period |
MM Total Return Bond Strategies Fund | Banc of America Merrill Lynch Commercial Mortgage, Inc. | $2,717,215 |
Citigroup Commercial Mortgage Trust | $25,273,145 | |
Citigroup Mortgage Loan Trust, Inc. | $2,772,652 | |
Citigroup, Inc. | $61,681,959 | |
Credit Suisse AG | $13,945,452 | |
Credit Suisse Group AG | $43,357,605 | |
Credit Suisse Mortgage Capital Certificates OA LLC | $13,198,640 | |
Credit Suisse Mortgage Capital Trust | $6,915,254 | |
Credit Suisse Mortgage Trust | $14,913,051 | |
GS Mortgage Securities Corp. II | $8,377,562 | |
GS Mortgage Securities Trust | $34,648,208 | |
Jefferies Group LLC | $606,843 | |
JPMorgan Alternative Loan Trust | $2,465,072 | |
JPMorgan Chase & Co. | $113,135,983 | |
JPMorgan Chase Bank | $2,081,553 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $22,338,609 | |
JPMorgan Mortgage Acquisition Trust | $1,013,095 | |
JPMorgan Mortgage Trust | $32,425,253 | |
Lehman XS Trust | $1,601,032 | |
Morgan Stanley | $84,875,785 | |
Morgan Stanley Capital I Trust | $8,713,792 | |
Morgan Stanley Resecuritization Trust | $434,751 | |
Raymond James Financial, Inc. (subsidiary) | $1,701,711 | |
Stifel Financial Corp. | $3,403,454 | |
The Charles Schwab Corp. | $5,364,074 | |
The Goldman Sachs Group, Inc. | $62,685,797 | |
Multisector Bond SMA Completion Portfolio | None | N/A |
Overseas SMA Completion Portfolio | None | N/A |
Select Mid Cap Growth Fund | None | N/A |
Small Cap Growth Fund | None | N/A |
Strategic Income Fund | Citigroup Mortgage Loan Trust, Inc. | $3,121,075 |
Citigroup, Inc. | $32,667,860 | |
Credit Suisse Mortgage Capital Certificates OA LLC | $21,014,070 | |
JPMorgan Chase & Co. | $86,830,633 | |
Morgan Stanley | $33,658,840 | |
Morgan Stanley Capital I Trust | $13,552,802 | |
The Goldman Sachs Group, Inc. | $60,202,519 | |
For Funds with fiscal period ending October 31, 2022 | ||
CT Intermediate Municipal Bond Fund | None | N/A |
Intermediate Duration Municipal Bond Fund | None | N/A |
MA Intermediate Municipal Bond Fund | None | N/A |
NY Intermediate Municipal Bond Fund | None | N/A |
Select Global Equity Fund | None | N/A |
Seligman Global Technology Fund | None | N/A |
Strategic CA Municipal Income Fund | None | N/A |
Strategic NY Municipal Income Fund | None | N/A |
Statement of Additional Information – April 27, 2023 | 247 |
Fund | Issuer | Value of securities owned at end of fiscal period |
For Funds with fiscal period ending December 31, 2022 | ||
Real Estate Equity Fund | None | N/A |
Statement of Additional Information – April 27, 2023 | 248 |
Statement of Additional Information – April 27, 2023 | 249 |
Statement of Additional Information – April 27, 2023 | 250 |
■ | 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 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 – April 27, 2023 | 251 |
Statement of Additional Information – April 27, 2023 | 252 |
Identity of Recipient | Conditions/restrictions on use of information | Frequency of Disclosure | ||
Allvue Systems Company | Used for front office trading, bank loan analytics, and compliance. | Daily | ||
Axioma Inc. | Used as a hosted risk analytics platform designed for research, portfolio holdings, investment oversight and strategy development. | Daily | ||
Bank of New York Mellon | Used as the accounting system of record for ETFs. | Daily | ||
BlackRock, Inc. | Used for front office trading and analytics, back office settlements, portfolio accounting and reconciliations, collateral management, portfolio risk oversight, compliance mandate monitoring and portfolio performance calculations. | Daily | ||
Bloomberg Finance L.P. | Used for portfolio analytics, statistical analysis and independent research. Used for executing cleared swaps electronically. Used for executing fixed income trades. Used for evaluating and assessing trading activity, execution and practices in respect of market abuse regulatory requirements. | Daily | ||
Bolger, Inc. | Used for commercial printing. | As Needed | ||
Bond Connect Company Limited | Used for executing Chinese fixed income trades. | Daily | ||
Boston Investors Communications Group, LLC | Used for writing services that require disclosing portfolio holdings in advance of their dissemination to the general public. | As Needed | ||
Capital Markets Services Group | Used for intraday post-trade information when equity exposures (either via futures or options trades) are modified beyond certain limits for certain Funds. | As Needed | ||
Castine LLC | Used for facilitating the evaluation of commission rates and providing flexible commission reporting. | Daily | ||
Catapult ME, Inc. | Used for commercial printing. | As Needed | ||
Citigroup, Inc. | Used for mortgage decision support. | Daily | ||
Compliance Solutions Strategies LLC | Used for reporting returns and analytics to client facing materials. Used for data storage and as a transformation solution to support Enhanced Client Regulatory Reporting and Fund Detail reporting. Used as a form reporting solution to support the Alternative Investment Fund Managers Directive and Money Market Funds Regulation quarterly reporting obligations. Used as a data dissemination service to support the dissemination of industry standard templates to entities authorized by Columbia Threadneedle Investments. | Monthly or Quarterly | ||
Deloitte Haskins & Sells, LLP | Used for calculating foreign capital gains tax accruals irrespective of the tax lot relief method. | Weekly |
Statement of Additional Information – April 27, 2023 | 253 |
Identity of Recipient | Conditions/restrictions on use of information | Frequency of Disclosure | ||
Donnelley Financial Solutions | Used for providing EDGAR filing and typesetting services, and printing of prospectuses, factsheets, annual and semi-annual reports. | As Needed | ||
DS Graphics, Inc. | Used for printing of prospectuses, factsheets, annual and semi-annual reports. | As Needed | ||
Depository Trust & Clearing Corporation | Used for providing trade allocation and acceptance services. | Daily | ||
Elevation Exhibits & Events | Used for trade show exhibits. | As Needed | ||
Equifax, Inc. | Used for ensuring Columbia Management does not violate the Office of Foreign Assets Control sanction requirements. | Daily | ||
Ernst & Young, LLP | Used for analyzing passive foreign investment company investments. | Monthly | ||
FactSet Research Systems, Inc. | Used for calculating portfolio performance attribution, portfolio analytics, data for fundamental research, and general market news and analysis. Used for executing equity and convertible trades. | Daily | ||
Fidelity National Information Services, Inc. | Used as a portfolio accounting system. | Daily | ||
Harte-Hanks, Inc. | Used for printing of prospectuses, factsheets, annual and semi-annual reports. | As Needed | ||
ICE Data Indices, LLC | Used for calculation and dissemination of ETF intraday indicative values. | Daily | ||
IHS Markit, Ltd. | Used as an asset database for analytics and investor reporting. | As Needed | ||
Institutional Shareholder Services Inc. | Used for proxy voting administration and research on proxy matters. | Daily | ||
Intex Solutions Inc. | Used for providing mortgage analytics. | As Needed | ||
Investment Company Institute | Disclosure of Form N-PORT data. | As Needed | ||
Investortools, Inc. | Used for municipal bond analytics, research, and decision support. | As Needed | ||
JDP Marketing Services | Used for writing Columbia Funds shareholder reports, quarterly fund commentaries and communications, including shareholder letters and management’s discussion of Columbia Funds’ performance. | As Needed | ||
John Roberts, Inc. | Used for commercial printing. | As Needed | ||
Kessler Topaz Meltzer & Check, LLP | Used for monitoring eligibility to participate in global litigation matters. | Monthly | ||
Kynex, Inc. | Used for providing portfolio attribution reports for Convertible Securities Fund. Used for portfolio analytics. | Daily | ||
MarketAxess | Use for executing fixed income trades | Daily | ||
Merrill Corporation | Used for printing of prospectuses, factsheets, annual and semi-annual reports. | As Needed | ||
Morningstar Investment Services, LLC | Used for independent research and ranking of funds. Used for statistical analysis. | As Needed |
Statement of Additional Information – April 27, 2023 | 254 |
Identity of Recipient | Conditions/restrictions on use of information | Frequency of Disclosure | ||
R. R. Donnelley & Sons Co. | Used for printing of prospectuses, factsheets, annual and semi-annual reports. Used for commercial printing. | As Needed | ||
Refinitiv | Used for executing foreign currency exchange orders. Used for executing fixed income trades. | Daily | ||
RegEd, Inc. | Used for reviewing external and certain internal communications prior to dissemination. | Daily | ||
SIX Group Services Ltd. | Used as a trade repository authorized by the Swiss regulator to submit holdings supporting the SIX Financial Market Infrastructure Act derivative reporting requirement. | Daily | ||
Sky Road LLC | Used for front office bank loan portfolio management and trading optimization. | Daily | ||
Sustainalytics US, Inc. | Used for: 1) validating the social impact score the Columbia Management analysts assign to each municipal investment and 2) providing ESG risk ratings and other related information for each corporate bond issuer. | Quarterly | ||
S.W.I.F.T. Scrl. | Used for sending trade messages via SWIFT to custodian. | Daily | ||
Taylor Impressions | Used for commercial printing. | As Needed | ||
TC ICAP | Used for executing equity and fixed income trades. | Daily | ||
Thomson Reuters Corp. | Used for statistical analysis. | As Needed | ||
Trepp, Inc. | Used for insights about commercial mortgage-backed securities mortgage bonds. | Daily | ||
Trumid Holdings, LLC | Used for executing fixed income trades. | Daily | ||
Virtu Financial | Used for executing equity trades. | Daily | ||
Visions, Inc. | Used for commercial printing. | As Needed | ||
Wilshire Associates, Inc. | Used for providing performance attribution reporting. | Daily |
Statement of Additional Information – April 27, 2023 | 255 |
Identity of Recipient | Conditions/restrictions on use of information | Frequency of Disclosure | ||
Ashland Partners & Co. LLP | Used by certain subadvisers for audit and Global Investment Performance Standards (GIPS) evaluation. | Annually | ||
Axioma, Inc. | Used by certain subadvisers for third-party risk enhancement and management. Used by certain subadvisers for Derivatives Rule (Rule 18f-4) analysis. | Daily | ||
BlackRock, Inc. | Used by certain subadvisers for order management and compliance. Used by certain subadvisers for analytical and statistical information. | Daily | ||
Bloomberg Finance L.P. | Used by certain subadvisers for analytical, portfolio management, statistical information, compliance and personal trade monitoring. | Daily or Annually | ||
BNY Mellon Corp. | Used by certain subadvisers for SWIFT messages from custodians to facilitate automated reconciliation. | Daily | ||
Brown Brothers Harriman & Co. | Used by certain subadvisers for electronic trade transmission and settlement. Used by certain subadvisers for corporate actions management. | Daily | ||
Castine LLC | Used by certain subadvisers for commission tracking. | Daily | ||
Citibank N.A. | Used by certain subadvisers for middle office functions. | Daily | ||
Compliance Solutions Strategies LLC | Used by certain subadvisers for back up of operational and reconciliation services. | Monthly | ||
ConsenSys Inc. | Used by certain subadvisers for commission tracking. | Daily | ||
Depository Trust & Clearing Corporation | Used by certain subadvisers for trade execution and SWIFT transactions. Used by certain subadvisers for trade monitoring, trade settlement, and for confirming TBAs. | Daily or Monthly | ||
Eagle Investment Systems, LLC | Used by certain subadvisers for portfolio accounting systems. | Daily | ||
Eze Castle Software LLC | Used by certain subadvisers for order management and compliance. | Daily | ||
FactSet Research Systems, Inc. | Used by certain subadvisers for analytical and statistical information. | Daily | ||
Financial Recovery Technologies Services | Used by certain subadvisers for class action monitoring services. | Quarterly | ||
FIS Brokerage Securities Services LLC | Used by certain subadvisers for confirmation and settlement of bank loan trades. | Daily | ||
FIS Protegent PTA | Used by certain subadvisers for code of ethics monitoring. | Daily | ||
Flextrade Systems Inc. | Used by certain subadvisers for an execution management system. | Daily | ||
FX Connect, LLC | Used by certain subadvisers for foreign exchange derivatives reconciliation. | Daily |
Statement of Additional Information – April 27, 2023 | 256 |
Identity of Recipient | Conditions/restrictions on use of information | Frequency of Disclosure | ||
Generic Network Systems | Used by certain subadvisers to provide server and application managed services related to optimizing the server structure. | Daily | ||
Global Trading Analytics, LLC | Used by certain subadvisers for transaction cost analysis and other analytics. | Daily | ||
Gresham Technologies plc | Used by certain subadvisers for electronic reconciliations of portfolio holdings. | Daily or Monthly | ||
ICE Data Services Inc. | Used by certain subadvisers for data and pricing. Used by certain subadvisers for liquidity reporting. | Daily | ||
IHS Markit Ltd. | Used by certain subadvisers for confirmation and settlement of bank loan trades. | Daily | ||
Infinit-O Global, Ltd. | Used by certain subadvisers for portfolio accounting systems. | Daily | ||
Instinet Holdings Incorporated | Used by certain subadvisers for an execution management system. | Daily | ||
Institutional Shareholder Services, Inc. | Used by certain subadvisers for proxy voting administration and research services. | Daily | ||
Narrative Science Inc. | Used by certain subadvisers for updating attribution commentary. | Monthly | ||
NAV Consulting, Inc. | Used by certain subadvisers for reconciliation services. | Daily | ||
Nex Group plc | Used by certain subadvisers for daily reconciliations on collateral management. | Daily | ||
Northern Trust Co. | Used by certain subadvisers for back-office operations. | Daily | ||
Portfolio BI, Inc. | Used by certain subadvisers for client reporting. | Daily | ||
Refinitiv | Used by certain subadvisers for analytical and statistical information. | Daily | ||
RELX Group | Used by certain subadvisers for compliance services. | Weekly | ||
Simcorp Dimension | Used by certain subadvisers for portfolio accounting systems. | Daily | ||
SS&C Technologies, Inc. | Used by certain subadvisers for portfolio accounting systems. Used by certain subadvisers for SWIFT messages from custodians to facilitate automated reconciliation. Used by certain subadvisers for analytical, portfolio management, and statistical information. | Daily | ||
State Street Bank and Trust Company | Used by certain subadvisers for middle office functions. | Daily or Monthly | ||
State Street Corp. | Used by certain subadvisers for order management and compliance. Used by certain subadvisers for trading. | Daily or As Needed | ||
Trade Informatics LLC | Used by certain subadvisers for transaction cost analysis and other analytics. | Daily |
Statement of Additional Information – April 27, 2023 | 257 |
Identity of Recipient | Conditions/restrictions on use of information | Frequency of Disclosure | ||
Tradeweb Markets LLC | Used by certain subadvisers for confirming TBAs, treasuries, and discount notes. | Daily | ||
VERMEG Co. | Used by certain subadvisers for management of swap counterparty exposure. | Daily | ||
Virtu Financial, Inc. | Used by certain subadvisers for transaction cost analysis and other analytics. | Daily |
Statement of Additional Information – April 27, 2023 | 258 |
* | Ameriprise Financial affiliate |
Statement of Additional Information – April 27, 2023 | 259 |
* | Ameriprise Financial affiliate |
Statement of Additional Information – April 27, 2023 | 260 |
Statement of Additional Information – April 27, 2023 | 261 |
Statement of Additional Information – April 27, 2023 | 262 |
Statement of Additional Information – April 27, 2023 | 263 |
Statement of Additional Information – April 27, 2023 | 264 |
Statement of Additional Information – April 27, 2023 | 265 |
Statement of Additional Information – April 27, 2023 | 266 |
Statement of Additional Information – April 27, 2023 | 267 |
Statement of Additional Information – April 27, 2023 | 268 |
Statement of Additional Information – April 27, 2023 | 269 |
Fund | Total Capital Loss Carryovers |
Amount not Expiring | |
Short-term | Long-term | ||
For Funds with fiscal period ending February 28/29 | |||
Global Value Fund | $52,761,717 | $7,307,726 | $45,453,991 |
Overseas Value Fund | $274,747,450 | $0 | $274,747,450 |
For Funds with fiscal period ending March 31 | |||
Short Term Bond Fund | $6,984,392 | $3,699,544 | $3,284,848 |
For Funds with fiscal period ending April 30 | |||
Bond Fund | $64,857,044 | $33,282,749 | $31,574,295 |
CA Intermediate Municipal Bond Fund | $4,696,124 | $4,558,845 | $137,279 |
NC Intermediate Municipal Bond Fund | $1,528,681 | $528,605 | $1,000,076 |
SC Intermediate Municipal Bond Fund | $1,064,208 | $536,199 | $528,009 |
Short Duration Municipal Bond Fund | $5,851,962 | $4,735,491 | $1,116,471 |
Small Cap Value Fund I | $7,021,227 | $7,021,227 | $0 |
Total Return Bond Fund | $175,720,066 | $91,843,703 | $83,876,363 |
For Funds with fiscal period ending May 31 | |||
Commodity Strategy Fund | $944,216 | $944,216 | $0 |
High Yield Bond Fund | $2,476,724 | $2,476,724 | $0 |
High Yield Municipal Fund | $7,393,456 | $2,409,939 | $4,983,517 |
Mortgage Opportunities Fund | $157,308,692 | $41,513,836 | $115,794,856 |
Multi Strategy Alternatives Fund | $54,307,065 | $39,650,304 | $14,656,761 |
Quality Income Fund | $113,116,689 | $61,613,303 | $51,503,386 |
Statement of Additional Information – April 27, 2023 | 270 |
Statement of Additional Information – April 27, 2023 | 271 |
Statement of Additional Information – April 27, 2023 | 272 |
Statement of Additional Information – April 27, 2023 | 273 |
Statement of Additional Information – April 27, 2023 | 274 |
Statement of Additional Information – April 27, 2023 | 275 |
Statement of Additional Information – April 27, 2023 | 276 |
Statement of Additional Information – April 27, 2023 | 277 |
Statement of Additional Information – April 27, 2023 | 278 |
Statement of Additional Information – April 27, 2023 | 279 |
Statement of Additional Information – April 27, 2023 | 280 |
Statement of Additional Information – April 27, 2023 | 281 |
Statement of Additional Information – April 27, 2023 | 282 |
Statement of Additional Information – April 27, 2023 | 283 |
Statement of Additional Information – April 27, 2023 | 284 |
Statement of Additional Information – April 27, 2023 | 285 |
Statement of Additional Information – April 27, 2023 | 286 |
Statement of Additional Information – April 27, 2023 | 287 |
Fund | Class | Percentage of Class Beneficially Owned |
Adaptive Retirement 2030 Fund | Class Adv | 93.77% |
Adaptive Retirement 2035 Fund | Class Adv | 30.52% |
Adaptive Risk Allocation Fund | Class Inst2 | 1.78% |
Flexible Capital Income Fund | Class Inst2 | 1.26% |
Floating Rate Fund | Class Inst2 | 7.05% |
Overseas Core Fund | Class Inst2 | 24.05% |
Select Large Cap Growth Fund | Class Inst2 | 2.30% |
Select Large Cap Value Fund | Class Inst2 | 1.06% |
Select Mid Cap Value Fund | Class Inst2 | 1.16% |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
Capital Allocation Aggressive Portfolio | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 75.76% | 68.45% |
Class C | 81.62% | |||
Class Inst | 25.24% | |||
CHARLES SCHWAB & CO INC CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 16.03% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Inst | 9.80% | N/A | |
MATRIX TRUST CO CUST FBO PO BOX 52129 PHOENIX AZ 85072-2129 |
Class Adv | 20.97% | N/A | |
Class Inst2 | 11.44% | |||
Class Inst3 | 80.59% | |||
Class R | 79.97% | |||
MERRILL LYNCH, PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF ITS CUSTOMERS 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 9.17% | N/A | |
Class Adv | 53.05% | |||
Class Inst | 25.81% |
Statement of Additional Information – April 27, 2023 | 288 |
Statement of Additional Information – April 27, 2023 | 289 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 15.18% | N/A | |
Class Inst2 | 8.58% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class Inst | 20.84% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 13.92% | N/A | |
Capital Allocation Moderate Aggressive Portfolio | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 62.24% | 54.86% |
Class C | 86.18% | |||
Class Inst | 10.91% | |||
CHARLES SCHWAB & CO INC CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst | 5.39% | N/A | |
Class Inst2 | 16.33% | |||
CHARLES SCHWAB BANK CUST WOODRIDGE CLINIC SC PS & 401K PLAN 2423 E LINCOLN DR PHOENIX AZ 85016-1215 |
Class R | 6.43% | N/A | |
GREAT-WEST TRUST COMPANY LLC TTEE F EMPLOYEE BENEFITS CLIENTS 401K 8515 E ORCHARD GREENWOOD VLG CO 80111-5002 |
Class Inst2 | 11.32% | N/A | |
Class Inst3 | 5.49% | |||
MATRIX TRUST CO CUST FBO PO BOX 52129 PHOENIX AZ 85072-2129 |
Class Adv | 16.74% | N/A | |
Class Inst3 | 73.48% | |||
Class R | 44.40% | |||
MERRILL LYNCH PIERCE FENNER & SMITH INC MUTUAL FUNDS OPERATIONS 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A | 12.02% | N/A | |
Class Adv | 35.52% | |||
Class Inst | 13.52% | |||
Class Inst3 | 5.02% | |||
Class V | 12.80% | |||
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class Inst2 | 27.43% | N/A | |
Class Inst3 | 10.17% | |||
MITRA & CO FBO C/O RELIANCE TRUST COMPANY WI 4900 WEST BROWN DEER ROAD MAILCODE: BD1N – ATTN: MF MILWAUKEE WI 53223-2422 |
Class R | 40.05% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 23.34% | N/A | |
Class Inst2 | 11.10% | |||
NEAR NORTH HEALTH SERVICE CORPORATION 1276 N CLYBOURN AVE CHICAGO IL 60610-2003 |
Class Adv | 9.82% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 11.43% | N/A | |
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class Inst | 7.63% | N/A |
Statement of Additional Information – April 27, 2023 | 290 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 25.17% | N/A | |
Capital Allocation Moderate Conservative Portfolio | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 82.64% | 77.84% |
Class C | 83.30% | |||
Class Inst | 32.29% | |||
C/O MISSIONSQUARE RETIREMENT ST PETERSBURG POLICE DROP PO BOX 2842 ST PETERSBURG FL 33731-2842 |
Class Adv | 16.14% | N/A | |
GREAT-WEST TRUST COMPANY LLC TTEE F EMPLOYEE BENEFITS CLIENTS 401K 8515 E ORCHARD GREENWOOD VLG CO 80111-5002 |
Class Inst2 | 8.99% | N/A | |
Class Inst3 | 8.02% | |||
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Inst | 11.33% | N/A | |
MATRIX TRUST COMPANY CUST. FBO LIFETIME CARE 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class R | 10.67% | N/A | |
MERRILL LYNCH, PIERCE, FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DRIVE EAST 3RD FLOOR JACKSONVILLE FL 32246-6484 |
Class A | 6.82% | N/A | |
Class Inst | 10.01% | |||
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class Inst2 | 8.94% | N/A | |
Class Inst3 | 32.96% | |||
Class R | 26.10% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 35.01% | N/A | |
Class Inst2 | 68.89% | |||
PAI TRUST COMPANY, INC. COMPANION ANIMAL HOSPITAL OF INDIAN 1300 ENTERPRISE DR DE PERE WI 54115-4934 |
Class R | 58.26% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 41.48% | N/A | |
PIMS/PRUDENTIAL RETIREMENT AS NOMINEE FOR THE TTEE EVANGELICAL COMMUNITY HOSPITAL 1 HOSPITAL DR LEWISBURG PA 17837-9350 |
Class Inst3 | 57.69% | N/A | |
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class Inst | 5.09% | N/A | |
STATE STREET BANK AND TRUST AS TRUSTEE AND/OR CUSTODIAN FBO ADP ACCESS PRODUCT 1 LINCOLN ST BOSTON MA 02111-2901 |
Class Inst | 6.67% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 5.04% | N/A |
Statement of Additional Information – April 27, 2023 | 291 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
Capital Allocation Moderate Portfolio | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 89.28% | 84.55% |
Class C | 89.11% | |||
Class Inst | 45.26% | |||
ASCENSUS TRUST COMPANY FBO PO BOX 10758 FARGO ND 58106-0758 |
Class R | 9.07% | N/A | |
CHARLES SCHWAB & CO INC CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class R | 9.86% | N/A | |
GREAT-WEST TRUST COMPANY LLC TTEE F EMPLOYEE BENEFITS CLIENTS 401K 8515 E ORCHARD GREENWOOD VLG CO 80111-5002 |
Class Inst2 | 21.85% | N/A | |
Class Inst3 | 8.82% | |||
HOSSLEY LIGHTING ASSOCIATES LLC 1202 DRAGON ST STE 100 DALLAS TX 75207-4021 |
Class Adv | 45.18% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Inst | 5.13% | N/A | |
MATRIX TRUST CO CUST FBO PHX-ONEAMERICA (WI OFFICE) PO BOX 52129 PHOENIX AZ 85072-2129 |
Class Inst3 | 66.16% | N/A | |
Class R | 58.87% | |||
MERRILL LYNCH, PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF ITS CUSTOMERS 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class Adv | 6.38% | N/A | |
Class Inst | 18.75% | |||
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class Inst3 | 22.24% | N/A | |
Class R | 12.92% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 6.53% | N/A | |
Class Inst2 | 38.55% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 35.79% | N/A | |
Class Inst2 | 6.57% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class Inst | 10.44% | N/A | |
STATE STREET BANK AND TRUST AS TRUSTEE AND/OR CUSTODIAN FBO ADP ACCESS PRODUCT 1 LINCOLN ST BOSTON MA 02111-2901 |
Class Inst2 | 6.49% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 17.76% | N/A | |
UBS WM USA SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class Inst | 6.99% | N/A |
Statement of Additional Information – April 27, 2023 | 292 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class Inst | 6.01% | N/A | |
Income Builder Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 72.22% | 59.93% |
Class C | 54.37% | |||
Class Inst | 52.15% | |||
CHARLES SCHWAB & CO INC CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 13.89% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 86.00% | N/A | |
FIIOC FBO 100 MAGELLAN WAY # KW1C COVINGTON KY 41015-1987 |
Class R | 7.06% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 7.26% | N/A | |
Class Inst | 7.36% | |||
MERRILL LYNCH, PIERCE, FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DRIVE EAST 3RD FLOOR JACKSONVILLE FL 32246-6484 |
Class Adv | 5.76% | N/A | |
Class Inst | 5.65% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 12 NEW YORK NY 10004-1932 |
Class Inst | 8.58% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 6.02% | N/A | |
Class Adv | 39.40% | |||
Class Inst2 | 57.98% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 41.07% | N/A | |
Class Inst2 | 18.44% | |||
PIMS/PRUDENTIAL RETIREMENT AS NOMINEE FOR THE TTEE 2100 PONTIAC LAKE ROAD WATERFORD MI 48328-2762 |
Class Adv | 9.50% | N/A | |
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 5.00% | N/A | |
Class Inst | 9.97% | |||
SAMMONS FINANCIAL NETWORK LLC 4546 CORPORATE DR STE 100 WEST DES MOINES IA 50266-5911 |
Class R | 88.17% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 10.61% | N/A | |
Class Inst | 9.00% |
Statement of Additional Information – April 27, 2023 | 293 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
Convertible Securities Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 22.57% | N/A |
Class C | 18.81% | |||
Class Inst | 28.28% | |||
ASCENSUS TRUST COMPANY FBO PO BOX 10758 FARGO ND 58106-0758 |
Class R | 40.86% | N/A | |
SEI PRIVATE TRUST COMPANY C/O MOODY 1 FREEDOM VALLEY DR OAKS PA 19456-9989 |
Class Inst2 | 9.69% | N/A | |
CAPITAL BANK & TRUST CO FBO C/O FASCORE 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 12.94% | N/A | |
CHARLES SCHWAB & CO INC & REINVEST ACCOUNT ATTN MUTUAL FUND DEPARTMENT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 6.10% | N/A | |
Class Inst2 | 16.39% | |||
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 37.09% | N/A | |
J P MORGAN SECURITIES LLC OMNIBUS ACCOUNT FOR THE EXCLUSIVE BENEFIT OF CUSTOMERS 4 CHASE METROTECH CENTER 3RD FL MUTUAL FUND DEPARTMENT BROOKLYN NY 11245-0003 |
Class Inst3 | 10.03% | N/A | |
JPMCB NA CUST FOR COLUMBIA INCOME BUILDER FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 26.14% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 8.85% | N/A | |
Class Inst | 7.17% | |||
MATRIX TRUST COMPANY CUST. FBO G/B MARKETING, INC. PROFIT SHARING 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class R | 7.20% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH 2029 CENTURY PARK E STE 2800 CENTURY CITY CA 90067-3014 |
Class A | 26.36% | N/A | |
Class C | 9.86% | |||
Class Inst | 15.93% | |||
Class R | 5.21% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 12 NEW YORK NY 10004-1932 |
Class C | 11.50% | N/A | |
Class Inst | 14.74% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 11.08% | N/A | |
Class Adv | 24.27% | |||
Class C | 5.09% | |||
Class Inst2 | 37.39% | |||
Class Inst3 | 16.35% | |||
NATIONWIDE TRUST COMPANY FSB C/O IPO PORTFOLIO ACCOUNTING PO BOX 182029 COLUMBUS OH 43218-2029 |
Class Inst2 | 5.90% | N/A |
Statement of Additional Information – April 27, 2023 | 294 |
Statement of Additional Information – April 27, 2023 | 295 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
MATRIX TRUST COMPANY CUST. FBO G/B MARKETING, INC. PROFIT SHARING 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class Adv | 8.83% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH 2029 CENTURY PARK E STE 2800 CENTURY CITY CA 90067-3014 |
Class A | 6.07% | N/A | |
Class Adv | 15.97% | |||
Class Inst | 6.66% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 5.09% | N/A | |
Class Adv | 18.03% | |||
Class Inst | 5.96% | |||
Class Inst2 | 58.37% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 42.14% | N/A | |
Class C | 9.09% | |||
STATE STREET CORPORATION 1 LINCOLN ST BOSTON MA 02111-2901 |
Class R | 18.71% | N/A | |
THE HARTFORD 1 HARTFORD PLZ HARTFORD CT 06155-0001 |
Class Inst3 | 11.88% | N/A | |
Class R | 15.18% | |||
WELLS FARGO CLEARING SERVICES 1 N JEFFERSON AVE SAINT LOUIS MO 63103-2287 |
Class C | 11.96% | N/A | |
Large Cap Enhanced Core Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 33.06% | N/A |
Class Inst | 15.58% | |||
CHARLES SCHWAB & CO INC & REINVEST ACCOUNT ATTN MUTUAL FUND DEPARTMENT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 10.45% | N/A | |
JOHN HANCOCK TRUST COMPANY LLC 690 CANTON ST STE 100 WESTWOOD MA 02090-2324 |
Class Adv | 12.12% | N/A | |
JPMCB NA CUST FOR COLUMBIA THERMOSTAT FUND 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class Inst3 | 29.40% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Inst | 11.73% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH 2029 CENTURY PARK E STE 2800 CENTURY CITY CA 90067-3014 |
Class A | 21.66% | 25.77% | |
Class Inst | 12.26% | |||
Class Inst3 | 38.97% | |||
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class Inst2 | 6.16% | N/A | |
Class R | 78.81% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 5.95% | N/A | |
Class Adv | 70.47% | |||
Class Inst | 11.33% | |||
Class Inst2 | 44.14% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 10.18% | N/A | |
Class Inst2 | 17.91% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class Inst | 10.70% | N/A |
Statement of Additional Information – April 27, 2023 | 296 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
RELIANCE TRUST CO CUST ADP ACCESS LARGE MARKET 401K PLAN 201 17TH ST NW STE 1000 ATLANTA GA 30363-1195 |
Class Inst3 | 6.04% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 7.43% | N/A | |
UBS WM USA SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class Inst | 5.83% | N/A | |
VANGUARD FIDUCIARY TRUST CO PO BOX 2600 VM 613 ATTN: OUTSIDE FUNDS VALLEY FORGE PA 19482-2600 |
Class Inst3 | 6.51% | N/A | |
Large Cap Growth Opportunity Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 5.85% | N/A |
Class C | 7.27% | |||
Class Inst | 13.44% | |||
ASCENSUS TRUST COMPANY FBO PO BOX 10758 FARGO ND 58106-0758 |
Class R | 8.11% | N/A | |
CHARLES SCHWAB & CO INC & REINVEST ACCOUNT ATTN MUTUAL FUND DEPARTMENT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 34.59% | N/A | |
FIIOC FBO 100 MAGELLAN WAY #KW1C COVINGTON KY 41015-1987 |
Class Adv | 8.70% | N/A | |
Class Inst2 | 8.12% | |||
GREAT-WEST TRUST COMPANY LLC FBO EMPOWER BENEFIT PLANS 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 8.51% | N/A | |
J P MORGAN SECURITIES LLC OMNIBUS ACCOUNT FOR THE EXCLUSIVE BENEFIT OF CUSTOMERS 4 CHASE METROTECH CENTER 3RD FL MUTUAL FUND DEPARTMENT BROOKLYN NY 11245-0003 |
Class Inst3 | 17.71% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class A | 5.64% | N/A | |
Class C | 13.18% | |||
Class Inst | 9.06% | |||
MATRIX TRUST COMPANY CUST. FBO G/B MARKETING, INC. PROFIT SHARING 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class Inst2 | 6.90% | N/A | |
Class R | 12.92% | |||
MERRILL LYNCH PIERCE FENNER & SMITH 2029 CENTURY PARK E STE 2800 CENTURY CITY CA 90067-3014 |
Class A | 31.18% | 25.55% | |
Class Inst | 16.07% | |||
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class R | 6.81% | N/A | |
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 12 NEW YORK NY 10004-1932 |
Class A | 8.08% | N/A | |
Class C | 7.02% | |||
Class Inst | 8.99% |
Statement of Additional Information – April 27, 2023 | 297 |
Statement of Additional Information – April 27, 2023 | 298 |
Statement of Additional Information – April 27, 2023 | 299 |
Statement of Additional Information – April 27, 2023 | 300 |
Statement of Additional Information – April 27, 2023 | 301 |
Statement of Additional Information – April 27, 2023 | 302 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
CHAIR OF THE BRD OF TRUSTEES OF TN CONSLDTD RET SYS & THE COMM OF FINA C/O FASCORE LLC FBO 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class Adv | 62.44% | N/A | |
CHARLES SCHWAB & CO INC & REINVEST ACCOUNT ATTN MUTUAL FUND DEPARTMENT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst | 10.06% | N/A | |
Class Inst2 | 25.11% | |||
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class A | 5.03% | N/A | |
Class I3 | 31.67% | |||
GREAT WEST LIFE & ANNUITY FUTURE FD C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 11.32% | N/A | |
GREAT-WEST TRUST COMPANY LLC FBO EMPOWER BENEFIT PLANS 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 13.09% | N/A | |
ING FUND OPERATIONS TTEE FBO ING LIFE INSURANCE & ANNUITY CO 1 ORANGE WAY WINDSOR CT 06095-4773 |
Class I3 | 6.47% | N/A | |
JPMCB NA CUST FOR COLUMBIA THERMOSTAT FUND 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class I3 | 9.42% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 7.51% | N/A | |
MAILCODE BD1N – ATTN MF C/O RELIANCE TRUST COMPANY WI VALLEE & CO FBO 50 4900 W BROWN DEER RD MILWAUKEE WI 53223-2422 |
Class I3 | 9.53% | N/A | |
MATRIX TRUST COMPANY CUST. FBO 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class R | 7.85% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH 2029 CENTURY PARK E STE 2800 CENTURY CITY CA 90067-3014 |
Class Inst2 | 7.90% | N/A | |
Class I3 | 12.61% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 12 NEW YORK NY 10004-1932 |
Class C | 7.13% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 5.70% | N/A | |
Class Adv | 7.35% | |||
Class Inst2 | 34.90% | |||
Class I3 | 10.97% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class C | 5.52% | N/A | |
PIMS/PRUDENTIAL RETIREMENT AS NOMINEE FOR THE TTEE NEW YORK CITY 160 WATER STREET ROOM 620 NEW YORK NY 10038-4922 |
Class Inst | 5.04% | N/A |
Statement of Additional Information – April 27, 2023 | 303 |
Statement of Additional Information – April 27, 2023 | 304 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
RELIANCE TRUST CO CUST ADP ACCESS LARGE MARKET 401K PLAN 201 17TH ST NW STE 1000 ATLANTA GA 30363-1195 |
Class I3 | 10.65% | N/A | |
TIAA FSB CUST/TTEE FBO RETIREMENT PLANS FOR WHICH TIAA ACTS AS RECORDKEEPER 211 N BROADWAY STE 1000 SAINT LOUIS MO 63102-2748 |
Class I3 | 7.19% | N/A | |
Small Cap Value Fund II | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 16.51% | N/A |
Class C | 51.86% | |||
SEI PRIVATE TRUST COMPANY C/O MOODY 1 FREEDOM VALLEY DR OAKS PA 19456-9989 |
Class I3 | 6.14% | N/A | |
CHARLES SCHWAB & CO INC & REINVEST ACCOUNT ATTN MUTUAL FUND DEPARTMENT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 5.09% | N/A | |
Class Inst | 10.51% | |||
Class Inst2 | 14.73% | |||
DCGT AS TTEE AND/OR CUST FBO PLIC VARIOUS RETIREMENT PLANS OMNIBUS ATTN NPIO TRADE DESK 711 HIGH ST DES MOINES IA 50392-0001 |
Class I3 | 8.51% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class A | 6.87% | N/A | |
Class I3 | 17.57% | |||
GREAT-WEST TRUST COMPANY LLC FBO 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class Adv | 12.69% | N/A | |
Class I3 | 7.79% | |||
Class R | 13.59% | |||
LINCOLN RETIREMENT SERVICES COMPANY FBO PO BOX 7876 FORT WAYNE IN 46801-7876 |
Class Inst | 5.20% | N/A | |
Class Inst2 | 12.47% | |||
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class A | 5.07% | N/A | |
Class C | 5.38% | |||
Class Inst | 12.77% | |||
MATRIX TRUST COMPANY CUST. FBO 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class R | 17.29% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH 2029 CENTURY PARK E STE 2800 CENTURY CITY CA 90067-3014 |
Class A | 10.82% | N/A | |
Class Adv | 20.19% | |||
Class Inst | 10.10% | |||
Class I3 | 9.61% | |||
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class Inst2 | 32.89% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 8.65% | N/A | |
Class Inst | 26.53% | |||
Class Inst2 | 16.92% | |||
Class I3 | 21.40% | |||
Class R | 16.35% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Inst2 | 7.98% | N/A |
Statement of Additional Information – April 27, 2023 | 305 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
PIMS/PRUDENTIAL RETIREMENT AS NOMINEE FOR THE TTEE 6465 S RAINBOW BLVD LAS VEGAS NV 89118-3215 |
Class Adv | 18.15% | N/A | |
PIMS/PRUDENTIAL RETIREMENT AS NOMINEE FOR THE TTEE 148 MARTINE AVE 7TH FLOOR 375 EXECUTIVE BLVD 2ND FLOOR WHITE PLAINS NY 10601-3311 |
Class Adv | 17.23% | N/A | |
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 11.06% | N/A | |
RELIANCE TRUST CO CUST ADP ACCESS LARGE MARKET 401K PLAN 201 17TH ST NW STE 1000 ATLANTA GA 30363-1195 |
Class A | 7.60% | N/A | |
Class R | 19.84% | |||
THE HARTFORD 1 HARTFORD PLZ HARTFORD CT 06155-0001 |
Class R | 18.18% | N/A | |
VANGUARD FIDUCIARY TRUST CO PO BOX 2600 VM 613 ATTN: OUTSIDE FUNDS VALLEY FORGE PA 19482-2600 |
Class Inst3 | 7.46% | N/A | |
VRSCO FBO AIGFSB CUST TTEE FBO 2727A ALLEN PKWY # 4-D1 HOUSTON TX 77019-2107 |
Class A | 10.56% | N/A | |
WELLS FARGO BANK FBO 1525 W W T HARRIS BLVD CHARLOTTE NC 28262-8522 |
Class Inst | 5.73% | N/A | |
WELLS FARGO CLEARING SERVICES 1 N JEFFERSON AVE SAINT LOUIS MO 63103-2287 |
Class C | 25.09% | N/A |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
Adaptive Retirement 2020 Fund | CHARLES SCHWAB & CO INC CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst3 | 72.75% | 51.37% |
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class Adv | 65.36% | 38.45%(a) | |
Class Inst3 | 27.25% | |||
PAI TRUST COMPANY INC LEHIGH VALLEY CENTER FOR INDEPENDENT 1300 ENTERPRISE DR DE PERE WI 54115-4934 |
Class Adv | 6.30% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 28.34% | N/A | |
Adaptive Retirement 2025 Fund | CHARLES SCHWAB & CO INC CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst3 | 18.55% | N/A |
Statement of Additional Information – April 27, 2023 | 306 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class Adv | 76.24% | 78.76%(a) | |
Class Inst3 | 81.45% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 22.98% | N/A | |
Adaptive Retirement 2030 Fund | CHARLES SCHWAB & CO INC CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst3 | 87.60% | 29.67% |
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class Adv | 6.23% | N/A(a) | |
Class Inst3 | 12.40% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 93.77% | 62.01% | |
Adaptive Retirement 2035 Fund | CHARLES SCHWAB & CO INC CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst3 | 57.92% | 26.68% |
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class Adv | 33.34% | 36.03%(a) | |
Class Inst3 | 39.17% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 66.06% | 35.63% | |
Adaptive Retirement 2040 Fund | CHARLES SCHWAB & CO INC CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst3 | 65.22% | 40.08% |
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class Adv | 45.23% | 34.91%(a) | |
Class Inst3 | 28.44% | |||
MATRIX TRUST COMPANY AS AGENT FOR ADVISOR TRUST, INC. ROUND LAKE AREA SCHOOLS 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class Inst3 | 6.34% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 53.98% | N/A | |
Adaptive Retirement 2045 Fund | CHARLES SCHWAB & CO INC CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst3 | 67.85% | 44.69% |
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class Adv | 61.27% | 41.85%(a) | |
Class Inst3 | 31.79% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 38.31% | N/A |
Statement of Additional Information – April 27, 2023 | 307 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
Adaptive Retirement 2050 Fund | CHARLES SCHWAB & CO INC CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst3 | 82.20% | 69.32% |
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class Adv | 95.60% | 30.00%(a) | |
Class Inst3 | 17.80% | |||
Adaptive Retirement 2055 Fund | CHARLES SCHWAB & CO INC CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst3 | 81.90% | 63.83% |
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class Adv | 63.90% | 28.21%(a) | |
Class Inst3 | 18.10% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 34.87% | N/A | |
Adaptive Retirement 2060 Fund | CHARLES SCHWAB & CO INC CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst3 | 59.52% | 27.14% |
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class Adv | 33.88% | 36.89%(a) | |
Class Inst3 | 40.48% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 65.77% | 35.78% | |
MM Growth Strategies Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class Inst | 100.00% | 100.00% |
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class Inst3 | 100.00% | N/A(a) | |
Select Large Cap Growth Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 29.46% | 29.48% |
Class C | 34.27% | |||
Class Inst | 44.29% | |||
ASCENSUS TRUST COMPANY FBO PO BOX 10758 FARGO ND 58106-0758 |
Class R | 8.94% | N/A | |
CHARLES SCHWAB & CO INC CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 23.46% | N/A | |
DCGT AS TTEE AND/OR CUST FBO 711 HIGH ST DES MOINES IA 50392-0001 |
Class R | 13.57% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 17.84% | N/A | |
GREAT-WEST TRUST COMPANY LLC FBO 8515 E ORCHARD RD 2T2 GREENWOOD VILLAGE CO 80111-5002 |
Class R | 44.49% | N/A |
Statement of Additional Information – April 27, 2023 | 308 |
Statement of Additional Information – April 27, 2023 | 309 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 5.78% | N/A | |
Class Inst | 6.23% | |||
MAC & CO ATTN MUTUAL FUND OPS 500 GRANT STREET ROOM 151-1010 PITTSBURGH PA 15219-2502 |
Class Adv | 17.83% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF IT CUSTOMER 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 7.91% | 32.97% | |
Class Inst | 18.14% | |||
Class Inst3 | 52.52% | |||
Class R | 7.80% | |||
MID ATLANTIC TRUST COMPANY FBO WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class R | 14.39% | N/A | |
MITRA CO C/O RELIANCE TRUST COMPANY WI 4900 WEST BROWN DEER ROAD MAILCODE: BD1N – ATTN: MF MILWAUKEE WI 53223-2422 |
Class Adv | 13.05% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Inst2 | 74.88% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 5.38% | N/A | |
Class C | 5.46% | |||
Class Inst2 | 13.07% | |||
RAYMOND JAMES ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 10.97% | N/A | |
STIFEL NICOLAUS & CO INC EXCLUSIVE BENEFIT OF CUSTOMERS 501 N BROADWAY SAINT LOUIS MO 63102-2188 |
Class C | 9.28% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 12.76% | N/A | |
Class Inst | 7.37% | |||
Solutions Aggressive Portfolio | COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class RT | N/A | 96.46%(a) |
JPMCB NA CUST FOR COLUMBIA ADAPTIVE RETIREMENT 2030 FUND ETF/MF 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class RT | 7.58% | N/A | |
JPMCB NA CUST FOR COLUMBIA ADAPTIVE RETIREMENT 2040 FUND ETF/MF 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class RT | 9.66% | N/A | |
JPMCB NA CUST FOR COLUMBIA ADAPTIVE RETIREMENT 2050 FUND ETF/MF 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class RT | 14.13% | N/A |
Statement of Additional Information – April 27, 2023 | 310 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
JPMCB NA CUST FOR COLUMBIA ADAPTIVE RETIREMENT 2060 FUND ETF/MF 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class RT | 18.10% | N/A | |
JPMCB NA CUST FOR COLUMBIA ADAPTIVE RISK ALLOCATION 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class RT | 14.20% | N/A | |
JPMCB NA CUST FOR COLUMBIA ADAPTIVE RETIREMENT 2035 FUND 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class RT | 6.89% | N/A | |
JPMCB NA CUST FOR COLUMBIA ADAPTIVE RETIREMENT 2045 FUND 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class RT | 10.36% | N/A | |
JPMCB NA CUST FOR COLUMBIA ADAPTIVE RETIREMENT 2055 FUND 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class RT | 15.53% | N/A | |
Solutions Conservative Portfolio | COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class RT | N/A | 94.04%(a) |
JPMCB NA CUST FOR COLUMBIA ADAPTIVE RETIREMENT 2030 FUND ETF/MF 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class RT | 11.91% | N/A | |
JPMCB NA CUST FOR COLUMBIA ADAPTIVE RETIREMENT 2020 FUND ETF/MF 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class RT | 9.89% | N/A | |
JPMCB NA CUST FOR COLUMBIA ADAPTIVE RISK ALLOCATION 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class RT | 60.36% | 60.36% | |
JPMCB NA CUST FOR COLUMBIA ADAPTIVE RETIREMENT 2025 FUND 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class RT | 6.34% | N/A | |
JPMCB NA CUST FOR COLUMBIA ADAPTIVE RETIREMENT 2035 FUND 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class RT | 5.54% | N/A |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
Bond Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 35.06% | N/A |
Class C | 46.29% | |||
Class Inst | 35.70% | |||
ASCENSUS TRUST COMPANY FBO PO BOX 10577 FARGO ND 58106-0577 |
Class C | 15.68% | N/A | |
Class R | 92.86% |
Statement of Additional Information – April 27, 2023 | 311 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A | N/A | 49.16% (a) | |
CHARLES SCHWAB & CO INC SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst | 10.09% | N/A | |
Class Inst2 | 5.13% | |||
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class A | 17.75% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class Inst3 | 19.61% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION CONSERVATIVE PORTFOLIO 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class Inst3 | 5.20% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION MODERATE AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class Inst3 | 11.55% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION MODERATE CONSERVATIVE PORTFOLIO 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class Inst3 | 6.98% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION MODERATE PORTFOLIO 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class Inst3 | 16.28% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class A | 5.41% | N/A | |
Class C | 10.23% | |||
Class Inst | 9.50% | |||
MATRIX TRUST COMPANY AS AGENT 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class R | 7.14% | N/A | |
MATRIX TRUST COMPANY CUST FBO 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class Adv | 6.57% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF IT CUSTOMER 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 13.64% | 33.43% | |
Class C | 6.57% | |||
Class Inst | 10.15% | |||
Class Inst3 | 38.16% | |||
Class V | 19.79% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 7.25% | N/A | |
Class Inst | 7.62% | |||
Class Inst2 | 63.42% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 66.62% | N/A | |
Class Inst2 | 27.67% |
Statement of Additional Information – April 27, 2023 | 312 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
RELIANCE TRUST COMPANY FBO MASSMUTUAL REGISTERED PRODUCT PO BOX 28004 ATLANTA GA 30358-0004 |
Class Adv | 12.35% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 5.43% | N/A | |
Class V | 5.83% | |||
CA Intermediate Municipal Bond Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 32.19% | N/A |
Class C | 22.54% | |||
Class Inst | 8.01% | |||
CHARLES SCHWAB & CO INC SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 5.08% | N/A | |
Class Inst2 | 55.61% | |||
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class A | 21.08% | N/A | |
Class Inst3 | 91.26% | |||
MERRILL LYNCH PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF IT CUSTOMER 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 8.98% | 55.13% | |
Class C | 5.66% | |||
Class Inst | 66.36% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 24.90% | N/A | |
Class Inst2 | 36.60% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 72.01% | N/A | |
Class Inst3 | 6.38% | |||
UBS WM USA SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class C | 25.39% | N/A | |
Class Inst | 8.44% | |||
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 12.57% | N/A | |
Class C | 29.96% | |||
Corporate Income Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 25.23% | N/A |
Class C | 52.13% | |||
Class Inst | 16.85% | |||
BAND & CO C/O US BANK NA 1555 N RIVERCENTER DR STE 302 MILWAUKEE WI 53212-3958 |
Class Inst | 17.20% | N/A | |
BMA INSURANCE COMPANY INC 1450 VETERANS BLVD REDWOOD CITY CA 94063-2617 |
Class Adv | 7.70% | N/A | |
CHARLES SCHWAB & CO INC SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 21.82% | N/A | |
Class Adv | 14.99% | |||
Class Inst2 | 81.40% | |||
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
N/A | N/A | 59.35% (a) |
Statement of Additional Information – April 27, 2023 | 313 |
Statement of Additional Information – April 27, 2023 | 314 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
NC Intermediate Municipal Bond Fund | EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class A | 11.29% | N/A |
MERRILL LYNCH PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF IT CUSTOMER 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 16.49% | 67.30% | |
Class C | 10.49% | |||
Class Inst | 12.59% | |||
Class Inst3 | 96.23% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 12 NEW YORK NY 10004-1932 |
Class C | 12.17% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 10.76% | N/A | |
Class Adv | 61.14% | |||
Class Inst | 9.38% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class A | 9.61% | N/A | |
Class Adv | 11.34% | |||
Class C | 38.80% | |||
SEI PRIVATE TRUST COMPANY C/O BMO HARRIS SWP ONE FREEDOM VALLEY DRIVE OAKS PA 19456-9989 |
Class Adv | 26.21% | N/A | |
STIFEL NICOLAUS & CO INC EXCLUSIVE BENEFIT OF CUSTOMERS 501 N BROADWAY SAINT LOUIS MO 63102-2188 |
Class C | 6.86% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 37.78% | N/A | |
Class C | 13.67% | |||
Class Inst | 63.37% | |||
SC Intermediate Municipal Bond Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 10.35% | N/A |
Class C | 17.57% | |||
CHARLES SCHWAB & CO INC SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class C | 11.68% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class A | 13.99% | N/A | |
Class C | 10.02% | |||
Class Inst3 | 31.88% | |||
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Adv | 5.38% | N/A | |
Class C | 17.30% | |||
MARIL & CO FBO C/O RELIANCE TRUST COMPANY WI MAILCODE: BD1N – ATTN: MF 4900 W BROWN DEER RD MILWAUKEE WI 53223-2422 |
Class Inst3 | 65.55% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF IT CUSTOMER 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 18.42% | 43.52% | |
Class Inst | 64.04% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 12 NEW YORK NY 10004-1932 |
Class A | 10.13% | N/A |
Statement of Additional Information – April 27, 2023 | 315 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 34.56% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 59.59% | N/A | |
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS HOUSE ACCT FIRM ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 5.95% | N/A | |
Class Inst | 14.18% | |||
STIFEL NICOLAUS & CO INC EXCLUSIVE BENEFIT OF CUSTOMERS 501 N BROADWAY SAINT LOUIS MO 63102-2188 |
Class C | 12.64% | N/A | |
TD AMERITRADE INC FBO OUR CUSTOMERS PO BOX 2226 OMAHA NE 68103-2226 |
Class A | 11.71% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 8.19% | N/A | |
Class C | 18.18% | |||
Short Duration Municipal Bond Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 36.02% | N/A |
Class C | 31.44% | |||
Class Inst | 45.21% | |||
CHARLES SCHWAB & CO INC SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Adv | 8.79% | N/A | |
Class C | 6.88% | |||
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class A | 17.41% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 6.95% | N/A | |
Class Inst | 14.37% | |||
MARIL & CO FBO C/O RELIANCE TRUST COMPANY WI 4900 W BROWN DEER RD MILWAUKEE WI 53223-2422 |
Class Inst2 | 11.82% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF IT CUSTOMER 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 11.56% | 47.56% | |
Class Inst | 5.99% | |||
Class Inst3 | 97.56% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 12 NEW YORK NY 10004-1932 |
Class Inst | 6.74% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 6.76% | N/A | |
Class Adv | 8.18% | |||
Class Inst2 | 35.64% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Inst2 | 49.07% | N/A |
Statement of Additional Information – April 27, 2023 | 316 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 10.77% | N/A | |
SEI PRIVATE TRUST COMPANY C/O BMO HARRIS SWP ONE FREEDOM VALLEY DRIVE OAKS PA 19456-9989 |
Class Adv | 67.48% | N/A | |
UBS WM USA 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class C | 12.09% | N/A | |
Class Inst | 7.55% | |||
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 6.44% | N/A | |
Class C | 16.29% | |||
Small Cap Value Fund I | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 16.76% | N/A |
Class C | 34.34% | |||
Class Inst | 5.34% | |||
ARC ENGINEERING INC TTEE FBO C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 7.97% | N/A | |
CHARLES SCHWAB & CO INC SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 5.88% | N/A | |
Class Inst2 | 17.01% | |||
JOHN COTTIS TTEE FBO C/O FASCORE 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 6.31% | N/A | |
JPMCB NA CUST FOR COLUMBIA INCOME BUILDER FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 32.05% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 15.79% | 35.78% | |
Class Inst | 67.11% | |||
MATRIX TRUST COMPANY AS AGENT 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class R | 5.45% | N/A | |
MATRIX TRUST COMPANY AS AGENT 35 IRON POINT CIR STE 300 FOLSOM CA 95630-8589 |
Class Inst3 | 9.16% | N/A | |
MATRIX TRUST COMPANY CUST FBO 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class R | 15.34% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF IT CUSTOMER 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 7.54% | N/A | |
Class Adv | 12.36% | |||
Class C | 5.70% | |||
Class Inst | 12.83% | |||
Class Inst3 | 29.99% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 12 NEW YORK NY 10004-1932 |
Class C | 5.41% | N/A |
Statement of Additional Information – April 27, 2023 | 317 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 7.60% | N/A | |
Class Adv | 36.02% | |||
Class Inst2 | 31.42% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 38.25% | N/A | |
Class Inst2 | 7.17% | |||
Class R | 24.27% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 10.70% | N/A | |
Class R | 8.48% | |||
SCOTT RECHEL TTEE FBO C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 8.10% | N/A | |
TIAA FSB CUST/TTEE FBO RETIREMENT PLANS FOR WHICH TIAA ACTS AS RECORDKEEPER ATTN TRUST OPERATIONS 211 N BROADWAY STE 1000 SAINT LOUIS MO 63102-2748 |
Class Inst2 | 35.60% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 6.65% | N/A | |
Total Return Bond Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 73.51% | 30.05% |
Class C | 56.16% | |||
Class Inst | 27.13% | |||
ASCENSUS TRUST COMPANY FBO PO BOX 10577 FARGO ND 58106-0577 |
Class R | 13.37% | N/A | |
CAPITAL BANK & TRUST COMPANY TTEE 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class Inst2 | 5.68% | N/A | |
CHARLES SCHWAB & CO INC SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Adv | 5.97% | N/A | |
Class Inst2 | 21.85% | |||
DANIEL KAREN & PETER BARTSCHKE TTEE C/O FASCORE STANDARD TOOL & DIE INC EE PSP & TR 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 5.24% | N/A | |
DCGT AS TTEE AND /OR CUST FBO PLIC VARIOUS RETIREMENT PLANS OMNIBUS ATTN NPIO TRADE DESK 711 HIGH ST DES MOINES IA 50392-0001 |
Class R | 17.51% | N/A | |
DEAN PERRY SHELIA REYNOLDS C/O FASCORE LLC FIRST COMMUNITY BANK 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 5.84% | N/A | |
FIIOC FBO 100 MAGELLAN WAY # KW1C COVINGTON KY 41015-1987 |
Class R | 7.06% | N/A |
Statement of Additional Information – April 27, 2023 | 318 |
Statement of Additional Information – April 27, 2023 | 319 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION MODERATE PORTFOLIO 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class Inst3 | 8.82% | N/A | |
JPMCB NA CUST FOR COLUMBIA THERMOSTAT FUND 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class Inst3 | 69.09% | 37.78% | |
JPMCB NA CUST FOR SOUTH CAROLINA 529 PLAN 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst | 77.57% | 29.67% | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 22.30% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF IT CUSTOMER 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 57.45% | N/A | |
Class Inst2 | 58.40% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Inst2 | 11.68% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class C | 45.44% | N/A | |
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 8.53% | N/A | |
VA Intermediate Municipal Bond Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 5.90% | N/A |
Class C | 10.90% | |||
Class Inst | 21.57% | |||
CHARLES SCHWAB & CO INC SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 29.71% | N/A | |
Class C | 36.17% | |||
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class C | 15.09% | N/A | |
Class Inst3 | 5.20% | |||
MERRILL LYNCH PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF IT CUSTOMER 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 19.83% | 51.38% | |
Class C | 5.03% | |||
Class Inst | 14.09% | |||
Class Inst3 | 93.18% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 12 NEW YORK NY 10004-1932 |
Class Inst | 7.07% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 14.13% | N/A | |
Class Adv | 27.91% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 64.96% | N/A |
Statement of Additional Information – April 27, 2023 | 320 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
SEI PRIVATE TRUST COMPANY C/O BMO HARRIS SWP ONE FREEDOM VALLEY DRIVE OAKS PA 19456-9989 |
Class Adv | 6.79% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 9.09% | N/A | |
Class C | 27.87% | |||
Class Inst | 29.90% |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
Adaptive Risk Allocation Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 72.93% | 83.53% |
Class C | 51.64% | |||
Class Inst | 88.73% | |||
ASCENSUS TRUST COMPANY FBO PO BOX 10758 FARGO ND 58106-0758 |
Class R | 9.16% | N/A | |
SEI PRIVATE TRUST COMPANY C/O PRINCIPAL FINANCIAL 1 FREEDOM VALLEY DR OAKS PA 19456-9989 |
Class Adv | 7.91% | N/A | |
CAPINCO C/O US BANK NA PO BOX 1787 MILWAUKEE WI 53201-1787 |
Class Inst3 | 95.89% | N/A | |
CHARLES SCHWAB & CO INC SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 5.17% | N/A | |
Class Inst2 | 25.57% | |||
CURRIE & CO C/O FIDUCIARY TRUST CO INT L CHURCH STREET STATION PO BOX 3199 NEW YORK NY 10008-3199 |
Class Adv | 6.27% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A | 7.17% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 24.63% | N/A | |
Class Inst2 | 40.99% | |||
Class R | 60.09% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 31.85% | N/A | |
Class Inst2 | 23.09% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 8.14% | N/A | |
Class R | 15.65% | |||
RELIANCE TRUST CO FBO PO BOX 78446 ATLANTA GA 30357 |
Class Adv | 24.60% | N/A |
Statement of Additional Information – April 27, 2023 | 321 |
Statement of Additional Information – April 27, 2023 | 322 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 18.93% | N/A | |
Class Adv | 13.92% | |||
Class Inst3 | 5.55% | |||
PAI TRUST COMPANY INC ENTERPRISE DR DE PERE WI 54115-4934 |
Class R | 20.03% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class A | 5.58% | N/A | |
Class Adv | 80.77% | |||
Class C | 5.97% | |||
Class Inst2 | 7.89% | |||
STIFEL NICOLAUS & CO INC EXCLUSIVE BENEFIT OF CUSTOMERS 501 N BROADWAY SAINT LOUIS MO 63102-2188 |
Class C | 6.58% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class A | 9.31% | N/A | |
THE HARTFORD 1 HARTFORD PLZ HARTFORD CT 06155-0001 |
Class R | 44.20% | N/A | |
Dividend Income Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 20.47% | N/A |
Class C | 13.33% | |||
Class Inst | 20.26% | |||
CHARLES SCHWAB & CO INC SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 8.36% | N/A | |
Class Inst2 | 27.25% | |||
Class V | 6.89% | |||
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 19.64% | N/A | |
EQUITABLE LIFE ON BEHALF OF VARIOUS 401K EXPEDITER PLANS 1290 AVENUE OF THE AMERICAS NEW YORK NY 10104-0101 |
Class R | 28.23% | N/A | |
ING NATIONAL TRUST 1475 DUNWOODY DR WEST CHESTER PA 19380-1478 |
Class R | 27.15% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 5.18% | N/A | |
Class Inst | 12.51% | |||
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A | 15.19% | N/A | |
Class C | 13.87% | |||
Class Inst | 9.25% | |||
Class Inst3 | 30.50% | |||
Class V | 15.66% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class A | 5.69% | N/A | |
Class C | 18.37% | |||
Class Inst | 16.84% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 17.74% | N/A | |
Class Adv | 52.90% | |||
Class Inst2 | 39.35% | |||
Class Inst3 | 19.32% |
Statement of Additional Information – April 27, 2023 | 323 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 21.19% | N/A | |
Class C | 5.82% | |||
Class Inst2 | 13.54% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 10.50% | N/A | |
Class Inst | 15.49% | |||
STATE STREET CORPORATION FBO ADP ACCESS 1 LINCOLN ST BOSTON MA 02111-2901 |
Class R | 5.85% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 7.79% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 16.66% | N/A | |
Class Inst | 6.71% | |||
Dividend Opportunity Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 74.67% | 52.03% |
Class C | 30.16% | |||
Class Inst | 41.05% | |||
CHARLES SCHWAB & CO INC SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 21.32% | N/A | |
DCGT AS TTEE AND/OR CUST FBO ATTN NPIO TRADE DESK 711 HIGH ST DES MOINES IA 50392-0001 |
Class Inst3 | 6.28% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 9.00% | N/A | |
EMPOWER TRUST FBO EMPOWER BENEFIT PLANS 8515 E ORCHARD RD 2T2 GREENWOOD VILLAGE CO 80111-5002 |
Class Adv | 16.36% | N/A | |
GREAT-WEST TRUST COMPANY LLC TTEE 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class Inst3 | 9.60% | N/A | |
JPMCB NA CUST FOR COLUMBIA INCOME BUILDER FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 45.00% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Inst | 6.76% | N/A | |
MARIL & CO FBO C/O RELIANCE TRUST COMPANY WI 4900 W BROWN DEER RD MILWAUKEE WI 53223-2422 |
Class Inst2 | 13.90% | N/A | |
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class C | 8.21% | N/A | |
Class Inst | 9.01% |
Statement of Additional Information – April 27, 2023 | 324 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 44.93% | N/A | |
Class C | 5.09% | |||
Class Inst2 | 15.08% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 27.66% | N/A | |
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 16.83% | N/A | |
Class Inst | 9.58% | |||
SAMMONS FINANCIAL NETWORK LLC 4546 CORPORATE DR STE 100 WEST DES MOINES IA 50266-5911 |
Class R | 83.24% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 29.44% | N/A | |
UBS WM USA SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class Inst | 8.33% | N/A | |
VANGUARD FIDUCIARY TRUST CO PO BOX 2600 ATTN: OUTSIDE FUNDS VALLEY FORGE PA 19482-2600 |
Class Inst3 | 8.54% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 19.74% | N/A | |
Class Inst | 5.51% | |||
Flexible Capital Income Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 55.97% | 33.57% |
Class C | 20.00% | |||
Class Inst | 32.83% | |||
CHARLES SCHWAB & CO INC SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 5.29% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 97.25% | N/A | |
EMPOWER TRUST FBO EMPOWER BENEFIT PLANS 8515 E ORCHARD RD 2T2 GREENWOOD VILLAGE CO 80111-5002 |
Class R | 5.38% | N/A | |
LINCOLN INVESTMENT PLANNING LLC FBO LINCOLN CUSTOMERS 601 OFFICE CENTER DR STE 300 FT WASHINGTON PA 19034-3275 |
Class Adv | 6.33% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 6.21% | N/A | |
Class Inst | 11.14% | |||
Class R | 5.83% | |||
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class R | 8.32% | N/A |
Statement of Additional Information – April 27, 2023 | 325 |
Statement of Additional Information – April 27, 2023 | 326 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION MODERATE AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 25.32% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION MODERATE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 20.26% | N/A | |
JPMCB NA CUST FOR COLUMBIA INCOME BUILDER FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 18.74% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 11.94% | N/A | |
MINNESOTA LIFE INS COMPANY ATTN KENNETH MONTAGUE 400 ROBERT STREET NORTH ST PAUL MN 55101-2099 |
Class Adv | 26.04% | N/A | |
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class Inst | 8.24% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 8.32% | N/A | |
Class Inst | 7.41% | |||
Class Inst2 | 56.09% | |||
NATIONWIDE TRUST COMPANY FSB FBO C/O IPO PORTFOLIO ACCOUNTING PO BOX 182029 COLUMBUS OH 43218-2029 |
Class Adv | 34.99% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Inst2 | 12.94% | N/A | |
RELIANCE TRUST CO FBO PO BOX 78446 ATLANTA GA 30357 |
Class Adv | 5.15% | N/A | |
SAMMONS FINANCIAL NETWORK LLC 4546 CORPORATE DR STE 100 WEST DES MOINES IA 50266-5911 |
Class R | 58.50% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 5.34% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 7.04% | N/A | |
High Yield Municipal Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 36.21% | N/A |
Class C | 25.75% | |||
Class Inst | 18.86% | |||
CHARLES SCHWAB & CO INC SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Adv | 7.04% | N/A | |
Class Inst2 | 25.10% |
Statement of Additional Information – April 27, 2023 | 327 |
Statement of Additional Information – April 27, 2023 | 328 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
ING LIFE INSURANCE AND ANNUITY CO ONE ORANGE WAY WINDSOR CT 06095-4773 |
Class Adv | 43.02% | N/A | |
Class R | 9.12% | |||
ING NATIONAL TRUST 1475 DUNWOODY DR WEST CHESTER PA 19380-1478 |
Class Adv | 8.23% | N/A | |
Class R | 9.03% | |||
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 34.31% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION MODERATE AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 41.79% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION MODERATE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 21.78% | N/A | |
JPMCB NA CUST FOR SOUTH CAROLINA 529 PLAN COLUMBIA 529 70% EQUITY PORTFOLIO 4 CHASE METROTECH CTR 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst | 7.75% | N/A | |
MASSACHUSETTS MUTUAL INSURANCE COM 1295 STATE STREET SPRINGFIELD MA 01111-0001 |
Class Adv | 11.19% | N/A | |
MATRIX TRUST COMPANY CUST FBO 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class R | 6.89% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 8.78% | N/A | |
Class Inst2 | 16.94% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class C | 5.09% | N/A | |
Class Inst2 | 13.77% | |||
RELIANCE TRUST CO FBO PO BOX 78446 ATLANTA GA 30357 |
Class Adv | 6.25% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 5.24% | N/A | |
THE HARTFORD 1 HARTFORD PLZ HARTFORD CT 06155-0001 |
Class R | 11.72% | N/A | |
TROY CLOVIS & SARAH HUNT TTEE FBO C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 12.46% | N/A | |
MM Value Strategies Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class Inst | 100.00% | 100.00% |
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class Inst3 | 100.00% | N/A (a) |
Statement of Additional Information – April 27, 2023 | 329 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
Mortgage Opportunities Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 16.44% | N/A |
Class C | 19.04% | |||
Class Inst | 20.54% | |||
ATTN MUTUAL FUND OPERATIONS MAC & CO 500 GRANT ST RM PITTSBURGH PA 15219-2502 |
Class Inst3 | 7.42% | N/A | |
CAPINCO C/O US BANK NA PO BOX 1787 MILWAUKEE WI 53201-1787 |
Class Inst3 | 15.25% | N/A | |
CHARLES SCHWAB & CO INC SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 9.12% | N/A | |
Class Adv | 7.55% | |||
Class Inst2 | 43.52% | |||
JPMCB NA CUST FOR COLUMBIA INCOME BUILDER FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 47.09% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 10.21% | N/A | |
Class Inst | 19.48% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class C | 9.67% | N/A | |
Class Inst | 10.18% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 62.68% | N/A | |
Class Adv | 55.75% | |||
Class C | 5.46% | |||
Class Inst2 | 30.93% | |||
Class Inst3 | 12.22% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 34.97% | N/A | |
Class C | 6.81% | |||
Class Inst2 | 11.67% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 27.66% | N/A | |
Class Inst | 11.85% | |||
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 13.28% | N/A | |
UBS WM USA SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class Inst | 20.10% | N/A | |
Class Inst3 | 11.30% | |||
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 8.15% | N/A | |
Class Inst | 8.46% | |||
Multi Strategy Alternatives Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 70.44% | 93.97% |
Class Inst | 95.90% | |||
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class Inst3 | 100.00% | N/A (a) | |
Class R | 100.00% |
Statement of Additional Information – April 27, 2023 | 330 |
Statement of Additional Information – April 27, 2023 | 331 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A | 19.76% | N/A | |
Class Adv | 5.92% | |||
Class C | 12.13% | |||
Class Inst | 14.56% | |||
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class R | 9.50% | N/A | |
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class Inst | 6.29% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 35.96% | N/A | |
Class Inst2 | 56.13% | |||
NATIONWIDE TRUST COMPANY FSB FBO C/O IPO PORTFOLIO ACCOUNTING PO BOX 182029 COLUMBUS OH 43218-2029 |
Class Inst2 | 7.21% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 49.72% | N/A | |
Class Inst2 | 9.95% | |||
SAMMONS FINANCIAL NETWORK LLC 4546 CORPORATE DR STE 100 WEST DES MOINES IA 50266-5911 |
Class R | 79.43% | N/A | |
UBS WM USA SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class C | 5.05% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 14.61% | N/A | |
Select Large Cap Value Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 13.67% | N/A |
Class C | 14.14% | |||
Class Inst | 5.25% | |||
CHARLES SCHWAB & CO INC SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 6.19% | N/A | |
Class Inst2 | 10.72% | |||
CITI PRIVATE BANK 1 480 WASHINGTON BLVD FL 8 JERSEY CITY NJ 07310-2092 |
Class Adv | 13.75% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 38.89% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 5.84% | N/A | |
Class Inst | 29.20% | |||
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A | 35.22% | N/A | |
Class C | 20.12% | |||
Class Inst | 17.52% | |||
Class Inst3 | 37.70% |
Statement of Additional Information – April 27, 2023 | 332 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class A | 8.81% | N/A | |
Class C | 17.63% | |||
Class Inst | 18.21% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 7.37% | N/A | |
Class Inst2 | 67.95% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 71.01% | N/A | |
Class Inst2 | 8.83% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 9.47% | N/A | |
SAMMONS FINANCIAL NETWORK LLC 4546 CORPORATE DR STE 100 WEST DES MOINES IA 50266-5911 |
Class R | 80.00% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 6.03% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 19.57% | N/A | |
Class Inst | 5.60% | |||
ZIONS FIRST NATIONAL BANK PO BOX 30880 SALT LAKE CTY UT 84130-0880 |
Class Inst | 5.86% | N/A | |
Select Small Cap Value Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 74.49% | 58.34% |
Class C | 34.38% | |||
Class Inst | 51.11% | |||
ASCENSUS TRUST COMPANY FBO PO BOX 10758 FARGO ND 58106-0758 |
Class C | 16.23% | N/A | |
Class R | 28.38% | |||
AUL AMERICAN GROUP RETIREMENT ANNUITY PO BOX 368 INDIANAPOLIS IN 46206-0368 |
Class Adv | 18.84% | N/A | |
BRET BURNETT & VICKI BURNETT TTEE F C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 5.03% | N/A | |
CAPITAL BANK & TRUST CO TTEE FBO C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 10.65% | N/A | |
CHARLES SCHWAB & CO INC SPECIAL CUSTODY A/C FBO CUSTOMERS ATTN MUTUAL FUND DEPT 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class C | 6.03% | N/A | |
Class Inst2 | 22.94% | |||
DCGT AS TTEE AND/OR CUST FBO ATTN NPIO TRADE DESK 711 HIGH ST DES MOINES IA 50392-0001 |
Class R | 7.79% | N/A |
Statement of Additional Information – April 27, 2023 | 333 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
GARB WINS BEN DECK GRAN & ESWA TTEE C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 6.14% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 29.26% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION MODERATE AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 35.04% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION MODERATE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 18.72% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 14.10% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class R | 15.70% | N/A | |
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class R | 6.69% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 35.32% | N/A | |
Class Inst2 | 20.56% | |||
NATIONWIDE TRUST COMPANY FSB FBO C/O IPO PORTFOLIO ACCOUNTING PO BOX 182029 COLUMBUS OH 43218-2029 |
Class Inst2 | 5.04% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 16.06% | N/A | |
Class Inst2 | 22.03% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class Inst | 25.07% | N/A | |
RBC CAPITAL MARKETS LLC MUTUAL FUND OMNIBUS PROCESSING OMNIBUS ATTN MUTUAL FUND OPS MANAGER 250 NICOLLET MALL SUITE 1400 MINNEAPOLIS MN 55401-7554 |
Class Inst | 10.25% | N/A | |
VRSCO FBO SOUTH SAN JOAQUIN CTY FIRE 457(B) HOUSTON TX 77019-2107 |
Class Adv | 24.47% | N/A | |
Class Inst2 | 25.04% | |||
WELLS FARGO BANK NA FBO OMNIBUS REINVEST REINVEST PO BOX 1533 MINNEAPOLIS MN 55480-1533 |
Class Inst3 | 7.26% | N/A |
Statement of Additional Information – April 27, 2023 | 334 |
Statement of Additional Information – April 27, 2023 | 335 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 13.67% | N/A | |
THE HARTFORD 1 HARTFORD PLZ HARTFORD CT 06155-0001 |
Class R | 17.63% | N/A | |
UBS WM USA SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class Inst | 7.74% | N/A | |
Class R | 6.84% | |||
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 8.93% | N/A | |
Class C | 17.78% | |||
Class Inst | 13.84% |
Statement of Additional Information – April 27, 2023 | 336 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION MODERATE CONSERVATIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 57.28% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Adv | 5.35% | N/A | |
Class C | 5.78% | |||
MATRIX TRUST COMPANY AS AGENT FOR NEWPORT TRUST COMPANY VIZIENT INC 401(K) MATCH RESTORAT 35 IRON POINT CIR STE 300 FOLSOM CA 95630-8589 |
Class Inst2 | 5.97% | N/A | |
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class Adv | 6.68% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 23.68% | N/A | |
Class Inst2 | 15.34% | |||
Class R | 7.95% | |||
PAI TRUST COMPANY INC 1300 ENTERPRISE DR DE PERE WI 54115-4934 |
Class R | 10.54% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 15.50% | N/A | |
Class Inst2 | 5.21% | |||
STATE STREET BANK AND TRUST AS TRUSTEE AND/OR CUSTODIAN FBO ADP ACCESS PRODUCT 1 LINCOLN ST BOSTON MA 02111-2901 |
Class R | 11.70% | N/A | |
T ROWE PRICE TRUST CO TTEE FBO RETIREMENT PLAN CLIENTS PO BOX 17215 BALTIMORE MD 21297-1215 |
Class Inst3 | 9.75% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 12.70% | N/A | |
VANGUARD FDUCIARY TRUST CO PO BOX 2600 ATTN: OUTSIDE FUNDS VALLEY FORGE PA 19482-2600 |
Class Inst2 | 15.76% | N/A | |
Disciplined Growth Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 69.82% | 58.86% |
Class C | 52.78% | |||
Class Inst | 71.04% | |||
ASCENSUS TRUST COMPANY FBO PO BOX 10758 FARGO ND 58106-0758 |
Class Inst2 | 8.98% | N/A | |
Class R | 34.04% | |||
CHARLES SCHWAB & CO INC ATTN MUTUAL FUND OPS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst3 | 6.08% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 15.68% | N/A | |
EMPOWER TRUST COMPANY LLC TTEE F EMPLOYEE BENEFITS CLIENTS 401K 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class Inst2 | 13.30% | N/A |
Statement of Additional Information – April 27, 2023 | 337 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
FIIOC FBO 100 MAGELLAN WAY # KW1C COVINGTON KY 41015-1987 |
Class Inst2 | 5.41% | N/A | |
Class R | 6.83% | |||
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 5.66% | N/A | |
Class Inst | 8.40% | |||
MATRIX TRUST COMPANY CUST. FBO 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class Inst2 | 20.15% | N/A | |
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class Inst2 | 7.49% | N/A | |
Class R | 55.26% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 6.16% | N/A | |
Class Adv | 10.16% | |||
Class Inst2 | 13.68% | |||
Class Inst3 | 73.57% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 86.93% | N/A | |
Class C | 7.60% | |||
Class Inst2 | 19.31% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 6.23% | N/A | |
Class Inst | 5.49% | |||
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 11.83% | N/A | |
Disciplined Value Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 44.48% | N/A |
Class C | 20.33% | |||
Class Inst | 22.39% | |||
ASCENSUS TRUST COMPANY FBO PO BOX 10758 FARGO ND 58106-0758 |
Class Inst3 | 9.52% | N/A | |
Class R | 46.02% | |||
CHARLES SCHWAB & CO INC ATTN MUTUAL FUND OPS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 9.66% | N/A | |
CHARLES SCHWAB TRUST BANK CUST 2423 E LINCOLN DR PHOENIX AZ 85016-1215 |
Class A | 7.64% | N/A | |
DONG II SEO & DAE HYUN SON TTEE FBO C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 18.63% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 59.86% | N/A | |
EMPOWER TRUST COMPANY LLC TTEE F EMPLOYEE BENEFITS CLIENTS 401K 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class Inst2 | 52.91% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Adv | 18.50% | N/A | |
MATRIX TRUST COMPANY CUST. FBO 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class R | 10.95% | N/A |
Statement of Additional Information – April 27, 2023 | 338 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
MERRILL LYNCH, PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF ITS CUSTOMERS 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 9.60% | N/A | |
Class Inst3 | 10.44% | |||
Class V | 7.70% | |||
MID ATLANTIC TRUST COMPANY FBO FRIPP ISLAND RESORT, INC. 401(K) PR 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class Inst3 | 6.99% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 36.86% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 41.55% | N/A | |
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 11.36% | N/A | |
STATE STREET BANK AND TRUST AS TRUSTEE AND/OR CUSTODIAN FBO ADP ACCESS PRODUCT 1 LINCOLN ST BOSTON MA 02111-2901 |
Class Inst3 | 11.50% | N/A | |
Class R | 18.55% | |||
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 33.08% | N/A | |
UBS WM USA SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class C | 46.18% | N/A | |
Class Inst | 42.26% | |||
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 6.94% | N/A | |
Floating Rate Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 71.25% | 38.47% |
Class C | 40.38% | |||
Class Inst | 36.01% | |||
ASCENSUS TRUST COMPANY FBO PO BOX 10758 FARGO ND 58106-0758 |
Class R | 9.96% | N/A | |
CAPITAL BANK & TRUST CO TTEE FBO C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 13.30% | N/A | |
CAPITAL BANK & TRUST COMPANY TTEE 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 6.63% | N/A | |
CHARLES SCHWAB & CO INC ATTN MUTUAL FUND OPS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 40.47% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 24.04% | N/A |
Statement of Additional Information – April 27, 2023 | 339 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
EMPOWER TRUST COMPANY LLC TTEE F EMPLOYEE BENEFITS CLIENTS 401K 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class Inst2 | 9.56% | N/A | |
FIIOC FBO 100 MAGELLAN WAY # KW1C COVINGTON KY 41015-1987 |
Class R | 6.66% | N/A | |
JPMCB NA CUST FOR COLUMBIA INCOME BUILDER FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 57.08% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 10.46% | N/A | |
Class Inst | 12.80% | |||
MAU SHERWOOD SUPPLY CO TTEE FBO C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 13.14% | N/A | |
MERRILL LYNCH, PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF ITS CUSTOMERS 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class C | 9.21% | N/A | |
Class Inst | 10.27% | |||
Class R | 7.93% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class A | 5.22% | N/A | |
Class C | 7.20% | |||
Class Inst | 13.94% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 50.36% | N/A | |
Class Inst2 | 20.34% | |||
Class Inst3 | 6.73% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 44.48% | N/A | |
Class C | 5.92% | |||
Class Inst2 | 6.88% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 9.29% | N/A | |
Class Inst | 7.61% | |||
RICHARD M KLINE DMDTRUSTEE FBO C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 5.81% | N/A | |
SEI PRIVATE TRUST COMPANY ATTN MUTUAL FUND ADMIN 1 FREEDOM VALLEY DR OAKS PA 19456-9989 |
Class Inst3 | 9.12% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 12.85% | N/A | |
UBS WM USA SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class Inst | 7.76% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 6.82% | N/A | |
Class Inst | 5.83% |
Statement of Additional Information – April 27, 2023 | 340 |
Statement of Additional Information – April 27, 2023 | 341 |
Statement of Additional Information – April 27, 2023 | 342 |
Statement of Additional Information – April 27, 2023 | 343 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION MODERATE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 14.80% | N/A | |
MATRIX TRUST COMPANY AS AGENT FOR ADVISOR TRUST, INC 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class R | 7.21% | N/A | |
MERRILL LYNCH, PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF ITS CUSTOMERS 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class Adv | 11.24% | N/A | |
Class Inst3 | 22.91% | |||
Class R | 6.53% | |||
Class V | 23.41% | |||
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class R | 9.98% | N/A | |
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class C | 5.12% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 55.24% | N/A | |
Class Inst2 | 7.09% | |||
Class R | 18.49% | |||
PAI TRUST COMPANY INC 1300 ENTERPRISE DR DE PERE WI 54115-4934 |
Class R | 9.01% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 20.93% | N/A | |
STATE STREET BANK AND TRUST AS TRUSTEE AND/OR CUSTODIAN FBO ADP ACCESS PRODUCT 1 LINCOLN ST BOSTON MA 02111-2901 |
Class R | 11.22% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 40.91% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 8.38% | N/A | |
Limited Duration Credit Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 65.72% | 43.61% |
Class C | 36.80% | |||
Class Inst | 55.40% | |||
CHARLES SCHWAB & CO INC ATTN MUTUAL FUND OPS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Adv | 12.43% | N/A | |
Class Inst2 | 52.87% | |||
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 63.33% | N/A | |
JPMCB NA CUST FOR COLUMBIA INCOME BUILDER FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 26.94% | N/A |
Statement of Additional Information – April 27, 2023 | 344 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 5.32% | N/A | |
Class Inst | 6.23% | |||
MERRILL LYNCH, PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF ITS CUSTOMERS 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 6.29% | N/A | |
Class C | 16.01% | |||
Class Inst | 9.66% | |||
MINNESOTA LIFE INS COMPANY ATTN KENNETH MONTAGUE 400 ROBERT STREET NORTH ST PAUL MN 55101-2099 |
Class Adv | 56.82% | N/A | |
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class C | 13.71% | N/A | |
Class Inst | 6.80% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 13.75% | N/A | |
Class Inst2 | 12.93% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 13.93% | N/A | |
Class Inst2 | 22.63% | |||
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 6.56% | N/A | |
UBS WM USA SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class Inst | 5.47% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 17.56% | N/A | |
Class Inst | 7.08% | |||
MN Tax-Exempt Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 71.36% | 66.24% |
Class C | 81.64% | |||
Class Inst | 67.63% | |||
CHARLES SCHWAB & CO INC ATTN MUTUAL FUND OPS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 39.76% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class A | 8.36% | N/A | |
Class Inst3 | 97.50% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class Inst | 5.19% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 29.80% | N/A | |
Class Inst2 | 27.43% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 69.34% | N/A | |
Class Inst2 | 5.67% |
Statement of Additional Information – April 27, 2023 | 345 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 24.98% | N/A | |
UBS WM USA SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class Inst | 15.11% | N/A | |
OR Intermediate Municipal Bond Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 7.15% | N/A |
Class C | 9.20% | |||
Class Inst | 5.55% | |||
CHARLES SCHWAB & CO INC ATTN MUTUAL FUND OPS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 8.03% | N/A | |
Class Adv | 6.93% | |||
Class Inst | 10.75% | |||
Class Inst2 | 59.19% | |||
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class A | 41.17% | N/A | |
Class C | 23.31% | |||
Class Inst3 | 26.10% | |||
MERRILL LYNCH, PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF ITS CUSTOMERS 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class Inst3 | 62.29% | N/A | |
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class C | 8.68% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 6.13% | N/A | |
Class Adv | 44.19% | |||
Class Inst2 | 12.22% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 46.73% | N/A | |
Class C | 13.60% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class A | 15.35% | N/A | |
Class C | 37.44% | |||
SEI PRIVATE TRUST COMPANY ATTN MUTUAL FUND ADMIN 1 FREEDOM VALLEY DR OAKS PA 19456-9989 |
Class Inst3 | 11.37% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 28.09% | N/A | |
Strategic Municipal Income Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 68.70% | 50.45% |
Class C | 45.36% | |||
Class Inst | 49.29% | |||
CHARLES SCHWAB & CO INC ATTN MUTUAL FUND OPS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 15.97% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class A | 6.66% | N/A | |
Class Inst3 | 40.80% |
Statement of Additional Information – April 27, 2023 | 346 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Inst | 5.82% | N/A | |
MERRILL LYNCH, PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF ITS CUSTOMERS 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class C | 8.71% | N/A | |
Class Inst | 8.99% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class C | 6.96% | N/A | |
Class Inst | 7.10% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 33.14% | N/A | |
Class Inst2 | 46.12% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 63.25% | N/A | |
Class Inst2 | 5.15% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 5.48% | N/A | |
Class Inst | 7.56% | |||
SEI PRIVATE TRUST COMPANY ATTN MUTUAL FUND ADMIN 1 FREEDOM VALLEY DR OAKS PA 19456-9989 |
Class Inst3 | 50.58% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 30.95% | N/A | |
UBS WM USA SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class Inst | 7.26% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 9.92% | N/A | |
Tax-Exempt Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 44.64% | 38.57% |
Class C | 48.52% | |||
Class Inst | 24.33% | |||
CHARLES SCHWAB & CO INC ATTN MUTUAL FUND OPS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 26.31% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class A | 15.09% | N/A | |
Class C | 5.92% | |||
Class Inst3 | 13.64% | |||
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Inst | 13.89% | N/A | |
MERRILL LYNCH, PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF ITS CUSTOMERS 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class Inst3 | 85.19% | N/A |
Statement of Additional Information – April 27, 2023 | 347 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 38.43% | N/A | |
Class Inst2 | 29.25% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 33.49% | N/A | |
Class Inst2 | 17.50% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 8.57% | N/A | |
RBC CAPITAL MARKETS LLC MUTUAL FUND OMNIBUS PROCESSING OMNIBUS ATTN MUTUAL FUND OPS MANAGER 250 NICOLLET MALL SUITE 1400 MINNEAPOLIS MN 55401-7554 |
Class C | 10.73% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 22.21% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class Adv | 21.92% | N/A | |
U.S. Social Bond Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 22.36% | 25.11% |
Class C | 28.41% | |||
Class Inst | 38.37% | |||
CHARLES SCHWAB & CO INC ATTN MUTUAL FUND OPS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 11.49% | N/A | |
Class Inst2 | 35.49% | |||
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class C | 6.32% | N/A | |
Class Inst3 | 79.57% | |||
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 10.71% | N/A | |
MERRILL LYNCH, PIERCE FENNER & SMITH FOR THE SOLE BENEFIT OF ITS CUSTOMERS 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 32.36% | N/A | |
Class C | 19.23% | |||
Class Inst | 26.79% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class A | 14.70% | N/A | |
Class C | 9.83% | |||
MORI & CO 922 WALNUT ST MAILSTOP TBTS 2 KANSAS CITY MO 64106-1802 |
Class Inst3 | 20.30% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 93.77% | N/A | |
Class Inst2 | 46.59% |
Statement of Additional Information – April 27, 2023 | 348 |
Statement of Additional Information – April 27, 2023 | 349 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
ASCENSUS TRUST CO FBO PO BOX 10758 FARGO ND 58106-0758 |
Class Inst3 | 9.19% | N/A | |
Class R | 6.68% | |||
CHARLES SCHWAB & CO INC SPECIAL CUSTODY ACCT FBO ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Adv | 5.00% | N/A | |
Class Inst2 | 25.56% | |||
DCGT AS TTEE AND/OR CUST FBO ATTN NPIO TRADE DESK 711 HIGH ST DES MOINES IA 50392-0001 |
Class Inst2 | 12.94% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 21.71% | N/A | |
LINCOLN INVESTMENT PLANNING LLC FBO LINCOLN CUSTOMERS 601 OFFICE CENTER DR STE 300 FT WASHINGTON PA 19034-3275 |
Class Adv | 12.55% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Inst | 9.37% | N/A | |
MATRIX TRUST COMPANY AS AGENT FOR NEWPORT TRUST COMPANY 35 IRON POINT CIR STE 300 FOLSOM CA 95630-8589 |
Class Inst3 | 26.56% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class Inst | 13.41% | N/A | |
Class Inst3 | 11.74% | |||
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class R | 7.80% | N/A | |
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class C | 5.36% | N/A | |
Class Inst | 8.67% | |||
NATIONAL FINANCIAL SERVICES LLC FBO CUSTOMERS MUTUAL FUNDS 499 WASHINGTON BLVD JERSEY CITY NJ 07310-1995 |
Class A | 9.07% | N/A | |
Class Adv | 26.24% | |||
Class C | 5.45% | |||
Class Inst2 | 24.62% | |||
Class Inst3 | 6.45% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 45.73% | N/A | |
Class Inst2 | 11.09% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 7.39% | N/A | |
Class Inst | 8.84% | |||
STATE STREET BANK FBO ADP ACCESS PRODUCT 1 LINCOLN ST BOSTON MA 02111-2901 |
Class R | 61.55% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 10.06% | N/A |
Statement of Additional Information – April 27, 2023 | 350 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 15.21% | N/A | |
Class Inst | 9.06% | |||
Contrarian Core Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE MINNEAPOLIS MN 55402-2405 |
Class A | 54.17% | N/A |
Class C | 34.27% | |||
Class Inst | 17.28% | |||
ASCENSUS TRUST CO FBO PO BOX 10758 FARGO ND 58106-0758 |
Class R | 6.79% | N/A | |
CHARLES SCHWAB & CO INC SPECIAL CUSTODY ACCT FBO ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst | 10.63% | N/A | |
Class Inst2 | 13.69% | |||
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 11.56% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 6.33% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION MODERATE AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 7.71% | N/A | |
JPMCB NA CUST FOR SOUTH CAROLINA 529 PLAN COLUMBIA 529 40% EQUITY PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst | 7.60% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 6.32% | N/A | |
Class Inst | 8.72% | |||
MASSACHUSETTS MUTUAL LIFE INS CO 1295 STATE ST MIP M200-INVST SPRINGFIELD MA 01111-0001 |
Class R | 5.08% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A | 8.08% | N/A | |
Class Inst | 5.14% | |||
Class Inst3 | 16.80% | |||
Class V | 25.99% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class C | 6.13% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FBO CUSTOMERS MUTUAL FUNDS 499 WASHINGTON BLVD JERSEY CITY NJ 07310-1995 |
Class A | 5.31% | N/A | |
Class Adv | 39.02% | |||
Class C | 5.91% | |||
Class Inst | 6.29% | |||
Class Inst2 | 44.50% | |||
Class Inst3 | 17.39% | |||
Class V | 6.32% |
Statement of Additional Information – April 27, 2023 | 351 |
Statement of Additional Information – April 27, 2023 | 352 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
JPMCB NA CUST FOR SOUTH CAROLINA 529 PLAN COLUMBIA 529 40% EQUITY PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst | 52.13% | N/A | |
LINCOLN INVESTMENT PLANNING LLC FBO LINCOLN CUSTOMERS 601 OFFICE CENTER DR STE 300 FT WASHINGTON PA 19034-3275 |
Class Adv | 8.28% | N/A | |
MATRIX TRUST COMPANY 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class Inst2 | 71.18% | N/A | |
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class C | 9.44% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FBO CUSTOMERS MUTUAL FUNDS 499 WASHINGTON BLVD JERSEY CITY NJ 07310-1995 |
Class Adv | 38.32% | N/A | |
Class Inst2 | 21.92% | |||
Class Inst3 | 9.79% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 26.19% | N/A | |
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 20.92% | N/A | |
Class Inst | 6.03% | |||
SAMMONS FINANCIAL NETWORK LLC 4546 CORPORATE DR STE 100 WEST DES MOINES IA 50266-5911 |
Class R | 96.32% | N/A | |
TIAA FSB CUST/TTEE FBO RETIREMENT PLANS FOR WHICH TIAA ACTS AS RECORDKEEPER ATTN TRUST OPERATIONS 211 N BROADWAY STE 1000 SAINT LOUIS MO 63102-2748 |
Class Adv | 9.67% | N/A | |
UBS WM USA SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class C | 5.72% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 5.11% | N/A | |
Class C | 26.53% | |||
Class Inst | 5.32% | |||
Emerging Markets Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE MINNEAPOLIS MN 55402-2405 |
Class A | 63.68% | N/A |
Class C | 47.55% | |||
Class Inst | 14.81% | |||
ASCENSUS TRUST CO FBO PO BOX 10758 FARGO ND 58106-0758 |
Class C | 6.50% | N/A | |
Class R | 9.15% | |||
CHARLES SCHWAB & CO INC SPECIAL CUSTODY ACCT FBO ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Adv | 28.33% | N/A | |
Class Inst | 5.61% | |||
Class Inst2 | 28.34% | |||
CHARLES SCHWAB TRUST BANK TTEE 2423 E LINCOLN DR PHOENIX AZ 85016-1215 |
Class A | 5.11% | N/A |
Statement of Additional Information – April 27, 2023 | 353 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
FIIOC FBO 100 MAGELLAN WAY # KW1C COVINGTON KY 41015-1987 |
Class R | 14.46% | N/A | |
ING NATIONAL TRUST 1475 DUNWOODY DR WEST CHESTER PA 19380-1478 |
Class Inst2 | 8.47% | N/A | |
J P MORGAN SECURITIES LLC OMNIBUS ACCOUNT FOR THE EXCLUSIVE BENEFIT OF CUSTOMERS 4 CHASE METROTECH CENTER 3RD FL MUTUAL FUND DEPARTMENT BROOKLYN NY 11245-0003 |
Class C | 11.73% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 12.05% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION MODERATE AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 10.99% | N/A | |
JPMCB NA CUST FOR COLUMBIA THERMOSTAT FUND 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class Inst3 | 5.81% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Inst | 19.28% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class Inst | 45.93% | 30.78% | |
Class Inst3 | 40.06% | |||
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class R | 9.34% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FBO CUSTOMERS MUTUAL FUNDS 499 WASHINGTON BLVD JERSEY CITY NJ 07310-1995 |
Class Adv | 18.57% | N/A | |
Class Inst2 | 38.12% | |||
Class Inst3 | 15.07% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 42.66% | N/A | |
Class C | 5.23% | |||
Class Inst2 | 12.29% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 5.67% | N/A | |
SAMMONS FINANCIAL NETWORK LLC 4546 CORPORATE DR STE 100 WEST DES MOINES IA 50266-5911 |
Class R | 20.04% | N/A | |
STATE STREET BANK FBO ADP ACCESS PRODUCT 1 LINCOLN ST BOSTON MA 02111-2901 |
Class R | 15.39% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 5.17% | N/A |
Statement of Additional Information – April 27, 2023 | 354 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 8.52% | N/A | |
Global Technology Growth Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE MINNEAPOLIS MN 55402-2405 |
Class A | 27.11% | N/A |
Class C | 24.24% | |||
Class Inst | 24.84% | |||
CHARLES SCHWAB & CO INC SPECIAL CUSTODY ACCT FBO ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 9.32% | N/A | |
Class Inst2 | 13.77% | |||
DCGT AS TTEE AND/OR CUST FBO ATTN NPIO TRADE DESK 711 HIGH ST DES MOINES IA 50392-0001 |
Class Inst3 | 9.14% | N/A | |
EMPOWER TRUST FBO 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class Inst2 | 8.90% | N/A | |
FIIOC FBO 100 MAGELLAN WAY # KW1C COVINGTON KY 41015-1987 |
Class Inst2 | 5.05% | N/A | |
J P MORGAN SECURITIES LLC OMNIBUS ACCOUNT FOR THE EXCLUSIVE BENEFIT OF CUSTOMERS 4 CHASE METROTECH CENTER 3RD FL MUTUAL FUND DEPARTMENT BROOKLYN NY 11245-0003 |
Class Inst3 | 19.97% | N/A | |
JOHN HANCOCK TRUST COMPANY LLC 690 CANTON ST STE 100 WESTWOOD MA 02090-2324 |
Class Adv | 7.10% | N/A | |
LINCOLN INVESTMENT PLANNING LLC FBO LINCOLN CUSTOMERS 601 OFFICE CENTER DR STE 300 FT WASHINGTON PA 19034-3275 |
Class Adv | 7.58% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Adv | 5.36% | N/A | |
Class C | 10.44% | |||
Class Inst | 24.99% | |||
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A | 10.09% | N/A | |
Class Inst | 11.04% | |||
Class Inst3 | 28.08% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class C | 8.21% | N/A | |
Class Inst | 6.07% | |||
NATIONAL FINANCIAL SERVICES LLC FBO CUSTOMERS MUTUAL FUNDS 499 WASHINGTON BLVD JERSEY CITY NJ 07310-1995 |
Class A | 13.96% | N/A | |
Class Adv | 16.45% | |||
Class Inst2 | 33.28% | |||
NATIONWIDE TRUST COMPANY FSB FBO C/O IPO PORTFOLIO ACCOUNTING PO BOX 182029 COLUMBUS OH 43218-2029 |
Class Adv | 9.87% | N/A |
Statement of Additional Information – April 27, 2023 | 355 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class A | 5.39% | N/A | |
Class Adv | 27.43% | |||
Class C | 10.84% | |||
Class Inst2 | 5.66% | |||
Class Inst3 | 19.17% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 5.38% | N/A | |
Class Inst | 7.41% | |||
T ROWE PRICE TRUST CO TTEE FBO RETIREMENT PLAN CLIENTS PO BOX 17215 BALTIMORE MD 21297-1215 |
Class Inst2 | 5.97% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 10.42% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 5.09% | N/A | |
Class C | 15.22% | |||
Greater China Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE MINNEAPOLIS MN 55402-2405 |
Class A | 6.70% | N/A |
Class C | 44.27% | |||
Class Inst | 9.05% | |||
CHARLES SCHWAB & CO INC SPECIAL CUSTODY ACCT FBO ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 7.77% | N/A | |
Class C | 6.79% | |||
Class Inst2 | 11.87% | |||
EMPOWER TRUST FBO 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class Inst2 | 11.75% | N/A | |
J P MORGAN SECURITIES LLC OMNIBUS ACCOUNT FOR THE EXCLUSIVE BENEFIT OF CUSTOMERS 4 CHASE METROTECH CENTER 3RD FL MUTUAL FUND DEPARTMENT BROOKLYN NY 11245-0003 |
Class C | 14.58% | 29.83% | |
Class Inst | 32.00% | |||
Class Inst3 | 90.21% | |||
JOHN HANCOCK TRUST COMPANY LLC 690 CANTON ST STE 100 WESTWOOD MA 02090-2324 |
Class Adv | 6.94% | N/A | |
LINCOLN INVESTMENT PLANNING LLC FBO LINCOLN CUSTOMERS 601 OFFICE CENTER DR STE 300 FT WASHINGTON PA 19034-3275 |
Class Adv | 11.07% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 6.42% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A | 8.94% | N/A | |
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class Adv | 9.64% | N/A |
Statement of Additional Information – April 27, 2023 | 356 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class A | 9.39% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FBO CUSTOMERS MUTUAL FUNDS 499 WASHINGTON BLVD JERSEY CITY NJ 07310-1995 |
Class A | 15.30% | N/A | |
Class Adv | 47.72% | |||
Class Inst2 | 51.84% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class A | 5.33% | N/A | |
Class Adv | 15.12% | |||
Class C | 13.81% | |||
Class Inst2 | 11.44% | |||
STATE STREET BANK FBO ADP ACCESS PRODUCT 1 LINCOLN ST BOSTON MA 02111-2901 |
Class Adv | 5.22% | N/A | |
Class Inst2 | 5.53% | |||
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class A | 5.34% | N/A | |
UBS WM USA SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class Inst | 7.39% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 8.25% | N/A | |
Class C | 5.55% | |||
Class Inst | 7.90% | |||
International Dividend Income Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE MINNEAPOLIS MN 55402-2405 |
Class A | 12.22% | N/A |
Class C | 23.24% | |||
CHARLES SCHWAB & CO INC SPECIAL CUSTODY ACCT FBO ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 7.93% | N/A | |
Class Inst | 5.10% | |||
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 44.44% | N/A | |
JPMCB NA CUST FOR COLUMBIA INCOME BUILDER FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 54.30% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 8.65% | N/A | |
MATRIX TRUST COMPANY AS AGENT FOR ADVISOR TRUST, INC. 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class R | 31.38% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A | 5.19% | N/A |
Statement of Additional Information – April 27, 2023 | 357 |
Statement of Additional Information – April 27, 2023 | 358 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class Inst3 | 100.00% | N/A(a) | |
Multisector Bond SMA Completion Portfolio | COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Shares | 100.00% | 100.00%(a) |
Overseas SMA Completion Portfolio | CHARLES SCHWAB & CO INC SPECIAL CUSTODY ACCT FBO ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Shares | 22.04% | N/A |
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Shares | 42.47% | 42.47% (a) | |
UBS WM USA SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Shares | 35.49% | 35.49% | |
Select Mid Cap Growth Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE MINNEAPOLIS MN 55402-2405 |
Class A | 60.51% | 31.33% |
Class C | 39.74% | |||
ARUNA KHANDELWAL 362 SPRAGUE RD NARBERTH PA 19072-1124 |
Class V | 5.08% | N/A | |
ASCENSUS TRUST CO FBO PO BOX 10758 FARGO ND 58106-0758 |
Class C | 10.40% | N/A | |
Class R | 15.53% | |||
CAPITAL BANK & TRUST COMPANY TTEE 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class Inst2 | 36.92% | N/A | |
CHARLES SCHWAB & CO INC SPECIAL CUSTODY ACCT FBO ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst | 11.96% | N/A | |
Class Inst2 | 5.63% | |||
DCGT AS TTEE AND/OR CUST FBO ATTN NPIO TRADE DESK 711 HIGH ST DES MOINES IA 50392-0001 |
Class Inst3 | 5.53% | N/A | |
Class R | 8.89% | |||
EMPOWER TRUST FBO 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class Inst3 | 9.84% | N/A | |
FPS TRUST COMPANY FBO 9200 E MINERAL AVE STE 225 CENTENNIAL CO 80112-3592 |
Class R | 9.40% | N/A | |
MATRIX TRUST COMPANY 717 17TH ST STE 1300 DENVER CO 80202-3304 |
Class R | 11.97% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class Adv | 56.60% | N/A | |
Class Inst3 | 47.14% | |||
Class V | 13.51% | |||
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class R | 12.80% | N/A |
Statement of Additional Information – April 27, 2023 | 359 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class C | 7.80% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FBO CUSTOMERS MUTUAL FUNDS 499 WASHINGTON BLVD JERSEY CITY NJ 07310-1995 |
Class A | 5.11% | N/A | |
Class Adv | 5.57% | |||
Class Inst | 11.67% | |||
Class Inst2 | 34.84% | |||
Class Inst3 | 23.03% | |||
Class R | 16.43% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 12.26% | N/A | |
PRINCIPAL TRUST COMPANY FBO ATTN SUSAN SAGGIONE 1013 CENTRE RD STE 300 WILMINGTON DE 19805-1265 |
Class R | 10.72% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 18.45% | N/A | |
Small Cap Growth Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE MINNEAPOLIS MN 55402-2405 |
Class A | 26.86% | N/A |
Class C | 31.02% | |||
Class Inst | 29.10% | |||
BAND & CO C/O US BANK NA 1555 N RIVERCENTER DR STE 302 MILWAUKEE WI 53212-3958 |
Class Inst | 9.30% | N/A | |
CHARLES SCHWAB & CO INC SPECIAL CUSTODY ACCT FBO ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 14.22% | N/A | |
DCGT AS TTEE AND/OR CUST FBO ATTN NPIO TRADE DESK 711 HIGH ST DES MOINES IA 50392-0001 |
Class R | 25.53% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 32.91% | N/A | |
EMPOWER TRUST FBO 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 6.39% | N/A | |
FPS TRUST COMPANY FBO 9200 E MINERAL AVE STE 225 CENTENNIAL CO 80112-3592 |
Class R | 8.03% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 6.13% | N/A | |
JPMCB NA CUST FOR COLUMBIA CAPITAL ALLOCATION MODERATE AGGRESSIVE PORTFOLIO 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 7.51% | N/A |
Statement of Additional Information – April 27, 2023 | 360 |
Statement of Additional Information – April 27, 2023 | 361 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
DCGT AS TTEE AND/OR CUST FBO ATTN NPIO TRADE DESK 711 HIGH ST DES MOINES IA 50392-0001 |
Class R | 17.81% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 24.01% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 8.68% | N/A | |
Class Inst | 7.71% | |||
MAILCODE BD1N ATTN MF C/O RELIANCE TRUST COMPANY WI MARIL & CO FBO JI 4900 W BROWN DEER RD MILWAUKEE WI 53223-2422 |
Class Inst3 | 33.92% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS ATTENTION SERVICE TEAM 4800 DEER LAKE DR E FL 3 JACKSONVILLE FL 32246-6484 |
Class A | 5.69% | N/A | |
Class C | 8.25% | |||
Class Inst | 14.93% | |||
Class Inst3 | 8.50% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 39 NEW YORK NY 10004-1932 |
Class C | 11.51% | N/A | |
Class Inst | 13.32% | |||
NATIONAL FINANCIAL SERVICES LLC FBO CUSTOMERS MUTUAL FUNDS 499 WASHINGTON BLVD JERSEY CITY NJ 07310-1995 |
Class A | 9.02% | N/A | |
Class Adv | 40.60% | |||
Class Inst2 | 47.96% | |||
Class Inst3 | 7.05% | |||
Class R | 10.56% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 33.80% | N/A | |
Class C | 5.74% | |||
Class Inst2 | 7.86% | |||
Class Inst3 | 5.63% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 6.37% | N/A | |
Class Inst | 8.54% | |||
RBC CAPITAL MARKETS LLC MUTUAL FUND OMNIBUS PROCESSING OMNIBUS ATTN MUTUAL FUND OPS MANAGER 250 NICOLLET MALL SUITE 1400 MINNEAPOLIS MN 55401-7554 |
Class Inst | 5.18% | N/A | |
SAMMONS FINANCIAL NETWORK LLC 4546 CORPORATE DR STE 100 WEST DES MOINES IA 50266-5911 |
Class R | 35.10% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 6.71% | N/A | |
UBS WM USA SPEC CDY A/C EXCL BEN CUST UBSFSI 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class Inst | 8.97% | N/A |
Statement of Additional Information – April 27, 2023 | 362 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 16.34% | N/A | |
Class Inst | 10.12% |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
CT Intermediate Municipal Bond Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 29.83% | N/A |
Class C | 43.66% | |||
Class Inst | 27.38% | |||
SEI PRIVATE TRUST COMPANY C/O TIAA-SWP 1 FREEDOM VALLEY DR OAKS PA 19456-9989 |
Class Inst | 8.42% | N/A | |
KELLY F SHACKELFORD PO BOX 672 NEW CANAAN CT 06840-0672 |
Class V | 21.23% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 21.02% | N/A | |
Class Inst | 19.27% | |||
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 8.37% | 48.71% | |
Class Inst | 7.92% | |||
Class Inst3 | 99.26% | |||
Class V | 12.68% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 12 NEW YORK NY 10004-1965 |
Class C | 18.88% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 18.99% | N/A | |
Class Adv | 90.38% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 9.45% | N/A | |
Class V | 5.00% | |||
THOMAS L DERIENZO 682 BUCKS HILL RD SOUTHBURY CT 06488-1951 |
Class A | 5.21% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 13.50% | N/A | |
Class C | 9.30% | |||
Class Inst | 13.73% | |||
Intermediate Duration Municipal Bond Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 18.01% | N/A |
Class C | 22.69% | |||
Class Inst | 20.74% | |||
SEI PRIVATE TRUST COMPANY C/O TIAA-SWP 1 FREEDOM VALLEY DR OAKS PA 19456-9989 |
Class Adv | 59.59% | N/A | |
CAPINCO C/O US BANK NA 1555 N RIVERCENTER DR STE 302 MILWAUKEE WI 53212-3958 |
Class Inst | 7.09% | N/A |
Statement of Additional Information – April 27, 2023 | 363 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
CHARLES SCHWAB & CO INC ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 28.18% | N/A | |
Class Adv | 7.91% | |||
Class Inst2 | 76.82% | |||
Class V | 6.25% | |||
JON R ALMEIDA TTEE JOHN J ALMEIDA REVOCABLE TRUST 27 RIDGEWOOD RD ATTLEBORO MA 02703-6407 |
Class V | 12.42% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 6.30% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class Inst | 13.02% | 27.69% | |
Class Inst3 | 95.28% | |||
Class V | 15.06% | |||
MERRILL LYNCH PIERCE 4800 DEER LAKE DR E FL 2 JACKSONVILLE FL 32246-6484 |
Class V | 6.52% | N/A | |
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 12 NEW YORK NY 10004-1965 |
Class A | 12.43% | N/A | |
Class C | 39.80% | |||
Class Inst | 13.12% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 16.32% | N/A | |
Class Adv | 15.38% | |||
Class Inst2 | 17.91% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 5.93% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Adv | 9.00% | N/A | |
UBS WM USA SPEC CDY 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class Inst | 6.74% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 15.62% | N/A | |
MA Intermediate Municipal Bond Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 9.61% | N/A |
Class C | 69.01% | |||
Class Inst | 43.78% | |||
COLUMBIA MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class Inst2 | 100.00% | N/A(a) | |
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 6.92% | 64.46% | |
Class Inst | 15.75% | |||
Class Inst3 | 99.77% | |||
Class V | 35.33% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 12 NEW YORK NY 10004-1965 |
Class Inst | 7.77% | N/A |
Statement of Additional Information – April 27, 2023 | 364 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 9.99% | N/A | |
Class Adv | 91.23% | |||
Class Inst | 13.83% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 8.64% | N/A | |
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class A | 59.29% | N/A | |
Class C | 20.64% | |||
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 6.84% | N/A | |
NY Intermediate Municipal Bond Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 21.12% | N/A |
Class C | 15.92% | |||
Class Inst | 27.83% | |||
CHARLES SCHWAB & CO INC ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class A | 6.65% | N/A | |
Class Inst2 | 71.05% | |||
J P MORGAN SECURITIES LLC OMNIBUS ACCOUNT FOR THE EXCLUSIVE BENEFIT OF CUSTOMERS 4 CHASE METROTECH CENTER 3RD FL MUTUAL FUND DEPARTMENT BROOKLYN NY 11245-0003 |
Class C | 6.39% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class A | 6.30% | N/A | |
Class C | 16.49% | |||
Class Inst | 5.39% | |||
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 23.79% | 53.54% | |
Class C | 13.84% | |||
Class Inst | 16.15% | |||
Class Inst3 | 97.71% | |||
Class V | 18.18% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 12 NEW YORK NY 10004-1965 |
Class A | 6.90% | N/A | |
Class C | 5.11% | |||
Class V | 7.65% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class A | 5.62% | N/A | |
Class Adv | 34.51% | |||
Class Inst2 | 23.98% | |||
PAUL E HOWARD & JUDITH A HOWARD JTWROS PO BOX 649 SCHOHARIE NY 12157-0649 |
Class V | 8.91% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class A | 7.95% | N/A | |
Class Adv | 65.33% | |||
Class C | 15.84% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class Inst | 9.66% | N/A |
Statement of Additional Information – April 27, 2023 | 365 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 8.42% | N/A | |
Class C | 10.92% | |||
Class Inst | 6.10% | |||
Select Global Equity Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 72.95% | 67.68% |
Class C | 58.45% | |||
Class Inst | 75.27% | |||
ASCENSUS TRUST COMPANY FBO PO BOX 10758 FARGO ND 58106-0758 |
Class R | 14.02% | N/A | |
CHARLES SCHWAB & CO INC ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 35.15% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 81.41% | N/A | |
FIIOC FBO 100 MAGELLAN WAY # KW1C COVINGTON KY 41015-1987 |
Class R | 6.18% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class Adv | 7.13% | N/A | |
Class Inst | 11.03% | |||
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class R | 11.86% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 23.32% | N/A | |
Class Inst2 | 43.51% | |||
Class R | 21.97% | |||
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 69.31% | N/A | |
PIMS/PRUDENTIAL RETIREMENT AS NOMINEE FOR THE TTEE/CUST PL BRITZ INC 401(K) PLAN 3265 W FIGARDEN DR FRESNO CA 93711-3912 |
Class R | 20.91% | N/A | |
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class C | 15.44% | N/A | |
STATE STREET BANK AND TRUST AS TRUSTEE AND/OR CUSTODIAN FBO ADP ACCESS PRODUCT 1 LINCOLN ST BOSTON MA 02111-2901 |
Class Inst2 | 5.51% | N/A | |
Class R | 12.12% | |||
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 6.54% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 5.48% | N/A |
Statement of Additional Information – April 27, 2023 | 366 |
Statement of Additional Information – April 27, 2023 | 367 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 18.90% | N/A | |
THE HARTFORD 1 HARTFORD PLZ HARTFORD CT 06155-0001 |
Class Inst3 | 14.46% | N/A | |
UBS WM USA SPEC CDY 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class Inst | 9.63% | N/A | |
VENERABLE INSURANCE & ANNUITY CO 1475 DUNWOODY DR WESTCHESTER PA 19380-1478 |
Class Adv | 5.00% | N/A | |
Class R | 67.37% | |||
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 11.71% | N/A | |
Class Inst | 10.59% | |||
Strategic CA Municipal Income Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 35.82% | 34.56% |
Class C | 38.42% | |||
Class Inst | 39.26% | |||
CHARLES SCHWAB & CO INC ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 65.31% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 30.18% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 5.50% | N/A | |
Class Inst | 6.68% | |||
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 10.72% | N/A | |
Class C | 10.36% | |||
Class Inst | 13.19% | |||
Class Inst3 | 69.05% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 12 NEW YORK NY 10004-1965 |
Class A | 6.46% | N/A | |
Class Inst | 14.45% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 84.54% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 13.72% | N/A | |
Class Inst2 | 24.61% | |||
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 9.65% | N/A | |
UBS WM USA SPEC CDY 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class A | 5.27% | N/A | |
Class Inst | 5.93% |
Statement of Additional Information – April 27, 2023 | 368 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 8.48% | N/A | |
Class C | 27.36% | |||
Class Inst | 6.80% | |||
Strategic NY Municipal Income Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 19.75% | N/A |
Class C | 28.20% | |||
Class Inst | 39.42% | |||
CHARLES SCHWAB & CO INC ATTN MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class Inst2 | 57.04% | N/A | |
EDWARD D JONES & CO FOR THE BENEFIT OF CUSTOMERS 12555 MANCHESTER RD SAINT LOUIS MO 63131-3710 |
Class Inst3 | 26.40% | N/A | |
LPL FINANCIAL 9785 TOWNE CENTRE DR SAN DIEGO CA 92121-1968 |
Class C | 6.08% | N/A | |
Class Inst | 18.63% | |||
MERRILL LYNCH PIERCE FENNER & SMITH INC FOR THE SOLE BENEFIT OF ITS CUSTOMERS 4800 DEER LAKE DR E JACKSONVILLE FL 32246-6484 |
Class A | 11.46% | N/A | |
Class C | 6.92% | |||
Class Inst | 12.06% | |||
Class Inst3 | 71.83% | |||
MORGAN STANLEY SMITH BARNEY LLC FOR THE EXCLUSIVE BENE OF ITS CUST 1 NEW YORK PLZ FL 12 NEW YORK NY 10004-1965 |
Class A | 5.14% | N/A | |
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 33.48% | N/A | |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Adv | 61.93% | N/A | |
Class C | 8.98% | |||
Class Inst2 | 28.68% | |||
RAYMOND JAMES FBO OMNIBUS FOR MUTUAL FUNDS ATTN: COURTNEY WALLER 880 CARILLON PKWY ST PETERSBURG FL 33716-1100 |
Class Inst | 10.20% | N/A | |
STIFEL NICOLAUS & CO INC EXCLUSIVE BENEFIT OF CUSTOMERS 501 N BROADWAY SAINT LOUIS MO 63102-2188 |
Class C | 7.59% | N/A | |
TD AMERITRADE INC FOR THE EXCLUSIVE BENEFIT OF OUR CLIENTS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 13.52% | N/A | |
UBS WM USA SPEC CDY 1000 HARBOR BLVD WEEHAWKEN NJ 07086-6761 |
Class C | 8.06% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class A | 6.72% | N/A | |
Class C | 17.00% |
Statement of Additional Information – April 27, 2023 | 369 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
Real Estate Equity Fund | AMERICAN ENTERPRISE INVESTMENT SVC 707 2ND AVE S MINNEAPOLIS MN 55402-2405 |
Class A | 65.95% | N/A |
Class C | 35.75% | |||
AMERICAN TITLE CO JACKSON INC TTEE C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 5.96% | N/A | |
ASCENSUS TRUST COMPANY FBO PO BOX 10758 FARGO ND 58106-0758 |
Class C | 17.82% | N/A | |
Class R | 9.42% | |||
C/O ROCKLAND SWP SEI PRIVATE TRUST COMPANY 1 FREEDOM VALLEY DR OAKS PA 19456-9989 |
Class Inst3 | 47.46% | N/A | |
CAPITAL BANK & TRUST CO TTEE FBO 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 25.71% | N/A | |
CHARLES J BOGDAN TTEE FBO OHIO HEAD & NECK SURGEONS INC 401K C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 9.64% | N/A | |
CHARLES SCHWAB & CO INC CUST A/C FOR THE EXCLUSIVE BENEFIT ATTENTION MUTUAL FUNDS 101 MONTGOMERY ST SAN FRANCISCO CA 94104-4151 |
Class C | 7.16% | N/A | |
Class Inst | 13.51% | |||
Class Inst2 | 29.58% | |||
JAMES GILSON & GLENN TORNILLO TTEE C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 5.47% | N/A | |
JOHN SULLIVAN TTEE FBO TMI GROUP 401K PSP 8515 E ORCHARD RD GREENWOOD VLG CO 80111-5002 |
Class R | 5.29% | N/A | |
JPMCB NA CUST FOR COLUMBIA INCOME BUILDER FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class Inst3 | 50.54% | N/A | |
LINCOLN INVESTMENT PLANNING LLC FBO LINCOLN CUSTOMERS 601 OFFICE CENTER DR STE 300 FT WASHINGTON PA 19034-3275 |
Class Adv | 66.02% | N/A | |
MERRILL LYNCH PIERCE FENNER & SMITH FBO 4800 DEER LAKE DR E FL 2 JACKSONVILLE FL 32246-6484 |
Class Adv | 7.89% | N/A | |
MID ATLANTIC TRUST COMPANY FBO 1251 WATERFRONT PL STE 525 PITTSBURGH PA 15222-4228 |
Class Inst2 | 21.64% | N/A | |
Class R | 5.45% | |||
NATIONAL FINANCIAL SERVICES LLC FEBO CUSTOMERS MUTUAL FUNDS 200 LIBERTY STREET 1WFC NEW YORK NY 10281-1015 |
Class Adv | 9.61% | N/A | |
Class Inst | 6.32% | |||
O AGUIRRE R FIELDS & R FIELDS TTEE C/O FASCORE LLC 8515 E ORCHARD RD # 2T2 GREENWOOD VLG CO 80111-5002 |
Class R | 6.11% | N/A |
Statement of Additional Information – April 27, 2023 | 370 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage of Fund (if greater than 25%) |
PERSHING LLC 1 PERSHING PLZ JERSEY CITY NJ 07399-0002 |
Class Inst2 | 11.47% | N/A | |
S GOLDBERG H MATRI & M BERMAN TTEE C/O FASCORE LLC 8515 E ORCHARD RD GREENWOOD VLG CO 80111-5002 |
Class Inst2 | 21.95% | N/A | |
TD AMERITRADE INC FBO OUR CUSTOMERS PO BOX 2226 OMAHA NE 68103-2226 |
Class Inst2 | 13.93% | N/A | |
WELLS FARGO CLEARING SERVICES LLC SPECIAL CUSTODY ACCT FOR THE EXCLUSIVE BENEFIT OF CUSTOMER 2801 MARKET ST SAINT LOUIS MO 63103-2523 |
Class C | 14.29% | N/A |
(a) | Combination of all share classes of Columbia Management initial capital and/or affiliated funds-of-funds’ investments. |
Statement of Additional Information – April 27, 2023 | 371 |
Statement of Additional Information – April 27, 2023 | 372 |
Statement of Additional Information – April 27, 2023 | A-1 |
Statement of Additional Information – April 27, 2023 | A-2 |
Statement of Additional Information – April 27, 2023 | A-3 |
Long-Term Rating | Short-Term Rating |
AAA | F1+ |
AA+ | F1+ |
AA | F1+ |
AA– | F1+ |
A+ | F1 or F1+ |
A | F1 or F1+ |
A– | F2 or F1 |
BBB+ | F2 or F1 |
BBB | F3 or F2 |
BBB– | F3 |
BB+ | B |
BB | B |
BB– | B |
B+ | B |
B | B |
B– | B |
CCC+ / CCC / CCC– | C |
CC | C |
C | C |
RD / D | RD / D |
Statement of Additional Information – April 27, 2023 | A-4 |
Statement of Additional Information – April 27, 2023 | A-5 |
■ | There is a missed interest payment, principal payment, or preferred dividend payment, as applicable, on a rated obligation which is unlikely to be recovered. |
■ | The rated entity files for protection from creditors, is placed into receivership, or is closed by regulators such that a missed payment is likely to result. |
■ | The rated entity seeks and completes a distressed exchange, where existing rated obligations are replaced by new obligations with a diminished economic value. |
Statement of Additional Information – April 27, 2023 | A-6 |
■ | There is a missed interest payment, principal payment, or preferred dividend payment, as applicable, on a rated obligation which is unlikely to be recovered. |
■ | The rated entity files for protection from creditors, is placed into receivership, or is closed by regulators such that a missed payment is likely to result. |
■ | The rated entity seeks and completes a distressed exchange, where existing rated obligations are replaced by new obligations with a diminished economic value. |
Statement of Additional Information – April 27, 2023 | A-7 |
1 Overview of key principles and approach | B-1 |
2 Role, structure and operation of boards | B-2 |
3 Board committees | B-5 |
4 Compensation | B-6 |
5 Audit, risk and control | B-7 |
6 Shareholder rights | B-8 |
7 Reporting | B-9 |
8 Social and environmental factors | B-11 |
9 Voting matters | B-13 |
■ | An empowered and effective board and management; |
■ | Appropriate checks and balances in company management structures; |
■ | Effective systems of internal control and risk management covering all material risks, including environmental, social and corporate governance (ESG) issues; |
■ | A commitment to promoting throughout the company a culture of transparency and accountability that is grounded in sound business ethics; |
■ | Compensation policies that reward the creation of long-term shareholder value through the achievement of corporate objectives; and |
■ | A commitment to protecting the rights and interests of all. |
Statement of Additional Information – April 27, 2023 | B-1 |
■ | Roles and independence; |
■ | Competence, objectivity and refreshment; |
■ | Effective functioning of boards; and |
■ | Communication and accountability to shareholders. |
Statement of Additional Information – April 27, 2023 | B-2 |
■ | Not be former executives of the company. We do not support the idea of a cooling off period for former executives, although in the case of individuals who have served in a junior capacity, a hiatus may be appropriate; |
■ | Not have close family ties with the company’s advisers, directors or senior employees; |
■ | Not serve as a board committee chair if they have served on the board for a period of time that may hinder their independence of thought; |
■ | Not hold cross-directorships or have significant links with other directors (see “Interlocking boards” below); |
■ | Not be major shareholders or representatives of any special interest group, including government representatives in cases of state ownership or representatives of affiliated companies; |
■ | Have no significant commercial involvement with the company as professional advisers, major suppliers or customers; |
■ | Not be entitled to performance-related pay, stock options, pensions, or benefit from large donations to charitable causes of their choice; |
■ | Not normally hold other directorships in companies in a closely-related industry so as to avoid potential conflicts of interest. |
Statement of Additional Information – April 27, 2023 | B-3 |
Statement of Additional Information – April 27, 2023 | B-4 |
Statement of Additional Information – April 27, 2023 | B-5 |
Statement of Additional Information – April 27, 2023 | B-6 |
Statement of Additional Information – April 27, 2023 | B-7 |
Statement of Additional Information – April 27, 2023 | B-8 |
■ | Comprehensive, covering the strategic direction of the business and all material issues, including any significant changes in the regulatory context and key ESG issues; |
■ | Balanced, with even-handed treatment of both good and bad aspects of a company; |
■ | Transparent, with narrative text that leverages plain language, and accounting notes that provide investors with a full understanding of the circumstances underlying the reported figures; |
■ | Underpinned by Key Performance Indicators (KPIs) that drive business performance, are comparable over time, and are supported by detailed information on how they are calculated; |
■ | Consistent and joined-up with other company reporting, including the compensation policy and corporate social responsibility or sustainability reporting. |
Statement of Additional Information – April 27, 2023 | B-9 |
Statement of Additional Information – April 27, 2023 | B-10 |
Statement of Additional Information – April 27, 2023 | B-11 |
Statement of Additional Information – April 27, 2023 | B-12 |
Statement of Additional Information – April 27, 2023 | B-13 |
i | The following guidelines do not apply to Pyrford International Ltd. |
ii | Such interlocking relationships can raise concerns when there is an imbalance of power between the two directors. |
iii | https://www.fsb-tcfd.org/publications/final-recommendations-report/. |
iv | UK Modern Slavery Act, OECD Guidelines for Multinational Enterprises. |
v | EU corporate mandatory human rights due diligence, Swiss mandatory human rights DD (focus weapons), German Supply Chain Code |
vi | See vote disclosure webpage here. |
Statement of Additional Information – April 27, 2023 | B-14 |
■ | the inability or perceived inability of a government authority to collect sufficient tax or other revenues to meet its payment obligations; |
■ | natural disasters, public health crises and ecological or environmental concerns; |
■ | the introduction of constitutional or statutory limits on a tax-exempt issuer’s ability to raise revenues or increase taxes; |
■ | the inability of an issuer to pay interest on or to repay principal or securities in which the funds invest during recessionary periods; and |
■ | economic or demographic factors that may cause a decrease in tax or other revenues for a government authority or for private operators of publicly financed facilities. |
Statement of Additional Information – April 27, 2023 | C-1 |
Statement of Additional Information – April 27, 2023 | C-2 |
Statement of Additional Information – April 27, 2023 | C-3 |
Statement of Additional Information – April 27, 2023 | C-4 |
Statement of Additional Information – April 27, 2023 | C-5 |
Statement of Additional Information – April 27, 2023 | C-6 |
Statement of Additional Information – April 27, 2023 | C-7 |
Statement of Additional Information – April 27, 2023 | C-8 |
Statement of Additional Information – April 27, 2023 | C-9 |
Statement of Additional Information – April 27, 2023 | C-10 |
Statement of Additional Information – April 27, 2023 | C-11 |
Statement of Additional Information – April 27, 2023 | C-12 |
Statement of Additional Information – April 27, 2023 | C-13 |
Statement of Additional Information – April 27, 2023 | C-14 |
Statement of Additional Information – April 27, 2023 | C-15 |
Statement of Additional Information – April 27, 2023 | C-16 |
Statement of Additional Information – April 27, 2023 | C-17 |
Statement of Additional Information – April 27, 2023 | C-18 |
Statement of Additional Information – April 27, 2023 | C-19 |
■ | Current or retired fund Board members, officers or employees of the funds or Columbia Management or its affiliates(b); |
■ | Current or retired Ameriprise Financial Services, LLC (Ameriprise Financial Services) financial advisors and employees of such financial advisors(b); |
■ | Registered representatives and other employees of affiliated or unaffiliated financial intermediaries (and their immediate family members and related trusts or other entities owned by the foregoing) having a selling agreement with the Distributor(b); |
■ | Registered broker-dealer firms that have entered into a dealer agreement with the Distributor may buy Class A shares without paying a front-end sales charge for their investment account only; |
■ | Portfolio managers employed by subadvisers of the funds(b); |
■ | Partners and employees of outside legal counsel to the funds or to the funds’ directors or trustees who regularly provide advice and services to the funds, or to their directors or trustees; |
■ | Direct rollovers (i.e., rollovers of fund shares and not reinvestments of redemption proceeds) from qualified employee benefit plans, provided that the rollover involves a transfer to Class A shares in the same fund; |
■ | Employees or partners of Columbia Wanger Asset Management, LLC; |
■ | Separate accounts established and maintained by an insurance company which are exempt from registration under Section 3(c)(11); |
■ | At a fund’s discretion, front-end sales charges may be waived for shares issued in plans of reorganization, such as mergers, asset acquisitions and exchange offers, to which the fund is a party; |
■ | Purchases by registered representatives and employees (and their immediate family members and related trusts or other entities owned by the foregoing (referred to as “Related Persons”)) of Ameriprise Financial Services and its affiliates; provided that with respect to employees (and their Related Persons) of an affiliate of Ameriprise Financial, such persons must make purchases through an account held at Ameriprise Financial or its affiliates. |
■ | Through or under a wrap fee product or other investment product sponsored by a financial intermediary that charges an account management fee or other managed agency/asset allocation accounts or programs involving fee-based compensation arrangements that have or that clear trades through a financial intermediary that has a selling agreement with the Distributor; |
■ | Through state sponsored college savings plans established under Section 529 of the Internal Revenue Code; |
■ | Through banks, trust companies and thrift institutions, acting as fiduciaries; or |
Statement of Additional Information – April 27, 2023 | S-1 |
■ | Through “employee benefit plans” created under Section 401(a), 401(k), 457 and 403(b), and qualified deferred compensation plans, that have a plan level or omnibus account maintained with the Fund or the Transfer Agent and transact directly with the Fund or the Transfer Agent through a third-party administrator or third-party recordkeeper. This waiver does not apply to accounts held through commissionable brokerage platforms. |
* | Any shareholder with a Direct-at-Fund account (i.e., shares held directly with the Fund through the Transfer Agent) that is eligible to purchase shares without a front-end sales charge by virtue of having qualified for a previous waiver may continue to purchase shares without a front-end sales charge if they no longer qualify under a category described in the prospectus or in this section. Otherwise, you must qualify for a front-end sales charge waiver described in the prospectus or in this section. |
(a) | The Funds no longer accept investments from new or existing investors in Class E shares, except by existing Class E and former Class F shareholders who opened and funded their account prior to September 22, 2006 that may continue to invest in Class E shares (Class F shares automatically converted to Class E shares on July 17, 2017). See the prospectus offering Class E shares of Columbia Large Cap Growth Fund (a series of CFST I) for details. |
(b) | Including their spouses or domestic partners, children or step-children, parents, step-parents or legal guardians, and their spouse’s or domestic partner’s parents, step-parents, or legal guardians. |
■ | In the event of the shareholder’s death; |
■ | For which no sales commission or transaction fee was paid to an authorized financial intermediary at the time of purchase; |
■ | Purchased through reinvestment of dividend and capital gain distributions; |
■ | That result from required minimum distributions taken from retirement accounts upon the shareholder’s attainment of the qualified age based on applicable IRS regulations; |
■ | That result from returns of excess contributions made to retirement plans or individual retirement accounts, so long as the financial intermediary returns the applicable portion of any commission paid by the Distributor; |
■ | For Class A shares: initially purchased by an employee benefit plan; |
■ | For Class C, Class E, and Class V shares: initially purchased by an employee benefit plan that are not connected with a plan level termination; |
■ | In connection with the fund’s Small Account Policy (as described in the prospectus); and |
■ | Issued in connection with plans of reorganization, including but not limited to mergers, asset acquisitions and exchange offers, to which the fund is a party and at the fund’s discretion. |
■ | Any client of Bank of America or one of its subsidiaries buying shares through an asset management company, trust, fiduciary, retirement plan administration or similar arrangement with Bank of America or the subsidiary. |
■ | Any employee (or family member of an employee) of Bank of America or one of its subsidiaries. |
■ | Any investor buying shares through a Columbia Management state tuition plan organized under Section 529 of the Internal Revenue Code. |
■ | Any trustee or director (or family member of a trustee or director) of a fund distributed by the Distributor. |
■ | Other than for the Multi-Manager Strategies Funds, any shareholder (as well as any family member of a shareholder or person listed on an account registration for any account of the shareholder) who holds Class Inst shares of a fund distributed by the Distributor is eligible to purchase Class Inst shares of other funds distributed by the Distributor, subject to a minimum initial investment of $2,000 ($1,000 for IRAs). If the account in which the shareholder holds Class Inst shares is not eligible to purchase additional Class Inst shares, the shareholder may purchase Class Inst shares in an account maintained directly with the Transfer Agent, subject to a minimum initial investment of $2,000 ($1,000 for IRAs). |
Statement of Additional Information – April 27, 2023 | S-2 |
Exhibit Number |
Exhibit Description | Filed Herewith or Incorporated by Reference |
Information About the Filing that Includes the Document Incorporated by Reference | ||||
Registrant that Made the Filing |
File No. of Such Registrant |
Type of Filing |
Exhibit of Document in that Filing |
Filing Date | |||
(a)(1) | Second Amended and Restated Agreement and Declaration of Trust, effective August 10, 2005 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #40 on Form N-1A | (a)(1) | 9/16/2005 |
(a)(2) | Amendment No. 1 to Second Amended and Restated Agreement and Declaration of Trust, effective September 19, 2005 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #40 on Form N-1A | (a)(2) | 9/16/2005 |
(a)(3) | Amendment No. 2 to Second Amended and Restated Agreement and Declaration of Trust, effective December 13, 2017 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #313 on Form N-1A | (a)(3) | 1/16/2018 |
(a)(4) | Amendment No. 3 to Second Amended and Restated Agreement and Declaration of Trust, effective March 7, 2018 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #318 on Form N-1A | (a)(4) | 3/29/2018 |
(a)(5) | Amendment No. 4 to Second Amended and Restated Agreement and Declaration of Trust, effective December 13, 2018 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #342 on Form N-1A | (a)(5) | 12/21/2018 |
(a)(6) | Amendment No. 5 to Second Amended and Restated Agreement and Declaration of Trust, effective June 12, 2019 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #351 on Form N-1A | (a)(6) | 6/21/2019 |
(a)(7) | Amendment No. 6 to Second Amended and Restated Agreement and Declaration of Trust, effective December 11, 2019 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #369 on Form N-1A | (a)(7) | 12/20/2019 |
(a)(8) | Amendment No. 7 to Second Amended and Restated Agreement and Declaration of Trust, effective October 9, 2020 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #383 on Form N-1A | (a)(8) | 12/23/2020 |
(a)(9) | Amendment No. 8 to Second Amended and Restated Agreement and Declaration of Trust, effective July 19, 2021 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #386 on Form N-1A | (a)(9) | 7/28/2021 |
(a)(10) | Amendment No. 9 to Second Amended and Restated Agreement and Declaration of Trust, effective June 23, 2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #395 on Form N-1A | (a)(10) | 7/18/2022 |
(a)(11) | Amendment No. 10 to Second Amendment and Restated Declaration of Trust, effective September 1, 2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #398 on Form N-1A | (a)(11) | 9/26/2022 |
(b) | By-Laws as amended November 2020 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #383 on Form N-1A | (b) | 12/23/2020 |
(c) | Not Applicable. | ||||||
(d)(1) | Amended and Restated Management Agreement, as of April 25, 2016, between Columbia Management Investment Advisers, LLC, Columbia Funds Variable Insurance Trust and the Registrant | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #257 on Form N-1A | (d)(1) | 4/27/2016 |
(d)(1)(i) | Schedule A and Schedule B, effective July 1, 2022, to the Management Agreement (amended and restated), dated April 25, 2016, between Columbia Management Investment Advisers, LLC, the Registrant, and Columbia Funds Variable Insurance Trust | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #395 on Form N-1A | (d)(1)(i) | 7/18/2022 |
Exhibit Number |
Exhibit Description | Filed Herewith or Incorporated by Reference |
Information About the Filing that Includes the Document Incorporated by Reference | ||||
Registrant that Made the Filing |
File No. of Such Registrant |
Type of Filing |
Exhibit of Document in that Filing |
Filing Date | |||
(g)(8) | Addendum to Master Global Custody Agreement (related to Columbia Adaptive Retirement 2025 Fund, Columbia Adaptive Retirement 2035 Fund, Columbia Adaptive Retirement 2045 Fund and Columbia Adaptive Retirement 2055 Fund) | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #318 on Form N-1A | (g)(8) | 3/29/2018 |
(g)(9) | Addendum to Master Global Custody Agreement (related to Multi-Manager International Equity Strategies Fund) | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #324 on Form N-1A | (g)(9) | 5/4/2018 |
(g)(10) | Addendum to Master Global Custody Agreement (related to Overseas SMA Completion Portfolio) | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #364 on Form N-1A | (g)(10) | 9/3/2019 |
(g)(11) | Addendum to Master Global Custody Agreement (related to Multisector Bond SMA Completion Portfolio) | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #364 on Form N-1A | (g)(11) | 10/25/2019 |
(g)(12) | Addendum, effective April 1, 2016, to the Second Amended and Restated Master Global Custody Agreement with JP Morgan Chase Bank, N.A., dated March 7, 2011 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #297 on Form N-1A | (g)(7) | 5/30/2017 |
(g)(13) | Custodian Agreement between Columbia Funds Series Trust, Columbia Funds Series Trust I and State Street Bank & Trust Company, dated January 21, 2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #402 on Form N-1A | (g)(13) | 12/21/2022 |
(g)(14) | Appendix A to the Custodian Agreement between Columbia Funds Series Trust, Columbia Funds Series Trust I and State Street Bank & Trust Company, dated January 21, 2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #402 on Form N-1A | (g)(14) | 12/21/2022 |
(h)(1) | Transfer and Dividend Disbursing Agent Agreement by and between Columbia Management Investment Services Corp., Columbia Funds Series Trust, Columbia Funds Series Trust II and the Registrant, dated June 15, 2021 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #386 on Form N-1A | (h)(1) | 7/28/2021 |
(h)(1)(i) | Schedule A and Schedule B, effective March 1, 2023, to the Transfer and Dividend Disbursing Agent Agreement by and between Columbia Management Investment Services Corp., the Registrant, Columbia Funds Series Trust and Columbia Funds Series Trust II, dated June 15, 2021 | Filed Herewith | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #404 on Form N-1A | (h)(1)(i) | 4/27/2023 |
(h)(2) | Form of Indemnification Agreement | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #46 on Form N-1A | (h)(6) | 3/24/2006 |
Exhibit Number |
Exhibit Description | Filed Herewith or Incorporated by Reference |
Information About the Filing that Includes the Document Incorporated by Reference | ||||
Registrant that Made the Filing |
File No. of Such Registrant |
Type of Filing |
Exhibit of Document in that Filing |
Filing Date | |||
(h)(10) | Master Inter-Fund Lending Agreement, dated May 1, 2018 | Incorporated by Reference | Columbia Funds Series Trust II | 333-131683 | Post-Effective Amendment #179 on Form N-1A | (h)(11) | 5/25/2018 |
(h)(10)(i) | Schedule A and Schedule B, effective July 1, 2022, to the Master Inter-Fund Lending Agreement dated May 1, 2018 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #395 on Form N-1A | (h)(10)(i) | 7/18/2022 |
(h)(11) | Fund of Fund Investment Management Agreement, dated January 19, 2022, between BlackRock ETF Trust, BlackRock ETF Trust II, iShares Trust, iShares, Inc., IShares U.S. ETF Trust and Columbia Funds Series Trust, Columbia Funds Series Trust I, Columbia Funds Series Trust II, Columbia Funds Variable Insurance Trust and Columbia Funds Variable Series Trust II | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #392 on Form N-1A | (h)(11) | 2/17/2022 |
(h)(12) | Fund of Fund Investment Management Agreement, dated December 21, 2021, between Fidelity Rutland Square Trust II and Columbia Funds Series Trust I and Columbia Funds Series Trust II | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #392 on Form N-1A | (h)(12) | 2/17/2022 |
(h)(13) | Fund of Fund Investment Management Agreement, dated January 19, 2022, between Vanguard Funds and Columbia Funds Series Trust I, Columbia Funds Variable Insurance Trust and Columbia Funds Variable Series Trust II | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #392 on Form N-1A | (h)(13) | 2/17/2022 |
(i)(1) | Opinion of Counsel of Ropes & Gray LLP | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #40 on Form N-1A | (i) | 9/16/2005 |
(i)(2) | Opinion of Counsel of Ropes & Gray LLP | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #68 on Form N-1A | (i)(2) | 1/16/2008 |
(i)(3) | Opinion of Counsel of Ropes & Gray LLP | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #81 on Form N-1A | (i)(3) | 11/25/2008 |
(i)(4) | Opinion of Counsel of Ropes & Gray LLP | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #95 on Form N-1A | (i)(4) | 11/20/2009 |
(i)(5) | Opinion of Counsel of Ropes & Gray LLP | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #143 on Form N-1A | (i)(5) | 3/14/2012 |
(i)(6) | Opinion of Counsel of Ropes & Gray LLP, with respect to Columbia Adaptive Risk Allocation Fund | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #153 on Form N-1A | (i)(6) | 6/15/2012 |
(i)(7) | Opinion of Counsel of Ropes & Gray LLP, with respect to Columbia Multi Strategy Alternatives Fund | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #219 on Form N-1A | (i)(8) | 1/27/2015 |
(i)(8) | Opinion of Counsel of Ropes & Gray LLP, with respect to Columbia Multi-Asset Income Fund and Columbia U.S. Social Bond Fund | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #223 on Form N-1A | (i)(9) | 3/24/2015 |
(i)(9) | Opinion of Counsel of Ropes & Gray LLP, with respect to Multi-Manager Directional Alternative Strategies Fund | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #276 on Form N-1A | (i)(10) | 9/30/2016 |
Exhibit Number |
Exhibit Description | Filed Herewith or Incorporated by Reference |
Information About the Filing that Includes the Document Incorporated by Reference | ||||
Registrant that Made the Filing |
File No. of Such Registrant |
Type of Filing |
Exhibit of Document in that Filing |
Filing Date | |||
(i)(10) | Opinion of Counsel of Ropes & Gray LLP, with respect to Columbia Adaptive Retirement 2020 Fund, Columbia Adaptive Retirement 2030 Fund, Columbia Adaptive Retirement 2040 Fund, Columbia Adaptive Retirement 2050 Fund, Columbia Adaptive Retirement 2060 Fund, Columbia Solutions Aggressive Portfolio and Columbia Solutions Conservative Portfolio | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #308 on Form N-1A | (i)(11) | 10/20/2017 |
(i)(11) | Opinion of Counsel of Ropes & Gray LLP, with respect to Columbia Adaptive Retirement 2025 Fund, Columbia Adaptive Retirement 2035 Fund, Columbia Adaptive Retirement 2045 Fund and Columbia Adaptive Retirement 2055 Fund | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #313 on Form N-1A | (i)(12) | 1/16/2018 |
(i)(12) | Opinion of Counsel of Ropes & Gray LLP, with respect to Multi-Manager International Equity Strategies Fund | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #324 on Form N-1A | (i)(13) | 5/4/2018 |
(i)(13) | Opinion of Counsel of Ropes & Gray LLP, with respect to Overseas SMA Completion Portfolio | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #357 on Form N-1A | (i)(13) | 9/3/2019 |
(i)(14) | Opinion of Counsel of Ropes & Gray LLP, with respect to Multisector Bond SMA Completion Portfolio | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #364 on Form N-1A | (i)(14) | 10/25/2019 |
(j)(1) | Consent of Morningstar, Inc. | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #21 on Form N-1A | 11(b) | 8/30/1996 |
(j)(2) | Consent of PricewaterhouseCoopers LLP, dated July 26, 2022, for Funds with fiscal year ended 3/31/2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #396 on Form N-1A | (j)(2) | 7/27/2022 |
(j)(3) | Consent of PricewaterhouseCoopers LLP, dated August 24, 2022, for Funds with fiscal year ended 4/30/2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #397 on Form N-1A | (j)(2) | 8/25/2022 |
(j)(4) | Consent of PricewaterhouseCoopers LLP, dated September 23, 2022, for Funds with fiscal year ended 5/31/2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #398 on Form N-1A | (j)(2) | 9/26/2022 |
(j)(5) | Consent of PricewaterhouseCoopers LLP, dated November 21, 2022, for Funds with fiscal year ended 7/31/2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #400 on Form N-1A | (j)(2) | 11/22/2022 |
(j)(6) | Consent of PricewaterhouseCoopers LLP, dated December 20, 2022, for Funds with fiscal year ended 8/31/2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #402 on Form N-1A | (j)(2) | 12/21/2022 |
(j)(7) | Consent of PricewaterhouseCoopers LLP, dated February 24, 2023, for Funds with fiscal year ended 10/31/2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #403 on Form N-1A | (j)(2) | 2/27/2023 |
(j)(8) | Consent of PricewaterhouseCoopers LLP, dated April 26, 2023, for the Fund with fiscal year ended 12/31/2022 | Filed Herewith | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #404 on Form N-1A | (j)(8) | 4/27/2023 |
(k) | Omitted Financial Statements: Not Applicable. | ||||||
(l) | Initial Capital Agreement: Not Applicable. |
Exhibit Number |
Exhibit Description | Filed Herewith or Incorporated by Reference |
Information About the Filing that Includes the Document Incorporated by Reference | ||||
Registrant that Made the Filing |
File No. of Such Registrant |
Type of Filing |
Exhibit of Document in that Filing |
Filing Date | |||
(m)(1) | Amended and Restated Distribution Plan, as of June 23, 2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #400 on Form N-1A | (m)(1) | 11/22/2022 |
(m)(2) | Amended and Restated Shareholder Servicing Plan, as of July 1, 2022, for certain Fund share classes of the Registrant | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #395 on Form N-1A | (m)(2) | 7/18/2022 |
(m)(3) | Amended and Restated Shareholder Services Plan, as of July 10, 2020, for Registrant’s Class V (formerly known as Class T) | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #376 on Form N-1A | (m)(3) | 7/28/2020 |
(m)(4) | Shareholder Servicing Plan Implementation Agreement, amended and restated as of June 14, 2017, for Registrant’s Class V (formerly known as Class T) shares between the Registrant and Columbia Management Investment Distributors, Inc | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #299 on Form N-1A | (m)(4) | 7/28/2017 |
(m)(4)(i) | Restated Schedule I, effective July 1, 2022 to Shareholder Servicing Plan Implementation Agreement for Registrant’s Class V (formerly known as Class T) shares between the Registrant and Columbia Management Investment Distributors, Inc | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #395 on Form N-1A | (m)(4)(i) | 7/18/2022 |
(m)(5) | Shareholder Servicing Plan Implementation Agreement between Registrant and Columbia Management Investment Distributors, Inc. | Incorporated by Reference | Columbia Funds Series Trust | 333-89661 | Post-Effective Amendment #82 on Form N-1A | (m)(4) | 5/28/2010 |
(m)(5)(i) | Restated Schedule I, dated July 1, 2022, to Shareholder Servicing Plan Implementation Agreement, between the Registrant, Columbia Funds Series Trust and Columbia Management Investment Distributors, Inc. | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #395 on Form N-1A | (m)(5)(i) | 7/18/2022 |
(n) | Rule 18f – 3 Multi-Class Plan, amended and restated as of June 17, 2020 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #376 on Form N-1A | (n) | 7/28/2020 |
(o) | Reserved | ||||||
(p)(1) | Code of Ethics of Columbia Atlantic Board Funds adopted under Rule 17j-1, effective March 2019 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #349 on Form N-1A | (p)(1) | 4/25/2019 |
(p)(2) | Columbia Threadneedle Investments Global Personal Account Dealing and Code of Ethics, effective November 22, 2022 | Incorporated by Reference | Columbia ETF Trust I | 333-209996 | Post-Effective Amendment #29 on Form N-1A | (p)(2) | 12/16/2022 |
(p)(3) | Code of Ethics of AQR Capital Management, LLC (a subadviser of Columbia Multi Strategy Alternatives Fund, Multi-Manager Alternative Strategies Fund and Multi-Manager Directional Alternative Strategies Fund), effective December 2022 | Filed Herewith | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #404 on Form N-1A | (p)(3) | 4/27/2023 |
Exhibit Number |
Exhibit Description | Filed Herewith or Incorporated by Reference |
Information About the Filing that Includes the Document Incorporated by Reference | ||||
Registrant that Made the Filing |
File No. of Such Registrant |
Type of Filing |
Exhibit of Document in that Filing |
Filing Date | |||
(p)(4) | Code of Ethics of Prudential Financial (for PGIM, Inc., a subadviser of Multi-Manager Total Return Bond Strategies Fund), dated August 29, 2018 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #338 on Form N-1A | (p)(6)(i) | 11/27/2018 |
(p)(4)(i) | Code of Ethics of Prudential Financial, dated January 10, 2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #395 on Form N-1A | (p)(4)(i) | 7/18/2022 |
(p)(4)(ii) | Personal Securities Trading Standards of Prudential Financial (for PGIM, Inc., a subadviser of Multi-Manager Total Return Bond Strategies Fund), dated April 27, 2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #397 on Form N-1A | (p)(4)(ii) | 8/25/2022 |
(p)(4)(iii) | U.S. Information Barrier Standards of Prudential Financial, dated July 15, 2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #400 on Form N-1A | (p)(4)(iii) | 11/22/2022 |
(p)(5) | Code of Ethics of TCW Investment Management Company LLC (a subadviser of Multi-Manager Alternative Strategies Fund and Multi-Manager Total Return Bond Strategies Fund), dated October 10, 2022 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #86 on Form N-1A | (p)(17) | 3/31/2023 |
(p)(6) | Code of Ethics of Water Island Capital, LLC (a subadviser of Multi-Manager Alternative Strategies Fund), effective June 7, 2021 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #387 on Form N-1A | (p)(6) | 8/26/2021 |
(p)(7) | Code of Ethics of Conestoga Capital Advisors, LLC (a subadviser of Multi-Manager Small Cap Equity Strategies Fund), dated April 13, 2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #395 on Form N-1A | (p)(7) | 7/18/2022 |
(p)(8) | Code of Ethics of Loomis, Sayles and Company, L.P. (a subadviser of Multi-Manager Growth Strategies Fund and Multi-Manager Total Return Bond Strategies Fund), effective January 14, 2000, as amended May 25, 2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #397 on Form N-1A | (p)(8) | 8/25/2022 |
(p)(9) | Code of Ethics of Boston Partners Global Investors Inc. (a subadviser of Multi-Manager Directional Alternative Strategies Fund), effective May 2021 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #387 on Form N-1A | (p)(10) | 8/26/2021 |
(p)(10) | Code of Ethics of Allspring Global Investments, LLC (a subadviser of Multi-Manager Directional Alternative Strategies Fund) effective October 1, 2022, last updated December 27, 2022 | Incorporated by Reference | Columbia Funds Variable Series Trust II | 333-146374 | Post-Effective Amendment #86 on Form N-1A | (p)(3) | 3/31/2023 |
(p)(11) | Code of Ethics of Los Angeles Capital Management LLC (a subadviser of Multi-Manager Growth Strategies Fund), effective August 1, 2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #400 on Form N-1A | (p)(11) | 11/22/2022 |
(p)(12) | Code of Ethics of Manulife Asset Management (US) LLC (a subadviser of Multi-Manager Alternative Strategies Fund), effective January 20, 2020 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #380 on Form N-1A | (p)(13) | 9/25/2020 |
Exhibit Number |
Exhibit Description | Filed Herewith or Incorporated by Reference |
Information About the Filing that Includes the Document Incorporated by Reference | ||||
Registrant that Made the Filing |
File No. of Such Registrant |
Type of Filing |
Exhibit of Document in that Filing |
Filing Date | |||
(p)(13) | Code of Ethics of Arrowstreet Capital, Limited Partnership (a subadviser of Multi-Manager International Equity Strategies Fund), effective April 13, 2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #397 on Form N-1A | (p)(13) | 8/25/2022 |
(p)(14) | Code of Ethics of Baillie Gifford Overseas Limited (a subadviser of Multi-Manager International Equity Strategies Fund), effective January 2023 | Filed Herewith | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #404 on Form N-1A | (p)(14) | 4/27/2023 |
(p)(15) | Code of Ethics of Causeway Capital Management LLC (a subadviser of Multi-Manager International Equity Strategies Fund), effective December 30, 2022 | Filed Herewith | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #404 on Form N-1A | (p)(15) | 4/27/2023 |
(p)(16) | Code of Ethics of AlphaSimplex Group, LLC (a subadviser of Multi-Manager Alternative Strategies Fund) | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #327 on Form N-1A | (p)(20) | 5/23/2018 |
(p)(17) | Code of Ethics of Voya Investment Management Co. LLC (a subadviser of Multi-Manager Total Return Bond Strategies Fund), effective November 2022 | Filed Herewith | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #404 on Form N-1A | (p)(17) | 4/27/2023 |
(p)(18) | Code of Ethics of J.P. Morgan Investment Management Inc. (a subadviser of Multi-Manager Directional Alternative Strategies Fund, Multi-Manager Small Cap Equity Strategies Fund), effective July 21, 2022 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #400 on Form N-1A | (p)(18) | 11/22/2022 |
(p)(19) | Code of Ethics of Hotchkis and Wiley Capital Management, LLC (a subadviser of Multi-Manager Small Cap Equity Strategies Fund), as of September 1, 2021 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #389 on Form N-1A | (p)(20) | 11/23/2021 |
(p)(20) | Code of Ethics of PGIM Quantitative Solutions LLC, (a subadviser of Columbia Multi Strategy Alternatives Fund) | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #392 on Form N-1A | (p)(20) | 2/17/2022 |
(p)(21) | Code of Ethics of Crabel Capital Management, LLC, (a subadviser of Multi-Manager Alternative Strategies Fund), effective April 2019 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #391 on Form N-1A | (p)(21) | 1/12/2022 |
(p)(22) | Code of Ethics of Jacobs Levy Investment Management, Inc. (a subadviser of Multi-Manager Small Cap Equity Strategies Fund), effective January 2016 | Incorporated by Reference | Columbia Funds Series Trust I | 2-99356 | Post-Effective Amendment #395 on Form N-1A | (p)(22) | 7/18/2022 |
(a) | 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 information 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. |
(b) | Allspring Global Investments, LLC (formerly known as Wells Capital Management Incorporated), performs investment management services for the Registrant and certain other clients. Information regarding the business of Allspring Global Investments, LLC and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by Allspring Global Investments, LLC and is incorporated herein by reference. Information |
about the business of Allspring Global Investments, LLC and the directors and principal executive officers of Allspring Global Investments, LLC is also included in the Form ADV filed by Allspring Global Investments, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-21122), which information is incorporated herein by reference. |
(c) | Alpha Simplex Group, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Alpha Simplex Group, LLC and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by Alpha Simplex Group, LLC and is incorporated herein by reference. Information about the business of Alpha Simplex Group, LLC and the directors and principal executive officers of Alpha Simplex Group, LLC is also included in the Form ADV filed by Alpha Simplex Group, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-62448), which information is incorporated herein by reference. |
(d) | AQR Capital Management, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of AQR Capital Management, LLC and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by AQR Capital Management, LLC and is incorporated herein by reference. Information about the business of AQR Capital Management, LLC and the directors and principal executive officers of AQR Capital Management, LLC is also included in the Form ADV filed by AQR Capital Management, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-55543), which information is incorporated herein by reference. |
(e) | Arrowstreet Capital, Limited Partnership performs investment management services for the Registrant and certain other clients. Information regarding the business of Arrowstreet Capital, Limited Partnership and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by Arrowstreet Capital, Limited Partnership and is incorporated herein by reference. Information about the business of Arrowstreet Capital, Limited Partnership and the directors and principal executive officers of Arrowstreet Capital, Limited Partnership is also included in the Form ADV filed by Arrowstreet Capital, Limited Partnership with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-56633), which information is incorporated herein by reference. |
(f) | Baillie Gifford Overseas Limited performs investment management services for the Registrant and certain other clients. Information regarding the business of Baillie Gifford Overseas Limited and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by Baillie Gifford Overseas Limited and is incorporated herein by reference. Information about the business of Baillie Gifford Overseas Limited and the directors and principal executive officers of Baillie Gifford Overseas Limited is also included in the Form ADV filed by Baillie Gifford Overseas Limited with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-21051), which information is incorporated herein by reference. |
(g) | Boston Partners Global Investors, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of Boston Partners Global Investors, Inc. and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by Boston Partners Global Investors, Inc. and is incorporated herein by reference. Information about the business of Boston Partners Global Investors, Inc. and the directors and principal executive officers of Boston Partners Global Investors, Inc. is also included in the Form ADV filed by Boston Partners Global Investors, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-61786), which information is incorporated herein by reference. |
(h) | Causeway Capital Management LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Causeway Capital Management LLC and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by Causeway Capital Management LLC and is incorporated herein by reference. Information about the business of Causeway Capital Management LLC and the directors and principal executive officers of Causeway Capital Management LLC is also included in the Form ADV filed by Causeway Capital Management LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-60343), which information is incorporated herein by reference. |
(i) | Conestoga Capital Advisors, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Conestoga Capital Advisors, LLC and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by Conestoga Capital Advisors, LLC and is incorporated herein by reference. Information about the business of Conestoga Capital Advisors, LLC and the directors and principal executive officers of Conestoga Capital Advisors, LLC is also included in the Form ADV filed by Conestoga Capital Advisors, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-60133), which information is incorporated herein by reference. |
(j) | Crabel Capital Management, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Crabel Capital Management, LLC and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by Crabel Capital Management, LLC and is incorporated herein by reference. Information about the business of Crabel Capital Management, LLC and the directors and principal executive officers of Crabel Capital Management, LLC is also included in the Form ADV filed by Crabel Capital Management, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-110141), which information is incorporated herein by reference. |
(k) | Hotchkis and Wiley Capital Management, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Hotchkis and Wiley Capital Management, LLC and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by Hotchkis and Wiley Capital Management, LLC and is incorporated herein by reference. Information about the business of Hotchkis and Wiley Capital Management, LLC and the directors and principal executive officers of Hotchkis and Wiley Capital Management, LLC is also included in the Form ADV filed by Hotchkis and Wiley Capital Management, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-60512), which information is incorporated herein by reference. |
(l) | 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. and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series 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 information is incorporated herein by reference. |
(m) | 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. and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series 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 information is incorporated herein by reference. |
(n) | Loomis, Sayles and Company, L.P. performs investment management services for the Registrant and certain other clients. Information regarding the business of Loomis, Sayles and Company, L.P. and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by Loomis, Sayles and Company, L.P. and is incorporated herein by reference. Information about the business of Loomis, Sayles and Company, L.P. and the directors and principal executive officers of Loomis, Sayles and Company, L.P. is also included in the Form ADV filed by Loomis, Sayles and Company, L.P. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-170), which information is incorporated herein by reference. |
(o) | 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 Prospectus(es) and Statement of Additional Information of the Registrant’s series 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 information is incorporated herein by reference. |
(p) | Manulife Investment Management (US) LLC (formerly known as Manulife Asset Management (US) LLC) performs investment management services for the Registrant and certain other clients. Information regarding the business of Manulife Investment Management (US) LLC and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by Manulife Investment Management (US) LLC and is incorporated herein by reference. Information about the business of Manulife Investment Management (US) LLC and the directors and principal executive officers of Manulife Investment Management (US) LLC is also included in the Form ADV filed by Manulife Investment Management (US) LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-42023), which information is incorporated herein by reference. |
(q) | PGIM, Inc. performs investment management services for the Registrant and certain other clients. Information regarding the business of PGIM, Inc. and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by PGIM, Inc. and is incorporated herein by reference. Information about the business |
of PGIM, Inc. and the directors and principal executive officers of PGIM, Inc. is also included in the Form ADV filed by PGIM, Inc. with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-22808), which information is incorporated herein by reference. |
(r) | PGIM Quantitative Solutions LLC (formerly known as QMA LLC), performs investment management services for the Registrant and certain other clients. Information regarding the business of PGIM Quantitative Solutions LLC and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by PGIM Quantitative Solutions LLC and is incorporated herein by reference. Information about the business of PGIM Quantitative Solutions LLC and the directors and principal executive officers of PGIM Quantitative Solutions LLC is also included in the Form ADV filed by PGIM Quantitative Solutions LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-62692), which information is incorporated herein by reference. |
(s) | TCW Investment Management Company LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of TCW Investment Management Company LLC and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by TCW Investment Management Company LLC and is incorporated herein by reference. Information about the business of TCW Investment Management Company LLC and the directors and principal executive officers of TCW Investment Management Company LLC is also included in the Form ADV filed by TCW Investment Management Company LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-29075), which information is incorporated herein by reference. |
(t) | Threadneedle International Limited may perform investment management services for the Registrant and certain other clients. Information regarding the business of Threadneedle International Limited and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series 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 information is incorporated herein by reference. |
(u) | Voya Investment Management Co. LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Voya Investment Management Co. LLC and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by Voya Investment Management Co. LLC and is incorporated herein by reference. Information about the business of Voya Investment Management Co. LLC and the directors and principal executive officers of Voya Investment Management Co. LLC is also included in the Form ADV filed by Voya Investment Management Co. LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-9046), which information is incorporated herein by reference. |
(v) | Water Island Capital, LLC performs investment management services for the Registrant and certain other clients. Information regarding the business of Water Island Capital, LLC and certain of its officers is set forth in the Prospectus(es) and Statement of Additional Information of the Registrant’s series subadvised by Water Island Capital, LLC and is incorporated herein by reference. Information about the business of Water Island Capital, LLC and the directors and principal executive officers of Water Island Capital, LLC is also included in the Form ADV filed by Water Island Capital, LLC with the SEC pursuant to the Investment Advisers Act of 1940 (File No. 801-57341), which information is incorporated herein by reference. |
(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 and Director | Senior Vice President | ||
Scott E. Couto | President and Director | None | ||
Jason S. Bartylla | 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 |
Name and Principal Business Address* |
Position and Offices with Principal Underwriter |
Positions and Offices with Registrant | ||
James Bumpus | Vice President and Head of Intermediary Markets | None | ||
Thomas A. Jones | Vice President and Head of Strategic Relations | None | ||
Gary Rawdon | Vice President – Sales Governance and Administration | None | ||
Leslie A. Walstrom | Global Head of Marketing | None | ||
Daniel J. Beckman | Vice President and Head of North America Product and Director | Board Member, President and Principal Executive Officer | ||
Marc Zeitoun | Chief Operating Officer, North American Distribution | None | ||
Wendy B. Mahling | Secretary | None | ||
Amy L. Hackbarth | Vice President and Assistant Secretary | None | ||
Mark D. Kaplan | Vice President and Assistant Secretary | None | ||
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. D’Alessandro | Vice President and Assistant Secretary | Assistant Secretary | ||
Megan Garcy | Vice President and Assistant Secretary | Assistant Secretary | ||
Christopher O. Petersen | Vice President and Assistant Secretary | Senior Vice President and Assistant Secretary | ||
Shweta J. Jhanji | Vice President and Treasurer | None | ||
Michael Tempesta | Anti-Money Laundering Officer and Identity Theft Prevention Officer | None | ||
Kristin Weisser | Conflicts Officer | None |
* | The principal business address of Columbia Management Investment Distributors, Inc. is 290 Congress Street, Boston, MA 02210. |
(c) | Not Applicable. |
■ | Registrant, 290 Congress Street, Boston, MA, 02210; |
■ | Registrant’s investment adviser and administrator, Columbia Management Investment Advisers, LLC, 290 Congress Street, Boston, MA, 02210; |
■ | Registrant’s subadviser, Allspring Global Investments, LLC (formerly known as Wells Capital Management Incorporated), 1415 Vantage Park Drive, 3rd Floor, Charlotte, NC 28203; |
■ | Registrant’s subadviser, AlphaSimplex Group, LLC, 200 State Street, Boston MA 02109; |
■ | Registrant’s subadviser, Arrowstreet Capital, Limited Partnership, 200 Clarendon Street, 30th Floor, Boston, MA 02116; |
■ | Registrant’s subadviser, AQR Capital Management, LLC, One Greenwich Plaza, Greenwich, CT 06830; |
■ | Registrant’s subadviser, Baillie Gifford Overseas Limited, Calton Square, 1 Greenside Row, Edinburgh, EH1 3AN, United Kingdom; |
■ | Registrant’s subadviser, Boston Partners Global Investors, Inc., 1 Beacon Street, 30th Floor, Boston, MA 02108; |
■ | Registrant’s subadviser, Causeway Capital Management LLC, 11111 Santa Monica Blvd., 15th Floor, Los Angeles, CA 90025; |
■ | Registrant’s subadviser, Conestoga Capital Advisors, LLC, Crosspoint at Valley Forge, 550 East Swedesford Road, Suite 120, Wayne, PA 19087; |
■ | Registrant’s subadviser, Crabel Capital Management, LLC, 1999 Avenue of the Stars, Suite 2550, Los Angeles, CA 90067; |
■ | Registrant’s subadviser, Hotchkis and Wiley Capital Management, LLC, 601 South Figueroa Street, 39th Floor, Los Angeles, CA 90017; |
■ | Registrant’s subadviser, Jacobs Levy Equity Management, Inc., 100 Campus Drive, 4th Floor East, Florham Park, NJ 07932; |
■ | Registrant’s subadviser, J.P. Morgan Investment Management Inc., 383 Madison Avenue, New York, NY 10179; |
■ | Registrant’s subadviser, Loomis, Sayles and Company, L.P., One Financial Center, Boston, MA 02111; |
■ | Registrant’s subadviser, Los Angeles Capital Management LLC, 11150 Santa Monica Blvd., Los Angeles, CA 90025; |
■ | Registrant’s subadviser, Manulife Investment Management (US) LLC, 197 Clarendon St, Boston, MA 02116; |
■ | Registrant’s subadviser, PGIM, Inc./Prudential Financial, Inc., 655 Broad Street, Newark, NJ 07102; |
■ | Registrant’s subadviser, PGIM Quantitative Solutions LLC (formerly known as QMA LLC), Gateway Center Two, Newark, NJ 07102; |
■ | Registrant’s subadviser, TCW Investment Management Company LLC, 865 South Figueroa Street, Suite 1800, Los Angeles, CA 90017; |
■ | Registrant’s subadviser, Voya Investment Management Co. LLC, 230 Park Avenue, New York, NY 10169; |
■ | Registrant’s subadviser, Water Island Capital, LLC, 41 Madison Avenue, 42nd floor, New York, NY 10010; |
■ | Registrant’s former provider of advisory service as delegated by former subadviser, DGHM, Real Estate Management Services Group, LLC, 1100 Fifth Avenue South, Suite 305, Naples, FL 34102; |
■ | Registrant’s former subadviser, BMO Asset Management Corp., 320 Canal Street, 12th Floor, Chicago, IL 60606; |
■ | Registrant’s former subadviser, Dalton, Greiner, Hartman, Maher & Co. LLC, 565 Fifth Avenue, Suite 2101, New York, NY 10017; |
■ | Registrant’s former subadviser, EAM Investors, LLC, 2533 South Coast Highway 101, Suite 240, Cardiff-by-the-Sea, CA 92007; |
■ | Registrant’s former subadviser, Federated Investment Management Company, Federated Investors Tower, 1001 Liberty Avenue, Pittsburgh, PA 15222-3779; |
■ | Registrant’s former subadviser, Wasatch Advisors Inc, 505 Wakara Way, 3rd Floor, Salt Lake City, UT 84108; |
■ | Registrant’s principal underwriter, Columbia Management Investment Distributors, Inc., 290 Congress Street, Boston, MA, 02210; |
■ | Registrant’s transfer agent, Columbia Management Investment Services Corp., 290 Congress Street, Boston, MA, 02210; |
■ | Registrant’s sub-transfer agent, SS&C GIDS, Inc., 2000 Crown Colony Dr., Quincy, MA 02169; |
■ | Registrant’s custodian, JP Morgan Chase Bank, N.A., 1 Chase Manhattan Plaza 19th Floor, New York, NY 10005; and |
■ | Registrant’s former custodian, State Street Bank and Trust Company, State Street Financial Center, One Lincoln Street, Boston, MA 02111. |
COLUMBIA FUNDS SERIES TRUST I | |
By: | /s/ Daniel J. Beckman |
Daniel J. Beckman Trustee and President |
Signature | Capacity | Signature | Capacity |
/s/ Daniel J. Beckman | Trustee and President (Principal Executive Officer) |
/s/ Patricia M. Flynn* | Trustee |
Daniel J. Beckman | Patricia M. Flynn | ||
/s/ Michael G. Clarke* | Chief Financial Officer, Principal Financial Officer and Senior Vice President |
/s/ Brian J. Gallagher* | Trustee |
Michael G. Clarke | Brian J. Gallagher | ||
/s/ Joseph Beranek* | Treasurer, Chief Accounting Officer (Principal Accounting Officer) and Principal Financial Officer |
/s/ Douglas A. Hacker* | Trustee |
Joseph Beranek | Douglas A. Hacker | ||
/s/ Pamela G. Carlton* | Chair of the Board | /s/ Nancy T. Lukitsh* | Trustee |
Pamela G. Carlton | Nancy T. Lukitsh | ||
/s/ George S. Batejan* | Trustee | /s/ David M. Moffett* | Trustee |
George S. Batejan | David M. Moffett | ||
/s/ Kathleen A. Blatz* | Trustee | /s/ Catherine James Paglia* | Trustee |
Kathleen A. Blatz | Catherine James Paglia | ||
/s/ Janet Langford Carrig* | Trustee | /s/ Natalie A. Trunow* | Trustee |
Janet Langford Carrig | Natalie A. Trunow | ||
/s/ J. Kevin Connaughton* | Trustee | /s/ Sandra L. Yeager* | Trustee |
J. Kevin Connaughton | Sandra L. Yeager | ||
/s/ Olive M. Darragh* | Trustee | ||
Olive M. Darragh |
* | By: Name: |
/s/ Joseph D’Alessandro | |
Joseph D’Alessandro** Attorney-in-fact |
|||
** | Executed by Joseph D’Alessandro on behalf of Michael G. Clarke pursuant to a Power of Attorney, dated February 1, 2021, on behalf of Joseph Beranek pursuant to a Power of Attorney, dated January 3, 2020, and on behalf of each of the Trustees pursuant to a Trustees Power of Attorney, dated January 1, 2023. |
/s/ George S. Batejan | Trustee | /s/ Brian J. Gallagher | Trustee |
George S. Batejan | Brian J. Gallagher | ||
/s/ Daniel J. Beckman | Trustee | /s/ Douglas Hacker | Trustee |
Daniel J. Beckman | Douglas Hacker | ||
/s/ Kathleen A. Blatz | Trustee | /s/ Nancy T. Lukitsh | Trustee |
Kathleen A. Blatz | Nancy T. Lukitsh | ||
/s/ Pamela G. Carlton | Trustee | /s/ David M. Moffett | Trustee |
Pamela G. Carlton | David M. Moffett | ||
/s/ Janet Langford Carrig | Trustee | /s/ Catherine James Paglia | Trustee |
Janet Langford Carrig | Catherine James Paglia | ||
/s/ J. Kevin Connaughton | Trustee | /s/ Natalie A. Trunow | Trustee |
J. Kevin Connaughton | Natalie A. Trunow | ||
/s/ Olive M. Darragh | Trustee | /s/ Sandra L. Yeager | Trustee |
Olive M. Darragh | Sandra L. Yeager | ||
/s/ Patricia M. Flynn | Trustee | ||
Patricia M. Flynn |
(d)(16)(i) | Amendment 1, dated March 10, 2023, to Subadvisory Agreement between Columbia Management Investment Advisers, LLC and Causeway Capital Management LLC, on behalf of Multi-Manager International Equity Strategies Fund, effective March 7, 2018 |
(h)(1)(i) | Schedule A and Schedule B, effective March 1, 2023, to the Transfer and Dividend Disbursing Agent Agreement by and between Columbia Management Investment Services Corp., the Registrant, Columbia Funds Series Trust and Columbia Funds Series Trust II, dated June 15, 2021 |
(j)(8) | Consent of PricewaterhouseCoopers LLP |
(p)(3) | Code of Ethics of AQR Capital Management, LLC, effective December 2022 |
(p)(14) | Code of Ethics of Baillie Gifford Overseas Limited, effective January 2023 |
(p)(15) | Code of Ethics of Causeway Capital Management LLC, effective December 30, 2022 |
(p)(17) | Code of Ethics of Voya Investment Management Co. LLC, effective November 2022 |
Exhibit No. | Description |
EX-101.INS | XBRL Instance Document |
EX-101.SCH | XBRL Taxonomy Extension Schema Document |
EX-101.CAL | XBRL Taxonomy Extension Calculation Linkbase |
EX-101.DEF | XBRL Taxonomy Extension Definition Linkbase |
EX-101.LAB | XBRL Taxonomy Extension Labels Linkbase |
EX-101.PRE | XBRL Taxonomy Extension Presentation Linkbase |
AMENDMENT NO. 1
TO THE SUBADVISORY AGREEMENT
This Amendment No. 1 (the Amendment), made and entered into as of March 10, 2023, is made a part of the Subadvisory Agreement between Columbia Management Investment Advisers, LLC, a Minnesota limited liability company (Investment Manager) and Causeway Capital Management LLC, a Delaware limited liability company (Subadviser), dated March 7, 2018 (the Agreement).
NOW, THEREFORE, the parties, intending to be legally bound, agree as follows:
1. | Notices. Section 12 to the Agreement shall be, and hereby is, amended by deleting the addresses for Subadviser and Investment Manager and replacing them with the following: |
In the case of Subadviser:
General Counsel
Causeway Capital Management LLC
1111 Santa Monica Blvd, 15th Floor
Los Angeles, CA 90025
Tel: (310) 231-6100
Email: compliance@causewaycap.com
In the case of Investment Manager:
David Weiss
Global Head of Multi-Manager Solutions
Ameriprise Financial, Inc.
290 Congress Street
Boston, MA 02210
Tel: (617) 385-9606
Email: David.Weiss@columbiathreadneedle.com
with a copy to:
Ryan C. Larrenaga
Vice President and Chief Counsel
Ameriprise Financial, Inc.
290 Congress Street
Boston, MA 02210
Tel: (617) 385-9536
Email: RYAN.C.LARRENAGA@columbiathreadneedle.com
2. | Schedule A. Schedule A to the Agreement shall be, and hereby is, deleted and replaced with the Schedule A attached hereto. |
3. | Miscellaneous. Capitalized terms not otherwise defined herein shall have the meanings set forth in the Agreement. This Amendment may be executed in counterparts, each of which will be deemed an original and all of which together will be deemed to be one and the same agreement. As modified herein, the Agreement is confirmed and remains in full force and effect. |
[REMAINDER OF THIS PAGE HAS BEEN LEFT BLANK INTENTIONALLY]
IN WITNESS WHEREOF, the parties hereto have caused this Amendment to be executed by their officers designated below as of the day and year first above written.
Columbia Management Investment Advisers, LLC |
Causeway Capital Management LLC | |||||||
By: | /s/ David Weiss | By: | /s/ Gracie V. Fermelia | |||||
Signature | Signature | |||||||
Name: | David Weiss | Name: | Gracie V. Fermelia | |||||
Printed | Printed | |||||||
Title: | Global Head of Multi-Manager Solutions and Assistant Secretary |
Title: | Chief Operating Officer |
AMENDMENT NO. 1
TO THE SUBADVISORY AGREEMENT
SCHEDULE A
[SCHEDULE LISTING FUND AND FEE RATE OMITTED]
TA Schedule CFST, CFST I and CFST II
SCHEDULE A
Effective March 1, 2023
Columbia Funds Series Trust
Columbia California Intermediate Municipal Bond Fund
Columbia Capital Allocation Moderate Aggressive Portfolio
Columbia Capital Allocation Moderate Conservative Portfolio
Columbia Convertible Securities Fund
Columbia Large Cap Enhanced Core Fund
Columbia Large Cap Growth Opportunity Fund
Columbia Large Cap Index Fund
Columbia Mid Cap Index Fund
Columbia North Carolina Intermediate Municipal Bond Fund
Columbia Overseas Value Fund
Columbia Select Large Cap Equity Fund
Columbia Select Mid Cap Value Fund
Columbia Short Term Bond Fund
Columbia Short Duration Municipal Bond Fund
Columbia Small Cap Index Fund
Columbia Small Cap Value Fund II
Columbia South Carolina Intermediate Municipal Bond Fund
Columbia Virginia Intermediate Municipal Bond Fund
Columbia Funds Series Trust I
Columbia Adaptive Retirement 2020 Fund
Columbia Adaptive Retirement 2025 Fund
Columbia Adaptive Retirement 2030 Fund
Columbia Adaptive Retirement 2035 Fund
Columbia Adaptive Retirement 2040 Fund
Columbia Adaptive Retirement 2045 Fund
Columbia Adaptive Retirement 2050 Fund
Columbia Adaptive Retirement 2055 Fund
Columbia Adaptive Retirement 2060 Fund
Columbia Adaptive Risk Allocation Fund
Columbia Balanced Fund
Columbia Bond Fund
Columbia Connecticut Intermediate Municipal Bond Fund
Columbia Contrarian Core Fund
Columbia Corporate Income Fund
Columbia Dividend Income Fund
Columbia Emerging Markets Fund
Columbia Global Technology Growth Fund
Columbia Greater China Fund
Columbia High Yield Municipal Fund
Columbia Intermediate Duration Municipal Bond Fund
Columbia International Dividend Income Fund
Columbia Large Cap Growth Fund
Columbia Massachusetts Intermediate Municipal Bond Fund
Columbia Multi Strategy Alternatives Fund
TA Schedule CFST, CFST I and CFST II
Columbia New York Intermediate Municipal Bond Fund
Columbia Oregon Intermediate Municipal Bond Fund
Columbia Real Estate Equity Fund
Columbia Select Large Cap Growth Fund
Columbia Select Mid Cap Growth Fund
Columbia Small Cap Growth Fund
Columbia Small Cap Value Fund I
Columbia Solutions Aggressive Portfolio
Columbia Solutions Conservative Portfolio
Columbia Strategic California Municipal Income Fund
Columbia Strategic Income Fund
Columbia Strategic New York Municipal Income Fund
Columbia Tax-Exempt Fund
Columbia Total Return Bond Fund
Columbia U.S. Social Bond Fund
Columbia U.S. Treasury Index Fund
Columbia Ultra Short Term Bond Fund
Multi-Manager Alternative Strategies Fund
Multi-Manager Directional Alternatives Strategies Fund
Multi-Manager Growth Strategies Fund
Multi-Manager International Equity Strategies Fund
Multi-Manager Small Cap Equity Strategies Fund
Multi-Manager Total Return Bond Strategies Fund
Multisector Bond SMA Completion Portfolio
Overseas SMA Completion Portfolio
Columbia Funds Series Trust II
Columbia Capital Allocation Aggressive Portfolio
Columbia Capital Allocation Conservative Portfolio
Columbia Capital Allocation Moderate Portfolio
Columbia Commodity Strategy Fund
Columbia Disciplined Core Fund
Columbia Disciplined Growth Fund
Columbia Disciplined Value Fund
Columbia Dividend Opportunity Fund1
Columbia Emerging Markets Bond Fund1
Columbia Flexible Capital Income Fund1
Columbia Floating Rate Fund
Columbia Global Opportunities Fund
Columbia Global Value Fund
Columbia Government Money Market Fund
Columbia High Yield Bond Fund
Columbia Income Builder Fund
Columbia Income Opportunities Fund
Columbia Integrated Large Cap Growth Fund
Columbia Integrated Large Cap Value Fund
Columbia Integrated Small Cap Growth Fund
Columbia Large Cap Value Fund
Columbia Limited Duration Credit Fund
Columbia Minnesota Tax-Exempt Fund
Columbia Mortgage Opportunities Fund
TA Schedule CFST, CFST I and CFST II
Columbia Overseas Core Fund
Columbia Pyrford International Stock Fund
Columbia Quality Income Fund
Columbia Select Global Equity Fund
Columbia Select Large Cap Value Fund
Columbia Select Small Cap Value Fund
Columbia Seligman Global Technology Fund
Columbia Seligman Technology and Information Fund
Columbia Short-Term Cash Fund
Columbia Strategic Municipal Income Fund
Columbia Ultra Short Duration Municipal Bond Fund
Multi-Manager Value Strategies Fund
TA Schedule CFST, CFST I and CFST II
SCHEDULE B
Effective March 1, 2023
Payments under the Agreement are payable to CMISC monthly.
Transfer agency costs are calculated separately for each of (i) Institutional 3 (Inst3) Class shares, (ii) Institutional 2 (Inst 2) Class shares, and (iii) all other classes of shares.
Each Fund shall pay to CMISC for the services to be provided by CMISC under the Agreement an amount equal to the sum of the following:
(a) (i) | Base transfer agency fee paid monthly of: |
1. | an annual per account fee equal to the Direct Account Fee for accounts established directly with the Fund (direct accounts); and |
2. | an annual rate equal to the Intermediary Controlled Account Rate on the daily value of accounts of intermediaries established with the Fund, including accounts established or maintained pursuant to the National Securities Clearing Corporations networking system (network accounts and, together with omnibus accounts, intermediary controlled accounts); PLUS |
(ii) | The Funds Allocated Share of CMISC Reimbursable Out-of-Pocket Expenses; PLUS |
(iii) | Sub-transfer agency fees (generally intended to offset amounts paid by CMISC to intermediaries for services they provide), subject to the limits set forth below |
1. | For all classes other than Inst2 or Inst 3: the amount charged by an intermediary up to the following sub-transfer agency fee limits, which vary among distribution channels as follows: |
Distribution Channel |
Sub-Transfer Agency Fee Limit | |
Retirement Channel Intermediary platforms that primarily service retirement accounts, including accounts of retirement plans qualified under sections 401(a), 401(k), 457 or 403(b) of the Internal Revenue Code of 1986, as amended (the Code), non-qualified deferred compensation plans governed by section 409A of the Code and individual retirement plans | (i) 0.25% of Fund assets held by Retirement Channel intermediaries or platforms charging an asset-based fee or (ii) $20 per account held by Retirement Channel intermediaries charging a per account fee | |
Supermarket Transaction Fee (TF) Channel Accounts in mutual fund platforms of the type commonly referred to as fund supermarkets that charge participants a transaction fee | (i) 0.12% of Fund assets held by Supermarket TF Channel intermediaries or platforms charging an asset-based fee or (ii) $20 per Supermarket TF Account held for intermediaries charging a per account fee |
TA Schedule CFST, CFST I and CFST II
Distribution Channel |
Sub-Transfer Agency Fee Limit | |
Supermarket No-Transaction Fee (NTF) Channel Accounts in mutual fund platforms of the type commonly referred to as fund supermarkets that do not charge participants a transaction fee | (i) 0.25% of Fund assets held by Supermarket NTF Channel intermediaries or platforms charging an asset based fee or (ii) $20 per account held by Supermarket NTF Channel intermediaries or platforms charging a per account fee | |
Bank Channel Accounts maintained by banks offering financial and banking services to high net worth clients (commonly referred to as private bank accounts) | (i) 0.20% of Fund assets held by Private Bank Channel intermediaries or platforms or (ii) $20 per account held by Bank Channel intermediaries or platforms charging a per account fee | |
Section 529 Plan Assets Accounts of portfolios of college saving plans authorized under section 529 of the Code (commonly referred to as Section 529 plans) (529 Plan Accounts) | 0.20% on Fund assets held in 529 Plan Accounts | |
Broker-Dealer Channel Intermediary platforms offering mutual funds in brokerage accounts or through advisory programs, including independent, regional and wirehouses firms | (i) 0.15% of Fund assets held by Broker-Dealer Channel intermediaries or platforms charging an asset-based fee or (ii) $20 per account held by Broker-Dealer Channel intermediaries or platforms charging a per account fee | |
Insurance Channel Insurance companies offering mutual funds in retirement/recordkeeping-type platforms, products and accounts. | (i) 0.25% of Fund assets held by Insurance Channel intermediaries on platforms charging an asset-based fee or (ii) $20 per account held by Insurance Channel intermediaries or platforms charging a per account fee |
The sub-transfer agency fee limit is applied by intermediary (or by platforms within an intermediary, where applicable), by Fund and by share class and not in the aggregate by distribution channel. For avoidance of doubt, per account limits applicable to certain channels are applied at the level of the underlying accounts serviced by the intermediary, not at the level of the omnibus account maintained by CMISC.
2. | For Inst2 Class shares: 0.05% of the average aggregate value of the Funds shares maintained in omnibus accounts (subject to paragraph (b) below). |
3. | For Inst3 Class shares: Inst3 Class shares do not pay sub-transfer agency fees set forth in paragraph (a)(iii). |
(b) | For Inst2 Class shares, the annual rate for the fees set forth in paragraphs (a)(i) (a)(iii)(2) shall not exceed 0.070%. |
TA Schedule CFST, CFST I and CFST II
(c) | For Inst3 Class shares, the annual rate for the fees set forth in paragraphs (a)(i) (a)(ii) shall not exceed 0.020%. |
In addition, CMISC shall be entitled to retain as additional compensation/reimbursement for its services all CMISC revenues for fees for wire, telephone, and redemption orders, IRA trustee agent fees and account transcripts due CMISC from shareholders of the Fund and interest (net of bank charges) earned with respect to balances in the accounts referred to in paragraph 2 of the Agreement. All determinations hereunder shall be in accordance with generally accepted accounting principles and subject to audit by the Funds independent accountants.
Definitions
Allocated Share for any month means that percentage of CMISC Reimbursable Out-of-Pocket Expenses which would be allocated to a Fund for such month in accordance with the methodology described below under the heading Methodology of Allocating CMISC Reimbursable Out-of-Pocket Expenses.
CMISC Reimbursable Out-of-Pocket Expenses means (i) networking account fees paid to dealer firms by CMISC on shareholder accounts established or maintained pursuant to the National Securities Clearing Corporations networking system, subject to a maximum annual rate of up to 0.20% of the month end value of the Funds shares maintained in networked accounts of each dealer firm, and (ii) out-of-pocket expenses incurred on behalf of the Funds by CMISC for stationery, forms, postage and similar items and those expenses identified as Out-of-Pocket Expenses below.
Direct Account Fee means $31.80 for the period from March 1, 2023 through June 30, 2023, and such other amount as may be set annually based on actual costs incurred by CMIS in servicing direct accounts (including an agreed-upon margin).
Intermediary Controlled Account Rate means 0.0053% for the period from March 1, 2023 through June 30, 2023 and thereafter shall be the rate equal to (x) the amount approved or ratified by the Board to approximate the projected expenses of servicing intermediary controlled accounts (including an agreed-upon margin), divided by (y) the net assets of intermediary controlled accounts invested in funds within the Columbia Fund complex for which CMISC serves as transfer agent (excluding any variable portfolio funds). For any given month, CMISC shall calculate the Intermediary Controlled Account Rate based on net assets of applicable Columbia Funds as of the 15th day of the month preceding such month (or the next succeeding business day if the 15th day of the preceding month is not a business day). For example, the Intermediary Controlled Account Rate effective September 1, 2023 shall be calculated based on net assets as of August 15, 2023.
Out-of-Pocket Expenses also include, but are not limited to, the following items:
* | Printing, storage and programming costs associated with, but not limited to envelopes, checks, confirmations and stationery |
* | Postage bulk, pre-sort, ZIP+4, barcoding, first class |
TA Schedule CFST, CFST I and CFST II
* | Telephone and telecommunication costs, including all lease, maintenance and line costs |
* | Proxy solicitations, mailings and tabulations |
* | Daily & Distributions advice mailings |
* | Implementing, monitoring or processing any Stop Orders |
* | Shipping, Certified and Overnight mail and insurance |
* | Year-end forms and mailings |
* | Duplicating services |
* | Courier services |
* | National Securities Clearing Corporation charges related to fund transactions |
* | Record retention costs including but not limited to the storage, movement, destruction, retrieval and handling charges |
* | Data processing and storage for anti-market timing omnibus monitoring |
* | Creation and maintenance of on-line records including reports, shareholder and dealer statements, year-end forms, and regulatory mailings |
* | Third party quality control assessments |
* | Compliance items including, but not limited to, lost shareholder review, lost certificate filings and compliance programs |
* | Electronic website linkages to third party account management applications |
* | Regulatory mailings inclusive of costs related to electronic delivery of such documents. |
* | At the request, or with the consent of the Trust, such other miscellaneous expenses reasonably incurred by CMISC in performing its duties and responsibilities under this Agreement. |
The Funds agree that postage and mailing expenses will be paid on the day of or prior to mailing as agreed with CMISC. In addition, the Funds will promptly reimburse CMISC for any other unscheduled expenses incurred by CMISC whenever the Funds and CMISC mutually agree that such expenses are not otherwise properly borne by CMISC as part of its duties under the Agreement.
TA Schedule CFST, CFST I and CFST II
Methodology of Allocating CMISC Reimbursable Out-of-Pocket Expenses
CMISC Reimbursable Out-of-Pocket Expenses are allocated to the Funds as follows:
A. Identifiable |
Based on actual services performed and invoiced to a Fund. | |
B. Unidentifiable |
Allocation will be based on three evenly weighted factors.
- number of shareholder accounts
- Number of transactions
- Average net assets |
TA Schedule CFST, CFST I and CFST II
IN WITNESS WHEREOF, the parties hereto have caused the forgoing Schedule A and Schedule B to be duly executed as of March 1, 2023.
COLUMBIA FUNDS SERIES TRUST
COLUMBIA FUNDS SERIES TRUST I
COLUMBIA FUNDS SERIES TRUST II,
on behalf of their respective series listed on Schedule A
By: |
/s/ Daniel J. Beckman | |
Name: Daniel J. Beckman | ||
Title: President |
COLUMBIA MANAGEMENT INVESTMENT SERVICES CORP.
By: |
/s/ Lyn Kephart-Strong | |
Name: Lyn Kephart-Strong | ||
Title: President |
CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
We hereby consent to the incorporation by reference in this Registration Statement on Form N-1A of Columbia Funds Series Trust I of our report dated February 22, 2023, relating to the financial statements and financial highlights, which appears in Columbia Real Estate Equity Funds Annual Report on Form N-CSR for the year ended December 31, 2022. We also consent to the references to us under the headings Financial Highlights, Independent Registered Public Accounting Firm and Organization and Management of Wholly-Owned Subsidiaries in such Registration Statement.
/s/PricewaterhouseCoopers LLP
Minneapolis, Minnesota
April 26, 2023
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AQR Capital Management, LLC | Code of Ethics 1 |
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AQR Capital Management, LLC | Code of Ethics 2 |
I. | Code of Ethics1 |
1.1 | Compliance with Applicable Federal and Other Securities Laws |
Employees are required to comply with all federal and other securities laws, rules and regulations applicable to the business of AQR. Policies concerning these laws are discussed in this Manual and other policies and procedures adopted by the Firm.
1.2 | Fiduciary Obligations |
The Firm is registered with the U.S. Securities and Exchange Commission (SEC) as an investment adviser under the Advisers Act and owes a fiduciary duty to its Clients.2 The SECs interpretation regarding the standard of conduct for investment advisers under the Advisers Act describes the nature and scope of these obligations. The Firms fiduciary duty is broad and applies to the entire adviser-Client relationship and obligates the Firm to act in the best interest of Clients at all times, meaning the Firm cannot place its own interests ahead of the interests of its Clients.
Fundamental to the fiduciary standard are the duties of loyalty and care. The duty of loyalty requires the Firm to not put its own interests ahead of its Clients interests. To meet its duty of loyalty, the Firm must provide full and fair disclosure to its Clients of all material facts relating to the advisory relationship and all conflicts of interest that might incline an investment adviser (consciously or unconsciously) to render advice that is not disinterested.
The duty of care includes, among other things:
| the duty to provide investment advice that is in the best interest of the Client (based on a reasonable understanding of the Clients objectives and the investment mandate and any applicable investment guidelines), which includes a duty to provide advice that is suitable for the Client |
| the duty to reasonably ensure that investment advice is based on materially accurate and complete information |
| the duty to seek best execution of a Clients transactions where the Firm has the responsibility to select broker-dealers to execute Client transactions |
| the duty to provide advice and monitoring at a frequency that is in the best interest of the Client, taking into account the scope of the agreed relationship |
All employees involved in the investment process must refrain from engaging in any personal business activity that could conflict with the proper execution and management of any fund, product, or strategy over which the Firm has discretionary investment authority, or that could impair the employees or the Firms ability to make impartial decisions with respect to the Firms investment program.
1.3 | Protecting Confidential Information |
Employees should take special caution to safeguard the Firms Confidential Information. Such information includes, but is not limited to, the following:
| the identity of the Firms Clients and information related to Client accounts, including but not limited to fees, securities holdings, and transactions |
| employee personal information, including performance reviews and compensation information |
| information related to the Firms investment process, research, code, signals, operational or organizational structure, Human Resources Department files, controls, performance, financial assets, net worth, revenues or net income |
1 | All employees are subject to the Code of Ethics. The CCO may, at the CCOs sole discretion, subject certain third-party service providers and contractors to this Code of Ethics or a modified version hereof, depending on the facts and circumstances of the engagement. |
2 | Capitalized terms used in this Manual are defined in Section II, Definitions, at the end of this Manual. |
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AQR Capital Management, LLC | Code of Ethics 3 |
| information related to the Firms portfolios, securities recommendations, trading and/or execution strategies, holdings, executed trades, or pending orders |
| software, algorithms, models, or programs developed by the Firm |
Employees should not circulate or discuss Confidential Information inside or outside of the Firm with unauthorized individuals. Employees also should not access, use, disclose, or divulge any Confidential Information except as may otherwise be required in connection with performance of their duties for the Firm.
Moreover, employees are prohibited from sending any Confidential information to their non-AQR email accounts, such as personal or academic email accounts. If you believe that there is a business need to send Firm work product to your non-AQR email account, you must obtain pre-approval from Compliance (esurveillance@aqr.com) before sending.
Employees must promptly report to the Compliance Department if: (1) they become aware that Confidential Information is not secured or may appear to be generally accessible (e.g., on a shared drive); or (2) they have inadvertently received or disclosed Confidential Information.
Other than in the ordinary course of the employees duties for the Firm, during and subsequent to the employees employment, the employee shall not copy, take pictures of, remove or forward from the Firms premises or systems, either directly or indirectly, any drawings or whiteboards, writings, prints, documents, telephone/address directories (whether in hard copy or digital), computer screens or other screen shots, hard drives, thumb or flash drives, cloud systems or anything else containing, embodying, or disclosing any Confidential Information without the prior permission of the CCO or his designee. Upon the termination or resignation of an employees employment with the Firm for any reason, the employee is expected to immediately return any such items to the Firm. Please contact Compliance at esurveillance@aqr.com if you have questions about this policy.
Confidential Information may be made available to certain employees for Compliance surveillance monitoring and other purposes as necessary to perform their duties for the Firm. Confidential Information may also be provided to third-party service providers as necessary to perform their contracted services for the Firm.
In addition, Confidential Information may be disclosed to government, regulatory or self-regulatory organizations to fulfill the Firms various regulatory obligations, or otherwise when disclosure is required by law, or is necessary for the purpose of, or in connection with, legal proceedings or to defend legal rights.
1.4 | Policy to Prevent Insider Trading |
(a) | Insider Trading |
It is a criminal violation of law and a violation of Firm policy to engage in insider trading. Insider trading is defined as trading in securities on the basis of material nonpublic information (MNPI) in breach of a duty of trust or confidence. Employees are also prohibited from passing along MNPI or tipping anyone to buy or sell securities while in possession of MNPI relating to those securities. A violation of these restrictions could have severe consequences for both the Firm and its employees. Any employee engaging in activity in violation of the provisions set forth in this section may be subject to disciplinary action, including termination of employment or referral of the matter to the appropriate regulatory agency for civil or criminal investigation. Any employee who learns of any actual or potential violation of the law or provisions of this section must promptly notify the CCO or any member of the Compliance Department.
Federal, state and international securities laws and regulations prohibit securities transactions while in possession of MNPI under certain circumstances, including, but not limited to:
| misappropriated information or information improperly obtained by the purchaser or seller |
| information provided by a corporate insider to the purchaser or seller in exchange for a monetary or non-monetary consideration |
| an individual prohibited from trading under the items referenced above tips the information to the purchaser or seller |
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AQR Capital Management, LLC | Code of Ethics 4 |
A violation of insider trading laws could result in civil and/or criminal penalties under both federal and state securities laws, including but not limited to:
| the Firm and/or the offending employee may be subject to criminal prosecution and, if convicted, significant monetary fines and imprisonment |
| the Firm may face SEC action (or other actions pursuant to a non-U.S. law or regulation) seeking monetary and administrative sanctions |
| the Firm and/or the offending employee may be subject to lawsuits by private plaintiffs |
| the Firm and/or the offending employee may face suspension, revocation or termination of their registrations or memberships |
(b) | Recognizing MNPI |
Information is considered material if there is a substantial likelihood that a reasonable investor would consider the information important in making an investment decision. Generally, this includes any information the disclosure of which is reasonably likely to have a meaningful effect on the price of an outstanding security. Information may be material even if it relates to speculative or contingent events.
The assessment of materiality is highly fact specific. When in doubt, employees should err on the side of caution and bring the information in question to the attention of the CCO or the Compliance Department for further consideration.
Information is considered nonpublic if such information has not been broadly disseminated to investors in the marketplace, such as an issuer releasing the information over the news wires, disclosing it in public filings made with a regulatory agency (e.g., Forms 10-K or 10-Q) or otherwise disseminating the information in a manner that makes it fully available to investors in the marketplace. The fact that nonpublic information is reflected in rumors in the marketplace does not necessarily mean that the information has been publicly disseminated. Even when some information regarding a matter has been made public, other aspects of the matter may remain nonpublic.
Examples of where MNPI may arise, depending on the circumstances, include, but are not limited to, the following events:
| impending or potential mergers, acquisitions, tender offers, joint ventures or changes in assets, such as large disposal of the same |
| earnings or revenue information and changes in previously disclosed financial information |
| liquidity issues or impending bankruptcy |
| events regarding the issuers securities (e.g., advance knowledge of a ratings downgrade, defaults on securities, calls of securities for redemption, public or private sales of additional securities, stock splits or changes in dividends, repurchase plans or changes to the rights of security holders) |
| new products or discoveries, or developments regarding clients or suppliers (e.g., the acquisition or loss of a major contract) |
| major government action involving the issuer (e.g., FDA decision on a new drug) |
| significant changes in control or management |
| content of forthcoming brokerage research reports |
| changes in auditors or auditor notification that the issuer may no longer rely on an auditors report |
| actual or threatened litigation or regulatory actions |
| information relating to the market for an issuers securities, such as a large order to purchase or sell securities |
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AQR Capital Management, LLC | Code of Ethics 5 |
| prepublication of information regarding articles or reports in the financial press |
(c) | Reporting Requirements |
Any employee who believes that they may be in possession of MNPI must promptly report the information to the CCO or any member of the Compliance Department.
Unless specifically permitted by the CCO or his designee, such employee must not:
| transact in the securities of the relevant issuer in any account (either personal accounts or accounts managed by the Firm) |
| discuss the information with anyone inside or outside of the Firm except for the CCO or any member of the Compliance Department |
| facilitate the use or disclosure of MNPI by othersincluding another AQR employee |
(d) | Restricted List |
The Firms Restricted List is maintained by the Compliance Department and is a list of issuers whose securities are subject to partial or complete trading prohibitions for personal and Firm trading, except as pre-approved by the CCO or his designee. Issuers are placed on the Restricted List for a variety of business or legal reasons, including to comply with the terms of confidentiality and other agreements, to prevent violations of the securities laws, and to avoid the appearance of misuse of Confidential Information by the Firm.
Employees should not speculate as to why an issuer was placed on the Restricted List. The Restricted List is highly confidential to the Firm and should not be disclosed externally without the Compliance Departments permission.
If a particular issuer is placed on the Restricted List, trading is generally prohibited in all securities related to the issuer, including: equity, options, rights, swaps, debt, warrants, convertible securities, and any other derivative whose market value is determined principally with reference to those securities. In some instances, the Compliance Department may determine that a partial trading prohibition is appropriate. The Restricted List generally does not prohibit trading in exchange traded funds (ETFs), broad-based indices, diversified baskets, or similar instruments containing the issuers securities.
Absent prior approval of the CCO or his designee, all employees are prohibited from engaging in any trade that is subject to a Restricted List prohibition, including for any personal account or any account managed by the Firm.
The effectiveness of the Restricted List depends to a large extent on employees notifying the Compliance Department on a timely basis of events that may require the placement of an issuer on the Restricted List. For that reason, it is critical that an employee notify the Compliance Department immediately if an employee:
| believes he or she has obtained or may obtain MNPI |
| receives a request to sign a non-disclosure agreement (NDA) or confidentiality agreement |
| has been asked to join a formal or informal creditors committee or board of directors |
An issuer will ordinarily be removed from the Restricted List when the Compliance Department determines that any MNPI in the Firms possession has been publicly disclosed or is no longer material and/or the term of the applicable NDA or confidentiality agreement has expired. In some cases, nonpublic information may continue to be material long after the conclusion of the transaction or relationship that led to the receipt of the information.
Any employee may request to add or remove issuers from the Restricted List by contacting the Compliance Department, which has ultimate authority to decide when an issuer should be added to or removed from the Restricted List.
The Compliance Department will maintain a record of all Restricted List entries, including the relevant dates and reasons for placing an issuer on and taking it off the Restricted List and the scope of the trading prohibitions. The Compliance Department will also monitor all personal accounts and all accounts managed by the Firm for trading in Restricted List securities.
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AQR Capital Management, LLC | Code of Ethics 6 |
If an employee is uncertain as to whether an issuer should be placed on or taken off the Restricted List, he or she should consult the Compliance Department, which will also address any questions or requests for exceptions to the prohibition against trading securities of issuers on the Restricted List.
(e) | Expert Networks, Political Intelligence Firms, and Similar Industry Consultants |
Another possible source of MNPI involves the use of expert networks, political intelligence firms, or similar industry consultants to provide information, advice, analysis, market or industry expertise for use in formulating investment views and decisions. Expert network firms provide specialized information about companies and industries to asset managers, mutual funds and other investment firms in exchange for fees. Political and/or economic intelligence firms collect intelligencee.g., information or analysis about fiscal or monetary policy decisions, legislative developments, political or regulatory actionsfrom current or former insiders, including members of Congress, their staffers, employees of regulatory agencies, and other Federal employees, and sell the information to asset managers, mutual funds and other investment firms whose businesses are affected by Federal legislations, regulation, policy changes, etc. Such service providers may have confidential information and/or MNPI by having relationships with, among others: (1) current or recent employees of public companies; (2) known significant suppliers or distributors to public companies; (3) attorneys, accountants and consultants engaged by public companies; (4) government officials; or (5) doctors serving on data safety monitoring boards for clinical trials. The use of expert networks, political intelligence firms, or similar industry consultants must be pre-approved by the Compliance Department.
(f) | Alternative Data |
The Firm uses various types of data for investment research. Data obtained from non-traditional sources (e.g., consumer transactions, social media mentions) is sometimes referred to as alternative data. Such data may contain potential MNPI or personal information depending on the nature and origin of the data.
The use of alternative data must be pre-approved by the Compliance Department.
Any questions concerning whether a particular data set constitutes alternative data and is subject to Compliance pre-approval should be raised with Compliance.
1.5 | Personal Trading Policy |
(a) | General Policy |
The Personal Trading Policy governs the personal trading and investments of all AQR employees globally and their Household Members. As an employee, you are prohibited from putting your own interests ahead of the interests of Clients and you must avoid transactions, activities, and relationships that might interfere with making decisions in the best interests of Clients. For example, employees may not execute transactions with the same individual employee at a broker-dealer firm with whom AQR conducts business.
All exceptions to this Personal Trading Policy must be approved by the CCO or his designee.
(b) | Personal Accounts |
Employees must disclose in the Compliance System all brokerage or other investment accounts, including trusts or investment clubs, in which the employee has direct or indirect influence or control (such as joint ownership, trading authorization, or the authority to exercise investment discretion) or a direct or indirect Beneficial Interest. Employees are presumed to have a Beneficial Interest in any account or securities held by their spouses, domestic partners, dependent children. The Personal Trading Policy applies equally to all accounts for Household Members.
(i) | Exempt Accounts No Disclosure Required |
Employees are not required to disclose the following types of accounts:
| 401(k) and 403(b) retirement plan accounts that only hold U.S. registered open-end mutual funds |
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AQR Capital Management, LLC | Code of Ethics 7 |
| Accounts held directly at U.S. registered mutual fund companies |
| However, you must disclose any accounts holding AQR Mutual Funds (unless held in AQRs 401(k) plan) (see footnote 5) |
| 529 college savings plans |
| Variable annuity contracts |
(ii) | Approved Broker Requirements |
As a general rule, all employees (and their Household Members) are required to conduct their personal trading through a broker listed on the Approved Broker List (an Approved Broker). Approved Brokers generally provide an electronic feed of transactions and holdings directly to AQR.3 Any exception to this requirement to maintain accounts at an Approved Broker must be approved by the CCO or his designee.
The list of Firm-approved brokers is subject to change and is maintained by the Compliance Department. The current list of Approved Brokers is available in the Personal Trading Quick Reference Guide, which is available on the Compliance Page (Go/Compliance).
(c) | Reporting Requirements |
(i) | Reporting Account Information |
Employees are required to complete an initial Compliance certification and disclose via the Firms Compliance System all accounts (other than those noted in Section 1.5(b)(i), above) no later than ten days after beginning their employment or being designated as subject to the Code of Ethics (both referred to as their start date). All new employees (and their Household Members) must agree to close or move their existing accounts to one of the Approved Brokers within 45 days of their start date unless an exception or extension has been received from the CCO or his designee.
Employees also must promptly report via the Compliance System any changes in their accounts, including the opening of any new accounts and closing of any existing accounts. It is the employees responsibility to promptly update the Compliance System with this information.
NoteWhen opening a new account (including accounts at an Approved Broker), the employee must report the account in the Compliance System and obtain approval before transacting in the account.
(ii) | Securities Exempt from the Personal Trading Policy |
The following is a list of securities that are exempt from the Personal Trading Policy, including all reporting and pre-clearance requirements (the Exempt Securities):
| direct obligations of the Government of the United States (i.e., treasury bills, treasury bonds and U.S. savings bonds) |
| bankers acceptances, bank certificates of deposit, commercial paper, and High Quality Short- Term Debt Instruments, including short term municipal bonds and repurchase agreements |
| shares issued by money market funds |
| shares issued by U.S. registered open-end funds (i.e., mutual funds) other than AQR Mutual Funds and ETFs |
| shares issued by unit investment trusts (other than ETFs) that are invested exclusively in unaffiliated mutual funds |
3 | In order to maintain personal securities accounts, employees and their Household Members are required to provide consent for their broker(s) to provide AQR their personal trading activity. |
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AQR Capital Management, LLC | Code of Ethics 8 |
All other types of securities, which include any common or preferred stock, debt securities, ETFs, AQR Mutual Funds, shares issued by a close-end investment company or non-U.S. registered mutual fund, and Private Placements (collectively referred to as Reportable Securities) are subject to the Personal Trading Policy and requirements set forth below.
If you have questions as to whether a type of security is exempt, please contact the Compliance Department at CoreCompliance@aqr.com.
(iii) | Holdings Reports |
As part of the initial Compliance certification, employees are required to disclose via the Firms Compliance System all holdings in Reportable Securities no later than ten days after their start date.4 At least annually, all employees are required to certify to and update as necessary their holdings in Reportable Securities.5
(iv) | Transaction Reports |
On a quarterly basis, each employee is required to certify that all transactions in Reportable Securities that occurred during the prior quarter have been accurately reported in the Compliance System or provide any necessary updates. All employees are required to complete the quarterly and annual Compliance certifications, even if they do not hold any accounts and did not enter into any transactions in Reportable Securities during the reporting period.
The Compliance Department will review these reports and any issues or potential violations will be escalated to the CCO or his designee.
(d) | Pre-Clearance Requirements |
(i) | General |
Unless explicitly exempted below, employees are required to submit a trade request in the Compliance System and receive an approval before undertaking any personal transactions in Reportable Securities. This includes, among others, all equity and debt securities, all transactions in Private Placements,6 and any loan on behalf of employees (or their Household Members) with a financial institution that will be collateralized by Reportable Securities.7
Employees are responsible for understanding and monitoring any margin activity (e.g., pro-active funding, capital requirements, Portfolio/Regulation T margin calls) in their personal accounts and pre- clear any liquidation sales related to a margin call. Failure to pre-clear any liquidation sales related to a margin call, including those transactions executed by a broker without the employees knowledge or direction, may result in a violation of the Code of Ethics and the potential imposition of a sanction.
NoteThe Compliance Department reserves the right to deny any pre-clearance request for any reason and the reasons for any such denial may not be shared with the employee.
(ii) | Approval Period |
If a pre-clearance request is approved, the approval is effective until local market close on the date of approval; provided, however, the CCO or his designee may shorten or rescind any approval if it is deemed appropriate to do so. Transactions also may not exceed the quantity of shares approved in the pre-clearance request.
4 | The initial holdings report must be current as of a date not more than 45 days prior to their start date. This requirement also applies to Private Placements and all Reportable Securities not held at a broker-dealer. |
5 | Holdings information must be current as of a date no more than 45 days prior to the date each subsequent annual report is submitted. AQR Mutual Funds holdings in the AQR 401k Plan at Merrill Lynch do not require reporting to the Compliance Department. |
6 | Employees are required to pre-clear all transactions (i.e., initial investment, additional funding to an existing investment or redemption/liquidating transactions) in a Private Placement. |
7 | For pre-clearance requests involving collateralized loans, employees will be required to provide the name of the financial institution, the Reportable Securities used as collateral and a description of the loans purpose. |
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AQR Capital Management, LLC | Code of Ethics 9 |
NoteFacts and circumstances may occur, post pre-clearance approval, which may result in the Compliance Department requiring a reversal of the trade and disgorgement of any resulting gains.
(iii) | Transactions Exempt from Pre-Clearance |
Employees are not required to obtain prior approval to transact in the following Reportable Securities:
| ETFs |
| AQR Mutual Funds |
| Non-US registered open-end funds (e.g., Non-U.S. mutual funds, UCITs) |
| Municipal Bonds |
| securities acquired through corporate actions, such as stock splits, reverse stock splits, mergers, consolidations, spin-offs, and other similar corporate reorganizations generally involving all holders of the same class of securities |
| Involuntary sales due to a company exercising a call provision on its outstanding debt |
| transactions involving the exercise and/or purchase of securities pursuant to an employer stock option plan and any other similar plans. Any subsequent sale of Reportable Securities received from such plans must be pre-cleared |
| securities purchased pursuant to an automatic investment plan, including a dividend reinvestment plan |
| securities issued by an exercise of rights to the holders of a class of securities |
| transactions in direct obligations of non-U.S. Governments |
(e) | Seven-Day Blackout Period |
Employees may not purchase or sell any Reportable Security, subject to certain de minimis thresholds, during the seven-calendar day period before or after either a buy or sell order for a Clients account is executed or while a Client order is pending for the same or related security (such as securities convertible into the security). The existence of recent Client trades and pending orders will be checked as part of the pre-clearance process described above, and pre-clearance may be denied if the Compliance Department determines it is inconsistent with the best interests of any Client.
NoteEmployees may not knowingly trade parallel to or against a Client in a Reportable Security at any time or in any amount.
This prohibition does not apply to Third-Party Managed Accounts (discussed in Section 1.5(h) below) or to securities and transactions that are not subject to the pre-clearance requirements (discussed in Section 1.5(d)(iii) above).
(f) | Required Holding Period |
An employee may not purchase and sell, or sell and purchase, the same security within 30 calendar days. This provision extends across all accounts (e.g., if you purchase a security in one account, you cannot sell that same security in less than 30 calendar days in a different brokerage account).
This prohibition does not apply to Third-Party Managed Accounts (discussed in Section 1.5(h) below) or to securities and transactions that are not subject to the pre-clearance requirements (discussed in Section 1.5(d)(iii) above).
(g) | Prohibited and Limited Transactions |
The following table lists additional prohibitions and restrictions on transactions and holdings in Reportable Securities. Other than the restrictions on Initial Public Offerings, the below prohibitions do not apply to Third-Party Managed Accounts (discussed in Section 1.5(h) below).
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AQR Capital Management, LLC | Code of Ethics 10 |
Transaction Types |
Prohibition or Limitation | |
Initial Public Offerings / Initial Token Offerings | Participation in an Initial Public Offering or any Initial Token Offering (as defined in Section 1.5(k) below) is prohibited. | |
Restricted List | Transactions in securities on the Firms Restricted List are prohibited. | |
Affiliated Managers Group, Inc. (AMG) Securities | Transactions in securities issued by Affiliated Managers Group, Inc. securities (ticker: AMG) are prohibited.8 | |
Short Sales | Short selling securities is prohibited. Pre-existing short positions must be exited within 30 days of start date (subject to the pre-clearance requirements). | |
Derivatives | All derivatives, including options, warrants, swaps, futures and forward contracts are prohibited. Pre-existing positions must be exited within 30 days of start date (subject to the pre-clearance requirements) or held until expiration unless an exception has been approved by the CCO or his designee. | |
Good until Cancelled / Limit Orders | Good until cancelled orders and limit orders other than a same-day limit order generally should be avoided. Such orders are difficult to pre-clear and can cause inadvertent pre-clearance violations. |
The below chart contains additional investment activities that are prohibited.
Type of Activity |
Prohibition | |
Front-Running | Front-Running is taking a position (or selling a position) in a security or interest in a personal account with knowledge that the Firm will soon take a position (or sell a position) in the same security or interest. Front-Running is an illegal activity and prohibited for all trading, whether for personal accounts or trading on behalf of the Firm. | |
Scalping | Scalping refers to taking improper advantage of a Clients trading for the benefit of an employees personal account. Scalping is an illegal activity and prohibited. |
(h) | Third-Party Managed Accounts |
Transactions within approved Third-Party Managed Accounts are exempt from the pre-clearance requirements and trading restrictions set forth in the Personal Trading Policy if the following conditions are met:
| the investment manager has exclusive, discretionary investment authority over the account and the employee (and their Household Members) have no direct or indirect influence or control over the account |
| the investment manager is independent and not affiliated with or related to the employee (or their Household Members) |
| the investment manager provides written confirmation that (1) the investment manager has been granted exclusive, discretionary investment authority, and (2) the account holder does not exercise investment discretion or otherwise have direct or indirect influence or control over the investment decisions9 |
8 | Please note the Firms portfolio management teams are also prohibited from purchasing or selling AMG securities in Client Accounts. |
9 | The written confirmation must be in a form acceptable to the Compliance Department and the manager, investment adviser or trustee may be asked to periodically provide an updated confirmation. |
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AQR Capital Management, LLC | Code of Ethics 11 |
| the account will not purchase any security issued in an initial public offering |
NoteRobo-advised accounts are not considered Third-Party Managed Accounts.10 As such, the transactions in these accounts must be limited to securities that are exempt from the Firms pre- clearance requirements, such as ETFs and mutual funds, and adhere to all reporting requirements.
(i) | Trading Activity |
Employees are discouraged from engaging in a pattern of investment transactions that either: (1) is so frequent as to potentially impact their ability to carry out their assigned responsibilities; (2) gives rise to conflicts or perceived conflicts with the best interest of AQRs Clients; or (3) uses company resources or information learned during the course of their association with AQR for personal gain.
NoteThe use of trading algorithms that operate autonomously for personal trading is prohibited. Employees are also strictly prohibited from buying or selling any funds managed by AQR (including AQR Mutual Funds) on the basis of material non-public information learned during the course of their association with AQR.
The Compliance Department monitors the frequency of personal trading and reserves the right to subjectively determine what constitutes excessive trading. The Compliance Department may restrict personal trading for a particular employee (and their Household Members) or for all employees.
(j) | Personal Trading Violations |
The CCO or his designee reserves the right to prohibit an employees personal trading at any time and for any reason. If an employee does not comply with the Personal Trading Policy, the Firm may require the employee to trade out of the applicable position and/or disgorge any resulting gains. Each employee agrees to exit or liquidate upon instructions from the CCO or his designee, with the understanding that no explanation is required if such instruction is given, and no liability will accrue to the Firm as a result of any losses arising out of such exit or liquidation.
Personal trading violations may lead to disciplinary or other action, including but not limited to: (1) a requirement that a trade/transaction be reversed (even if a loss is incurred in doing so) in the event that an employee does not receive pre-approval from Compliance prior to transacting; (2) the suspension of personal trading privileges; (3) other employment-related action, including termination of employment; or (4) referral of the matter to the appropriate regulatory or government agency.
(k) | Bitcoin and Other Cryptocurrencies |
The trading of Bitcoin and other cryptocurrencies (collectively, Cryptocurrencies) is permitted, but may be subject to additional review and restrictions by the Compliance Department based on regulatory guidance. As noted above, Employees (and their Household Members) are prohibited from participating in or fundraising for any initial token offerings, including but not limited to an initial coin offering (ICO), security token offering (STO), initial exchange offering (IEO), or initial dex offering (IDO) (collectively, Initial Token Offerings). As noted above, employees (and their Household Members) are also prohibited from engaging in derivative transactions, which includes futures and options on cryptocurrencies.
NoteAs stated above, the use of trading algorithms that operate autonomously for personal trading, including for trading cryptocurrencies, is prohibited.
1.6 | Violations and Sanctions |
A failure to comply with the Manual or the Firms other policies and procedures may not necessarily amount to a violation. The CCO or his designee makes the determination as to what constitutes a violation and, where applicable, will work with the Human Resources Department and/or the employees supervisor to determine the appropriate disciplinary action, if any. When evaluating the appropriate disciplinary action for a Code of Ethics violation, if any, relevant facts and circumstances are considered, including, but not limited to, the frequency of occurrence and length of time since any previous violation by the employee.
10 | Robo-advisers are digital platforms that provide automated, algorithm-driven financial planning services with little to no human supervision. A robo-advised account is an account offered by a robo-adviser on its digital platform. |
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AQR Capital Management, LLC | Code of Ethics 12 |
Violations that demonstrate a lack of respect for the Firms commitment to adhere to high ethical, integrity and business conduct standards may result in disciplinary action, including termination of employment. Additionally, a violation of law may lead to disciplinary action that may include termination of employment and/or referral of the matter to the appropriate regulatory or government agency.
1.7 | Duty to Report Violations and Cooperate with Firm Investigations |
Employees are required to report promptly any known or suspected violations of the Manual, any Firm policy or procedure, or any law or regulatory requirement related to our business, including, but not limited to:
| violations of any applicable securities laws or regulatory requirements |
| breach of fiduciary duty arising under any applicable laws |
| violations of any similar laws or regulations by the Firm or any of its employees or agents |
Reporting can be made to a manager, the CCO, any member of the Compliance Department or anonymously via the AQR Hotline.11 Managers and members of the Compliance Department have an obligation to escalate any such reports to the CCO or his designee, who will determine how to proceed and whether a matter should be reported to any regulatory authority.
Employees (and former employees as needed) must also cooperate as requested by the Firm with any investigation, inquiry, internal review, examination or litigation related to the Firms business or potential misconduct.
NoteNotwithstanding anything herein to the contrary, this Manual will not be interpreted or applied in any manner that would violate an employees legal rights as an employee under applicable law. For example, nothing in this Manual prohibits or in any way restricts any employee from reporting possible violations of law or regulation to, otherwise communicating directly with, cooperating with or providing information to any governmental or regulatory body or any self-regulatory organization or making other disclosures that are protected under applicable law or regulations of the SEC or any other governmental or regulatory body or self-regulatory organization. An employee does not need prior authorization from AQR before taking any such action and an employee is not required to inform AQR if he or she chooses to take such action.
1.8 | Non-Retaliation Statement |
The Firm strictly prohibits intimidation or retaliation against anyone who (i) makes a good faith report about a known or suspected violation of the Manual or any Firm policy or procedure, or any law or regulation, or (ii) assists with any inquiry or investigation of any such violation.
The Firm will endeavor to maintain the confidentiality of any report of potential wrongdoing to the extent practicable and ensure that no employee will face any unlawful retaliatory action for making such report. Information provided will be handled discreetly and shared only with those individuals that the Firm has a need to inform, such as regulators and those who are involved in investigating, resolving and, if necessary, remediating the issue. Employees who have concerns about or are aware of possible retaliatory action must report it, either to their manager, a Human Resources representative, or the Hotline.
1.9 | Legal and Regulatory Inquiries |
The financial markets in which AQR participates are highly regulated and, as a result, the Firm and/or its employees may from time to time be involved in certain legal or regulatory matters. Any employee who receives a legal or regulatory inquiry or request for information (relating to AQR or any other entity or person) from entities including, but not limited to, a regulator, government agency, self-regulatory organization, supervisory authority, legislative body, market exchange or litigant should immediately contact the CCO or his designee.
Employees may not reach out to government agencies, regulators or self-regulatory organizations for routine guidance or questions on business, legal or regulatory matters without pre-approval from the CCO or his designee. Nothing in this section shall interfere with an employees legal rights as an employee under applicable law, as discussed above.
11 | The telephone numbers for the Hotline are located on the Compliance Page (Go/Compliance). |
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AQR Capital Management, LLC | Code of Ethics 13 |
Nothing in this Manual shall prohibit or restrict an employee from participating, cooperating, or testifying in any action, investigation, or proceeding with, or providing information to, any governmental agency, legislative body, or any self-regulatory organization, provided that, to the extent permitted by law, upon an employees receipt of any subpoena, court order or other legal process compelling the disclosure of any such information, documents, or testimony, an employee shall give prompt prior written notice to the CCO or the Compliance Department in order to provide the Firm reasonable opportunity to take appropriate steps to protect its Confidential Information.
II. | Definitions |
1. | AQR Mutual Funds: U.S. registered investment companies advised or sub-advised by AQR Capital Management, LLC and AQR Arbitrage, LLC. |
3. | Client: A person or entity with an advisory or sub-advisory agreement with the Firm. |
5. | Confidential Information: Any non-public information, records, files, documents, correspondence or other material regarding the Firm, employees, Clients, or the business of the Firm. |
8. | Private Placements: An offering of unregistered securities to a limited pool of investors (e.g., hedge fund, private equity fund, venture capital fund, real estate fund). |
10. | Restricted List: The Firms list of securities for which personal and Firm trading is either partially or wholly prohibited unless pre-approved by the CCO or his designee. |
11. | Third-Party Managed Account: An account that is managed by an independent investment manager who has exclusive discretionary authority over all investment decisions in the account. |
AQR Capital Management, LLC | One Greenwich Plaza | Greenwich, CT 06830 | U.S. | p: +1.203.742.3600 | f: +1.203.742.3100 | w: aqr.com
CODE OF ETHICS | 2023 |
INDEX OF UPDATES |
3 | |||||
1. INTRODUCTION |
6 | |||||
1.1 APPLICATION | 6 | |||||
1.2 SCOPE | 6 | |||||
1.3 PURPOSE | 6 | |||||
1.4 STAFF OBLIGATIONS | 6 | |||||
1.5 VIOLATIONS | 7 | |||||
1.6 INTERPRETATION AND WAIVER | 7 | |||||
1.7 MONITORING | 7 | |||||
1.8 MATERIAL CHANGES | 7 | |||||
2. ETHICAL PRINCIPLES |
8 | |||||
2.1 INTRODUCTION | 8 | |||||
2.2 GUIDING ETHICAL PRINCIPLES | 8 | |||||
2.3 RESOLVING ETHICAL ISSUES | 10 | |||||
3. CONFLICTS OF INTEREST |
10 | |||||
3.1 INTRODUCTION | 10 | |||||
3.2 IDENTIFICATION AND TYPES OF CONFLICT OF INTEREST | 10 | |||||
3.3 DUTY TO DISCLOSE | 11 | |||||
3.4 OUTSIDE BUSINESS INTERESTS AND PERSONAL ASSOCIATIONS | 12 | |||||
4. PERSONAL ACCOUNT DEALING POLICY |
16 | |||||
4.1 HIGH LEVEL OVERVIEW | 16 | |||||
4.2 GENERAL RULE ON PA DEALING | 16 | |||||
4.3 APPLICATION OF PERSONAL ACCOUNT DEALING POLICY | 17 | |||||
4.4 PROHIBITED AND EXEMPT SECURITIES AND TRANSACTIONS | 17 | |||||
4.5 PROCEDURES FOR OBTAINING PERMISSION | 19 | |||||
4.6 PRACTICAL PROCEDURES TO BE FOLLOWED IN SPECIAL CIRCUMSTANCES | 20 | |||||
4.7 REPORTING REQUIREMENTS | 21 | |||||
4.8 SUMMARY TABLE OF SECURITY TYPES AND PRE-CLEARANCE AND REPORTING REQUIREMENTS | 22 | |||||
5. INDUCEMENTS POLICY |
23 | |||||
5.1 GUIDELINES | 23 | |||||
5.2 RESTRICTIONS IN CONNECTION WITH THE SALE OF PACKAGE PRODUCTS, I.E. OEICS | 27 | |||||
5.3 PACKAGED PRODUCTS GUIDANCE ON REASONABLE INDIRECT BENEFITS | 28 | |||||
5.4 FINRA SPECIFIC REQUIREMENTS FOR REGISTERED PERSONS OF BGFS | 29 | |||||
5.5 SPECIFIC REQUIREMENTS FOR GIVING OR RECEIPT OF GIFTS, HOSPITALITY, AND ENTERTAINMENTS TO KOREAN PUBLIC OFFICIALS | 29 | |||||
6. ACKNOWLEDGEMENT AND CERTIFICATION |
30 | |||||
6.1 RECEIPT AND ACKNOWLEDGEMENT OF THE CODE | 30 | |||||
6.2 ANNUAL REPORT TO BAILLIE GIFFORD BOARDS | 30 | |||||
APPENDIX I SPECIFIC REQUIREMENTS FOR GIVING OR RECEIPT OF GIFTS, HOSPITALITY, AND ENTERTAINMENTS TO KOREAN PUBLIC OFFICIALS | 31 |
2
Index of Updates Date Reason for change Material Regulatory 4.5.1. Separate broker notification letter for BGFS representatives no longer required. 4.5.1. New paragraph added about broker confirmations. 4.8. Minor
updates to description of unlisted investments in the summary table. Minor housekeeping changes throughout the policy to change all references to holdings
reports to Code of Ethics Declarations. Additional client requirement added to the list of clients with specific requirements link in section 5.1.15. Change of job title for Lindsay Gold from Head of Compliance to Compliance Director (Page 5). Reference to CFTC added in Section 6.0. Changes to ensure
BGE is covered by the policy. No No No No No No Yes No
CODE OF ETHICS
2023
Change
Requirement
October 2017
Changes made to reflect MiFID II requirements. New requirements on Inducements relating to MiFID, equivalent third country or optional exemption business under FCA COBS 2.3A for firms which make personal recommendations to a retail
client in the UK and, in particular, rules on inducements relating to the provision of investment services and ancillary services that the FCA will adopt under new FCA COBS 2.3A 5R. Chapter 5 updated with minor housekeeping changes throughout.
Yes
Yes
May 2018
No
No
August 2018
Minor updates to summary table in section 4.8 to include references to cryptocurrencies and structured deposits.
No
No
September 2018
Removal of references to Baillie Gifford Life Limited. This entity is no longer carrying out insurance business and has applied for the cancellation of all its regulatory permissions.
No
No
October 2018
New Guidance for partners and staff considering external appointments section added to the Conflicts of Interest chapter of the Code of Ethics Policy, plus a link to the guidance note. Not a material change as this is the
publication of guidance and not a Code of Ethics Policy change. Summary table in section 4.8 updated to consolidate the two rows relating to exchange traded funds into one row.
No
No
November 2018
Housekeeping update to the PA dealing policy following changes to the workplace pension arrangements.
No
No
January 2019
March 2019
Updates to summary table in section 4.8 to reflect the 3 security types added. Certificate of Deposit, Fixed Term Deposit and Fixed Term Bond.
No
No
April 2019
Changed Lindsay Golds title from Head of Compliance to Compliance Director and changed Monitoring, Ethics Conduct and Assurance team name to Monitoring and Ethics team.
No
No
July 2019
Update political contributions sections to confirm that pre-clearance can be obtained from US based Compliance Counsel and the Code of Ethics team, rather than the Compliance Director.
No
No
September 2019
Updates made to reference the new FCA Conduct Rules introduced under SMCR and make enhancements to the Outside Business Interests section.
Yes
Yes
September 2019
OBI section of the policy updates to include a new table of examples and a new streamlined process which consolidates the pre-existing Code of Ethics policy and the HR OBI and Employment
Policy which has since been decommissioned.
Yes
No
September 2019
Whistleblowing Policy removed (now standalone), BGA(HK) semi-annual declaration process referenced and various housekeeping amendments.
No
No
March 2020
Additional conflict disclosure requirements for investment decision makers to reflect an increased industry focus in this area.
Yes
No.
December 2020
Housekeeping changes to change unlisted investments to private companies and clarifying personal associations
No
No
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CODE OF ETHICS | 2023 |
January 2021 | Alastair Maclean replaces Lindsay Gold, as Director, Group Compliance and Legal. | No | Yes | |||
May 2021 | Addition of section 3.4.3 Disclosure Procedures for External Board/Committee Appointments. Minor housekeeping updates to clarify the policy which included: adding ETFs to the section in 4.3; FX and cryptocurrency in 4.4.2.1; Automatic sales for fees in 4.4.2.2; updating various links throughout the policy; updating the Group Compliance and Legal Director title throughout. |
No | No | |||
August 2021 | Housekeeping changes: No change to process, tidying up policy wording and making it clearer. | No | No | |||
January 2022 | References to: 1) Compliance Monitoring and Ethics Team updated to Compliance Code of Ethics Team; and 2) Head of Compliance Monitoring and Ethics updated to Head of Group Compliance Staff Regulatory Responsibilities. | No | No | |||
March 2022 | Post-Brexit updates made for UK/EU MiFID references throughout the policy. Name change for the Policies Training & Reporting team to Events & Global Registrations team. | No | No | |||
May 2022 | Following a query from an Investment Trust Board, we have decided to tighten up the language around PA dealing during BG Investment Trust share buy-backs. New section 4.4.5. added.
Various minor housekeeping updates. |
No No |
No No | |||
January 2023 | Incorporate South Koreas Anti-Graft Rule in section 5.5. | No | Yes |
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CODE OF ETHICS | 2023 |
Letter from the Joint Senior Partner and Group Compliance, Legal and Governance Services Director
Dear Colleagues,
The Code of Ethics Policy is a very important area for us because our clients have put a great deal of trust in Baillie Gifford to manage their assets in their long-term interests. For us to respect that trust there are two things that we must focus on:
| Firstly, making sure that we put clients interests at the heart of everything that we do; and |
| Secondly, making sure that we identify and manage any conflicts of interest between our interests and those of the client. |
The compliance culture and ethics of a firm are vitally important to clients and regulators alike. Our clients refer to the Code of Ethics Policy as the window on the culture of the firm. They are interested in adherence with the policy and often ask for information on code violations as an indicator of the overall culture of the firm.
Regulators have also put culture and conduct at the centre of their agenda. Culture is regarded as the DNA of the business; shaping behaviours and ethics. At Baillie Gifford we have built our reputation by our conduct as individuals, acting with integrity and in the interests of our clients.
The Code of Ethics Policy sets out the processes, procedures and principles in this area and we ask you to give it your full attention. If you have any questions, please do not hesitate to contact a member of the Compliance Code of Ethics team or email CodeofEthicsQueries@bailliegifford.com.
Thank you.
Andrew Telfer | Alastair Maclean | |
Joint Senior Partner of Baillie Gifford & Co | Director, Group Compliance, Legal and Governance Services |
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CODE OF ETHICS | 2023 |
1. | Introduction |
1.1 | Application |
The Code of Ethics applies to
| All employees of Baillie Gifford entities |
| Partners |
| Fixed term, temporary and agency staff |
| Interns and summer students |
| Secondees |
| Individuals providing services via Personal Service Companies |
| Contractors (with systems access) |
Each of these individuals and in some specified cases, persons who are connected to the individual, are required to comply with the Code of Ethics which forms part of the Personal Responsibilities section of the Group Compliance Manual (located via the Landing Page on the Loop) and their employment contract. These individuals are known as access persons for the purposes of US securities laws.
1.2 | Scope |
The Code covers all firms within the Baillie Gifford Group and has been adopted by the relevant Boards of Baillie Gifford regulated entities within the Group and the Groups Compliance Committee. It is designed to ensure compliance with relevant regulatory requirements applicable to the Baillie Gifford Group and in particular UK FCA, CBI, US SEC, and South Koreas requirements.
The Code of Ethics covers:
| the FCA Conduct Rules which apply to the vast majority of staff11 |
| guiding ethical principles which apply to all staff |
| managing conflicts of interest which may occur between Baillie Gifford and the personal interests of members of staff |
| personal dealings in shares |
| receiving and giving of gifts, hospitality and other forms of inducement. |
1.3 | Purpose |
At Baillie Gifford we have a fiduciary duty to our clients when acting as their investment manager or adviser. This requires us at all times to act in the best interests of our clients and to treat them fairly. We must avoid situations where we place our own interests ahead of the interests of clients. The Code of Ethics is designed to assist us in ensuring we meet these fiduciary standards when acting for clients.
1.4 | Staff Obligations |
As a member of staff, you are obliged to comply with your regulatory obligations under the various regulatory systems to which the Group is subject, including applicable federal securities laws. You are required to:
| Read and adhere to the Code of Ethics. If you have any questions, please email CodeofEthicsQueries@bailliegifford.com (secure mailbox); and |
| Complete and submit a Code of Ethics Declaration and submit a Certificate of Compliance on first becoming a member of staff and annually thereafter. |
1 | The Conduct Rules do not apply to ancillary staff not performing a financial services role. This would cover our mailroom staff, security guards, cleaning and catering staff. |
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CODE OF ETHICS | 2023 |
You will be provided with details of any changes to the Code at the time these are made. Training will be provided on the terms of the Code as part of your staff induction and annually thereafter, or more frequently in the event of a material change.
1.5 | Violations |
Failure on the part of members of staff or their Connected Persons (where applicable) to follow these procedures will be taken seriously and regarded as a disciplinary matter under the rules and procedures set out in the Staff Handbook. If it is determined that gross misconduct has taken place, the member of staff may be subject to instant dismissal without payment in lieu of notice.
In addition, any conduct by a member of staff that violates the Code of Ethics, including the Ethical Principles, will be considered from an FCA Conduct Rule Breach perspective (see section 2.1 below for details of the FCA Conduct Rules). If it is deemed that a Code of Ethics violation is significant in nature (e.g. evidence of intent; client materially affected; trend of repeated violations etc.), it may be escalated within Baillie Gifford to be assessed further by senior members of the HR, Compliance and Business Risk departments. Depending on the severity of the case, a formal Conduct Rule Breach may subsequently be reported to the FCA in accordance with regulatory reporting timelines.
Any member of staff who becomes aware of a violation of the Code of Ethics must promptly report that violation to the Group Compliance, Legal and Governance Services Director , who may, at his discretion, refer the violation to the Legal and Compliance Partner as well as the relevant Board and Compliance Committee for resolution in terms of section 1.6 below.
1.6 | Interpretation and Waiver |
With respect to matters of interpretation or dispute arising under the Code of Ethics, the Group Compliance, Legal and Governance Services Director may refer to the Compliance Committee of Baillie Gifford who may, exercising their reasonable judgment, make determinations as to the meaning and effect of the Code of Ethics. The Group Compliance, Legal and Governance Services Director may, in consultation with the Compliance Committee, grant written waivers of the provisions of the Code in appropriate instances. However, waivers will be granted only in rare instances and some provisions of the Code that are mandated by law or regulation cannot be waived. The Group Compliance, Legal and Governance Services Director is responsible for maintaining appropriate records of and preparing any reports required with respect to, any waivers of provisions of the Code.
1.7 | Monitoring |
Adherence by staff to the terms of the Code will be monitored by the Compliance Department. The issue, receipt and content of Code of Ethics Declarations and Certificates will be co-ordinated and monitored by that Department. Regular monitoring of personal account dealing, gifts and entertainment records and other forms of inducements will also be undertaken to ensure there are no actions which are contrary to our regulatory obligations and that we always act in the best interests of clients. The results of this monitoring will be reported to the relevant Boards and Compliance Committee.
1.8 | Material Changes |
Material changes to the Code of Ethics must be ratified by the relevant Boards of the SEC regulated firms and investment companies within the Group and the Groups Compliance Committee.
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2. | Ethical Principles |
2.1 | Introduction |
Baillie Giffords reputation and success is based upon its professional conduct and maintenance of high ethical standards. It is expected and indeed demanded from our clients that we adhere to robust ethical standards in all aspects of our activities.
This section of the Code of Ethics sets out guiding principles which apply to all staff relating to ethical conduct. It also provides some guidance on addressing and resolving ethical issues.
In addition, many individuals within the Group will be subject to ethical principles and codes of conduct which are adopted by various professional organisations to which they are members. Baillie Giffords Code of Ethics is designed to be complementary to, and consistent, with these other standards.
The FCAs Senior Managers and Certification Regime (SMCR) introduces a set of Conduct Rules which reflect the core standards expected of staff who work within the Financial Services industry. These can be found in the FCAs Code of Conduct sourcebook (COCON) and are composed of nine rules, five of which are applicable to all staff (other than ancillary staff referred to earlier) and four additional rules applicable only to Senior Managers. The five Conduct Rules which are applicable to all staff are as follows:
1. You must act with integrity;
2. You must act with due care, skill and diligence;
3. You must be open and cooperative with the FCA, PRA and other regulators;
4. You must pay due regard to the interests of customers and treat them fairly; and
5. You must observe proper standards of market conduct.
These conduct rules compliment Baillie Giffords own guiding ethical principles and are embedded within these. The four additional rules applicable only to Senior Managers are covered separately in the SMCR Policy.
The Code of Ethics cannot cover every ethical situation that might arise at Baillie Gifford. After having read and understood the content of the Code of Ethics Policy, all members of staff will be responsible for complying not only with its letter, but also with its spirit and principles. These are set out in the Guiding Ethical Principles below.
2.2 | Guiding Ethical Principles |
Each member of staff must follow these guiding principles:
2.2.1. Fairness
To act fairly at all times when dealing with clients and counterparties of Baillie Gifford. Fairness requires impartiality, objectivity, and honesty.
For example, when communicating with clients you should make every reasonable effort to provide full, fair and accurate information and should avoid withholding any relevant information.
A non-exhaustive list of other examples of conduct that might breach the fairness principle is as follows:
| Misleading a client about the risks of an investment; |
| Misleading a client about the likely performance of a product by providing inappropriate projections of future returns; or |
| Failing to acknowledge, or seek to resolve, mistakes in dealing with clients. |
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CODE OF ETHICS | 2023 |
2.2.2. Honesty and integrity
To act honestly and with integrity in fulfilling the responsibilities of your role and seek to avoid any acts or omissions or business practices which damage Baillie Giffords reputation or which are deceitful, oppressive, or improper.
For example, Baillie Gifford should only employ fair methods to win or retain business for the firm. Staff should avoid offering unduly lavish or overly frequent gifts and hospitality and should avoid pay to play practices, i.e. making political contributions to those in a position to influence the selection of Baillie Gifford. Baillie Gifford is committed to carrying on business fairly, honestly and openly and has a zero-tolerance approach to bribery.
A non-exhaustive list of other examples of conduct that might breach the honesty and integrity principle is as follows:
| Falsifying documents; |
| Providing false or inaccurate information to a client, regulator, auditor, Baillie Gifford itself or a third party; |
| Mismarking the value of investments; |
| Misleading others in Baillie Gifford about the nature of risks being accepted; or |
| Failing to disclose personal dealing activity; receipt or provision of gifts and entertainment; political contributions or other outside business interests as required by the Code of Ethics. |
2.2.3. Adherence to law and regulation
To observe applicable law, regulations and professional conduct standards when carrying out your activities and to interpret and apply them to the best of your knowledge and ability according to these guiding ethical principles. To be open and cooperative with Baillie Giffords regulators.
For example, you must familiarise yourself with, and adhere to at all times, the requirements contained in the: Anti-Financial Crime Policy; the Anti-Money Laundering, Counter-Terrorist Financing & Sanctions Policy; the Anti-Bribery & Corruption Policy; the Code of Ethics Policy; the Market Abuse and Insider Dealing Policy; Data Protection Policy; and Information Security & Electronic Communications Policy. These policies set out your personal compliance responsibilities and are available to all staff in the Personal Responsibilities section of the Group Compliance Manual.
A non-exhaustive list of conduct that might breach the open and cooperative with regulators principle is as follows:
| Providing false or inaccurate information to regulators; |
| Failing to supply a regulator with appropriate documents or information when requested or required to do so and within the time limits attaching to that request or requirement; or |
| Failing to attend an interview or answer questions put by a regulator. |
2.2.4. Market conduct
When executing transactions or engaging in any form of market dealings, to observe the standards of market integrity, good practice and conduct required by, or expected of, participants in that market. To comply with relevant market codes and exchange rules.
2.2.5. Loyalty to clients
To place the interests of our clients ahead of your own interests and to manage fairly and effectively, and to the best of your ability, any relevant conflict of interest. To the extent feasible, conflicts of interest should be avoided or at least appropriately managed and disclosed in accordance with Baillie Giffords conflicts procedures.
Baillie Giffords investment recommendations and other proprietary information are for the exclusive use of our clients. We should not use this proprietary information for personal benefit. If in doubt, refer to the Compliance Department for guidance.
2.2.6. Maintaining confidentiality
To respect the confidentiality of information on current, former and prospective clients which is obtained through your work and refrain from using or disclosing this for unethical purposes or illegal advantage.
For example, you must be extremely careful when sharing confidential client data with an outside party and should only do so if it is absolutely necessary. Authorisation may be required from your Head of Department for this. If in
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CODE OF ETHICS | 2023 |
doubt, you should refer to the Information Security and Electronic Communications Policy (located in the Staff Handbook on the Loop) which includes the three levels of data security classification and rules on how to handle this data.
2.2.7. Transparency
If you are in any doubt that you may have a conflict of interest, or if you think that there could be a perception of one, you should disclose the details to your Head of Department, to the Compliance Department or to the relevant chairperson of the board, committee or group concerned, as appropriate.
For example, consider the situation where you have a personal shareholding in a company and you are contributing to an investment discussion on whether to buy or sell this company for clients. It is essential to disclose this potential conflict to the chairperson and other members of that decision-making group. Please see section 3.3 for further details on additional disclosure requirements for investment decision makers (investors and CD staff on Portfolio Construction Groups).
2.3 | Resolving Ethical Issues |
In business life we will be confronted from time to time with ethical issues to determine. In dealing with these an important consideration is any impact the decision may have on clients. Also, has the process of coming to the decision been fair, with full consideration of the facts, issues and alternatives? Has it involved all stakeholders with an interest? Have you identified any competing interests or conflicts of interest? These questions would be relevant where considering whether to accept a gift or entertainment, and also considering the implications of an incident.
3. | Conflicts of Interest |
3.1 | Introduction |
Inherent throughout the Code of Ethics is the principle that all members of staff have a responsibility to place the interests of the Groups clients ahead of their own and resolve conflicts in favour of the Groups clients. In order to achieve this, all activities undertaken by members of staff must be conducted in such a manner as to avoid any actual or potential conflicts of interest or any abuse of an individuals position of trust and responsibility. Furthermore, all action taken by staff must be undertaken in a manner which does not interfere with the interests of Baillie Giffords clients or take unfair advantage of Baillie Giffords relationship with its clients.
3.2 | Identification and Types of Conflict of Interest |
3.2.1. What is a conflict of interest?
A conflict of interest arises when personal matters or obligations interfere with business activities and influence the decisions made by members of staff, which have or could have a detrimental effect on the firms clients. When considering conflicts of interest, it is important to consider how the situation would be viewed by an independent party.
3.2.2. Identification of conflicts of interest
Conflicts of interests which require to be identified by members of staff are those which arise between:
| the Group, its connected persons and a client of the Group; or |
| one client of the Group and another client of the Group. |
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3.2.3. Types of conflicts of interest
When identifying whether a conflict of interest arises in the course of business and whether the existence of this conflict may adversely affect the interests of a client, staff should consider whether the individual, firm or certain persons connected with the firm:
| are likely to make a financial gain or avoid a financial loss at the expense of a client; |
| has an interest in the outcome of the service provided to the client or of a transaction carried out on behalf of the client; |
| has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client; |
| carries on the same business as the client; or |
| receives or will receive from a person (other than the client) an inducement in relation to the service provided, in the form of monies, goods or services, other than the standard commission or fee. |
The Group Compliance Manual (located via the Landing Page on the Loop) contains Baillie Giffords conflicts policy and matrix. This matrix details potential and actual conflicts of interest which have been recognised by the firm. Please refer to this document for further information regarding the types of conflict which have been identified.
If you are in doubt about whether a conflict has arisen please consult the Group Compliance, Legal and Governance Services Director.
3.3 | Duty to Disclose |
All members of staff have in the first instance an obligation to manage or avoid all conflicts of interest. If it is not possible to manage or avoid a conflict of interest, then the potential or actual conflict which may impair your objectivity when undertaking your daily activities must be disclosed. All disclosures should be made to your Head of Department and the Group Compliance, Legal and Governance Services Director.
Baillie Gifford does not prohibit investors from investing in the same stocks as our clients. Nevertheless, there is an inherent conflict of interest risk that needs to be carefully managed should investors choose to do this.
Additional disclosure requirements for investment decision makers.
Investment decision makers should make the following protective disclosures where appropriate:
| Investment decision makers should declare any pre-existing personal shareholdings in a company if they are contributing to an investment discussion on whether to trade in that company for clients. This potential conflict must be disclosed to the chairperson of the relevant decision-making group, whom failing another member of that decision-making group. On occasion, it may be prudent for an investment decision maker to step out of an investment discussion if it is felt that a conflict, or perception of a conflict, cannot be managed effectively. Such a course of action should be determined on a case by case basis. |
| Investment decision makers must also declare any personal trading activity in a company held by clients if they have been, or will be, involved in an investment discussion concerning that company. This disclosure requirement is regardless of whether the company is being traded for clients at the time. Again, this potential conflict must be disclosed to the chairperson of the relevant decision-making group, whom failing another investment decision maker in that decision-making group. |
For both scenarios above, Investors have the option of retaining their own contemporaneous record of any disclosures made or notifying the Compliance Department who will record the protective disclosure in the Code of Ethics System. Notifications to Compliance should be emailed to CodeofEthicsQueries@bailliegifford.com (secure mailbox). An audit trail record would be beneficial in the event of any retrospective enquiry.
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3.4 | Outside Business Interests and Personal Associations |
A personal conflict of interest can arise in relation to certain outside business interests or personal associations. Members of staff must ensure that they do not engage in any activities that would detract, divert from or conflict with, the proper performance of their Baillie Gifford employment or would conflict with the interests of the firm or our clients. Members of staff must also ensure that any personal association does not affect, or reasonably appear to affect, our conduct or actions in Baillie Gifford and therefore conflict with our duties to clients or the firm.
To ensure that we comply with the requirements of global regulation, we require members of staff and Partners to inform Compliance at CodeofEthicsQueries@bailliegifford.com of any external interests at any time during employment.
3.4.1 Types of Outside Business Interests
The following table is a non-exhaustive list of potential outside business interests. If you have any other interests or activities that you think may need to be disclosed, please contact the Compliance Code of Ethics team for guidance at CodeofEthicsQueries@bailliegifford.com (secure mailbox).
Outside Business Interest |
Disclosure Requirements | |
Paid work out with Baillie Gifford. | In general, all regular paid work outwith Baillie Gifford should be disclosed to Compliance (email to CodeofEthicsQueries@bailliegifford.com). In addition, such work should also be agreed with your line manager and/or head of department as appropriate.
Discretion can be used for any ad hoc paid work that is de minimis in nature and has no obvious connection to Baillie Gifford business. Such paid work is unlikely to require disclosure. | |
Business related external directorships, non-executive directorships or other external board/committee appointments (e.g. nominations committee or board observer positions ).
Business related would include:
Listed companies;
Private companies in which Baillie Gifford invests or is likely to invest;
Trade bodies or professional bodies;
Clients;
Suppliers etc. |
All such positions must be disclosed to Compliance (email to CodeofEthicsQueries@bailliegifford.com).
Additional disclosure and approval requirements are outlined in section 3.4.3. | |
Non-business related external directorships or non-executive directorships.
Non-business related would include:
Private family run businesses;
One-person limited companies;
Charitable organisations or not for Profit organisations (where not a client). |
All such appointments must be disclosed to Compliance (email to CodeofEthicsQueries@bailliegifford.com).
No additional approval is required. |
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External investment or finance related roles at educational, charitable, religious or social organisations.
Investment or finance related roles would include:
investment adviser;
trustee;
treasurer etc. |
All investment adviser related roles should be disclosed to Compliance (email to CodeofEthicsQueries@bailliegifford.com).
In addition, such roles should also be agreed with your line manager and/or Head of Department as appropriate. | |
Politically exposed appointments | A politically exposed person, or PEP, is an individual who is or has, at any time in the preceding year, been entrusted with prominent public functions, or is an immediate family member, or a known close associate of such a person), whether paid or unpaid.
All such appointments must be disclosed to Compliance (email to CodeofEthicsQueries@bailliegifford.com).
In addition, such roles should also be disclosed to your line manager and/or Head of Department as appropriate. |
3.4.2 Outside Business Interests disclosure procedures
The Compliance Code of Ethics team are the central hub for all outside business interest disclosures. This team will disseminate relevant information as appropriate to the Human Resources Department, Group Governance Services Department and the Events & Global Registrations and Anti-Financial Crime teams.
Outside business interest disclosures should be emailed to the Compliance Code of Ethics team (CodeofEthicsQueries@bailliegifford.com) at the earliest opportunity. Where possible, this should be prior to the commencement of any role or appointment. Disclosures should contain the following information:
| Date the outside business interest commenced or ceased; |
| Name of the external company/organisation and brief description of what they do; |
| Brief description of your role/involvement; |
| Details of any remuneration if applicable; |
| Details of any connection to Baillie Gifford (e.g. client or prospective client, investee company, broker, supplier etc.). |
If applicable, the Compliance Code of Ethics team will obtain approval from the Group Compliance, Legal and Governance Services Director on your behalf and will either confirm that this has been received or will request further information if required.
Please note that Partners or Chief Executive Officers of Baillie Gifford subsidiary companies who require to seek approval from the joint Senior Partners for external appointments, must seek this approval themselves.
In addition to the above:
- | Requirements for FCA Regulated Roles |
The Firm is required to ensure that individuals in FCA regulated roles are fit and proper to perform the activities for which they are regulated and that they do not engage in any activities which could conflict with the performance of their role. In addition to the above requirements, individuals in regulated roles must inform Compliance when:
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CODE OF ETHICS | 2023 |
| they become aware that a company, partnership or unincorporated association of which the individual has been controller, director, senior manager, partner or company secretary (either during the time they held the position or within one year of such involvement) has: |
| been put into liquidation, wound up, ceased trading, had a receiver or administrator appointed or entered into a voluntary arrangement with its creditors |
| been adjudged by a court liable for any fraud, misfeasance, wrongful trading or misconduct |
| been investigated or been involved in an investigation by an inspector appointed under companies or any other legislation, or required to produce documents to the Secretary of State, or any other authority, under any such legislation |
| been convicted of any criminal offence, censured, disciplined or publicly criticised, by any inquiry, by the Takeover Panel or any governmental or statutory authority, or any other regulatory body |
- | Specific Requirements for BGFS |
Registered Persons of BGFS are required to obtain prior written approval from the Chief Compliance Officer of BGFS for any Contractor, Director, Office or Partner appointments or any work for which they expect to receive compensation outside of their Baillie Gifford employment. Please note that this supersedes the requirement to obtain approval from the Group Compliance, Legal and Governance Services Director.
- | Specific Requirements for BGA(HK) |
Licensed Persons of BGA(HK) are required to obtain prior written approval from the Compliance Officer of BGA(HK) for any Director appointments or any work for which they will receive compensation outside of their Baillie Gifford employment. The Compliance Code of Ethics team will co-ordinate this. In addition to the above, there are also SFC Notification requirements relating to any directorships, partnerships or proprietorships taken on by a licenced representative. The BGA(HK) Compliance Officer will advise on the relevant steps to take with regards to this notification.
3.4.3 Disclosure and Approval Requirements Procedures for Business-related External Positions
From time to time, Investors or other relevant Baillie Gifford staff may be invited to take up a business-related external position (see section 3.4.1 for details). Such roles may be linked to public or private company in which our clients have a shareholding interest and are often offered to the largest shareholders. This type of opportunity is in alignment with our long term investment approach and our stewardship policy for greater engagement with our investee companies on corporate governance, long term incentives and performance matters.
Whilst there are benefits to accepting such positions, there are also potential conflicts of interest that need to be carefully managed. Each business-related external position needs to be considered on a case by case basis to ensure participation in such a role would not conflict with the duties owed to Baillie Giffords clients. The disclosure and approval requirements for such positions are as follows:
| All business-related external positions must be approved by the Director of Group Compliance, Legal and Governance Services for approval. Where deemed appropriate, the Director will discuss the case with the Chair of the Equity Leadership Group and the Management Committee will be informed for noting. The factors taken into consideration when assessing each opportunity will include: |
| Scope, time commitment and any remuneration |
| The likelihood of receiving Material Non-Public Information (MNPI) |
| Any potential conflicts of interest |
| Committee on Foreign Investment in the United States (CFIUS) requirements if applicable (legal advice may be required). |
| In addition, prior approval must also be sought from the individuals Head of Department. For Partners and Chief Executive Officers of Baillie Gifford subsidiary companies should seek prior approval from the joint Senior Partners. |
3.4.4 Personal Associations
We also must take steps to ensure that any personal interest or personal association does not affect, or reasonably appear to affect, our conduct or actions in Baillie Gifford and therefore conflict with our duties to clients or the firm.
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Any Significant Relationship with another person working in a relevant business connected to Baillie Gifford may need to be disclosed by email to the Compliance Department (CodeofEthicsQueries@bailliegifford.com).
Relevant businesses would include:
| Investment managers |
| Brokers |
| Clients of Baillie Gifford |
| Consultants/advisers to clients of Baillie Gifford or investors in Baillie Gifford funds |
| Companies in which Baillie Gifford invests on behalf of our clients |
| Other organisations with which Baillie Gifford has a contractual relationship. |
A relationship with another person would be deemed significant if an independent third party might reasonably consider that it could affect your actions or those of a personal associate (whether or not it does so affect your conduct). If you have a relationship with an associated person that could potentially give rise to a conflict of interest, or the perception of one, then this should be disclosed to the Compliance Department. The Compliance Department will determine if the relationship needs to be recorded and whether any action needs to be taken to manage the conflict.
Please note that personal associations can go further than our definition of connected person under PA Dealing, i.e. this disclosure requirement is not limited to immediate family members living in your household. Some examples of potential personal associations that may need to be disclosed/recorded are as follows:
| A personal friend works at a supplier and is directly involved in the Baillie Gifford account and/or you are directly involved in the appointment of that supplier. |
| A close friend works at an audit firm and is directly involved in an external review of your department. |
| An extended family member works at a company that Baillie Gifford invests in for clients, in a role where they are likely to have access to sensitive business information. |
Please note that none of the personal association examples above would fall under our definition of connected persons for PA Dealing purposes, however potentially would be disclosable under this section of the Code of Ethics. However, please also note that not every instance of the above would necessarily have to be recorded. Each scenario would be considered on a case-by-case basis to establish what, if any, conflict risk there is.
These disclosures are designed to ensure that our work is carried out on behalf of clients in an environment that is free from any suggestion of improper influence. If you are in any doubt as to whether a business interest or personal association or relationship needs to be disclosed, please contact a member of the Compliance Department for guidance.
3.4.5 Record Keeping and Annual Certification
A record of all Outside Business Interests and Personal Associations disclosed to Compliance will be maintained in the Code of Ethics System. These will form part of your personal Annual Code of Ethics Declaration. Updates can be made to these disclosures when completing your annual declaration, or alternately at any point throughout the year by emailing the details to Compliance (CodeofEthicsQueries@bailliegifford.com).
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4. | Personal Account Dealing Policy |
4.1 | High Level Overview |
Baillie Giffords first priority is in ensuring that in all circumstances, the firms clients interests are placed first and each client obtains the best execution of trades which we can arrange on their behalf. In order to ensure that this priority is consistently met, all staff have a responsibility to ensure that in no circumstances will clients be disadvantaged by employee PA Dealing.
The basic premise of Baillie Giffords PA Dealing Policy is that PA Dealing is permitted subject to a number of restrictions. Baillie Gifford therefore gives general permission to all members of staff and to their Connected Persons (defined later) to carry out investment transactions in designated investments in accordance with the following procedures. All staff must ensure that undertaking PA Dealing activities does not distract them from their day-to-day responsibilities.
4.2 | General Rule on PA dealing |
A member of staff or their Connected Persons are prohibited from
1. | Entering into a PA deal where |
a) | that person is prohibited from entering into it under the law and regulations governing market abuse and insider dealing as set out in the Baillie Gifford Market Abuse Policy. The Policy requires that no member of staff make personal use of material non-public information or engage in a securities transaction available only by reason of his or her position within Baillie Gifford. If a member of staff is aware that an investment opportunity is being actively considered by Baillie Gifford, they must first ensure that this is made available to Baillie Gifford before taking personal advantage of the opportunity. It is the personal responsibility of the member of staff to ensure that they are familiar with the provisions of that Policy. |
b) | it involves the misuse or improper disclosure of confidential or proprietary information relating to clients or transactions for clients; or |
c) | it conflicts or is likely to conflict with an obligation under Europes Markets in Financial Instruments Directive II (MiFID II) / the UKs MiFID Org Regulation, the UK version of Europes Markets in Financial Instruments Directive II (MiFID II) or other regulatory obligations which Baillie Gifford owes to its clients. |
2. | Advising, recommending or procuring any other person to enter into a transaction which would be precluded under 1 above. |
3. | Disclosing any information or opinion to any other person where it is reasonably likely that the result of that disclosure will lead to an activity precluded under 1 or 2 above. |
a) | Entering into a PA deal or purchasing a contract of insurance, the purpose of which is to hedge away the risk of any downward adjustment in deferred remuneration which that member of staff may be entitled to receive under the firms remuneration policy. |
A person will be considered to have undertaken such personal hedging if:
a) | The staff member enters into a contract with a third party; and |
b) | The contract requires the third party to make payments directly or indirectly to the staff member that are linked to or commensurate with the amounts by which the staff members variable remuneration has been reduced. |
Failure on the part of members of staff or their Connected Persons to follow these procedures will be regarded as a disciplinary matter under the rules and procedures set out in the Code. If it is determined that gross misconduct has taken place, the member of staff may be subject to instant dismissal without payment in lieu of notice (If you are in any doubt as to whether an intended transaction for yourself or for a Connected Person is subject to the rules of the Policy you should check with the Compliance Department beforehand).
The remainder of this policy details the following information:
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4.3 | Application of Personal Account Dealing Policy |
4.4 | Prohibited and Exempt Securities and Transactions |
4.5 | Practical Procedures for Obtaining Permission |
4.6 | Practical Procedures to be followed in Special Circumstances |
4.7 | Reporting Requirements |
4.8 | Summary table of Security Types and Pre-Clearance and Reporting Requirements |
4.3 | Application of Personal Account Dealing Policy |
The PA dealing rules apply to the following:
| All those listed in section 1.1 of this Policy |
And Connected Persons which include:
| Immediate family (immediate family includes spouses, co-habitees, children under the age of 18 and immediate family members sharing the same household. It would also include parents/in-laws or other persons where decision making as to their investments is taken by them under advice from the member of staff); |
| Organisations for whom members of staff have an active investment advisory input (this could include charities, churches, clubs etc); |
| Trusts where as trustee the member of staff exercises investment influence (i.e. as sole trustee or a trustee exercising a considerable influence. In this case the trust must be made aware of the connection with Baillie Gifford & Co and must be requested to report transactions in securities of companies under our management to the member of staff serving as a trustee. He should then report the transaction to the Group Compliance, Legal and Governance Services Director); and |
| Syndicates where friends/family group together for the purpose of purchasing shares |
Throughout this Policy, the above categories are referred to as Connected Persons.
The Policy applies to the following types of instruments (covered securities):
| equities |
| bonds; |
| ETFs |
| derivatives; |
| BG OEICS; |
| Investment Trusts and other close end vehicles; |
| private companies; and |
| spread betting on financial instruments. |
It also applies to any investment in any of the above instruments through a wrapper product such as an ISA, SIPP, share plan, Variable Insurance Product or the Baillie Gifford workplace pension available through Aegons ARC platform.
The table in section 4.8 sets out various security types and transactions and whether they are covered by the Personal Account Dealing Policy, Preclearance and Reporting Requirements.
If a member of staff is in any doubt as to whether an instrument is included or not in the Policy they should contact the Compliance Code of Ethics Team or email CodeofEthicsQueries@bailliegifford.com.
4.4 | Prohibited and Exempt Securities and Transactions |
4.4.1. Prohibited securities and transactions
No member of staff is permitted to purchase or sell, directly or indirectly, any security in which he or she acquires any direct or indirect personal holding and which, to his or her knowledge, is currently being purchased or sold by Baillie
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Gifford or which, to his or her knowledge, Baillie Gifford is actively considering recommending for purchase or sale. These prohibitions shall continue until the time that Baillie Gifford decides not to recommend such purchase or sale, or if this recommendation is made, until the time that Baillie Gifford completes, or decides not to enter into, the recommended purchase or sale. These prohibitions also apply to any purchase and sale by any member of staff of any convertible security, option, warrant or other derivative security, or any private placement of any issuer whose underlying securities are being actively considered for recommendation to, or are currently being purchased or sold by, Baillie Gifford. Any profits realised on trades made by members of staff within the proscribed period may require to be disgorged, particularly where the member of staff had, or was in a position to have had, knowledge of the fact that securities were being purchased or sold on behalf of Baillie Giffords clients.
4.4.2. Exempt securities and transactions
4.4.2.1 Securities exempt from pre-clearance requirements
The pre-clearance and reporting obligations shall not apply to the following exempt securities:
a) | purchases or sales of securities that are direct obligations of the government of the United States or United Kingdom, bankers acceptances, bank certificates of deposit, commercial paper, high-quality short-term debt instruments (including repurchase agreements); |
b) | shares of money market mutual funds; |
c) | shares of registered open-end management investment companies other than the Baillie Gifford sponsored OEICS and mutual funds; |
d) | shares of US unit investment trusts (i.e. variable insurance contracts that are funded by insurance company separate accounts organised as unit investment trusts) that are invested exclusively in one or more registered investment companies. Please note that UK Investment Trusts are not exempt securities and that pre-clearance requirements apply. |
e) | FX or cryptocurrency transactions |
The pre-clearance requirements shall not apply to the following transactions (although revised holdings will need to be disclosed in your Annual Code of Ethics Declaration):-
4.4.2.2 Transactions exempt from pre-clearance requirements
a) | purchases effected upon the exercise of rights (e.g. automatic reinvestment of dividends) provided by an issuer pro rata to all holders of a class of its securities to the extent such rights were acquired from such issuer, and sales of such rights so acquired; |
b) | personal transactions effected under a discretionary portfolio management service where there is no prior communication in connection with the transaction between the portfolio manager and the relevant member of staff or other person for whose account the transaction is executed; |
c) | personal transactions in any default fund available in Baillie Giffords workplace pension available through Aegons ARC platform; |
d) | ongoing monthly transactions in an automatic investment plan, where permission was obtained for the initial investment and there has been no change to the standing instruction thereafter; |
e) | sales automatically placed by the broker to cover ongoing management fees. |
4.4.3. Prohibition on short-term profits
No member of staff may engage in the purchase and sale, or sale and purchase, of the same (or equivalent) securities within 60 calendar days. All profits realised on such short-term trades will normally require to be disgorged. Subject to pre-clearance a securities transaction which occurs within the 60-day period as a result of a change in personal circumstances which takes place or becomes known during the period may not be considered a violation of this section or subject to the disgorgement rule upon review and approval of the Group Compliance, Legal and Governance Services Director.
4.4.4. Investor PA trades (Blackout Period)
Investment Personnel are not permitted to PA trade in the seven calendar day period after a fund/strategy that they are involved in has traded in the same security.
In addition, Investment Personnel are not permitted to PA trade in the seven calendar day period before a fund/strategy that they are involved in trades in the same security, where they were aware, at the point of requesting
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permission to trade and at the point of placing their PA dealing instruction, that a client order in that security was pending.
All profits realised on trades by Portfolio Managers within the proscribed period will normally require to be disgorged.
4.4.5. Baillie Gifford Investment Trust share buy-backs
If a member of staff has specific knowledge about a Baillie Gifford Investment Trust share buy-back, i.e. specific knowledge around the price, timing and volume of the transaction, they should refrain from any PA dealing in that Investment Trust until such times as the share buy-back is complete. A general awareness of share buy-backs or share buy-back programmes would not preclude a member of staff from PA dealing in that Investment Trust.
4.5 | Procedures for Obtaining Permission |
Prior to undertaking a PA Deal, members of staff are required to:
| obtain permission to use their desired broker (it is only necessary to follow this procedure on the first occasion of using a particular stockbroker); and |
| to obtain internal pre-clearance from the Code of Ethics System (every time a PA deal is undertaken). |
It is important that members of staff take all reasonable steps to ensure that these procedures are followed by whoever is dealing. The onus is on the member of staff to obtain permission and ensure that contract notes are sent to the Head of Group Compliance Staff Regulatory Responsibilities where the dealing is for a Connected Person.
4.5.1. Procedures for obtaining broker permission
Before a member of staff or a Connected Person begins to effect a transaction with a particular firm of stockbrokers permission must be obtained to use that broker. It should be noted that this also applies to on-line dealing. The reason for this permission is to inform the Broker that the member of staff works for Baillie Gifford and to ensure that brokers supply to the Head of Group Compliance Staff Regulatory Responsibilities, no later than 30 days after the end of the quarter in which the trading activity occurred, duplicate copies of confirmations of all personal securities transactions. Such confirmations may also contain a statement declaring that the reporting or recording of any such transaction shall not be construed as an admission that the member of staff making the report has any direct or indirect beneficial ownership in the security.
Each confirmation received from the broker shall be treated confidentially and will be maintained on file by the Compliance Department. The reports are, however, available for inspection by authorised members of the staff of regulatory authorities supervising Baillie Giffords investment business.
Note: No broker confirmation letters are required for transactions undertaken in an automatic investment plan, including the Baillie Gifford workplace pension available through Aegons ARC platform. Furthermore, no NonExecutive Director of a Baillie Gifford company shall be required to report or provide broker confirmation unless the Director knew or should have known that during the 15 calendar days before and after such Directors transaction in any security, Baillie Gifford purchased or sold the same security, or Baillie Gifford considered purchasing or selling the same security.
In addition, broker confirmation letters may not be required if your broker operates a transaction data feed to Baillie Giffords Code of Ethics System (although your broker may require a separate declaration for this). Should, for whatever reason, a broker be unable to provide duplicate copies of personal transactions directly to Baillie Gifford, the staff member must promptly provide copies of their trade confirmations directly to the Code of Ethics team. This should be provided in email format to the secure team mailbox.
Please contact CodeofEthicsQueries@bailliegifford.com for further details.
Every member of staff must (for their own dealing and that of a Connected Person):
| Notify the firm of stockbrokers that they work at Baillie Gifford & Co; |
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| Not accept or request any credit or special dealing facilities in connection with his dealings (The only exception to this rule is that the Management Committee may give special dispensation for members of staff to agree on rates. Where this permission is given the details must be supplied to the Group Compliance, Legal and Governance Services Director); |
| Notify the Head of Group Compliance Staff Regulatory Responsibilities that they or their Connected Person proposes to deal with the particular firm of stockbrokers and obtain his permission to do so; |
| Prepare the relevant Broker Authorisation letter (either member of staff letter or Connected Person). Take two copies of the letter, both copies must be signed by the Head of Group Compliance Staff Regulatory Responsibilities with one being sent to the stockbroker and the other copy sent to the Head of Group Compliance Staff Regulatory Responsibilities ; and |
| Ensure that a copy of the contract note is sent by the stockbroker to the Group Compliance, Legal and Governance Services Director or an electronic confirmation if provided through an on-line dealing service. |
The quick guide document sets out the procedures for obtaining broker consent via a data feed through the Code of Ethics System.
Click on the appropriate link below to obtain a copy of the Baillie Gifford Broker Notification Letter, required for brokers without a data feed:
Letter 1 (Broker authorisation for member of staff)
Letter 2 (Broker authorisation for Connected Persons)
4.5.2. Procedures for obtaining internal permission
In addition to broker permission being obtained, members of staff are also required to obtain electronic internal pre-clearance from the Code of Ethics System. Pre-clearance of a PA deal will remain valid until close of business on the next business day from the time permission is obtained. If the proposed transaction is not completed during the period in which the pre-clearance is granted, the member of staff must seek additional pre-clearance prior to completing the transaction. In the case of postal deals (e.g. deals that require an application form or instruction form to be completed, i.e. dealing is not direct through a broker); your dealing instruction should be sent within this pre-clearance period, although the trade itself does not have to be executed.
The quick guide video sets out the procedures for submitting Trade Requests through the Code of Ethics System.
PA Dealing information will be reviewed and monitored by the Compliance Department. Should the monitoring conducted by the Compliance Department detect a potential violation of this Code or any apparent trading irregularity, that Department shall take whatever steps deemed appropriate under the circumstances to investigate said potential violation or trading irregularity. If the Compliance Department reasonably believes a violation or trading irregularity to exist, said violation or trading irregularity shall be reported to the Group Compliance, Legal and Governance Services Director.
4.6 | Practical procedures to be followed in special circumstances |
Remote Access to the Code of Ethics System: Remote access is available on all Baillie Gifford devices. If a member of staff is away from the office (e.g. on business or on holiday), trade requests can be submitted through all BG devices.
Maternity/Parental Leave: If you are out of the office on maternity leave, or a period of flexible parental leave exceeding four weeks, there is no requirement for you to obtain PA dealing permission for any trades conducted by you (or a Connected Person) during this leave. If applicable, shareholdings in the Code of Ethics System can be amended upon your return to the office.
Limit Orders: The use of buy or sell limit orders is not prohibited under this policy, however, these must be carefully managed by members of staff as pre-clearance is only valid until close of business on the next business day from the
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time permission is obtained. If, upon expiry of the permission period, the limit price has not been met, the member of staff must obtain fresh permission via the Code of Ethics System or ensure the limit instruction is cancelled.
Stop Loss Orders: As for limit orders, stop loss orders (i.e. instruction to automatically sell securities if the share price reaches a pre-determined minimum price) are not prohibited under this policy, however, these must be carefully managed by members of staff as pre-clearance is only valid until close of business on the next business day from the time permission is obtained. If you wish to maintain a stop loss instruction beyond the permission period, fresh permission must be obtained via the Code of Ethics System.
4.7 | Reporting Requirements |
4.7.1. Initial reporting requirements
All new members of staff are required to disclose all personal securities holdings in which they have any direct or indirect holdings to the Compliance Department, within 10 days of commencing employment. The information provided must be current and no more than 45 days prior to the date the person joined the firm. Initial Code of Ethics Declarations must be submitted to Compliance via the Code of Ethics System.
4.7.2. Annual reporting requirements
Each member of staff is also required to file an annual report disclosing all personal securities holdings by 1 February of each year. The information must be current as of a date no more than 45 days prior to the date the report was submitted. Annual Code of Ethics Declarations must be submitted electronically via the Code of Ethics System. The quick guide video sets out the procedures for submitting an Annual Declaration via the Code of Ethics System.
Note: Declarations must include shares owned through an automatic investment plan. Each declaration may also contain a statement declaring that the reporting or recording of any such transaction shall not be construed as an admission that the member of staff making the report has any direct or indirect beneficial ownership in the security. NonExecutive Directors of Baillie Gifford companies are not required to provide initial or annual Code of Ethics Declarations.
4.7.3. Specific Requirements for BGA(HK)
Semi-Annual Holdings Disclosure This requirement applies to all BGA(HK) employees, licenced persons, Managers-in-Charge, Directors, other than non-executive directors and it is in addition to the annual declaration. Each member of staff is required to file a report disclosing all personal securities holdings semi-annually in January and July each year. The information must be current and no more than 45 days prior to the date the report is submitted. Holdings reports must include shares owned through an automatic investment plan. This semi-annual exercise is coordinated and managed by the Compliance Department.
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4.8 | Summary table of Security Types and Pre-Clearance and Reporting Requirements |
This list is not all inclusive and may be updated from time to time. Please contact the Compliance Code of Ethics team for guidance as needed or email CodeofEthicsQueries@bailliegifford.com.
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5. | Inducements Policy |
An area where a conflict of interest may arise is in the context of the giving or receipt of a gift or hospitality which may be viewed as a form of inducement.
Baillie Gifford must take reasonable steps to ensure that it and any person acting on its behalf does not pay or accept any fee or commission or provide or receive any non-monetary benefit if it is likely to conflict to a material extent with any duty that Baillie Gifford owes to its customers or any duty which the recipient firm owes to its customers.
This Inducements Policy sets out the principles and procedures which all members of staff within Baillie Gifford must adhere to with regard to the giving or receipt of a gift or hospitality or anything else which may be viewed as an inducement, such as donations or political contributions.
The overriding principle is that all members of staff should not accept gifts, favours, entertainment, hospitality or other inducements of material value that could be seen as likely to influence their decision-making or make them feel beholden to a person or other firm.
Similarly, Baillie Gifford and its members of staff should not offer gifts, favours, entertainment, hospitality or other inducements of value that could be viewed as overly generous or aimed at influencing decision-making or making the recipient feel beholden to Baillie Gifford or that member of staff.
Note: These general principles apply in addition to the more specific guidelines set out below. However, the guidelines do not attempt to cover every situation and must be interpreted in the light of the particular circumstances of each case. If you are in any doubt about any particular situation, you should consult with your Head of Department or the Compliance Department.
The remainder of this policy details the following information:
5.1 Guidelines for Gifts & Entertainment, Donations and Political Contributions.
5.2 Restrictions in Connection with the Sale of Packaged Products, i.e. OEICs.
5.3 Packaged Products Guidance on Reasonable Indirect Benefits
5.4 FINRA Specific Requirements for Registered Persons of BGFS
5.5 Specific Requirements for giving or receipt of gifts, hospitality, and entertainments to Korean Public Officials
5.1 | Guidelines |
5.1.1. Application to all staff
The general principles and guidelines apply to all staff within Baillie Gifford irrespective of whether they are in direct contact with clients or potential clients or not.
5.1.2. Application to all third parties
Whilst the FCA and CBI requirements relate to managing or minimising conflicts which affect the services provided to our clients and to firms who in turn are advising clients, our principles also apply to other third parties who supply goods or services, whether these are supplied to clients or on the clients behalf or are supplied to Baillie Gifford itself. This ensures that the standards set are consistently applied by all staff and for all relationships.
5.1.3. No Solicitation
Baillie Gifford expressly prohibits staff from soliciting for themselves or for members of their family or for the firm itself, gifts, hospitality, entertainment or anything of value from a client, potential client, supplier or any other entity with which Baillie Gifford does business (other than fees and expenses properly due and payable).
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5.1.4. No Cash Gifts
No member of staff may give or accept any financial instruments, including cash gifts to or from a client, potential client, or any entity that does business with or on behalf of Baillie Gifford. This applies equally to the giving or receiving of promotional competition prizes.
5.1.5. Donations
As a general rule, no cash donations should be made in connection with our clients or prospective clients. Donations of non-cash prizes are acceptable, providing they meet the criteria in the Inducements policy. Cash donations are more likely to be viewed as giving rise to a conflict and our general policy is that these should be avoided. Any cash donations which are proposed, as an exception to the general rule, should be pre-cleared with the Group Compliance, Legal and Governance Services Director. For example, it may be permissible to make a cash donation to a charity on the death of a long standing contact as a client, although the amount of the donation should be carefully considered.
Please note that this does not affect charitable donations, approved via our Sponsorship Committee, which are not connected with our clients or prospects.
5.1.6. Political Contributions Policy
Political contributions by financial services firms and their personnel have come under increased regulatory scrutiny in the US. Regulators have expressed concern that some in the financial services industry are inappropriately influencing the awarding of business for state and local government entities by making political contributions to officials holding or running for office. These pay-to-play activities are now restricted by numerous federal, state, and local laws. The Securities and Exchange Commission (SEC) has enacted a pay-to-play rule for investment advisors. This rule restricts the political contributions and political fundraising activities that may be engaged in by investment advisors and their personnel. The consequences for violations of the SEC rule and other state and local laws are significant. In the event of a violation, Baillie Gifford could be prohibited or restricted from doing business with certain government entities.
Given the scale of our activities in the US, the following procedures apply to all staff within Baillie Gifford, irrespective of whether they are in direct contact with clients or potential clients or not, and to their connected persons (see section 4.3 of the Code of Ethics for a definition of connected persons). There will also be additional reporting obligations for US based staff. The requirements are as follows:
1. | All members of staff are required to obtain preclearance from the Compliance Department before either they or a connected person: |
| make any political contributions, either directly or indirectly, to US federal, state or local officials; or |
| participate in any political fund-raising activity in the US. |
Preclearance requests should be submitted by email to Baillie Giffords US based Compliance Counsel and the Code of Ethics Team.
2. | All members of staff must confirm on an annual basis, that they have disclosed to the Compliance Department any political contributions made to US federal, state or local officials and any political fund-raising activity in the US. This disclosure will form part of the Annual Code of Ethics Declaration that staff submit via the Code of Ethics System. |
3. | In addition to requirement (2) above, US based staff must confirm on a quarterly basis that they have disclosed to the Compliance Department any political contributions made to US federal, state or local officials and any political fund-raising activity in the US. The disclosure should be submitted via the Code of Ethics System upon request from the Compliance Department. |
4. | Upon joining the firm, all new members of staff must disclose to the Compliance Department any political contributions made to US federal, state or local officials and any political fund-raising activity in the US within the previous two years. This disclosure will form part of the existing Personal Compliance Responsibilities Certificate that all new staff are required to submit upon joining the firm. |
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Whilst strictly speaking the above requirements apply to US political contributions only, members of staff should also give due consideration to all other political contributions (UK or otherwise) from a general conflict of interest and transparency perspective. Staff should disclose to the Compliance Department, any political contributions that may give rise to an actual conflict of interest, a potential conflict of interest or the perception of one.
5.1.7. De Minimis Gifts
Gifts given or received which are of a de minimis nature due to their characteristics or likely cost are unlikely to give grounds for suggestions of undue influence and are therefore exempt. Typical examples of de minimis gifts would include umbrellas, diaries and pens with advertising logos for the donor company.
The Compliance Department should be consulted in any questionable situation.
5.1.8. Gifts which are not De Minimis
All gifts given or received which are not de minimis must be recorded in the Code of Ethics System. It is generally acceptable for members of staff to retain gifts received that are below £50 in value (or equivalent in another currency), provided this is not with undue frequency. In the case of gifts received above £50 in value (or equivalent in another currency), the member of staff concerned should consult with their Head of Department as to the appropriate course of action. In the majority of cases gifts above £50 (or equivalent in another currency) which are received should be:
| surrendered to the Events Team for use for charitable purposes or distribution as part of the firms annual Christmas raffle; |
| returned to the third party concerned; or |
| distributed amongst the Department in the case of perishable gifts, e.g. hampers. |
Where the member of staff wishes to retain a gift above £50 (or equivalent in another currency), then he or she should pay for the estimated cost of the gift above this limit and this amount should be given to the Finance Department for use for charitable purposes.
Similarly, gifts above £50 in value (or equivalent in another currency) should generally not be given by a member of staff.
5.1.9. Promotional Competition/Prizes
In offering any promotional competition or prizes, the member of staff responsible should:
| consider the likely impact or influence the prize would have on the recipient; and |
| consult with a Partner or the relevant Board on the likely impact of the competition on the brand of Baillie Gifford. |
In all cases the prize offered should be of reasonable value, i.e. it should not be excessive or inappropriate.
Any competition prizes won by a member of staff at a business-related event, e.g. a conference or seminar, should be recorded for transparency in the Code of Ethics System.
5.1.10. Business Lunches/ Dinners
The establishment and maintenance of strong relationships with our clients, suppliers, intermediaries and consultants is integral to our ability to provide effective investment management services. Routine business lunches or dinners are good mechanisms for building and maintaining relationships and are unlikely to give grounds for suggestion of undue influence unless they become overly frequent or are unduly lavish.
Routine business lunches and dinners given do not require to be reported. These should be recorded in Baillie Giffords expenses system. The Business Expense Claims procedure will provide an adequate control over the magnitude of costs incurred by Baillie Gifford when giving such lunches and dinners.
Many of Baillie Giffords clients (particularly those covered by ERISA) are subject to specific reporting requirements regarding their acceptance of business lunches and dinners. In order for Baillie Gifford to ensure that it is able to
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provide clients with their required information, the following additional information should be recorded on the Business Expense Claim Form, with respect to any clients for whom we have hosted a business lunch or dinner:
| The name of the client being entertained; |
| The names of the individuals being entertained; |
| The total cost of the lunch or dinner. |
Generally, routine business lunches and dinners received do not need to be reported. The exception to this is business lunches and dinners received from UK or European financial institution or intermediary that provides advice or portfolio management services to retail clients (UK/EU MiFID firms). Such lunches and dinners do need to be recorded in the Code of Ethics System.
5.1.11. Entertainment/Hospitality Given
All members of staff must exercise discretion in offering hospitality. Members of staff should not provide extravagant or excessive entertainment to a client, prospective client, or any person or entity that does or seeks to do business with or on behalf of Baillie Gifford or our clients. Similarly, a member of staff should not provide entertainment to such parties with undue frequency.
With the exception of occasions where the client is a UK/EU MiFID firm (see below), members of staff may provide entertainment or hospitality, such as a dinner (unconnected with business), sporting, charitable or cultural event of reasonable value provided that the person or Baillie Gifford is present at the event. If the person or Baillie Gifford is not present, then the entertainment becomes a gift and the procedures in section 5.1.8 apply, i.e. gifts above £50 (or equivalent in another currency) should generally not be given by a member of staff.
In considering the hospitality or entertainment event, you should note that attending expensive or exclusive sporting or cultural events can draw criticism. Invitations should not be offered if they could be construed as being unusual or risk creating a sense of obligation to the host or bias in their favour.
In situations of any doubt, consult with your Head of Department.
All entertainment or hospitality must be recorded in the Code of Ethics System.
In many cases the value of an event will not be clear. Here, you should give your best estimate of the value at the time the decision is taken, considering the street value of the event in the eyes of a third party.
An acceptable minor non-monetary benefit is one which is capable of enhancing the quality of service provided to the client and consists of hospitality of a reasonable de minimis value such as food and drink during a business meeting, conference, seminar or training event. Baillie Gifford have set a de minimis limit of £100 (or equivalent in another currency) per head to allow a reasonable level of hospitality at business events. Standalone hospitality that is not directly linked to a business event, e.g. sporting events, is no longer permitted. These restrictions apply to hospitality provided to UK/EU MiFID firms only and not to hospitality provided to UK or Overseas segregated clients or suppliers).
5.1.12. Entertainment/Hospitality Received
All members of staff must exercise discretion in accepting hospitality. Members of staff should not accept extravagant or excessive entertainment from a client, prospective client, a business in which Baillie Gifford invests, or any person
or entity that does or seeks to do business with or on behalf of Baillie Gifford or our clients. Similarly, a member of staff should not accept entertainment from such parties with undue frequency.
Members of staff may accept entertainment or hospitality, such as a dinner (unconnected with business), sporting, charitable or cultural event of reasonable value provided that the person or firm providing the entertainment is present at the event. If the person or firm is not present, then the entertainment becomes a gift and the procedures in section 5.1.8 apply, i.e. gifts above £50 (or equivalent in another currency) should generally not be accepted by a member of staff.
It is the policy of the firm not to accept standalone hospitality from broker firms. For this purpose, standalone hospitality would include invitations to and attendance at sporting or cultural events and any associated travel,
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accommodation, drinks and meals. This policy would not affect routine business lunches or dinners, or reasonable hospitality attached to conferences or other educational events or social events which are distributed widely and of a de minimis nature (i.e. under £100 (or equivalent in another currency) per head). This covers by way of example a broker drinks evening at which the broader asset management community is invited.
In considering the hospitality or entertainment event, you should note that attending expensive or exclusive sporting or cultural events can draw criticism. Invitations should not be accepted if they could be construed as being unusual or risk creating a sense of obligation to the host or bias in their favour.
In situations of any doubt, consult with your Head of Department.
All entertainment or hospitality must be recorded in the Code of Ethics System.
In many cases the value of an event will not be clear. Here, you should give your best estimate of the value at the time the decision is taken, considering the street value of the event in the eyes of a third party.
Do not hesitate to ask the host for further information about the event (e.g. cost) in order to reach a decision.
5.1.13. Travel/Accommodation Costs
In the case of a member of staff receiving hospitality or entertainment, travel and accommodation costs should be paid for by that member of staff or a request made to the organiser of the event that the individual member of staff be invoiced for these costs. Where the third party has arranged a discounted hotel rate or other reduction in the cost of the accommodation or travel, it is reasonable for the member of staff to accept this reduced rate. Likewise, where the host provides communal transport which is not excessive or unduly lavish, for example the use of a mini bus.
In the case of Baillie Gifford offering hospitality, travel expenses will ordinarily be paid for by the recipient of the entertainment or hospitality. However, there may be occasions where reasonable accommodation costs can be provided by Baillie Gifford subject to this meeting the general principles of this Policy.
5.1.14. Disclosure
A key aspect of Baillie Giffords Inducements Policy is disclosure. Under our procedures, all gifts (other than de minimis) and hospitality which are given or received are recorded in the Code of Ethics System. Disclosures should be made to your normal gifts and entertainment representatives for Trading, Investors and Clients Department, and Compliance for all other departments.
Likewise, all members of staff should consider if an inducement which has been offered or received should be disclosed to a client, or potential client. This will depend upon the circumstances of each case. As an example, where a fee is paid to a third-party consultant in order to place details of Baillie Gifford on a consultant database, we should disclose this payment to any potential client of the consultant who considers us for an investment mandate.
5.1.15. Client Specific Code of Ethics Requirements
A small number of Baillie Giffords clients have specific code of ethics requirements which go beyond Baillie Giffords Inducements Policy. Members of staff, and Client Contacts in particular, should consider these additional requirements when giving gifts and/or entertainment to these clients.
For record keeping purposes, Compliance maintain a list of clients with specific Code of Ethics requirements.
5.2 | Restrictions in Connection with the Sale of Package Products, i.e. OEICs |
If a firm is required to disclose commission (or commission equivalent) (under COBS 6.4) to a client in relation to the sale of a packaged product, a member of staff should not enter into any of the following arrangements:
| volume overrides where commission (or commission equivalent) paid in respect of several transactions is more than a simple multiple of the commission (or commission equivalent) payable in respect of one transaction of the same kind; and |
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CODE OF ETHICS | 2023 |
| an agreement to indemnify the payment of commission (or commission equivalent) on terms that would or might confer an additional financial benefit on the recipient in the event of the commission (or commission equivalent) becoming repayable. |
5.3 | Packaged Products Guidance on Reasonable Indirect Benefits |
The general principles at the beginning of this section are particularly important in relation to packaged products. Staff must not pay or accept any fee or commission or provide or receive any non-monetary benefit if it is likely to conflict to a material extent with any duty the firm owes to its customers or any duty which the recipient firm (which includes independent intermediaries) owes to its customers.
In relation to the sale of packaged products, we are only able to provide minor non-monetary benefits if they are designed to enhance the quality of service to the client. The list below indicates the kind of benefits that are capable of enhancing the quality of the service provided to a client and, depending on the circumstances, are capable of being given or received without conflicting with clients best interests. However, these need to be considered on a case by case basis.
Benefits are unlikely to give rise to conflicts if they are:
| reasonable and proportionate, |
| of a limited scale and nature, |
| do not need to be relied upon by the intermediary, |
| could reasonably not be expected to result in the channelling of business from the intermediary to Baillie Gifford, and |
| do not result in the intermediary recovering more than its reasonable costs. |
The list below summarises the kind of reasonable non-monetary benefits which the provider firm can give or receive. This list is summary only and any member of staff should contact the Compliance Department for further guidance before deciding whether to give or accept the benefit (* = only if available to independent intermediaries generally):
1. | Gifts, hospitality and promotional competition prizes of a reasonable value. Gifts and corporate hospitality given to intermediaries must not exceed an aggregate limit of £1,000 (or equivalent in another currency) per intermediary firm, per calendar year. This limit applies to gifts and corporate hospitality only and excludes conferences, seminars and training events. For large intermediary firms, the £1,000 (or equivalent in another currency) limit can be applied at regional office level. In addition, events must be designed for business purposes that result in advisers being able to provide a better service to their customers. |
2. | A product provider can assist another firm to promote its packaged products so that the quality of its service to clients is enhanced. |
Points (3) to (6) in relation to joint marketing exercises:
3. | Generic product literature (letter heading, leaflets, forms and envelopes) as long as the literature enhances the quality of the service to the client and is not primarily of promotional benefit to the product provider, and the distribution cost is borne by the intermediary. |
4. | Freepost envelopes* |
5. | Product specific literature (for example, key features, minimum information) subject to specific conditions. |
6. | Draft articles, news items and financial promotions for publication in the intermediarys magazine as long as any cost borne by the provider firm is not more than market rate and excludes any distribution costs. |
7. | Take part or pay towards the cost of seminars and conferences organised by another firm as long as it is: |
| For a genuine business purpose |
| Reasonable and proportionate. |
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CODE OF ETHICS | 2023 |
Any costs paid should be associated with the level of Baillie Giffords participation and by reference to the time that Baillie Gifford staff have played an active role. Baillie Gifford should not be paying all an advisory firms costs incurred in running a seminar or conference.
8. | Freephone link * |
9. | Technical services |
| Quotations and projections relating to its packaged products and advice on completion of forms or other documents |
| Access to data processing facilities or to data related to the firms business |
| Access to 3rd party electronic dealing or quotation systems |
| Software giving information about the firms packaged products. Any payments to an intermediary that go beyond that which is required to operate software supplied by Baillie Gifford would not be permitted. Likewise, any payments to develop an intermediarys general IT systems would not be permitted. |
10. | Generic technical information in writing, not necessarily related to the firms business* or if it is of a specialist nature is made available to a particular class of intermediary. |
11. | Training facilities (lectures, venues, written material, software) * |
If Baillie Gifford is giving an advisory firm training on the features and benefits of its products or services, the training should be made reasonably available to all advisory firms that could recommend Baillie Giffords products, even if only on a first-come, first-served basis.
Please note, that whilst this section applies to packaged products, the arrangements in (12) above can also be applied to our institutional business, although consideration must be given to overseas clients with specific code of ethics requirements on inducements.
5.4 | FINRA Specific Requirements for Registered Persons of BGFS |
Registered persons of BGFS are not permitted to give or receive any gifts of value in excess of $100 per individual per year to another FINRA members registers persons.
Small gifts of less than $100 per year per recipient are aggregated toward the annual gift limit. For further information on BGFSs Gifts and Entertainment policy, please see the BGFS Written Supervisory Procedures.
5.5 | Specific Requirements for giving or receipt of gifts, hospitality, and entertainment to Korean Public Officials |
South Koreas Anti-Graft Law introduced a general prohibition on giving anything of value and/or benefits to Korean public officials. The Law provides specific threshold limits and several exceptions, including for giving of meals and gifts, and entertainment expenses.
Any activity conducted locally by BGO and its employees or representatives in or into South Korea must be strictly within the prescribed limits and conditions outlined in Appendix I of this Policy. Activity conducted fully outwith South Korea should be compliance with the Group Policy standards on Inducements set out above, with due consideration to the fact that certain clients and prospects will similarly be bound by the provisions of the Law.
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6. | Acknowledgement and Certification |
6.1 | Receipt and Acknowledgement of the Code |
All members of staff are required to receive a copy of the Code of Ethics and any amendments to the Code of Ethics. All members of staff are required to complete an annual certification, confirming that they have read the Code of Ethics and acknowledging that they are subject to its requirements. Further, all members of staff confirm through the annual certification that they have complied with the Code and that they have disclosed or reported all information required to be disclosed or reported according to the requirements of the Code.
All certifications of receipt of the Code shall be filed with the Compliance Department by submitting a Certificate of Compliance.
6.2 | Annual Report to Baillie Gifford Boards |
The Group Compliance, Legal and Governance Services Director will prepare and submit to the appropriate Baillie Gifford Boards an annual report which:
| certifies that the firm or investment company as appropriate has adopted procedures designed to prevent Access Persons from violating the Code; |
| identifies any violations of the current procedures for personal securities investing and managements recommended response; and |
| makes any recommended changes in the procedures, as appropriate, based on operating experience under the Code, evolving industry practices or amendments to applicable laws or regulations. |
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Appendix I Specific Requirements for giving or receipt of gifts, hospitality, and entertainments to Korean Public Officials
The Anti-Graft Law prohibits (i) making of an improper request and (ii) giving of cash or anything else of value (such as hospitality, entertainment, etc.) to public officials.
Public officials are defined as government officers, employees of quasi-governmental enterprises, persons serving a public capacity, and employees of media and educational institutions (both public and private), employees of various energy and utility companies, private individuals engaged in public work such an on a committee or doing inspection, employees of universities, newspapers, broadcasters and online new agencies. Public officials have certain duties to reject, and report improper requests and gifts.
Violations of the Anti-Graft Law by company employees are subject to criminal penalties and/or administrative fines. The company itself will be additionally liable for its employees actions, unless it can show it exercised a considerable care and supervision in terms of training, monitoring and control to prevent the violation of the Anti-Graft Law.
I. | Prohibition of Making of an improper request |
Improper requests include requests that Public officials to take an action in violation of law regardless of whether or not accompanied by giving cash or other benefit. Examples such as:
| request an Public Officials go beyond his/her authority or deviate from established laws, or due requirements, procedures, or standards, |
| request an Public Officials to grant an approval on or permit or an exemption, |
| request an Public Officials to sway a public investigation or assessment, or |
| request an Public Officials to sway an allocation of subsidies. |
II. | Prohibition of Giving of cash or anything of value |
Giving, in virtually any form, to officials is restricted and subject to extremely narrow exceptions. Details are set out below:
Guidance |
Exemption | |||
Giving of gift or economic benefit (such as cash, entertainment etc.) to a Public officer- whether or not having any connection to his/ her duty | The amounts must not exceed in value of KRW 1 million in any one instance, or totalling over KRW 3 million annually.
One instance may include a series of meals and gifts during a weekend event.
Gifts, by employees of a company, funded by that company, are aggregated for this purpose. |
Exemption may be granted if both conditions are satisfied:
I. the amounts are within the relevant limits:
i. for small physical gifts up to KRW 50,000 [KRW 100,000 (KRW 200,000 from 24 days before Lunar New Years Day and Chuseok to 5 days after Lunar New Years Day and Chuseok) if the gift comprises agricultural or fisheries products],
ii. Up to KRW 200,000 for small gifts comprising of agricultural or fisheries products given during on or after 24 days prior to Korean New Year or Korean Thanks Giving Day but no later than 5 days from the Korean New Year or Korean Thanks Giving Day,
iii. for wedding or funeral cash contributions up to KRW 50,000, or floral arrangements worth up to KRW 100,000. If cash contributions and floral arrangements are provided together, the total amount shall not exceed KRW 100,000.
II. the purpose of the giving is to facilitate the relationship or as a matter of social courtesy | ||
Giving of gift or economic benefit (such as cash, entertainment etc.) to Public officials- connected to his/her duty | Prohibited. |
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Guidance Exemption Exemption may be granted if both conditions are satisfied: I. the meal is less than KRW 30,000, and II. the purpose of the giving is to
facilitate the relationship or as a matter of social courtesy. Permissible provided that, i. the event is relevant to the Public officials duties, meals, etc. are provided uniformly
to all participants of the event ; and, ii. the amounts must be conventional for such events, and evenly given.
CODE OF ETHICS
2023
Giving of Meals
Prohibited.
Giving of meals, transport, or other expense for an official event which may be sponsored by the BG.
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CODE OF ETHICS | 2023 |
Baillie Gifford & Co Head Office
Calton Square, 1 Greenside Row, Edinburgh EH1 3AN
Telephone +44 (0)131 275 2000 www.bailliegifford.com
33
CODE OF ETHICS
CAUSEWAY CAPITAL MANAGEMENT TRUST
and
CAUSEWAY CAPITAL MANAGEMENT LLC
I. INTRODUCTION
A. Standards of Conduct. This Code of Ethics has been adopted by the Trust and the Adviser in compliance with Rule 17j-1 under the 1940 Act and Rule 204A-1 under the Advisers Act. Capitalized terms used in this Code are defined in Appendix 1 to this Code. All Appendixes referred to herein are attached to and are a part of this Code.
This Code is based on the principles that the trustees, managers, officers, and employees of the Trust and the Adviser have a fiduciary duty to the Trust and that the board of managers, officers, and employees of the Adviser or its parent holding company also have a fiduciary duty to the Advisers other clients. Fiduciaries owe their clients duties of loyalty, honesty, good faith and fair dealing. As fiduciaries, Covered Persons must at all times:
1. Place the interests of the Funds and Private Accounts first. Covered Persons must scrupulously avoid serving their own personal interests ahead of the interests of the Funds and Private Accounts. Covered Persons may not induce or cause a Fund or Private Account to take action, or not to take action, for personal benefit, rather than for the benefit of the Fund or Private Account. For example, a Covered Person would violate this Code by causing a Fund or Private Account to purchase a Security he or she owned for the purpose of increasing the price of that Security or by Market Timing Funds or Private Accounts.
2. Avoid taking inappropriate advantage of their positions. Covered Persons may not, for example, use their knowledge of portfolio transactions to profit by the market effect of such transactions. Receipt of investment opportunities, perquisites, or gifts from persons seeking business with the Trust or the Adviser could call into question the exercise of a Covered Persons independent judgment.
3. Conduct all personal Securities Transactions in full compliance with this Code including the reporting requirements. All personal Securities Transactions must be conducted consistent with this Code and in such a manner as to avoid actual or potential conflict of interest or any abuse of an individuals position of trust and responsibility. Doubtful situations should be brought to the attention of the Compliance Officer (or a designee) and resolved in favor of the Funds and Private Accounts.
4. Comply with all applicable federal securities laws. Covered Persons must comply with all applicable federal securities laws. It is prohibited for a Covered Person, in connection with the purchase or sale, directly or indirectly, by the person of a Security held or to be acquired by a Fund or Private Account:
(i) | To employ any device, scheme or artifice to defraud a Fund or Private Account; |
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(ii) | To make any untrue statement of a material fact to a Fund or Private Account or omit to state a material fact necessary in order to make the statements made to a Fund or Private Account, in light of the circumstances under which they are made, not misleading; |
(iii) | To engage in any act, practice or course of business that operates or would operate as a fraud or deceit on a Fund or Private Account; or |
(iv) | To engage in any manipulative practice with respect to a Fund or Private Account. |
This Code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its specific provisions will not act as a shield from liability for personal trading or other conduct that violates a fiduciary duty to Fund shareholders or Private Account clients. Access Persons and Investment Personnel should bring to the attention of the Compliance Officer (or a designee) any known circumstances or situations that may create an actual, potential or perceived conflict of interest.
Violations of the Code must be reported promptly to the Compliance Officer. Failure to comply with the Code may result in sanctions, including termination of employment.
B. Appendixes to the Code. The Appendixes to this Code are attached to and are a part of the Code. The Appendixes include the following:
1. | Definitions (Appendix 1), |
2. | Contact Persons (Appendix 2), |
3. | Certification of Compliance with Code of Ethics (Appendix 3 and 3-I), |
a) | Personal Securities Holdings and Accounts Disclosure Form (Appendix 3-A) |
4. | Form Letter to Broker, Dealer or Bank (Appendix 4). |
5. | Report of Securities Transactions (Appendix 5) |
6. | Initial Public Offering / Private Placement Clearance Form (Appendix 6) |
C. Application of the Code to Independent Fund Trustees. The following provisions do not apply to Independent Fund Trustees and their Immediate Families.
1. | Personal Securities Transactions (Section II) |
2. | Initial, Quarterly and Annual Holdings Reporting Requirements (Section III.A) |
II. PERSONAL SECURITIES TRANSACTIONS
A. Prohibited Transactions.
1. Prohibited Securities Transactions. The following Securities Transactions are prohibited and will not be authorized by the Compliance Officer (or a designee) absent exceptional circumstances. The prohibitions apply only to the categories of persons specified.
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a. Pending Buy or Sell Orders (Investment Personnel and Access Persons). Any purchase or sale of Securities (except Funds) by Investment Personnel or Access Persons on any day during which any Fund or Private Account has a pending buy or sell order in the same Security (or Equivalent Security) until that order is executed or withdrawn. This prohibition applies whether the Securities Transaction is in the same direction (e.g., two purchases) or the opposite direction (a purchase and sale) as the transaction of the Fund or Private Account. See exemption in Section II.B.2.
b. Seven-Day Blackout (Investment Personnel and Access Persons). Purchases or sales of Securities (except Funds and registered open-end investment companies that are not ETFs) by Investment Personnel or Access Persons within seven calendar days before and after a purchase or sale of the same Securities (or Equivalent Securities) by any Fund or Private Account. For example, if a Fund or Private Account trades a Security on day one, day eight is the first day any Investment Personnel or Access Persons may trade that Security (or Equivalent Security) for an account in which he or she has a beneficial interest. This prohibition applies whether the Securities Transaction is in the same direction or the opposite direction as the transaction of the Fund or Private Account. This prohibition also does not apply where a personal trade follows or precedes a Fund or Private Account trade to purchase or sell a basket of securities to invest cash or raise cash (e.g., program trades or cash equitization trades). Investment Personnel and Access Persons may not cause a Fund or Private Account to refrain from trading in order to avoid the application of this prohibition. See exemption in Section II.B.2.
c. Intention to Buy or Sell for a Fund or Private Account (Investment Personnel and Access Persons). Purchases or sales of Securities (except Funds) by an Access Person or Investment Person at a time when that Access Person or Investment Person intends, or knows of anothers intention, to purchase or sell that Security (or an Equivalent Security) on behalf of a Fund or Private Account. This prohibition also applies whether the Securities Transaction is in the same direction or the opposite direction as the transaction of the Fund or Private Account. This prohibition does not apply with respect to Fund or Private Account trades to purchase or sell a basket of securities to invest cash or raise cash (e.g., program trades or cash equitization trades).
d. Sixty Day Short-Term Trading Profit Restriction (Investment Personnel and Access Persons). Investment Personnel are prohibited from profiting from any purchase and sale, or sale and purchase, of a Security or Equivalent Security within sixty calendar days. All Access Persons are prohibited from profiting from any purchase and sale, or sale and purchase, of a Fund or Private Account within sixty calendar days.
e. Restricted List (Investment Personnel and Access Persons). Investment Personnel and Access Persons are prohibited from purchases or sales of Securities on the Advisers Restricted List, if any.
f. Holdings Restriction (Investment Personnel and Access Persons). Investment Personnel and Access Persons are prohibited from purchasing Securities or Equivalent Securities (except Funds and ETFs) currently held or sold short by any Fund or Private Account.
g. Excessive Trading (Investment Personnel and Access Persons). Excessive trading is strongly discouraged. Excessive trading means trading with a frequency that potentially imposes an administrative burden on the Compliance department, interferes with regular job duties, or adversely affects clients, as determined by the Compliance Officer in his or her discretion. In general, any Access Person requesting preclearance
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for more than 10 Securities Transactions in a month should expect additional scrutiny regarding his or her trades. The Compliance Officer or a designee monitors trading activity, and may report such activity to Adviser management and/or limit the number of Securities Transactions by an Access Person during a given period. Notwithstanding the foregoing, this rule does not apply to Securities Transactions in an account that is managed by a broker or adviser with discretionary authority over the account.
2. Always Prohibited Securities Transactions. The following Securities Transactions for Funds or Private Accounts are prohibited for all Access Persons and Investment Persons and will not be authorized under any circumstances.
a. Inside Information. Any transaction in a Security while in possession of material nonpublic information regarding the Security or the issuer of the Security. For more detailed information, see the Advisers Insider Trading Policy in its Compliance Policies and Procedures.
b. Market Manipulation. Transactions intended to raise, lower, or maintain the price of any Security or to create a false appearance of active trading.
c. Others. Any other transactions deemed by the Compliance Officer (or a designee) to involve a conflict of interest, possible diversions of a corporate opportunity, an appearance of impropriety, or an administrative burden, or determined by the Compliance Officer (or designee) in his or her discretion to be prohibited for any other reason. For example, Access Persons and Investment Personnel should not execute Securities Transactions for their own account with the same individual employee at a broker-dealer firm that Causeway uses for trading for Funds and Private Accounts.
3. Initial Public Offerings (Investment Personnel and Access Persons). Any purchase of Securities by Investment Personnel or Access Persons in an initial public offering (other than a new offering of a registered open-end investment company) or purchase of cryptocurrency tokens or Initial Coin Offerings (which may be analogous to IPOs) is only permitted if the Compliance Officer grants permission in advance after considering, among other facts, whether the investment opportunity should be reserved for a Fund or Private Account and whether the opportunity is being offered to the person by virtue of the persons position as an Investment Person or Access Person. If authorized, the Compliance Officer will maintain a record of the reasons for such authorization (see Appendix 6).
4. Private Placements (Investment Personnel and Access Persons). Acquisition of Beneficial Interests in Securities in a Private Placement by Investment Personnel or Access Persons is only permitted if the Compliance Officer (or a designee) grants permission in advance after considering, among other facts, whether the investment opportunity should be reserved for a Fund or Private Account and whether the opportunity is being offered to the person by virtue of the persons position as an Investment Person or Access Person. If a Private Placement transaction is permitted, the Compliance Officer will maintain a record of the reasons for such approval (see Appendix 6). Investment Personnel who have acquired securities in a Private Placement are required to disclose that investment to the Compliance Officer when they play a part in any subsequent consideration of an investment in the issuer by a Fund or Private Account, and the decision to purchase securities of the issuer by a Fund or Private Account must be independently authorized by a Portfolio Manager with no personal interest in the issuer.
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B. Exemptions.
1. The following Securities Transactions are exempt from the restrictions set forth in Section II.A.
a. Mutual Funds/CITs. Securities issued by any registered open-end investment companies or collective investment trusts (excluding Funds, mutual fund clients and collective investment trusts for which the Adviser serves as investment adviser or subadviser and ETFs);
b. No Knowledge. Securities Transactions where neither the Access Person nor Investment Person nor an Immediate Family member knows of the transaction before it is completed (for example, Securities Transactions effected for an Access Person or Investment Person by a trustee of a blind trust or by an automated or robo adviser without Access Person or Investment Person input or approval, or discretionary trades involving an investment partnership or investment club in which the Access Person or Investment Person is neither consulted nor advised of the trade before it is executed);
c. Certain Corporate Actions. Any acquisition of Securities through stock dividends, dividend reinvestments, stock splits, reverse stock splits, mergers, consolidations, spin-offs, or other similar corporate reorganizations or distributions generally applicable to all holders of the same class of Securities;
d. Rights. Any acquisition of Securities through the exercise of rights issued by an issuer pro rata to all holders of a class of its Securities, to the extent the rights were acquired in the issue;
e. Charities and Inheritances. Any disposition of Securities (or Equivalent Securities) donated or transferred to charitable or similar organizations, or any acquisition of Securities (or Equivalent Securities) through inheritance or similar estate transfer processes. This exception does not apply to a donation where the Access Person or Investment Person knows that the recipient will immediately sell the Securities (or Equivalent Securities).
f. Miscellaneous. Any transaction in the following: (1) bankers acceptances, (2) bank certificates of deposit, (3) commercial paper, (4) high quality short-term debt, including repurchase agreements, (5) Securities that are direct obligations of the U.S. Government, (6) municipal bonds, and (7) other Securities as may from time to time be designated in writing by the Compliance Officer on the grounds that the risk of abuse is minimal or non-existent.
2. Personal Transactions in Securities that also are being purchased, sold or held by a Fund or Private Account are exempt from the prohibitions of Sections II.A.1. a and b if the Investment Person or Access Person does not, in connection with his or her regular functions or duties, make, participate in, or obtain information regarding the purchase or sale of Securities by that Fund or Private Account.
3. Application to Commodities, Futures, Options on Futures and Options on Broad-Based Indexes. Commodities, futures (including currency futures and futures on securities comprising part of a broad-based, publicly traded market based index of stocks, but not including futures on single securities) and options on futures and options on broad-based indexes are not subject to the prohibited transaction provisions of Section II.A., but are subject to the Codes transaction reporting requirements.
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4. Application to Currencies and Cryptocurrencies. Currencies, such as US Dollars or euros, are not Securities and are not subject to the Code. Similarly, cryptocurrencies, such as Bitcoin, which are a virtual or digital representation of value, are not Securities and are not subject to the Code. However, purchases of cryptocurrency tokens and ICOs are subject to preclearance, and, depending on the instrument, derivatives on tokens are subject to preclearance.
III. REPORTING AND PRECLEARANCE REQUIREMENTS
A. Reporting | and Preclearance Requirements for Access Persons and Investment Personnel |
1. Preclearance Procedures. Access Persons and Investment Persons must obtain approval from the Compliance Officer prior to entering into any Securities Transactions (including IPOs and Private Placements) or purchases or sales of cryptocurrency tokens or ICOs (which are subject to the same procedures as Securities Transactions below), except that preclearance is not required for the exempt Securities Transactions set forth in Section II.B or for Securities Transactions in Funds or federal Thrift Savings Plan funds. An Access Persons or Investment Persons first failure to preclear a Securities Transaction within a five year period will not be considered a violation and will receive a warning, unless the Securities Transaction involves a violation of the prohibitions of Section II.A. Access Persons and Investment Persons may preclear Securities Transactions only where they have a present intent to transact in the Security.
To preclear a Securities Transaction, an Access Person or Investment Person shall communicate his or her request to the Compliance Officer, either through the automated preclearance system or a manual process, and provide the following information:
a) | Issuer name; |
b) | Type of security (stock, bond, note, etc.); and |
c) | Nature of transaction (purchase or sale). |
Approval of a Securities Transaction, once given, is effective only for two business days or until the employee discovers that the information provided at the time the transaction was approved is no longer accurate, whichever is shorter.
2. Initial Holdings and Accounts Report. Every Access Person and Investment Person must submit within 10 calendar days of becoming an Access Person or Investment Person an Initial Holdings and Accounts Report (see Appendix 3-A) to the Compliance Officer listing all Securities accounts and Securities that he or she holds in such accounts in which that Access Person or Investment Person (or Immediate Family member) has a Beneficial Interest. The information in the Initial Holdings and Accounts Report must be current as of a date not more than 45 calendar days prior to the date the person becomes an Access Person or Investment Person.
3. Quarterly Reporting Requirements. Every Access Person and Investment Person (and Immediate Family member) must arrange for the Compliance Officer or a designee to receive directly from any broker, dealer, or bank that effects any Securities Transaction, duplicate copies of each confirmation for each such transaction and periodic statements for each brokerage account in which such Access Person or Investment Person (and Immediate Family member) has a Beneficial Interest. Attached hereto as Appendix 4 is a form of letter that may be used to request such
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documents from such entities. All copies must be received no later than 30 calendar days after the end of the calendar quarter. Each confirmation or statement must disclose the following information:
a) | the date of the transaction; |
b) | the title (and exchange ticker symbol or CUSIP number, interest rate and maturity date, as applicable); |
c) | the number of shares and principal amount; |
d) | the nature of the transaction (e.g., purchase or sale); |
e) | the price of the Security; and |
f) | the name of the broker, dealer or bank through which the trade was effected. |
If an Access Person or Investment Person (or Immediate Family member) is not able to arrange for duplicate confirmations and periodic statements to be sent that contain the information required above, or if a transaction is consummated without an intermediary, he or she must submit a quarterly transaction report (see Appendix 5) within 30 calendar days after the completion of each calendar quarter to the Compliance Officer or a designee.
4. Every Access Person or Investment Person who establishes a Securities account during the quarter in which that Access Person or Investment Person (or Immediate Family member) has a Beneficial Interest must submit an Account Report (see Appendix 5) to the Compliance Officer or a designee. This report must be submitted to the Compliance Officer or a designee within 30 calendar days after the completion of each calendar quarter.
5. Annual Holdings and Accounts Report. Every Access Person and Investment Person must annually submit an Annual Holdings and Accounts Report (see Appendix 3-A) listing all Securities accounts and Securities in which that Access Person or Investment Person (or Immediate Family member) has a Beneficial Interest. The information in the Annual Holdings Report must be current as of a date no more than 45 calendar days before the report is submitted.
6. An Access Person or Investment Person is not required to report Securities accounts that may only hold open-end mutual funds (except ETFs) or collective investment trusts; however, an Access Person or Investment Person is required to report Securities accounts that are permitted to hold other Securities or ETFs even if the Securities account does not currently hold other Securities or ETFs.
B. | Reporting Requirements for Independent Fund Trustees |
Each Independent Fund Trustee (and his or her Immediate Family) must report to the Compliance Officer or a designee any trade in a Security by any account in which the Independent Fund Trustee has any Beneficial Interest if the Independent Fund Trustee knew or, in the ordinary course of fulfilling his or her duty as a Trustee of the Trust, should have known that during the 15-calendar day period immediately preceding or after the date of the transaction in a Security by the Trustee such Security (or an Equivalent Security) was or would be purchased or sold by a Fund or such purchase or sale by a Fund was or would be considered by the Fund, except with respect to purchases or sales of a basket of securities to invest cash or raise cash (e.g., program trades or cash equitization trades). Independent Fund Trustees who need to report such transactions should refer to the procedures outlined in Section III.A.2.
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C. | Exemptions, Disclaimers and Availability of Reports |
1. | Exemptions. |
(a) A Securities Transaction involving the following circumstances or Securities is exempt from the reporting requirements discussed above: (1) neither the Access Person or Investment Person nor an Immediate Family member had any direct or indirect influence or control over the transaction; (2) Securities directly issued by the U.S. Government; (3) bankers acceptances; (4) bank certificates of deposit; (5) commercial paper; (6) high quality short-term debt instruments, including repurchase agreements; and (7) shares issued by open-end mutual funds or collective investment trusts (excluding Funds, mutual fund and collective investment trust clients for which the Adviser serves as investment adviser or subadviser and ETFs).
(b) An Access Person or Investment Person shall not be required to make a transaction report under Section III.A. to the extent that information in the report would duplicate information recorded by the Adviser pursuant to Rule 204-2(a)(13) of the Advisers Act.
(c) With respect to transactions effected pursuant to an Automatic Investment Plan, Access Persons and Investment Persons need not make quarterly transaction reports under Section III.A.
2. Disclaimers. Any report of a Securities Transaction for the benefit of a person other than the individual in whose account the transaction is placed may contain a statement that the report should not be construed as an admission by the person making the report that he or she has any direct or indirect beneficial ownership in the Security to which the report relates.
3. Availability of Reports. All information supplied pursuant to this Code may be made available for inspection to the Board of Trustees of the Trust, the management of the Adviser, the Compliance Officer, any party to which any investigation is referred by any of the foregoing, the SEC, any self-regulatory organization of which the Adviser is a member, any state securities commission or regulator, and any attorney or agent of the foregoing or of the Trust. Information supplied pursuant to this Code may also be maintained by a third-party vendor engaged by the Adviser to facilitate administration of the Code, provided the vendor has agreed to maintain the confidentiality of such information.
IV. FIDUCIARY DUTIES
A. Confidentiality. Covered Persons are prohibited from revealing information relating to the investment intentions or activities of the Funds or Private Accounts except to persons whose responsibilities require knowledge of the information.
B. Corporate Opportunities. Access Persons and Investment Persons may not take personal advantage of any opportunity properly belonging to the Funds or Private Accounts. This includes, but is not limited to, acquiring Securities for ones own account that would otherwise be acquired for a Fund or Private Account.
C. Undue Influence. Covered Persons may not cause or attempt to cause any Fund or Private Account to purchase, sell or hold any Security in a manner calculated to create any personal benefit to the Covered Person. If a Covered Person (or Immediate Family member) stands to benefit materially from an investment decision for a Fund or Private Account which the Covered Person is recommending or participating in, the Covered Person must disclose to those persons with authority to make investment
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decisions for the Fund or Private Account (or, if the Covered Person in question is a person with authority to make investment decisions for the Fund or Private Account, to the Compliance Officer) any Beneficial Interest that the Covered Person (or Immediate Family member) has in that Security or an Equivalent Security, or in the issuer thereof, where the decision could create a material benefit to the Covered Person (or Immediate Family member) or the appearance of impropriety. The person to whom the Covered Person reports the interest, in consultation with the Compliance Officer, must determine whether or not the Covered Person will be restricted in making investment decisions.
V. COMPLIANCE WITH THIS CODE OF ETHICS
A. Compliance Officer Review
1. Monitoring of Personal Securities Transactions. The Compliance Officer or a designee will review personal Securities Transactions and holdings reports made pursuant to Section III.
2. Investigating Violations of the Code. The Compliance Officer will investigate any suspected violation of the Code and report the results of each investigation to the Chief Operating Officer of the Adviser. The Chief Operating Officer together with the Compliance Officer will review the results of any investigation of any reported or suspected violation of the Code.
3. Annual Reports. At least annually, the Compliance Officer must furnish to the Trusts Board of Trustees, and the Board of Trustees must consider, a written report that (1) describes any issues arising under this Code or procedures since the last report to the Board of Trustees, including, but not limited to, information about material violations of the Code or procedures and sanctions imposed in response to the material violations, and (2) certifies that the Fund and the Adviser have adopted procedures reasonably necessary to prevent Covered Persons from violating the Code.
B. Remedies
1. Sanctions. If the Compliance Officer and the Chief Operating Officer of the Adviser determine that a Covered Person has committed a violation of the Code following a report of the Compliance Officer, the Compliance Officer and the Chief Operating Officer of the Adviser may impose sanctions and take other actions as they deem appropriate, including a letter of caution, suspension of personal trading rights, suspension of employment (with or without compensation), fine, civil referral to the SEC, criminal referral, and termination of the employment of the violator for cause. Absent exceptional circumstances, an Access Persons first violation of the Code within a five year period would result in a 30- calendar day suspension of personal trading privileges, a second violation within a five year period would result in a 90- calendar day suspension of personal trading privileges, and a third violation within a five year period would result in a 2-year suspension of trading privileges. For these purposes, violations would be measured from the date the violation occurred and include, for accumulation purposes, past violations. A suspension of trading privileges would generally entail a prohibition from purchasing Securities, but would not prohibit purchases of registered open-end investment companies or collective investment trusts and would not prohibit sales of Securities or purchases of Securities to cover short positions.
The Compliance Officer and the Chief Operating Officer of the Adviser also may require the Covered Person to reverse the trade(s) in question and forfeit any profit or absorb any loss derived therefrom. The amount of profit shall be calculated by the Compliance Officer and the Chief Operating Officer of the Adviser. Such profit and any other monetary fine imposed hereunder shall
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be paid by the Covered Person to the Adviser and forwarded by the Adviser to a charitable organization selected by the Compliance Officer and the Chief Operating Officer of the Adviser. The Compliance Officer and the Chief Operating Officer of the Adviser may not review his or her own transaction.
2. Sole Authority. The Compliance Officer and the Chief Operating Officer of the Adviser have sole authority, subject to the review set forth in Section V.B.1 above, to determine the remedy for any violation of the Code, including appropriate disposition of any monies forfeited pursuant to this provision. Failure to promptly abide by a directive to reverse a trade or forfeit profits may result in the imposition of additional sanctions.
C. Exceptions to the Code. Exceptions to the Code will rarely, if ever, be granted. The Compliance Officer may grant exceptions to the requirements of the Code on a case by case basis if the Compliance Officer finds that the proposed conduct involves negligible opportunity for abuse, or upon a showing by the employee that he or she would suffer extreme financial hardship should an exception not be granted. Should the subject of the exception request involve a Securities Transaction, a change in the employees investment objectives, tax strategies, or special new investment opportunities would not constitute acceptable reasons for an exception. Any exceptions granted must be in writing.
D. Compliance Certification. The Adviser shall provide each Covered Person with a copy of the Code of Ethics and any amendments. Each Access Person and Investment Person shall certify that he or she has received, read and understands the Code and any amendments by executing the Certification of Compliance with the Code of Ethics form (see Appendix 3). In addition, on an annual basis, all Access Persons and Investment Persons will be required to re-certify on such form (see Appendix 3) that they have read and understand the Code and any amendments, that they have complied with the requirements of the Code, and that they have reported all Securities Transactions required to be disclosed or reported pursuant to the requirements of the Code. Independent Fund Trustees and members of the board of managers of the Advisers parent holding company should complete Appendix 3-I only.
E. Inquiries Regarding the Code. The Compliance Officer will answer any questions about the Code or any other compliance-related matters.
DATED: April 25, 2005
REVISED: November 1, 2005; January 30, 2006; January 28, 2008; February 1, 2010; August 2, 2010; August 10, 2010; July 1, 2013; June 30, 2015; June 30, 2016; December 29, 2017; June 29, 2018; June 3, 2019; June 30, 2020; October 1, 2020; June 30, 2021; June 30, 2022; December 30, 2022
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Appendix 1
DEFINITIONS
1940 Act means the Investment Company Act of 1940, as amended.
Access Person means any officer, general partner or Advisory Person of the Trust, the Adviser, or Causeway (Shanghai) Information Consulting Co., Ltd.; provided, that the employees of SEI Investments Global Funds Services and its affiliates (collectively, SEI) shall not be deemed to be Access Persons as their trading activity is covered by the Code of Ethics adopted by SEI in compliance with Rule 17j-1 under the 1940 Act. Unless otherwise determined by the Compliance Officer in writing, Independent Fund Trustees and members of the board of managers of the Advisers parent holding company who are not Advisory Persons are deemed not to be Access Persons under this Code on the grounds that they do not have regular access to information or recommendations regarding the purchase or sale of Securities by Funds or Private Accounts and the risk of abuse is deemed minimal.
Adviser means Causeway Capital Management LLC.
Advisers Act means the Investment Advisers Act of 1940, as amended.
Advisory Person means
(1) any trustee, member of the board of managers of the Advisers parent holding company, or officer, general partner or employee of the Adviser, Causeway (Shanghai) Information Consulting Co., Ltd., or the Trust (or of any company in a Control relationship with any of such companies) who, in connection with his or her regular functions or duties, makes, participates in, or obtains or has access to information regarding the purchase or sale of Securities by, or the nonpublic portfolio holdings of, the Funds or Private Accounts, or has access to or whose functions relate to the making of any recommendations with respect to such purchases or sales, and
(2) any natural person in a Control relationship to the Trust or the Adviser who obtains information concerning recommendations made to the Funds or Private Accounts with respect to the purchase or sale of Securities by the Funds or Private Accounts.
Automatic Investment Plan means a program in which regular periodic purchases (or withdrawals) are made automatically in (or from) investment accounts in accordance with a predetermined schedule and allocation. An Automatic Investment Plan includes a dividend reinvestment plan.
Beneficial Interest means the opportunity, directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise, to profit, or share in any profit derived from, a transaction in the subject Securities. A Covered Person is deemed to have a Beneficial Interest in Securities owned by members of his or her Immediate Family. Common examples of Beneficial Interest include joint accounts, spousal accounts, UTMA accounts, partnerships, trusts and controlling interests in corporations. Any uncertainty as to whether a Covered Person has a Beneficial Interest in a Security should be brought to the attention of the Compliance Officer. Such questions will be resolved in accordance with, and this definition shall be subject to, the definition of beneficial owner found in Rules 16a-1(a)(2) and (5) promulgated under the Securities Exchange Act of 1934.
Code means this Code of Ethics, as it may be amended from time to time.
i
Compliance Officer means the Chief Compliance Officer of the Adviser and the Trust and the persons designated in Appendix 2, as such Appendix shall be amended from time to time.
Control shall have the same meaning as that set forth in Section 2(a)(9) of the 1940 Act.
Covered Person means any Access Person, Investment Person, Independent Fund Trustee, member of the board of managers of the Advisers parent holding company, or member, officer or employee of the Adviser, Causeway (Shanghai) Information Consulting Co., Ltd., or the Advisers parent holding company (or of any company in a Control relationship with any of such companies).
Equivalent Security means any Security issued by the same entity as the issuer of a subject Security, including options, rights, stock appreciation rights, warrants, preferred stock, restricted stock, phantom stock, futures on single securities, bonds, and other obligations of that company or security otherwise convertible into that security. Options on securities and futures on single securities are included even if, technically, they are issued by the Options Clearing Corporation, a futures clearing authority, or a similar entity.
ETF means exchange-traded fund.
Fund means a portfolio of the Trust.
Immediate Family of a person means any of the following persons who reside in the same household as such person:
child | grandparent | son-in-law | ||
stepchild | spouse | daughter-in-law | ||
grandchild | sibling | brother-in-law | ||
parent | mother-in-law | sister-in-law | ||
stepparent | father-in-law |
Immediate Family includes adoptive relationships and any other relationship (whether or not recognized by law) which the Compliance Officer determines could lead to the possible conflicts of interest, diversions of corporate opportunity, or appearances of impropriety which this Code is intended to prevent.
Independent Fund Trustee means a trustee of the Trust who is not an interested person as that term is defined in Section 2(a)(19) of the 1940 Act.
Initial Coin Offering or ICO, which may also be referred to as a token offering, is similar to an IPO and used to raise capital, often providing the buyer certain rights once issued.
Initial Public Offering or IPO is an offering of securities registered under the Securities Act of 1933 by an issuer who immediately before the registration of such securities was not subject to the reporting requirements of sections 13 or 15(d) of the Securities Exchange Act of 1934.
Investment Personnel and Investment Person mean (1) employees of the Adviser, Causeway (Shanghai) Information Consulting Co., Ltd., or the Trust (or of any company in a Control relationship with any of such companies) who, in connection with his or her regular functions or duties, makes or participates in making recommendations regarding the purchase or sale of Securities, or (2) any natural person who Controls the Adviser or the Trust and who obtains information concerning recommendations made to the Funds or Private Accounts regarding the purchase and sale of Securities by the Funds or Private Accounts. References to Investment Personnel include without limitation Portfolio Managers.
ii
Market Timing means transactions deemed by the Compliance Officer to constitute the short-term buying and selling of shares of Funds or Private Accounts to exploit pricing inefficiencies.
Portfolio Manager means a person who has or shares principal day-to-day responsibility for managing the portfolio of a Fund or Private Account.
Private Account means the portion of a portfolio of a private client or mutual fund client for which the Adviser serves as investment adviser or subadviser.
Private Placement means a limited offering exempt from registration pursuant to Rules 504, 505 or 506 or under Section 4(2) or 4(6) of the Securities Act of 1933.
Restricted List means the list of companies maintained by the Compliance Officer about which the Adviser or its affiliates potentially possess material nonpublic information.
SEC means the Securities and Exchange Commission.
Security means a security as defined in Section 2(a)(36) of the 1940 Act or Section 202(a)(18) of the Advisers Act, including, but not limited to, stock, notes, bonds, debentures, and other evidences of indebtedness (including loan participations and assignments), limited partnership interests, investment contracts, and all derivative instruments of the foregoing, such as options and warrants. Security does not include futures and options on futures (except for single security futures and options on futures), but the purchase and sale of such instruments are nevertheless subject to the reporting requirements of the Code. Security also does not include currencies or cryptocurrencies, but the purchase and sale of ICOs and tokens are nevertheless subject to the reporting requirements of the Code.
Securities Transaction means a purchase or sale of Securities in which a person (or Immediate Family member of such person) has or acquires a Beneficial Interest.
Trust means Causeway Capital Management Trust, an investment company registered under the 1940 Act for which the Adviser serves as investment adviser.
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Appendix 2
CONTACT PERSONS
COMPLIANCE OFFICER
1. | Kurt J. Decko, Chief Compliance Officer/General Counsel |
2. | Kevin Hu, Senior Compliance Officer |
No Compliance Officer is permitted to preclear or review his/her own transactions or reports under this Code.
Appendix 3
CERTIFICATION OF COMPLIANCE WITH CODE OF ETHICS
I acknowledge that I have received the Code of Ethics dated December 30, 2022, and certify that:
1. I have read the Code of Ethics and any amendments and I understand that it applies to me and to all accounts in which I or a member of my Immediate Family has any Beneficial Interest.
2. In accordance with Section III.A of the Code of Ethics, I will report or have reported all Securities Transactions in which I have, or a member of my Immediate Family has, a Beneficial Interest, except for transactions exempt from reporting under Section III.C.
3. I have listed on Appendix 3-A of this form all accounts and securities in which I have, or any member of my Immediate Family has, any Beneficial Interest.
4. I will comply or have complied with the Code of Ethics in all other respects.
5. I agree to disgorge and forfeit any profits on prohibited transactions in accordance with the requirements of the Code of Ethics.
|
Access Persons/Investment Persons Signature |
|
Print Name |
Date:
Appendix 3-A
PERSONAL SECURITIES HOLDINGS and ACCOUNTS DISCLOSURE FORM
(for use as an Initial or Annual Holdings and Accounts Report)
Pursuant to Section III.A.1 or III.A.3 of the Code of Ethics, please list all Securities accounts and, if not included in a listed Securities account, all Securities in which you (or your Immediate Family member) have a Beneficial Interest. You do not need to list those Securities that are exempt pursuant to Section III.C.
Is this an Initial or Annual Report? |
|
|||||
Name of Access Person/Investment Person: |
|
|||||
Name of Account Holder(s): |
|
|||||
Relationship to Access Person/Investment Person: |
|
SECURITIES ACCOUNTS:
☐ N/A - Neither I nor an Immediate Family member has a Beneficial Interest in any Securities Account.
☐ Listed below are my reportable securities accounts:
Account Number | Name of Broker/Dealer/Bank |
(Attach separate sheets as necessary)
SECURITIES HOLDINGS:
☐ N/A - All Securities are held in the Securities Accounts listed above.
☐ The below Securities are held outside of the Securities Accounts listed above:
(Attach separate sheets as necessary)
I certify that this Report constitutes all the Securities accounts and Securities that must be reported pursuant to this Code.
|
||||
Access Person/Investment Person Signature |
||||
|
| |||
Print Name |
Date |
Appendix 3-I
CERTIFICATION OF COMPLIANCE WITH CODE OF ETHICS
(Independent Fund Trustees
and
members of the board of managers of the Advisers parent holding company)
I acknowledge that I have received the Code of Ethics dated December 30, 2022, and certify that:
1. I have read the Code of Ethics and any amendments, and I understand that it applies to me and to all accounts in which I or a member of my Immediate Family has any Beneficial Interest.
2. I will report or have reported all Securities Transactions required to be reported under Section III.B of the Code in which I have, or a member of my Immediate Family has, a Beneficial Interest (Independent Fund Trustees only).
3. I will comply or have complied with applicable provisions of the Code of Ethics in all other respects.
Signature |
Print Name |
Date:
Appendix 4
Form of Letter to Broker, Dealer or Bank
<Date>
<Broker Name and Address>
Subject:Account #
Dear :
Causeway Capital Management LLC (Adviser), my employer, is a registered investment adviser. In connection with the Code of Ethics adopted by the Adviser, I am required to request that you send duplicate confirmations of individual transactions as well as duplicate periodic statements for the referenced account to my employer. Please note that the confirmations and/or periodic statements must disclose the following information:
1) | date of the transaction; |
2) | the title of the security (including exchange ticker symbol or CUSIP number, interest rate and maturity date, as applicable); |
3) | the number of shares and principal amount; |
4) | the nature of the transaction (e.g., purchase or sale); |
5) | the price of the security; and |
6) | the name of the firm effecting the trade. |
If you are unable to provide this information, please let me know immediately. Otherwise, please address the confirmations and statements directly to:
<address>
Your cooperation is most appreciated. If you have any questions regarding these requests, please contact me or the Advisers Chief Compliance Officer/General Counsel, Kurt J. Decko at (310) 231-6100.
Sincerely, |
<Name of Access Person/Investment Person> |
Appendix 5
REPORT OF SECURITY TRANSACTIONS
FOR QUARTER ENDED
Investment Persons and Access Persons: You do not need to report transactions in 1) direct obligations of the U.S. Government, 2) bankers acceptances, bank CDs, commercial paper, high quality short-term debt instruments, including repurchase agreements, 3) shares of an open-end investment company or collective investment trust (excluding Funds, mutual fund and collective investment trust clients for which the Adviser serves as investment adviser or subadviser and ETFs), 4) transactions for which you had no direct or indirect influence or control; and 5) transactions effected pursuant to an Automatic Investment Plan.
Independent Fund Trustees: If you are an Independent Fund Trustee, then you only need to report a transaction if you, at the time of that transaction, knew or, in the ordinary course of fulfilling your official duties as a Trustee to the Trust, should have known that, during the 15-calendar day period immediately before or after your transaction in a Security:
1) | a Fund purchased or sold such Security or |
2) | a Fund or the Adviser considered purchasing or selling such Security. |
Note that purchases or sales of a basket of securities by a Fund to invest cash or raise cash (e.g., program trades or cash equitization trades) do not trigger a reporting obligation.
Disclose all Securities Transactions for the period covered by this report:
Title of Security* |
Number Shares |
Date of Transaction |
Price at Which Effected |
Principal Amount |
Bought or Sold |
Name of Broker/Dealer/Bank | ||||||
* Please disclose the interest rate or maturity date and exchange ticker symbol or CUSIP number, as applicable.
Did you establish any securities accounts during the period covered by this report? Yes No
If Yes, please complete the following:
Name of Broker |
Date of Account Opening |
Account Number | ||
The above is a record of every Securities Transaction or account opened which I had, or in which I acquired, any direct or indirect Beneficial Interest during the period indicated above.
I certify that the Compliance Officer has received confirmations or account statements pertaining to all Securities Transactions executed that disclose the information required above, and has received notice of any accounts opened, during the period covered by this report.
I have nothing to report for the period covered by this report.
Date: |
Signature: |
Appendix 6
INITIAL PUBLIC OFFERING / PRIVATE PLACEMENT
CLEARANCE FORM
(for the use of the Compliance Officer only)
The Code for the Trust and the Adviser prohibits any acquisition of Securities in an Initial Public Offering (other than shares of open-end investment companies) and Private Placement by any Investment Person or Access Person unless permitted by the Compliance Officer. In these instances, a record of the rationale supporting the approval of such transactions must be completed and retained for a period of five years after the end of the fiscal year in which approval is granted. This form should be used for such recordkeeping purposes; the Compliance Officers signature on an appropriate preclearance form for such securities also shall suffice for record keeping purposes.
Name: |
Date of Request | ||
Name of IPO / Private Placement: | ||
Date of Offering: | ||
Number of Shares/Interests | ||
Price: | ||
Name of Broker/Dealer/Bank |
___ | I have cleared the IPO / Private Placement transaction described above. |
Reasons supporting the decision to approve the above transaction: |
Name of Compliance Officer |
Signature of Compliance Officer |
Date |
CODE OF ETHICS
Voya Financial, Inc.
Voya Investment Management LLC
Voya Investments, LLC
Voya Investment Management Co. LLC
Voya Investment Management (UK) Limited
Voya Alternative Asset Management LLC
Pomona Management LLC
Voya Investments Distributor, LLC
Voya Realty Group, LLC
Voya Investment Trust Co.
Voya funds
NOVEMBER 4, 2022
1. | Adoption of Code of Ethics |
This Code of Ethics (the Code) has been adopted by each of the registered investment companies advised by Voya Investments, LLC (or an affiliate) and operating under the Voya funds umbrella (the Voya funds) and by each of the following Voya Entities (collectively, referred to as Voya Entities):
Voya Investment Management LLC
Voya Investments, LLC
Voya Investment Management Co. LLC
Voya Alternative Asset Management LLC
Pomona Management LLC
Voya Investments Distributor, LLC (VID)
Voya Realty Group, LLC
Voya Investment Trust Co.
Voya Investment Management (UK) Limited
The provisions of the Code are applicable to all directors, trustees, officers and persons employed or appointed by one or more of the Voya Entities as well as their immediate family members living in such designated persons household (collectively, referred to as Employees) unless otherwise noted. Employees on short-term disability, whose access rights have not been revoked will still be subject to the Code. Employees on long-term disability, whose access rights have been revoked will not be subject to the Code during the leave period.
In addition, the Code is applicable to the trustees/directors of each of the Voya funds (the Voya funds Directors).
All Employees and the Directors of the Voya funds (collectively, referred to as Covered Persons) will be provided with a copy of this Code upon employment with the Voya Entities or appointment and notified when any material amendments are made to the Code.
The Code is not intended to supersede or otherwise replace the Voya Code of Business Conduct and Ethics. All of the policies and guidelines contained in the Voya Code of Business Conduct and Ethics shall remain in full force and effect as to Employees.
2. | Covered Persons |
Certification of Compliance. All Covered Persons are required to certify to the Voya IM Compliance Department annually, or whenever this Code is materially amended, that they have:
| read and understand the provisions contained in the Code; |
| complied with all the requirements of the Code; and |
| reported all transactional information required by the Code. |
Generally, as an employee of the Company, you may be held personally liable for any improper or illegal acts committed during the course of your employment; non-compliance with this policy may be deemed to encompass one of these acts. Accordingly, you must read this policy and comply with the spirit and the strict letter of its provisions. Failure to comply may result in the imposition of serious sanctions, which may include, but are not limited to, letter of written reprimand, the disgorgement of profits, cancellation of trades, selling of positions, and suspension of personal trading privileges, dismissal, and referral to law enforcement or regulatory agencies.
Covered Persons are required to certify their receipt and understanding of and compliance with the Code within ten days of becoming a Covered Person. On an annual basis, all Covered Persons are required to re-certify their understanding of and compliance with the Code. You will be provided with timely notification of these certification requirements and directions on how to complete them by the Code of Ethics Office. Other reporting and certification requirements are set forth in the Gift & Entertainment, Political Contributions, and Personal Securities Transactions Sections of this Code.
3. | Violations of the Code |
Employees are required to report any known or suspected violations of the Code to the Voya IM Compliance Department immediately. An Employee who violates this Code or fails to report a violation of the Code may be subject to sanctions. For example, if the same security is purchased or sold on the same day by an Employee, the Employee following a violation, may be required to disgorge profits to charity. In addition, any Employee that violates the Codes pre-clearance or transaction reporting provisions may also be suspended from further trading for a period.
4. | Exceptions to the Code |
Exceptions to the Code will only be made under extraordinary circumstances. No exception may be granted for those sections of the Code that are mandated by regulation.
Exceptions may be made only upon prior request, and no exception will be granted subsequent to a violation of the Code. To be granted an exception to the Code, a written request regarding the nature of the exception must be made and submitted to Voya IMs Chief Compliance Officer and approved by her or him and a member of Voya IMs Management Committee. Exceptions to the Code shall be reported as applicable to the Chief Compliance Officer of the Voya funds and the Voya funds Directors.
5. | Statement of Fiduciary Standards |
A fiduciary is a person or organization that manages money or property for another, usually a client, and, as a result, has a legal duty to act in the best interests of that client. This Code is based on the overriding principle that the Employees have a fiduciary duty to clients, including the Voya funds, while the Voya funds Directors of the have a fiduciary duty only to the Voya funds. Our investment advisers owe a fiduciary duty to the Clients for which they serve as an adviser or sub-adviser. Covered Persons of our investment advisers must avoid activities, interests, and relationships that could interfere or appear to interfere with our advisers fiduciary duties. Accordingly, Covered Persons shall conduct their activities in accordance with the following standards:
5.1. | Clients Interests Come First. In the course of fulfilling their duties and responsibilities, Covered Persons must at all times place the interests of the clients (or, in the case of the Voya funds Directors, the Voya funds) first. In particular, Covered Persons shall avoid putting their own personal interests ahead of the interests of a client. |
5.2. | Conflicts of Interest Shall Be Avoided. Covered Persons must avoid any situations involving an actual or potential conflict of interest or possible impropriety with respect to their duties and responsibilities to, in the case of an Employee, a Voya Entity or a client of a Voya Entity or in the case of a Voya funds Director, the Voya funds. |
5.3. | Compromising Situations Shall Be Avoided. Covered Persons shall never take advantage of their position of trust and responsibility. Covered Persons must avoid any situation that might compromise or call into question their exercise of full independent judgment in the best interests of clients. |
All activities of Covered Persons shall be guided by, and adhere to, these fiduciary standards. The remainder of this Code sets forth specific rules and procedures that are consistent with these fiduciary standards. However, all activities by Employees are required to conform to these standards regardless of whether the activity is specifically covered in this Code. Any violation of the Code by an Employee may include but not be limited to reprimand, suspension, disgorgement of trading profits and termination of employment.
6. | Duty of Confidentiality |
Covered Persons must keep confidential any non-public information regarding Voya, a Voya Entity, a Voya fund, and any client or any entity whose securities they know or should know are under investment review by a portfolio management team acting on behalf of a Voya Entity. Covered Persons have the highest fiduciary obligation not to reveal confidential information of any nature to any party that does not have an explicitly clear and compelling need to know such information.
All information submitted by a Covered Person to the Voya IM Compliance Department pursuant to this Code will be treated as confidential information. It may, however, be made available to senior management, governmental and governmental agencies with regulatory authority over the Voya Entities, as well as to the Voya funds Directors, and each of their auditors and legal advisors, as appropriate.
7. | Covered Persons Duty to Comply with Federal Securities Laws |
Voya Entities activities are governed by the federal securities laws, including the Investment Advisers Act of 1940, as amended (the Advisers Act) and the Investment Company Act of 1940, as amended. Covered Persons are expected to adhere to the federal securities laws, whether or not the activity is specifically covered in this Code.
8. | Personal Trading Restrictions |
The restrictions of this section apply to all Employees, covered under the personal trading policies and procedures of Voya Investment Management (Voya IM), and to accounts over which they have the authority to make investment decisions, for all transactions involving securities.
8.1. | Pre-Clearance of Securities Transactions. Except for the transactions listed below, approval must be obtained from the Voya IM Compliance Department before entering an order to buy or sell or transfer securities by gift, engaging in derivative transactions, or selling of shares in connection with margin calls. An approval to trade is only valid on the business day it is received (note: such approvals terminate at close of business day on the date such approval is granted). If you receive an approval and do not complete the trade that same day, you must seek pre-clearance to complete the trade the next (or any subsequent) business day. Except as noted below, an approval must be received for every transaction. Pre-clearance |
approvals for securities traded on a U.S. exchange or in a U.S. market are effective until the close of business on the day that your pre-clearance request has been approved. Pre-clearance approvals for securities traded on a foreign exchange or in a foreign market are effective until the close of business on the business day following approval of your pre-clearance request. If you want to modify your trade request previously submitted in any way (e.g., date of execution or share quantity), you must submit a new pre-clearance request. |
The Voya Entities utilize a vendor system to process personal trading. All preclearance requests shall be made via the system, which can be accessed at: Protegent PTA.
Employees assigned portfolio management or trading responsibility are prohibited from knowingly buying or selling the same security traded in an associated client account for a period of 15 days (7 days prior to the client trade and 7 days after the client trade).
Private Placement investment personnel must obtain pre-clearance to purchase or sell private placements.
8.2. | Pre-Clearance and Holding Period Requirements for Voya Financial securities. |
Employees must obtain pre-clearance for transactions involving Voya Financial securities, including:
| Open market purchases and sales; |
| Gifting or making a charitable contribution of your holdings; |
| Transactions in Voya Company Stock Fund in the 401(k) (other than automatic purchases made pursuant to an established payroll-deduction program, or transactions involving automatic and/or pro-rata rebalances); or |
| Sales of Restricted Stock (other than the immediate sales upon vesting of securities). |
Employees who wish to transact in Voya securities should consider the following before seeking pre-clearance and transacting:
Voya Securities must be held for a minimum of 60 calendar days from the acquisition date, including the Voya Company Stock Fund in Voya 401(k) accounts.
Employees are prohibited from shorting any securities issued by Voya.
Employees are prohibited from trading securities issued by Voya during the Closed Period for Voya Financial Instruments, including trades in Voya 401(k) accounts.
Warning: Failure to Pre-Clear will result in sanctions including suspension of personal trading privileges.
8.3. | Exceptions to Pre-Clearance of Securities Transactions. |
| Direct obligations of the Government of the United States; |
| High quality short-term debt instruments, including bankers acceptances, bank certificates of deposit, commercial paper, money market securities and repurchase agreements; |
| Shares of open-end funds, including shares held in Voyas 401(k) plan (as defined in Transactions in Voya Fund Shares, below); |
| Transactions in accounts over which an Employee has no direct or indirect control or influence (managed or discretionary accounts); |
| Transactions under any incentive compensation plan sponsored by the Voya Entities; |
| Transactions made through an automatic dividend reinvestment plan, automatic payroll deduction or similar program (excluding Self Directed Brokerage Accounts) where the timing of purchases and sales is controlled by someone other than the Employee; |
| Transactions involving Bitcoins or other cryptocurrencies; |
| Transactions made through a fully discretionary Robo-Advisor program; |
| An exercise of pro-rata rights issued by a company to all the holders of a class of its securities; |
| On any given day, transactions involving 100 shares or less (per account) of common stock issued by companies included in the S&P 500 Index; and |
| On any given day, transactions involving 100 shares or less (per account) of Exchange-Traded Funds. |
| Transactions involving penny stocks. |
| Transactions involving options on an index. |
| Transactions involving interval closed-end funds. |
While the securities transactions noted above may not need to be pre-cleared, they may need to be held and reported in accordance with the reporting requirements set forth below.
8.4. | Prohibition on Initial Public Offerings and Initial Coin Offerings. Employees are prohibited from acquiring securities in initial public offerings, or initial coin offerings; except for transactions made pursuant to an employee incentive compensation, retention or other program put in place by a Voya Entity. |
8.5. | Restrictions on Private Placements. Employees are prohibited from acquiring non-public securities (a private placement) without the prior approval of the Voya IM Compliance Department. If an Employee is granted approval to make such a personal investment, that Employee will not participate in any consideration of whether clients should invest in the same issuers public or non-public securities. |
8.6. | Prohibition on Short-Term Trading Profits. Employees are prohibited from profiting from the purchase and sale, or sale and purchase, of the same (or related) securities or exchange |
traded funds as well as shares of open-end funds advised or sub-advised by the Voya Entities. Profits made in connection with short-term trades may be subject to disgorgement. |
8.7. | Borrowing Money from Suppliers or Clients. Employees may not borrow money from any of Voya IMs suppliers, consultants, or clients. However, the receipt of credit on customary terms in connection with the purchase of goods or services is not considered to be borrowing within the foregoing prohibition. In addition, acceptance of loans from other banks or financial institutions on customary terms to finance proper and usual activities, such as home mortgage loans, is permitted except where prohibited by law. |
9. | Holding period requirements are as follows: |
Shares of securities (including, Voya Company Stock Fund, individual stocks, bonds, closed-end funds, derivatives, etc.) must be held for 60 calendar days from the purchase date.
Shares of exchange-traded funds must be held for 30 calendar days from the purchase date.
Shares of open-end funds advised or sub-advised by the Voya Entities (including 401(k) transactions other than those involving the Voya Company Stock Fund) must be held for 30 calendar days from the purchase date. Note: The 30-calendar day holding period for shares of open-end funds advised or sub-advised by the Voya Entities is measured from the time of the most recent purchase of the shares of the relevant Voya fund.
9.1. | Prohibition of Short Selling and Derivatives of Voya Securities. Because of the heightened legal risk, the potential misalignment of your interests and those of Voya Financial and its shareholders, and the inappropriateness of engaging in speculative transactions involving Voya Financial securities, you may not engage in: |
| Short sales of Voya Financial common stock. For example, you cannot sell Voya Financial common stock that you do not own, or if you own the stock, you cannot deliver it against such sale, and borrowing shares to complete the sale; or |
| Hedging or other transactions involving options (including exchange-traded options), puts, calls, forward contracts or other derivatives involving Voya Financial securities (excluding stock awards granted under any Voya Financial incentive plan). |
9.2. | Prohibition of Trading in Voya Securities during the Closed Period. Employees are prohibited from trading Voya Securities, including the Voya Company Stock Fund in Voyas 401(k) plan, during the Closed Period for Voyas Financial Instruments as set forth by Voya Financial. The Voya Closed Periods are set forth on the vendor system utilized to process personal trading requests, which can be accessed at: Protegent PTA. |
10. | Reporting Obligation |
10.1. | Disinterested Directors/Trustees |
Voya funds Directors who are not deemed to be interested persons (as that term is defined under the Investment Company Act of 1940, as amended (IC Act) of a Voya fund, its investment adviser or the advisers affiliate (the Disinterested Directors) must submit a quarterly report containing the information set forth in 10.2 - 10.5 below, only with respect to those transactions for which such person knew or, in the ordinary course of fulfilling his or
her official duties as a Disinterested Director, should have known, that during the 15-day period immediately before or after the Disinterested Directors transaction in securities that are otherwise subject to the reporting requirements described herein, an applicable Voya und had purchased or sold the security at issue or that an investment adviser or sub-adviser for an applicable Voya fund had considered purchasing or selling such security.
10.2. | Initial Disclosure of Personal Holdings. Employees are required to disclose all their personal securities holdings to the Voya IM Compliance Department within 10 days of commencing employment with a Voya Entity. The holdings report must be current as of a date not more than 45 days prior to the commencement of employment. |
10.3. | Securities Transaction Records. Employees should be aware that the Voya Entities maintain a list of designated broker-dealers with whom Employees may maintain a brokerage account. Employees shall notify the Voya IM Compliance Department if they intend to open, or have opened, a brokerage account. If requested, Employees shall direct their brokers to supply Compliance with duplicate confirmation statements of their securities transactions and copies of all periodic statements for their accounts. Employees must report new authorized brokerage accounts to the Compliance Department within thirty (30) days of funding the account. Note: Employees may not trade in the new account prior to reporting the account. Any brokerage account opened to facilitate cryptocurrency trading is a reportable account under the Code and must be held with an approved designated broker. |
10.4. | Quarterly Account and Transaction Reports. Employees are required to submit a report listing their securities transactions made during the previous quarter within 30 days of the end of each calendar quarter. |
10.5. | Annual Holdings Report. Employees are required to submit a report listing all securities held as of December 31 of the year reported within 30 days of the end of the calendar year. The holdings reports must be current as of a date not more than 45 days prior to the date the report is submitted. |
10.6. | Information to be Reported. Employees are required to provide the following information when submitting reports as required by 10.2. through 10.5., above: |
10.7. | Initial and Annual Holdings Reports must include the: |
| title or description and type of security, the exchange ticker symbol or CUSIP number, the number of shares or principal amount of each security; |
| broker-dealer or bank where accounts are held; and |
| date the report is submitted. |
10.8. | Quarterly Transaction Reports must include the: |
| title or description and type of security, the exchange ticker symbol or CUSIP number, the number of shares and principal amount of each security (as well as the interest rate and maturity date, if applicable); |
| trade date and type of transaction (i.e., buy, sell, open, close, etc.): |
| price of the security; |
| broker-dealer or bank account through which the transaction was affected; and |
| date the report is submitted. |
All reports, other than the Initial Disclosure of Personal Holdings, shall be made via the vendor system, which can be accessed at: Protegent PTA.
11. | Transactions in Shares of Open-End Funds |
The following restrictions and requirements apply to all purchases and sales of shares of open-end funds advised or sub-advised by the Voya Entities other than money market and short-term bond funds (Voya Advised Shares) and all holdings of Voya Advised Shares by Covered Persons, including those in which they have a beneficial ownership interest, except as provided below.
These restrictions and requirements do not apply to purchases of Voya Advised Shares through (1) an automatic dividend reinvestment plan; or (2) through any other automatic investment plan, automatic payroll deduction plan, or other automatic plan approved by the Voya IM Compliance Department.
11.1. | Compliance with Prospectus |
All transactions in shares of open-end funds advised or sub-advised by the Voya Entities must be in accordance with the policies and procedures set forth in the Prospectus and Statement of Additional Information for the relevant fund, including but not limited to the funds policies and procedures relating to short term trading and forward pricing of securities.
11.2. | Additional Restrictions |
Certain Covered Persons may be considered insiders to a closed-end fund advised or sub-advised by the Voya Entities. In such cases, these persons will be notified of their status as well as advised of additional restrictions imposed on them and their ability to transact in such closed-end fund.
Solely to facilitate compliance with timely Form 4 and 5 filing requirements with the Securities and Exchange Commission, all such insiders must submit a written report of any transaction involving the closed-end fund on the trade date of such transaction to the Voya IM Compliance Department.
12. | Voya IM Gift & Entertainment Policy |
As a general rule, an Employee should not give or accept an inappropriate or significant gift or entertainment to/from a third party that has any business dealings with Voya Financial. The following provides guidelines related to the giving or acceptance of gifts, entertainment or non-cash compensation by Voya IM employees. All Voya IM employees who are also FINRA registered representatives are, to the extent they are conducting business on behalf of a Voya IM broker-dealer, also subject to the requirements of the FINRA. (Note: those requirements are described more fully in the appropriate broker-dealer Compliance Manual).
This Policy should be read in conjunction with the Voya Financial Conflicts of Interest Policy.
12.1. | Nominal Business Gifts and Business Entertainment |
Giving or receiving gifts in a business setting may give rise to an appearance of impropriety or raise a potential conflict of interest. It could also, depending on facts and circumstances, qualify as paying or receiving non-cash compensation for a testimonial or endorsement under Rule 206(4)-1. As a general rule, employees should not give to or accept from a third party (e.g., client, broker, or vendor) any gift or gratuity. However, gifts less than $100 per year per person as well as occasional, normal and customary meals and/or business entertainment (where the person providing the entertainment is present) that on a fair market value basis does not exceed $300 per incident or $1,000 per year, the cost of which would be paid for by Voya IM as a reasonable business expense if not paid for by the third party, and which is not given or accepted in exchange for a testimonial or endorsement, are permitted. Any gifts or entertainment in excess of these limits should be declined or returned.
Ultimately, except for personal gifts explained more fully below, gifts or entertainment must have a clear connection with Voya IMs business and are not permitted if an independent third party might think that the employee would be influenced in conducting business or might otherwise provide an endorsement of that third party. Any gift or entertainment given or received in connection with Voya IM giving or receiving a testimonial or endorsement will qualify as a paid testimonial or endorsement under Rule 206(4)-1. While gifts and entertainment under $1,000 are considered de minimis compensation and testimonials/endorsements given for de minimis compensation are exempt from some of the provisions of Rule 206(4)-1, such arrangements with third parties are still subject to adviser oversight and required disclosures. Employees should seek prior approval from the Legal and Compliance Departments prior to engaging in a testimonial or endorsement arrangement.
Family members (including domestic partners) of Employees are not permitted to accept fees, gifts, entertainment, invitations to seminars/conferences, payments or other favors in connection with any business of Voya IM. Any questions should be directed to your supervisor or Compliance Officer, and in the case of FINRA registered representatives conducting business on behalf of a Voya IM broker-dealer, your broker-dealer supervisor.
Employees who plan to gift or entertain anyone affiliated with a public entity, including but not limited to state and municipal pension plans, have a special responsibility to both know and adhere to the policy stated above, and to comply fully with additional policies, procedures, and restrictions placed on such employees by statue statutes, municipal regulations or internal policies. Public entity employees may be under an even more stringent restrictions or outright prohibitions with regard to receipt of meals and entertainment. Any Voya employee seeking to entertain a public entity employee should first check with Compliance/Legal to see what, if any, additional restrictions may apply. Compliance and Legal can assist in determining what such restrictions are prior to the gifting or entertaining of such individuals.
| Gifts |
The following are some guidelines or examples of acceptable gifts.
| An acceptable gift may not exceed a face value of $100 per third party, per year. |
| Purely personal gifts are permissible. Personal gifts are gifts that serve a personal (not business) purpose, are paid by the giver (not the givers employer) and are between close friends or family members (e.g., gifts that are related to commonly recognized personal events, such as births, promotion, wedding, or retirement). |
| Discounts or rebates on merchandise or services that do not exceed those available to arms length clients. The final total cost or value of goods or services is subject to a $100 limit per third party, per year. |
| Advertising or promotional items with a value of not more than $100 per third party, per year. |
| Business Meals and Entertainment |
| The following are some guidelines regarding acceptable business meals and entertainment: |
| Normal, customary, and occasional business meals or entertainment where the meal or entertainment takes place in one event and the person providing the entertainment is present. A good test is whether Voya IM would consider such an expense reasonable, if not paid for by a third party. Also, a good rule of thumb is whether an employee can eat, drink, or enjoy the entertainment in one sitting. |
| Business meals and entertainment should be consistent with FINRA guidance and advice. As such, the total fair market value of the event may not exceed $300 per employee, per event, subject to an annual maximum amount of $1,000 per third party. Exceptions to these limits may be granted but must be pre-approved by Compliance and the employees MC representative. |
| Entertainment, such as tickets to sporting events, golf fees, or ski lift tickets, will be evaluated based on the published ticket price. Again, in all cases both the giver and the recipient must be present. |
| The cost of local transportation does not count towards the $300 per event/$1,000 annual limit, provided that the mode of transportation must be reasonable. Any travel and lodging related to the event should be paid for by Voya IM subject to the Voya IM Travel and Expenses policies and procedures |
Any exceptions to the above guidelines must be approved by the employees manager and MC representative prior to acceptance.
13. | Outside Business Activities |
13.1. | Outside Business Interests and Private Investments |
All employees are required to devote their full time and efforts to the business of Voya IM. You are not to maintain outside employment activities that compromise job performance or interfere with your regular duties. In addition, no person may make use of either his or her position as an employee or information acquired during employment or make personal investments in a manner that may create a conflict, or the appearance of a conflict, between the employees personal interests and the interests of Voya IM.
To assist in ensuring that such conflicts are avoided, an employee must obtain the written approval of the employees supervisor and the Compliance Department prior to:
| Serving as a director, officer, general partner or trustee of, or as a consultant to, any business, corporation or partnership, including family-owned businesses and charitable, non-profit and political organizations. |
| Serving as a registered representative of any broker-dealer other than VID. |
| Making any monetary investment in any non-publicly traded business, corporation or partnership, including passive investments in private companies. |
| Accepting employment of any kind or engaging in any other business outside of Voya IM. |
| Acting or representing that the employee is acting as agent for Voya IM, an Adviser or any other firm in any investment banking matter or as a consultant or finder. |
| Forming or participating in any stockholders or creditors committee that purports to represent security holders or claimants in connection with a bankruptcy or distressed situation or in becoming actively involved in a proxy contest (see also, 8 Personal Trading Restrictions). |
| Receiving compensation of any nature, directly or indirectly, from any person, firm, corporation, estate, trust or association other than Voya IM, whether as a fee, commission, bonus or other consideration such as stock, options or warrants other than compensation earned prior to commencement of employment with Voya IM. |
Every employee is required to complete a disclosure form on the PTA Compliance site, which can be accessed at Protegent PTA and have such form approved by the employees supervisor and the Compliance Department prior to serving in any of the capacities or making any of the investments described heretofore. Similarly, each employee is required to maintain the data initially disclosed on such form and notify the Compliance Department (and the employees supervisor) in the event of any change to the information provided after initial approval. From time to time, employees may be asked to renew their outside business activity information.
In addition, an employee must advise the Legal Department and his or her supervisor if the employee is or believes that he or she may become a participant, either as a plaintiff, defendant or witness, in any litigation or arbitration that could reasonably relate to the business of Voya IM. Written confirmation of such advice should be obtained from the employees supervisor and the Legal Department.
13.2. | Control Persons of Public Companies |
Every employee must disclose to Voya IM if their spouse or any of their parents, siblings or children (Immediate Family Members) hold a position as a director or executive officer of any public company. Voya IM may, in its sole discretion, place limitations on an employees investment activities in the event an employees Immediate Family Member holds a position as a director or executive officer of any public company. Similarly, each employee is required to maintain the data initially disclosed on such form and notify the Compliance Department (and the employees supervisor) in the event of any change after initial approval.
From time to time, an employee of Voya IM may be offered a position as an executive officer or director of a publicly traded company, which, if accepted, would subject the employee to requirements arising under Section 16 of the 1934 Act (Section 16). Prior to accepting the position, the employee must receive clearance from the Chief Compliance Officer and a member of the Voya
IM senior management team. If the employee is permitted to accept the position, the employee will also be subject to the following procedures:
| Trades for client accounts or funds over which the employee has sole or shared investment discretion must also comply with the publicly traded companys policies and procedures. It is the responsibility of the employee to understand and adhere to such companys reporting requirements. |
| Appropriate disclosure must be provided to affected clients. The disclosure can be provided via offering documents or other communications sent to affected investors. |
| In accordance with Voya IMs policies on confidential information and insider trading, the employee may not, under any circumstances, trade in the companys securitieswhether for personal or client accountsif the employee is in possession of material, non-public information regarding the company. Likewise, material, non-public information regarding the company may not be shared with other Voya IM personnel, other than the Voya IM Legal or Compliance Department. |
13.3. | Political Activity |
While Voya maintains a political action committee, political contributions from Advisers or their respective employees may raise various legal and regulatory issues. Most notably, Rule 206(4)-5 under the Advisers Act prohibits an Adviser from receiving compensation from a government entity for two years if the Adviser or certain employees contributed money to a government official who is in a position to influence the selection of the Adviser to manage a public fund or provide investment advice to a government entity. Also, some states and municipalities may have laws disqualifying an Adviser from managing assets for various governmental entities if the Adviser or certain of its representatives have made contributions or provided gifts to certain candidates for office. To ensure compliance with these laws and to avoid actual and potential conflicts of interest, Voya IM has adopted the procedures described below, which requires pre-approval by Compliance and the Voya Political Activity Review Committee (PARC) of certain political activities. The activities requiring pre-approval and the procedures for obtaining pre-approval are set out below.
Prior to making any personal contribution (whether it be monetary, or event driven, such as hosting a fundraiser) in an individual capacity to an incumbent or candidate, political party committee or political action committee at the state or local level (including a current state or local government employee running for federal office), all employees of Voya IM must submit a request for approval from Compliance and PARC through the PTA Compliance site, which can be accessed at Protegent PTA.
| All political contributions to a state or local governmental official in an amount equal to or exceeding $150 will also require pre-approval from the employees manager. |
| Personal political activities of employees must be kept separate from employment and any expenses related to these activities may not be charged to an Adviser; personal political contributions will not be reimbursed. Also, employees are not to use Voya IMs facilities (such as telephones and photocopiers) and may not use working hours for political campaign purposes. |
| When acting in a volunteer capacity to a candidate running for office at the state or local level, you must obtain pre-approval from Compliance. All requests must be submitted |
through the PTA Compliance site. For volunteer activity, it is important that your activities cannot be viewed as connected with your position with Voya IM. To the extent that your volunteer activity involves soliciting or fundraising for political contributions, you will also be required to obtain pre-approval from Compliance. |
| Employees should take extra care when soliciting fellow employees to ensure that the solicitation never gives the appearance of being coercive or otherwise related to their employment. |
| Employees who seek or are appointed to any government position, federal, state or local, paid or unpaid, must obtain pre-approval from Compliance of such activity to ensure compliance with applicable conflict of interest laws. All requests must be submitted through the PTA Compliance site. |
| Employees may not engage in any lobbying activities on behalf of Voya IM or any affiliated entity without prior approval from Compliance. Please contact the Compliance Department if you are not sure whether your activities would be considered lobbying. |
The use of an Advisers funds in connection with an election is generally prohibited by law. In order to avoid any allegations of impropriety, it is Voya IMs policy that its funds may not be contributed to federal, state or local election campaigns. Any exception to this item, such as requests for company support of political events, political candidates and their campaigns, political parties or political action committees, must be pre-approved by Compliance. All requests must be submitted through the PTA Compliance site, which can be accessed at Protegent PTA.
| Employee participation in the Voya political action committee is strictly voluntary. |
| Gifts to government officials, including entertainment and meals, are generally prohibited. |
| State and local laws dealing with campaign fund raising vary from jurisdiction to jurisdiction. Some laws expressly prohibit government officials from contracting, on behalf of their political organizations, with any firm(s) whose employees have made a donation to that officials political campaign. |
Voya IM employees are required to complete a Political Contribution/Activity Certification on a quarterly basis. Please note that Compliance will keep necessary records based on the information gathered, in compliance with SEC Rule 204-2.
Note: all references to employees in this Section also apply to an employees Immediate Family Members.
Code of Ethics Guide Securities Transactions Matrix
Type of Security |
Pre-Clearance |
Reporting |
Holding Period | |||
Covered Securities Transactions for Pre-Clearance | ||||||
Individual Stocks | Yes | Yes | 60 calendar days from purchase | |||
Bonds | Yes | Yes | 60 calendar days from purchase | |||
Closed-End Funds, including closed-end funds advised or sub-advised by the Voya Entities | Yes | Yes | 60 calendar days from purchase | |||
Preferred Stock | Yes | Yes | 60 calendar days from purchase | |||
Exchange Traded Funds (ETFs) | Yes | Yes | 30 calendar days from purchase | |||
Exchange Traded Notes (ETNs) | Yes | Yes | 60 calendar days from purchase | |||
Structured Notes | Yes | Yes | 60 calendar days from purchase | |||
Derivatives on an individual stock | Yes | Yes | 60 calendar days from purchase | |||
Derivatives on an Exchange Traded Fund | Yes | Yes | 30 calendar days from purchase | |||
Transactions involving Voya securities, including the Voya Company Stock Fund in Voyas 401(k) plan accounts | Yes | Yes | 60 calendar days from purchase | |||
Sales of Voya performance shares acquired from a vesting (other than the immediate sale upon vesting) | Yes | Yes | N/A | |||
Sales of Restricted Stock | Yes | Yes | N/A | |||
Sales of stock acquired via Stock Purchase Plans including sales of Voya stock acquired through Voyas Stock Purchase Plan | Yes | Yes | N/A | |||
Private Investments and Outside Activities | ||||||
Private Placements | Yes | Yes | N/A | |||
Outside Activities | Yes | Yes | N/A |
Type of Security |
Pre-Clearance |
Reporting |
Holding Period | |||
Transactions Exempt from Pre-Clearance | ||||||
Direct obligations of the Government of the United States | No | No | N/A | |||
High quality short-term debt instruments
Including: Bankers acceptances, bank certificates of deposit, commercial paper, money market securities and repurchase agreements |
No | No | N/A | |||
Shares of open-end funds advised or sub-advised by the Voya Entities
Including: funds held within the Voya 401(k) |
No | Yes | 30 calendar days from the most recent purchase date of the relevant fund | |||
Shares of open-end funds that are not managed by the Voya Entities | No | No | N/A | |||
Managed or discretionary accounts | No | Yes | N/A | |||
Incentive compensation plan sponsored by the Voya Entities | No | Yes | N/A | |||
Automatic dividend reinvestment plan, automatic payroll deduction, etc.
Excluding: Self Directed Brokerage |
No | Yes | N/A | |||
Bitcoin or other cryptocurrencies | No | No | N/A | |||
Exercise of pro-rata rights issued by a company to all the holders of a class of its securities | No | Yes | N/A | |||
On any given day, transactions involving 100 shares or less (per account) of common stock issued by companies included in the S&P 500 Index | No | Yes | 60 calendar days from purchase | |||
On any given day, transactions involving 100 shares or less (per account) of Exchange-Traded Funds. | No | Yes | 30 calendar days from purchase |
Type of Security |
Pre-Clearance |
Reporting |
Holding Period | |||
Penny stocks | No | Yes | 60 calendar days from purchase | |||
Options on an index | No | Yes | N/A | |||
Interval closed-end funds | No | Yes | 60 calendar days from purchase | |||
Prohibited Investments | ||||||
Short sales of Voya Financial common stock | ||||||
Hedging or other transactions involving options
Including: exchange-traded options, puts, calls, forward contracts or other derivatives involving Voya Financial securities
Excluding: stock awards granted under any Voya Financial incentive plan | ||||||
Trading in securities issued by Voya during the Closed Period for Voya Financial Instruments | ||||||
Initial Public Offerings | ||||||
Initial Coin Offerings | ||||||
Borrowing Money from Clients/Suppliers |
Other Key Reminders |
Employees assigned portfolio management or trading responsibility are prohibited from knowingly buying or selling the same security traded in an associated client account for a period of 15 days (7 days prior to the client trade and 7 days after the client trade) |
Approvals for U.S. Securities are effective until the close of business on the day that pre-clearance request is approved.
Approvals for foreign securities are effective until the close of business on the business day following pre-clearance approval. |