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 |
Ticker Symbol |
SEMI |
3 | |
3 | |
3
| |
4 | |
4
| |
7 | |
9
| |
9 | |
9
| |
9 | |
10 | |
10 | |
10
| |
11 | |
15
| |
16 | |
20
| |
22 | |
23
| |
24 | |
24
| |
25 | |
25
| |
26 | |
26
| |
28 | |
28
| |
29 | |
31 | |
32 |
Annual Fund Operating Expenses (expenses that you
pay each year as a percentage of the value of your investment) | |
Management fees(a) |
[_____] % |
Distribution and/or service (12b-1) fees |
[_____] % |
Other expenses |
[_____] % |
Total annual Fund operating expenses |
[_____] % |
Less: Fee waivers and/or expense reimbursements |
[_____] % |
Total annual Fund operating expenses after fee waivers and/or expense reimbursements |
[_____] % |
|
1 year |
3 years |
5 years |
10 years |
|
$[_____] |
$[_____] |
$[_____] |
$[_____] |
Year by Year Total Return (%) as of December 31 Each Year |
Best and Worst Quarterly Returns
During the Period Shown in the Bar Chart |
||
![]() |
Best |
[_____] |
— |
Worst |
[_____] |
— |
|
Inception Date |
1 Year |
Life of Fund |
|
At NAV |
03/29/2022 |
|
|
|
returns before taxes |
|
— |
— |
|
returns after taxes on distributions |
|
— |
— |
|
returns after taxes on distributions and sale of Fund shares |
|
— |
— |
|
S&P Global 1200® Information Technology Index (Net) (reflects reinvested dividends net of withholding taxes but reflects no deductions for fees, expenses or other taxes) |
|
— |
— |
|
MSCI ACWI (Net) (reflects reinvested dividends net of withholding taxes but reflects no
deductions for fees, expenses or other taxes) |
|
— |
— |
|
S&P 500® Index (reflects no deductions for fees, expenses or taxes) |
|
— |
— |
|
PHLX Semiconductor Sector Index (reflects no deductions for
fees, expenses or taxes) |
|
— |
— |
|
Portfolio Management |
Title |
Role with Fund |
Managed Fund Since |
Rahul Narang |
Senior Portfolio Manager |
Lead
Portfolio Manager |
August 2024 |
Portfolio Implementation |
Title |
Role with Fund |
Managed Fund Since |
Christopher Lo, CFA |
Senior Portfolio Manager |
Implementation Portfolio Manager |
2022 |
Columbia Select Technology ETF | |
|
[_____]% |
Portfolio Management |
Title |
Role with Fund |
Managed Fund Since |
Rahul Narang |
Senior Portfolio Manager |
Lead
Portfolio Manager |
August 2024 |
Portfolio Implementation |
Title |
Role with Fund |
Managed Fund Since |
Christopher Lo, CFA |
Senior Portfolio Manager |
Implementation Portfolio Manager |
2022 |
Declaration and Distribution Schedule
| |
Declarations |
Annually |
Distributions |
Annually |
Columbia ETF Trust I |
Columbia Diversified Fixed Income Allocation ETF: DIAL |
Columbia International Equity Income ETF: INEQ |
Columbia Multi-Sector Municipal Income ETF: MUST |
Columbia Research Enhanced Core ETF: RECS |
Columbia Research Enhanced Real Estate ETF: CRED |
Columbia Research Enhanced Value ETF: REVS |
Columbia Select Technology ETF: SEMI |
Columbia Short Duration Bond ETF: SBND |
Columbia Short Duration High Yield ETF: HYSD |
Columbia U.S. Equity Income ETF: EQIN |
Columbia U.S. High Yield ETF: NJNK |
Columbia ETF Trust II |
Columbia EM Core ex-China ETF: XCEM |
Columbia India Consumer ETF: INCO |
Columbia Research Enhanced Emerging Economies ETF: ECON |
Trust, Fund Name and Fiscal Year End: |
|
Columbia ETF Trust I - October 31 |
|
Columbia Diversified Fixed Income Allocation ETF Columbia International Equity Income ETF Columbia Multi-Sector Municipal Income ETF Columbia Research Enhanced Core ETF Columbia Research Enhanced Value ETF Columbia Select Technology ETF Columbia Short Duration Bond ETF Columbia U.S. Equity Income ETF |
|
Columbia ETF Trust I - December 31 |
|
Columbia Research Enhanced Real Estate ETF |
|
Columbia ETF Trust II - March 31 |
|
Columbia EM Core ex-China ETF Columbia India Consumer ETF Columbia Research Enhanced Emerging Economies ETF |
|
2 | |
7 | |
10 | |
16 | |
16
| |
53 | |
88
| |
88 | |
90 | |
90 | |
95
| |
96 | |
97
| |
97 | |
98
| |
98 | |
99
| |
100 | |
105
| |
105 | |
106
| |
109 | |
109
| |
123 | |
127 | |
127 | |
130
| |
132 | |
132
| |
134 | |
134
| |
134 | |
136
| |
138 | |
138
| |
139 | |
141 | |
141 | |
148
| |
150 | |
151 | |
165 | |
170 | |
171 | |
171
| |
172 | |
A-1 | |
B-1 |
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 |
Active Fund(s) |
Funds that are actively managed and do not seek to replicate the performance of a specified index. As of the date of this SAI, the following
Columbia ETFs are Active Funds: Columbia International Equity Income
ETF, Columbia Select Technology ETF, Columbia Short Duration High
Yield ETF, Columbia U.S. Equity Income ETF, and Columbia U.S. High
Yield ETF. |
Administrator |
The Bank of New York Mellon or BNY Mellon |
Administrative Services Agreement |
The Fund Administration and Accounting Agreement, as amended, if applicable, between a Trust, on behalf of its Funds, and the Administrator |
Advisers Act |
Investment Advisers Act of 1940, as amended |
Ameriprise Financial |
Ameriprise Financial, Inc. |
Authorized Participant |
A broker-dealer or other participant in the Continuous Net Settlement System of the National Securities Clearing Corporation (NSCC) or a participant in DTC with access to the DTC system, and who has executed an agreement with the Distributor that governs transactions in the Funds’
Creation Units |
Balancing Amount |
An amount equal to the difference between the NAV of a Creation Unit and the market value of the In-Kind Creation (or Redemption) Basket, used to ensure that the NAV of a Fund Deposit (or Redemption) (other than the Transaction Fee) is identical to the NAV of the Creation Unit being purchased |
Board |
A Trust’s Board of Trustees |
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. |
Cash Component |
An amount of cash, including a Transaction Fee, calculated in connection with creations |
Cash Redemption Amount |
An amount of cash, including a Transaction Fee, calculated in connection with redemptions |
CEA |
Commodity Exchange Act |
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), ALPS Distributors, Inc. and/or any sub-adviser, as applicable, pursuant to Rule 17j-1 under the 1940 Act |
CET I |
Columbia ETF Trust I |
CET II |
Columbia ETF Trust II |
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 |
Creation Unit |
An aggregation or block of shares that each Fund issues and redeems on a continuous basis at NAV. Shares will not be issued or redeemed except in Creation Units, which can vary by size (number of Shares) from Fund to
Fund. A Fund’s Creation Unit size is disclosed in its
prospectus. |
Custodian |
BNY Mellon |
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 |
ALPS Distributors, Inc. |
DTC |
Depository Trust Company |
Exchange |
NYSE Arca, Inc. |
FDIC |
Federal Deposit Insurance Corporation |
FHLMC |
The Federal Home Loan Mortgage Corporation |
FINRA |
Financial Industry Regulatory Authority |
Fitch |
Fitch Ratings, Inc. |
FNMA |
Federal National Mortgage Association |
Foreign Funds |
Collectively, Columbia International Equity Income ETF and each series of
CET II |
The Fund(s) or a Fund |
One or more of the ETFs listed on the front cover of this SAI |
Fund Deposit |
The In-Kind Creation Basket and Cash Component necessary to purchase a Creation Unit from a Fund |
Fund Redemption |
The In-Kind Redemption Basket and Cash Redemption Amount received in connection with the redemption of a Creation Unit |
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 |
IIV or Intraday Indicative Value |
An approximate per-share value of a Fund’s portfolio, disseminated every
fifteen seconds throughout the trading day by the Exchange or other
information providers |
In-Kind Creation Basket |
Basket of securities or other instruments to be deposited to purchase Creation Units of a Fund |
In-Kind Redemption Basket |
Basket of securities or other instruments received upon redemption of a Creation Unit |
Independent Trustees |
The Trustees of the Board who are not “interested persons” (as defined
in the 1940 Act) of the Funds |
Index |
The index identified in an Index Fund’s prospectus, the performance of
which the Fund seeks to track |
Index Fund(s) |
Index-based ETFs that seek to track the performance of a specified index; each series of CET I and CET II are Index Funds other than those identified as Active Funds in the definition of "Active Funds" above. |
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 Management Services Agreement |
The Investment Management Services Agreement, as amended, if applicable, between a Trust, on behalf of its Funds, and the Investment Manager |
Investment Manager |
Columbia Management Investment Advisers, LLC |
IRS |
United States Internal Revenue Service |
LIBOR |
London Inter-bank Offered Rate |
Moody’s Ratings |
Moody’s Investors Service, Inc. |
NASDAQ |
National Association of Securities Dealers Automated Quotations system |
NAV |
Net asset value per share of a Fund |
Non-Indexed Fund(s) |
A Fund that is not an Index Fund (and therefore is actively managed), but
like an Index Fund discloses its portfolio holdings each Business Day
(unlike a Semi-Transparent Fund, which does not disclose its
portfolio holdings each Business Day). Each of the following Funds
is a Non- Indexed Fund: Columbia International Equity Income ETF,
Columbia Select Technology ETF, Columbia Short Duration High Yield
ETF, Columbia U.S. Equity Income ETF and Columbia U.S. High Yield
ETF. |
Fund Name: |
Referred to as: |
Columbia Diversified Fixed Income Allocation ETF |
Diversified Fixed Income Allocation ETF |
Columbia EM Core ex-China ETF |
EM Core ex-China ETF |
Columbia India Consumer ETF |
India Consumer ETF |
Columbia International Equity Income ETF |
International Equity Income ETF |
Columbia Multi-Sector Municipal Income ETF |
Multi-Sector Municipal Income ETF |
Columbia Research Enhanced Core ETF |
Research Enhanced Core ETF |
Columbia Research Enhanced Emerging Economies ETF |
Research Enhanced Emerging Economies ETF |
Columbia Research Enhanced Real Estate ETF |
Research Enhanced Real Estate ETF |
Columbia Research Enhanced Value ETF |
Research Enhanced Value ETF |
Columbia Select Technology ETF |
Select Technology ETF |
Columbia Short Duration Bond ETF |
Short Duration Bond ETF |
Columbia Short Duration High Yield ETF |
Short Duration High Yield ETF |
Columbia U.S. Equity Income ETF |
U.S. Equity Income ETF |
Columbia U.S. High Yield ETF |
U.S. High Yield ETF |
Fund |
Fiscal Year End |
Prospectus Date |
Date Began Operations |
Diversified* |
Fund Investment Category** |
Diversified Fixed Income Allocation
ETF |
October 31 |
[2/28/2025] |
10/12/2017 |
Yes |
Fixed Income |
EM Core ex-China ETF |
March 31 |
8/1/2024 |
9/2/2015 |
No |
Equity |
India Consumer ETF |
March 31 |
8/1/2024 |
8/10/2011 |
No |
Equity |
International Equity Income ETF |
October 31 |
[2/28/2025] |
6/13/2016 |
Yes |
Equity |
Multi-Sector Municipal Income ETF |
October 31 |
[2/28/2025] |
10/10/2018 |
Yes |
Fixed Income |
Research Enhanced Core ETF |
October 31 |
[2/28/2025] |
9/25/2019 |
Yes |
Equity |
Research Enhanced Emerging
Economies ETF |
March 31 |
8/1/2024 |
9/14/2010 |
No |
Equity |
Research Enhanced Real Estate ETF |
December 31 |
5/1/2024 |
4/26/2023 |
No |
Equity |
Research Enhanced Value ETF |
October 31 |
[2/28/2025] |
9/25/2019 |
Yes |
Equity |
Select Technology ETF |
October 31 |
[2/28/2025] |
3/29/2022 |
No |
Equity |
Short Duration Bond ETF |
October 31 |
[2/28/2025] |
9/21/2021 |
No |
Fixed Income |
Short Duration High Yield ETF |
March 31 |
8/27/2024 |
9/5/2024 |
No |
Fixed Income |
U.S. Equity Income ETF |
October 31 |
[2/28/2025] |
6/13/2016 |
Yes |
Equity |
U.S. High Yield ETF |
March 31 |
8/27/2024 |
9/5/2024 |
No |
Fixed Income |
Fund |
Effective Date of Name Change |
Previous Fund Name |
International Equity Income ETF |
June 1, 2024
October 14, 2022 |
Columbia International ESG Equity Income ETF
Columbia Sustainable International Equity Income ETF |
Research Enhanced Emerging Economies ETF |
June 28, 2024 |
Columbia Emerging Markets Consumer ETF |
Select Technology ETF |
February 28, 2025
August 12, 2024 |
Columbia Semiconductor and Technology ETF
Columbia Seligman Semiconductor and Technology ETF |
U.S. Equity Income ETF |
June 1, 2024 October 14, 2022 |
Columbia U.S. ESG Equity Income ETF Columbia Sustainable U.S. Equity Income ETF |
Fund |
B
Buy or sell
commodities |
C
Issuer
Diversification |
D
Concentrate
in any one
industry |
E
Act as an
underwriter |
F
Lending |
G
Borrowing |
H
Issue senior
securities | |
Diversified Fixed Income Allocation ETF |
A1 |
B1 |
C1 |
D1 |
E1 |
F1 |
G1 |
H1 |
EM Core ex-China ETF |
A2 |
B2 |
C2 |
D2 |
E2 |
F2 |
G2 |
H2 |
India Consumer ETF |
A2 |
B2 |
C2 |
D2 |
E2 |
F2 |
G2 |
H2 |
International Equity Income ETF |
A1 |
B1 |
C1 |
D1 |
E1 |
F1 |
G1 |
H1 |
Multi-Sector Municipal Income ETF |
A1 |
B1 |
C1 |
D3 |
E1 |
F1 |
G1 |
H1 |
Research Enhanced Core ETF |
A1 |
B1 |
C1 |
D3 |
E1 |
F1 |
G1 |
H1 |
Research Enhanced Emerging Economies ETF |
A2 |
B2 |
C2 |
D2 |
E2 |
F2 |
G2 |
H2 |
Research Enhanced Real Estate ETF |
A1 |
B1 |
C2 |
D3 |
E1 |
F1 |
G1 |
H1 |
Research Enhanced Value ETF |
A1 |
B1 |
C1 |
D3 |
E1 |
F1 |
G1 |
H1 |
Select Technology ETF |
A1 |
B1 |
C2 |
D4 |
E1 |
F1 |
G1 |
H1 |
Short Duration Bond ETF |
A1 |
B1 |
C2 |
D3 |
E1 |
F1 |
G1 |
H1 |
Short Duration High Yield ETF |
A1 |
B1 |
C2 |
D5 |
E1 |
F1 |
G1 |
H1 |
U.S. Equity Income ETF |
A1 |
B1 |
C1 |
D1 |
E1 |
F1 |
G1 |
H1 |
U.S. High Yield ETF |
A1 |
B1 |
C2 |
D5 |
E1 |
F1 |
G1 |
H1 |
Type of Investment |
Equity Funds* |
Fixed Income Funds* |
|
Asset Backed Securities |
• |
• |
|
Bank Obligations (Domestic and Foreign) |
• |
• |
|
Collateralized Bond Obligations |
• |
• |
|
Commercial Paper |
• |
• |
|
Common Stock |
• |
• |
|
Convertible Securities |
• |
• |
|
Corporate Debt Securities |
• |
• |
|
Custody Receipts and Trust Certificates |
• |
• |
|
Debt Obligations |
•(a) |
• |
|
Depositary Receipts |
• |
• |
|
Type of Investment |
Equity Funds* |
Fixed Income Funds* |
|
Derivatives |
• |
• |
|
Dollar Rolls |
• |
• |
|
Exchange-Traded Notes |
• |
• |
|
Foreign Currency Transactions |
• |
• |
|
Foreign Securities |
• |
• |
|
Guaranteed Investment Contracts (Funding Agreements) |
• |
• |
|
High-Yield Securities |
• |
• |
|
Illiquid Investments |
• |
• |
|
Inflation Protected Securities |
• |
• |
|
Initial Public Offerings |
• |
• |
|
Inverse Floaters |
• |
• |
|
Investments in Other Investment Companies (Including ETFs) |
• |
• |
|
Listed Private Equity Funds |
• |
• |
|
Money Market Instruments |
• |
• |
|
Mortgage-Backed Securities |
• |
• |
|
Municipal Securities |
• |
• |
|
Participation Interests |
• |
• |
|
Partnership Securities |
• |
• |
|
Preferred Stock |
• |
• |
|
Private Placement and Other Restricted Securities |
• |
• |
|
Real Estate Investment Trusts |
• |
• |
|
Repurchase Agreements |
• |
• |
|
Reverse Repurchase Agreements |
• |
• |
|
Short Sales |
•(b) |
•(b) |
|
Sovereign Debt |
• |
• |
|
Standby Commitments |
• |
• |
|
U.S. Government and Related Obligations |
• |
• |
|
Variable- and Floating-Rate Obligations |
• |
• |
|
Warrants and Rights |
• |
• |
|
Fund |
Assets
(in millions) |
Annual rate at each asset level |
Diversified Fixed Income Allocation ETF(a) |
All assets |
0.28% |
EM Core ex-China ETF(b) |
All assets |
0.16% |
India Consumer ETF(b) |
All assets |
0.75% |
International Equity Income ETF(a) |
All assets |
0.45% |
Multi-Sector Municipal Income ETF(a) |
All assets |
0.23% |
Research Enhanced Core ETF(a) |
All assets |
0.15% |
Research Enhanced Emerging Economies ETF(b) |
All assets |
0.49% |
Research Enhanced Real Estate ETF(a) |
All assets |
0.33% |
Research Enhanced Value ETF(a) |
All assets |
0.19% |
Select Technology ETF(a) |
All assets |
0.75% |
Short Duration Bond ETF(a) |
All assets |
0.25% |
Short Duration High Yield ETF(a) |
All assets |
0.44% |
U.S. Equity Income ETF(a) |
All assets |
0.35% |
U.S. High Yield ETF(a)
|
All assets |
0.46% |
|
Investment
Advisory Services Fees | ||
|
2024 |
2023 |
2022 |
For Funds with fiscal period ending March 31 | |||
EM Core ex-China ETF |
$746,933 |
$187,924 |
$80,982 |
India Consumer ETF |
953,513 |
577,359 |
709,377 |
Research Enhanced Emerging Economies ETF |
330,084 |
472,770 |
800,775 |
Short Duration High Yield ETF(a)
|
N/A |
N/A |
N/A |
U.S. High Yield ETF(a)
|
N/A |
N/A |
N/A |
|
2023 |
2022 |
2021 |
For Funds with fiscal period ending October 31
| |||
Diversified Fixed Income Allocation ETF |
1,296,624 |
2,559,232 |
2,772,311 |
International Equity Income ETF |
29,536 |
23,648 |
24,201 |
Multi-Sector Municipal Income ETF |
708,182 |
435,109 |
216,791 |
Research Enhanced Core ETF |
214,853 |
63,900 |
85,594 |
Research Enhanced Value ETF |
39,200 |
42,563 |
9,030 |
|
Investment
Advisory Services Fees | ||
|
2023 |
2022 |
2021 |
Select Technology ETF |
$147,802 |
$43,546(b) |
N/A |
Short Duration Bond ETF |
123,483 |
104,781 |
$5,453(c) |
U.S. Equity Income ETF |
162,960 |
93,242 |
20,806 |
For Funds with fiscal period ending December 31
| |||
Research Enhanced Real Estate ETF |
8,267(d) |
N/A |
N/A |
|
|
Other
Accounts Managed (excluding the Fund) |
| ||
Fund |
Portfolio Manager |
Number and type
of account* |
Approximate
Total Net Assets
(excluding the Fund) |
Performance
Based
Accounts** |
Ownership of Fund shares |
India Consumer ETF |
Henry Hom |
7 RICs
12 other accounts |
$1.56 billion
$1.73 million |
None |
None |
Christopher Lo |
12 RICs
12 other accounts |
$13.13 billion
$132.52 million |
None |
None | |
Research Enhanced Emerging Economies ETF |
Henry Hom |
7 RICs
12 other accounts |
$1.75 billion
$1.73 million |
None |
None |
Christopher Lo |
12 RICs
12 other accounts |
$13.32 billion
$132.52 million |
None |
None | |
Short Duration High Yield ETF |
Brett Kaufman(c) |
2 RICs
4 PIVs
35 other accounts |
$98.79 million
$258.23 million
$13.78 billion |
None |
None |
|
Kris Keller(c) |
2 RICs
4 PIVs
33 other accounts |
$98.79 million
$258.23 million
$13.76 billion |
None |
None |
U.S. High Yield ETF |
Daniel DeYoung(c) |
5 RICs
2 PIVs
10 other accounts |
$3.29 billion
$15.10 billion
$469.15 million |
None |
None |
|
David Janssen(c) |
3 RICs
100 other accounts |
$495.05 million
$27.43 million |
None |
None |
For Funds with fiscal year ending October 31 – Information is as of
October 31, 2023, unless otherwise noted | |||||
Diversified Fixed Income Allocation ETF |
David Janssen |
2 RICs
76 other accounts |
$127.83 million
$19.84 million |
None |
$10,001– $50,000(a) |
Gene Tannuzzo |
7 RICs
2 PIVs
13 other accounts |
$12.74 billion
$213.02 million
$1.45 billion |
None |
$50,001– $100,000(a) | |
International Equity Income ETF |
Henry Hom |
7 RICs
9 other accounts |
$971.11 million
$0.90 million |
None |
None |
Christopher Lo |
12 RICs
18 other accounts |
$10.62 billion
$1.42 billion |
None |
None | |
Multi-Sector Municipal Income ETF |
William Callagy |
398 other accounts |
$541.55 million |
None |
$1– $10,000(a) |
Douglas Rangel |
8 RICs
5 other accounts |
$2.94 billion
$69.22 million |
None |
None | |
Catherine
Stienstra(b) |
8 RICs
3 other accounts |
$5.43 billion
$1.75 million |
None |
$50,001– $100,000(a) | |
Research Enhanced Core ETF |
Henry Hom |
7 RICs
9 other accounts |
$747.66 million
$0.90 million |
None |
$1– $10,000(a) |
Christopher Lo |
12 RICs
18 other accounts |
$10.40 billion
$1.42 billion |
None |
$10,001– $50,000(a) | |
Jason Wang |
1 RIC
5 other accounts |
$18.67 million
$2.05 million |
None |
None | |
Research Enhanced Value ETF |
Henry Hom |
7 RICs
9 other accounts |
$958.87 million
$0.90 million |
None |
None |
Christopher Lo |
12 RICs
18 other accounts |
$10.61 billion
$1.42 billion |
None |
None | |
Jason Wang |
1 RIC
5 other accounts |
$229.88 million
$2.05 million |
None |
None | |
Select Technology ETF |
Christopher Lo |
12 RICs
18 other accounts |
$10.60 billion
$1.42 billion |
None |
None |
|
Rahul Narang(d) |
1 RIC 8 other accounts |
$3.54 billion $304.64 million |
None |
None |
|
|
Other
Accounts Managed (excluding the Fund) |
| ||
Fund |
Portfolio Manager |
Number and type
of account* |
Approximate
Total Net Assets
(excluding the Fund) |
Performance
Based
Accounts** |
Ownership of Fund shares |
Short Duration Bond ETF |
David Janssen |
2 RICs
76 other accounts |
$423.85 million
$19.84 million |
None |
$10,001– $50,000(a) |
Gregory Liechty |
6 RICs
8 PIVs
44 other accounts |
$5.36 billion
$1.67 billion
$3.67 billion |
None |
$10,001– $50,000(a) | |
Ronald Stahl |
6 RICs
8 PIVs
54 other accounts |
$5.36 billion
$1.67 billion
$4.65 billion |
None |
$100,001– $500,000(a) | |
U.S. Equity Income ETF |
Henry Hom |
7 RICs
9 other accounts |
$933.56 million
$0.90 million |
None |
$1– $10,000(a) |
Christopher Lo |
12 RICs
18 other accounts |
$10.58 billion
$1.42 billion |
None |
None | |
For Funds with fiscal year ending December 31 – Information is as of
December 31, 2023, unless otherwise noted | |||||
Research Enhanced Real Estate ETF |
Henry Hom |
7 RICs
12 other accounts |
$1.25 billion
$1.54 million |
None |
None |
Christopher Lo |
12 RICs 18 other accounts |
$12.23 billion $1.54 billion |
None |
None |
|
Amounts
Reimbursed | ||
|
2024 |
2023 |
2022 |
For Funds with fiscal period ending March 31 | |||
EM Core ex-China ETF |
$0 |
$0 |
$0 |
India Consumer ETF |
29,866 |
15,895 |
16,614 |
Research Enhanced Emerging Economies ETF |
2,994 |
2,033 |
2,594 |
Short Duration High Yield ETF(a)
|
N/A |
N/A |
N/A |
U.S. High Yield ETF(a)
|
N/A |
N/A |
N/A |
|
2023 |
2022 |
2021 |
For Funds with fiscal period ending October 31
| |||
Diversified Fixed Income Allocation ETF |
0 |
0 |
0 |
International Equity Income ETF |
0 |
0 |
0 |
Multi-Sector Municipal Income ETF |
0 |
0 |
0 |
Research Enhanced Core ETF |
0 |
0 |
0 |
Research Enhanced Value ETF |
0 |
0 |
0 |
Select Technology ETF |
0 |
0(b) |
N/A |
Short Duration Bond ETF |
798 |
0 |
0(c) |
U.S. Equity Income ETF |
0 |
0 |
0 |
For Funds with fiscal period ending December 31
| |||
Research Enhanced Real Estate ETF |
0(d) |
N/A |
N/A |
Name, address, year of birth |
Position held with Subsidiary
and length of service |
Principal occupation during past five years |
Ravi Chandiran Cunnoosamy
Suite 450, 4th Floor,
Barkly Wharf East, Le Caudan Waterfront, Port Louis, Mauritius Born 1971 |
Director since February 2014 |
Business Manager, Trust and Agency Services of Deutsche Bank
since 2011 |
Shahed Ahmad Hoolash Suite 450, 4th Floor, Barkly Wharf East, Le Caudan Waterfront, Port Louis, Mauritius Born 1977 |
Director since
March 2010 |
Head of Corporate Services, Deutsche International Trust Corporation (Mauritius) Limited since 2013; Head of Transaction Management and Client Services, Deutsche International Trust Corporation (Mauritius) Limited (2007 - 2013) |
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 |
163 |
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 |
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;
Trustee of Gerald Rauenhorst
1982 Trusts, since 2020;
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 |
163 |
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 |
163 |
Trustee, New York
Presbyterian Hospital
Board, since 1996;
Director, DR Bank (Audit
Committee, since 2017
and Audit Committee
Chair since November
2023); Director,
Evercore Inc. (Audit
Committee, Nominating
and Governance
Committee) (financial
services company),
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 |
163 |
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 |
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, January
2020-December 2023; Adjunct
Professor of Finance, Bentley
University, January 2018-April
2023; 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 |
161 |
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 |
161 |
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 |
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 Emeritus of Economics and Management, Bentley University, since 2023; Professor of Economics and Management, Bentley University, 1976-2023; Dean, McCallum Graduate School of Business, Bentley University, 1992-2002 |
163 |
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 |
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 |
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 |
163 |
Trustee, Catholic
Schools Foundation,
since 2004 |
Audit, Contracts,
Investment Review
Committee |
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 |
163 |
Director, SpartanNash
Company (food
distributor), since
November 2013 (Chair
of the Board since May
2021); Director,
Aircastle Limited
(aircraft leasing), since
August 2006 (Chair of
Audit Committee);
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 |
161 |
None |
Compliance,
Contracts, Board
Governance, Investment
Review Committee |
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 |
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 |
163 |
Director, CSX
Corporation
(transportation
suppliers); Director,
PayPal Holdings Inc.
(payment and data
processing services);
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 |
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. |
163 |
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 |
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 |
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 |
161 |
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 |
163 |
Former Director, NAPE (National Alliance for Partnerships in Equity) Education Foundation, October 2016-October 2020; Advisory Board, Jennersville YMCA, June 2022-June 2023 |
Audit,
Contracts, Investment
Review Committee |
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 |
President and Principal Executive Officer of the Columbia Funds, since June 2021; Vice President, Columbia Management Investment Advisers, LLC, since April 2015; formerly, Vice President – Head of North America Product, Columbia Management Investment Advisers, LLC, April 2015 – December 2023; President and Principal Executive Officer, Columbia Acorn/Wanger Funds, since July 2021; President, Ameriprise Trust Company, since July 2024 |
163 |
Chairman, Ameriprise Trust Company, since July 2024 (Director since October 2016); Director, Columbia Management Investment Distributors, Inc., since November 2018; former Member of Board of Governors, Columbia Wanger Asset Management, LLC, January 2022 – September 2024 |
None |
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,
Principal Financial Officer
(2009) and Senior Vice
President (2019) |
Senior Vice President and North America Head of Operations &
Investor Services and Member of Board of Governors, Columbia
Management Investment Advisers, LLC, since June 2023 and
January 2024, respectively (previously Senior Vice President and
Head of Global Operations & Investor Services, March 2022 - June
2023, Vice President, Head of North America Operations, and Co-
Head of Global Operations, June 2019 - February 2022 and Vice
President – Accounting and Tax, May 2010 - May 2019); senior
officer of Columbia Funds and affiliated funds, since 2002.
Director, Ameriprise Trust Company, since June 2023; Director,
Columbia Management Investment Services Corp., since
September 2024; Member of Board of Governors, Columbia
Wanger Asset Management, LLC, since October 2024. |
Marybeth Pilat
290 Congress Street Boston, MA 02210
1968 |
Treasurer and Chief Accounting Officer (Principal Accounting Officer) and Principal Financial Officer (2020) |
Vice President – Product Pricing and Administration, Columbia Management Investment Advisers, LLC, since May 2017. |
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 |
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; President, Chief Executive Officer
and Chairman of the Board, Columbia Management Investment
Distributors, Inc., since January 2024, February 2012 and
November 2008, respectively; Chairman of the Board and Director,
TAM UK International Holdings Limited, since July 2021; President
and Chairman of the Board, Columbia Wanger Asset Management,
LLC, since October 2024; formerly Chairman of the Board and
Director, Threadneedle Asset Management Holdings, Sàrl, March
2013 – December 2022 and December 2008 – December 2022,
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). |
Veronica A. Seaman 290 Congress Street Boston, MA 02210 1962 |
Vice President (2025) |
Vice President, Global Operations and Investor Services, since 2010; Director (since 2018), and President (since 2024), Columbia Management Investment Service Corp. |
Fiscal Period |
Audit
Committee |
Compliance
Committee |
Contracts
Committee |
Board
Governance
Committee |
Investment
Review Committee |
For the fiscal year ending March 31, 2024 |
5 |
5 |
5 |
4 |
4 |
For the fiscal year ending October 31, 2023 |
5 |
4 |
5 |
6 |
5 |
For the fiscal year ending December 31, 2023 |
5 |
5 |
5 |
5 |
5 |
|
Batejan |
Blatz |
Carlton |
Carrig |
Connaughton |
Darragh |
Flynn |
Diversified Fixed Income Allocation ETF |
A |
A |
A |
A |
D |
A |
A |
EM Core ex-China ETF |
A |
A |
A |
A |
A |
A |
A |
India Consumer ETF |
A |
A |
A |
A |
A |
A |
A |
International Equity Income ETF |
A |
A |
A |
A |
A |
A |
A |
Multi-Sector Municipal Income ETF |
A |
A |
A |
A |
A |
A |
A |
Research Enhanced Core ETF |
A |
A |
A |
A |
A |
A |
A |
Research Enhanced Emerging Economies ETF |
D |
A |
A |
A |
A |
A |
A |
Research Enhanced Real Estate ETF |
A |
A |
A |
A |
A |
A |
A |
Research Enhanced Value ETF |
A |
A |
A |
A |
A |
A |
A |
Select Technology ETF |
A |
A |
A |
A |
C |
A |
A |
Short Duration Bond ETF |
A |
A |
A |
A |
A |
A |
A |
Short Duration High Yield ETF |
A |
A |
A |
A |
A |
A |
A |
U.S. Equity Income ETF |
A |
A |
A |
A |
A |
A |
A |
U.S. High Yield ETF |
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) |
|
Gallagher |
Hacker |
Lukitsh |
Moffett |
Paglia |
Trunow |
Yeager |
Diversified Fixed Income Allocation ETF |
A |
A |
A |
A |
A |
A |
A |
EM Core ex-China ETF |
A |
A |
A |
A |
C |
A |
A |
India Consumer ETF |
A |
A |
A |
A |
C |
A |
A |
International Equity Income ETF |
A |
A |
A |
A |
A |
A |
A |
Multi-Sector Municipal Income ETF |
A |
A |
A |
A |
A |
A |
A |
Research Enhanced Core ETF |
A |
A |
A |
A |
C |
A |
A |
Research Enhanced Emerging Economies ETF |
A |
A |
A |
A |
A |
A |
A |
Research Enhanced Real Estate ETF |
A |
A |
A |
A |
A |
A |
A |
Research Enhanced Value ETF |
A |
A |
A |
A |
A |
A |
A |
Select Technology ETF |
A |
A |
A |
A |
C |
A |
A |
Short Duration Bond ETF |
A |
A |
A |
A |
A |
A |
A |
Short Duration High Yield ETF |
A |
A |
A |
A |
A |
A |
A |
U.S. Equity Income ETF |
A |
A |
A |
A |
A |
A |
A |
U.S. High Yield ETF |
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) |
|
Beckman |
Diversified Fixed Income Allocation ETF |
B |
EM Core ex-China ETF |
A |
India Consumer ETF |
A |
International Equity Income ETF |
C |
Multi-Sector Municipal Income ETF |
A |
Research Enhanced Core ETF |
C |
Research Enhanced Emerging Economies ETF |
A |
Research Enhanced Real Estate ETF |
A |
Research Enhanced Value ETF |
C |
Select Technology ETF |
C |
Short Duration Bond ETF |
A |
Short Duration High Yield ETF |
A |
U.S. Equity Income ETF |
C |
U.S. High Yield ETF |
A |
Aggregate Dollar Range of Equity Securities in all Funds in the
Columbia Funds Complex Overseen by the Trustee |
E(a) |
Trustees |
Amount Deferred
from Total Compensation(b) | |
George S. Batejan |
$451,500 |
$22,575 |
Kathleen Blatz |
$461,500 |
$0 |
Pamela G. Carlton |
$560,000 |
$13,750 |
Janet Langford Carrig |
$464,500 |
$464,500 |
J. Kevin Connaughton |
$466,500 |
$0 |
Olive M. Darragh |
$452,250 |
$90,450 |
Patricia M. Flynn |
$436,500 |
$0 |
Brian J. Gallagher |
$476,250 |
$185,750 |
Douglas A. Hacker |
$447,750 |
$0 |
Nancy T. Lukitsh |
$451,250 |
$0 |
David M. Moffett |
$437,750 |
$0 |
Catherine James Paglia |
$447,750 |
$0 |
Natalie A. Trunow |
$437,750 |
$218,875 |
Sandra L. Yeager |
$465,250 |
$232,625 |
Trustees |
Estimated Total Cash
Compensation from the
Columbia Funds
Complex To Be Paid to
Trustee for Fiscal Year
Ended 2025 |
Estimated Amount to be Deferred from Total Compensation |
George S. Batejan |
$241,167 |
$12,058 |
Kathleen Blatz |
$235,000 |
$0 |
Pamela G. Carlton |
$320,833 |
$32,083 |
Janet Langford Carrig |
$235,000 |
$235,000 |
J. Kevin Connaughton |
$238,000 |
$0 |
Olive M. Darragh |
$229,000 |
$45,800 |
Patricia M. Flynn |
$220,167 |
$0 |
Brian J. Gallagher |
$241,417 |
$0 |
Douglas A. Hacker |
$229,417 |
$0 |
Nancy T. Lukitsh |
$229,417 |
$0 |
David M. Moffett |
$229,167 |
$0 |
Catherine James Paglia |
$229,417 |
$0 |
Natalie A. Trunow |
$229,167 |
$114,583 |
Sandra L. Yeager |
$247,000 |
$123,500 |
Fund |
Aggregate Compensation from Fund
Independent Trustees | ||||||
Hacker |
Lukitsh |
Moffett(a) |
Paglia(b) |
Shaw(c) |
Trunow(d) |
Yeager(e) | |
For Funds with fiscal period ending March 31
| |||||||
EM Core ex-China ETF |
$1,246 |
$1,282 |
$1,243 |
$1,247 |
N/A |
$1,244 |
$1,297 |
Amount Deferred |
$0 |
$0 |
$0 |
$0 |
N/A |
$622 |
$649 |
India Consumer ETF |
$977 |
$1,007 |
$977 |
$978 |
N/A |
$977 |
$1,017 |
Amount Deferred |
$0 |
$0 |
$0 |
$0 |
N/A |
$488 |
$508 |
Research Enhanced Emerging Economies ETF |
$935 |
$964 |
$935 |
$935 |
N/A |
$935 |
$973 |
Amount Deferred |
$0 |
$0 |
$0 |
$0 |
N/A |
$468 |
$486 |
Short Duration High Yield ETF(f)
|
$489 |
$489 |
$488 |
$489 |
N/A |
$488 |
$526 |
Amount Deferred |
$0 |
$0 |
$0 |
$0 |
N/A |
$244 |
$263 |
|
Total Brokerage
Commissions | ||
Fund |
2024 |
2023 |
2022 |
For Funds with fiscal period ending March 31 | |||
EM Core ex-China ETF |
$648,283 |
$36,484 |
$19,373 |
India Consumer ETF |
56,228 |
12,208 |
24,012 |
Research Enhanced Emerging Economies ETF |
25,348 |
28,840 |
45,911 |
Short Duration High Yield ETF(a)
|
N/A |
N/A |
N/A |
U.S. High Yield ETF(a)
|
N/A |
N/A |
N/A |
|
Brokerage
directed for research | |
Fund |
Amount of
Transactions |
Amount of
Commissions Imputed or Paid |
For Funds with fiscal period ending March 31 | ||
EM Core ex-China ETF |
$0 |
$0 |
India Consumer ETF |
0 |
0 |
Research Enhanced Emerging Economies ETF |
0 |
0 |
Short Duration High Yield ETF(a)
|
N/A |
N/A |
U.S. High Yield ETF(a)
|
N/A |
N/A |
For Funds with fiscal period ending October 31
| ||
Diversified Fixed Income Allocation ETF |
0 |
0 |
International Equity Income ETF |
0 |
0 |
Multi-Sector Municipal Income ETF |
0 |
0 |
Research Enhanced Core ETF |
0 |
0 |
Research Enhanced Value ETF |
0 |
0 |
Select Technology ETF |
4,962,315 |
1,227 |
Short Duration Bond ETF |
0 |
0 |
U.S. Equity Income ETF |
0 |
0 |
For Funds with fiscal period ending December 31
| ||
Research Enhanced Real Estate ETF(b)
|
0 |
0 |
Fund |
Issuer |
Value of securities owned at end of fiscal period |
For Funds with fiscal period ending March 31, 2024
| ||
EM Core ex-China ETF |
None |
N/A |
India Consumer ETF |
None |
N/A |
Research Enhanced Emerging Economies ETF |
None |
N/A |
Short Duration High Yield ETF(a)
|
N/A |
N/A |
Fund |
Issuer |
Value of securities owned at end of fiscal period |
U.S. High Yield ETF(a)
|
N/A |
N/A |
For Funds with fiscal period ending October 31, 2023
| ||
Diversified Fixed Income Allocation ETF |
Barclays PLC |
$641,225 |
Citigroup Global Markets |
$466,310 | |
Morgan Stanley |
$491,776 | |
International Equity Income ETF |
None |
N/A |
Multi-Sector Municipal Income ETF |
None |
N/A |
Research Enhanced Core ETF |
Citigroup Global Markets |
$1,078,353 |
Goldman Sachs Group, Inc. (The) |
$1,367,156 | |
J.P. Morgan Securities LLC |
$5,546,269 | |
Morgan Stanley |
$1,173,346 | |
Virtu Americas LLC |
$22,983 | |
Wells Fargo Securities, LLC |
$2,062,234 | |
Research Enhanced Value ETF |
Citigroup Global Markets |
$184,537 |
Goldman Sachs Group, Inc. (The) |
$233,780 | |
J.P. Morgan Securities LLC |
$899,301 | |
Morgan Stanley |
$200,846 | |
Virtu Americas LLC |
$3,975 | |
Wells Fargo Securities, LLC |
$352,959 | |
Select Technology ETF |
None |
N/A |
Short Duration Bond ETF |
Barclays Plc |
$190,864 |
Citigroup, Inc. |
$186,767 | |
Goldman Sachs Group, Inc. (The) |
$78,905 | |
Morgan Stanley |
$117,248 | |
U.S. Equity Income ETF |
None |
N/A |
For Funds with fiscal period ending December 31,
2023 | ||
Research Enhanced Real Estate ETF |
None |
N/A |
Fund |
Standard Transaction Fee |
Maximum Transaction Fee |
Variable Charge |
Diversified Fixed Income Allocation ETF |
$500 |
$2,000 |
Up to 2% |
EM Core ex-China ETF |
$2,000 |
$2,000 |
None |
India Consumer ETF |
$1,000 |
$1,000 |
Fixed $425 (Redemptions Only) |
International Equity Income ETF |
$2,000 |
$8,000 |
None |
Multi-Sector Municipal Income ETF |
$500 |
$2,000 |
Up to 2% |
Research Enhanced Core ETF |
$900 |
$2,000 |
None |
Research Enhanced Emerging Economies ETF |
$1,000 |
$1,000 |
None |
Research Enhanced Real Estate ETF |
$500 |
$2,000 |
None |
Research Enhanced Value ETF |
$650 |
$2,000 |
None |
Select Technology ETF |
$500 |
$2,000 |
None |
Short Duration Bond ETF |
$500 |
$2,000 |
Up to 2% |
Short Duration High Yield ETF |
$500 |
$2,000 |
Up to 2% |
U.S. Equity Income ETF |
$500 |
$2,000 |
None |
U.S. High Yield ETF |
$500 |
$2,000 |
Up to 2% |
Fund |
Total
Capital Loss
Carryovers |
Amount not
Expiring | |
Short-term |
Long-term | ||
For Funds with fiscal period ending March 31
| |||
EM Core ex-China ETF |
$3,119,719 |
$2,020,515 |
$1,099,204 |
Research Enhanced Emerging Economies ETF |
$228,118,226 |
$5,127,837 |
$222,990,389 |
For Funds with fiscal period ending October 31
| |||
Diversified Fixed Income Allocation ETF |
$90,401,307 |
$54,663,601 |
$35,737,706 |
International Equity Income ETF |
$694,434 |
$0 |
$694,434 |
Multi-Sector Municipal Income ETF |
$3,743,459 |
$1,837,742 |
$1,905,717 |
Research Enhanced Core ETF |
$1,609,773 |
$1,399,574 |
$210,199 |
Research Enhanced Value ETF |
$2,017,333 |
$1,398,321 |
$619,012 |
Select Technology ETF |
$232,838 |
$232,838 |
$0 |
Short Duration Bond ETF |
$2,223,127 |
$1,703,787 |
$519,340 |
U.S. Equity Income ETF |
$708,673 |
$419,408 |
$289,265 |
Name and Address |
Percentage |
CHARLES SCHWAB & CO., INC.
2423 E LINCOLN DRIVE PHOENIX, AZ 85016-1215 |
30.28% |
MORGAN STANLEY SMITH BARNEY LLC 1300 THAMES ST 6TH FLOOR
BALTIMORE, MD 21231 |
15.54% |
NATIONAL FINANCIAL SERVICES LLC
499 WASHINGTON BLVD.
JERSEY CITY, NJ 07310 |
11.21% |
MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED
4804 DEER LAKE DR E JACKSONVILLE, FL 32246 |
10.18% |
LPL FINANCIAL LLC 1055 LPL WAY
FORT MILL, SC 29715 |
7.87% |
Name and Address |
Percentage |
CHARLES SCHWAB & CO., INC.
2423 E LINCOLN DRIVE PHOENIX, AZ 85016-1215 |
19.07% |
NATIONAL FINANCIAL SERVICES LLC
499 WASHINGTON BLVD.
JERSEY CITY, NJ 07310 |
18.43% |
MORGAN STANLEY SMITH BARNEY LLC 1300 THAMES ST 6TH FLOOR
BALTIMORE, MD 21231 |
18.11% |
AMERICAN ENTERPRISE INVESTMENT SERVICES 690 AMERIPRISE FINANCIAL CENTER MINNEAPOLIS, MN 55474 |
5.49% |
Name and Address |
Percentage |
MERRILL LYNCH, PIERCE, FENNER & SMITH INCORPORATED
4804 DEER LAKE DR E JACKSONVILLE, FL 32246 |
21.24% |
MORGAN STANLEY SMITH BARNEY LLC 1300 THAMES ST 6TH FLOOR
BALTIMORE, MD 21231 |
17.66% |
NATIONAL FINANCIAL SERVICES LLC
499 WASHINGTON BLVD.
JERSEY CITY, NJ 07310 |
10.49% |
CHARLES SCHWAB & CO., INC.
2423 E LINCOLN DRIVE PHOENIX, AZ 85016-1215 |
10.01% |
UBS FINANCIAL SERVICES INC.
1000 HARBOR BLVD WEEHAWKEN, NJ 07086 |
5.52% |
BANK OF AMERICA, NA/GWIM TRUST OPERA 1201 MAIN STREET 9TH FLOOR
DALLAS, TX 75202 |
5.29% |
Name and Address |
Percentage |
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
4 CHASE METROTECH CENTER
BROOKLYN, NY 11245 |
36.34% |
AMERICAN ENTERPRISE INVESTMENT SERVICES
690 AMERIPRISE FINANCIAL CENTER
MINNEAPOLIS, MN 55474 |
22.54% |
CHARLES SCHWAB & CO., INC.
2423 E LINCOLN DRIVE PHOENIX, AZ 85016-1215 |
13.52% |
MORGAN STANLEY SMITH BARNEY LLC
1300 THAMES ST 6TH FLOOR
BALTIMORE, MD 21231 |
6.03% |
Name and Address |
Percentage |
LPL FINANCIAL LLC 1055 LPL WAY
FORT MILL, SC 29715 |
29.19% |
NATIONAL FINANCIAL SERVICES LLC
499 WASHINGTON BLVD.
JERSEY CITY, NJ 07310 |
14.27% |
BOFA SECURITIES, INC.
4804 DEER LAKE DR E JACKSONVILLE, FL 32246 |
14.12% |
CHARLES SCHWAB & CO., INC. 2423 E LINCOLN DRIVE
PHOENIX, AZ 85016-1215 |
13.90% |
Name and Address |
Percentage |
GOLDMAN, SACHS & CO.
30 HUDSON STREET PROXY DEPARTMENT JERSEY CITY, NJ 07302 |
9.48% |
J.P. MORGAN SECURITIES LLC 383 MADISON AVENUE NEW YORK, NY 10179 |
6.22% |
Name and Address |
Percentage |
AMERICAN ENTERPRISE INVESTMENT SERVICES
690 AMERIPRISE FINANCIAL CENTER
MINNEAPOLIS, MN 55474 |
34.70% |
CHARLES SCHWAB & CO., INC.
2423 E LINCOLN DRIVE PHOENIX, AZ 85016-1215 |
12.68% |
WELLS FARGO CLEARING SERVICES LLC
2801 MARKET STREET ST. LOUIS, MO 63103 |
11.25% |
NATIONAL FINANCIAL SERVICES LLC
499 WASHINGTON BLVD.
JERSEY CITY, NJ 07310 |
9.20% |
MORGAN STANLEY SMITH BARNEY LLC
1300 THAMES ST 6TH FLOOR
BALTIMORE, MD 21231 |
5.33% |
Name and Address |
Percentage |
LPL FINANCIAL LLC 1055 LPL WAY
FORT MILL, SC 29715 |
20.70% |
BOFA SECURITIES, INC.
4804 DEER LAKE DR E JACKSONVILLE, FL 32246 |
16.28% |
NATIONAL FINANCIAL SERVICES LLC
499 WASHINGTON BLVD.
JERSEY CITY, NJ 07310 |
15.68% |
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
4 CHASE METROTECH CENTER
BROOKLYN, NY 11245 |
10.99% |
AMERICAN ENTERPRISE INVESTMENT SERVICES
690 AMERIPRISE FINANCIAL CENTER
MINNEAPOLIS, MN 55474 |
10.62% |
CHARLES SCHWAB & CO., INC.
2423 E LINCOLN DRIVE PHOENIX, AZ 85016-1215 |
8.97% |
PERSHING LLC
ONE PERSHING PLAZA JERSEY CITY, NJ 07399 |
6.49% |
Name and Address |
Percentage |
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
4 CHASE METROTECH CENTER
BROOKLYN, NY 11245 |
46.60% |
CHARLES SCHWAB & CO., INC. 2423 E LINCOLN DRIVE
PHOENIX, AZ 85016-1215 |
39.58% |
Name and Address |
Percentage |
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION 4 CHASE METROTECH CENTER BROOKLYN, NY 11245 |
89.18% |
Name and Address |
Percentage |
SEI PRIVATE TRUST COMPANY
ONE FREEDOM VALLEY DRIVE
SHORT HILLS, NJ 07078 |
31.94% |
CHARLES SCHWAB & CO., INC.
2423 E LINCOLN DRIVE PHOENIX, AZ 85016-1215 |
28.43% |
LPL FINANCIAL LLC 1055 LPL WAY
FORT MILL, SC 29715 |
15.53% |
NATIONAL FINANCIAL SERVICES LLC 499 WASHINGTON BLVD. JERSEY CITY, NJ 07310 |
10.89% |
Name and Address |
Percentage |
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
4 CHASE METROTECH CENTER
BROOKLYN, NY 11245 |
64.38% |
WELLS FARGO SECURITIES, LLC 1525 WEST W.T. HARRIS BLVD, 1B1 CHARLOTTE, NC 28262 |
18.62% |
Name and Address |
Percentage |
BOFA SECURITIES, INC.
4804 DEER LAKE DR E JACKSONVILLE, FL 32246 |
9.20% |
CHARLES SCHWAB & CO., INC. 2423 E LINCOLN DRIVE
PHOENIX, AZ 85016-1215 |
5.26% |
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 |
Long-Term Rating |
Short-Term Rating |
AAA AA+
AA AA– |
K1+ |
A+ |
K1+ or K1 |
A |
K1 |
A– |
K1 or K2 |
BBB+ |
K2 |
BBB |
K2 or K3 |
BBB– |
K3 |
BB+
BB BB–
B+ B
B– |
B |
CCC+ CCC
CCC– CC
C |
C |
D |
D |
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 |
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) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Registration
Statement |
(a) |
8/16/2012 | |
(a)(2) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Pre-Effective
Amendment #1
on Form N-1A |
(a)(2) |
5/31/2016 | |
(a)(3) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #7
on Form N-1A |
(a)(3) |
2/28/2018 | |
(a)(4) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #10
on Form N-1A |
(a)(4) |
7/17/2018 | |
(a)(5) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #15
on Form N-1A |
(a)(5) |
7/26/2019 | |
(a)(6) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #20
on Form N-1A |
(a)(6) |
2/25/2021 | |
(a)(7) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #23
on Form N-1A |
(a)(7) |
9/17/2021 | |
(a)(8) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #23
on Form N-1A |
(a)(8) |
9/17/2021 | |
(a)(9) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #27
on Form N-1A |
(a)(9) |
3/18/2022 | |
(a)(10) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #28
on Form N-1A |
(a)(10) |
12/12/2022 | |
(a)(11) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #32
on Form N-1A |
(a)(11) |
3/31/2023 | |
(a)(12) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #39
on Form N-1A |
(a)(12) |
8/20/2024 | |
(a)(13) |
Filed Herewith |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #40
on Form N-1A |
(a)(13) |
12/19/2024 | |
(b) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #20
on Form N-1A |
(b) |
2/25/2021 | |
(c) |
Stock Certificate:
Not Applicable |
|
|
|
|
|
|
(d)(1) |
Incorporated by Reference |
Columbia ETF Trust I |
333-209996 |
Pre-Effective Amendment #1 on Form N-1A |
(d)(1) |
5/31/2016 |
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 | |||
(d)(1)(i) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #39
on Form N-1A |
(d)(1)(i) |
8/20/2024 | |
(e)(1) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #10
on Form N-1A |
(e)(1) |
7/17/2018 | |
(e)(1)(i) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #10
on Form N-1A |
(e)(1)(i) |
7/17/2018 | |
(e)(1)(ii) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #15
on Form N-1A |
(e)(1)(ii) |
7/26/2019 | |
(e)(1)(iii) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #20
on Form N-1A |
(e)(1)(iii) |
2/25/2021 | |
(e)(1)(iv) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #23
on Form N-1A |
(e)(1)(iv) |
9/17/2021 | |
(e)(1)(v) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #27
on Form N-1A |
(e)(1)(v) |
3/18/2022 | |
(e)(1)(vi) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #31
on Form N-1A |
(e)(1)(vi) |
2/28/2023 | |
(e)(1)(vii) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #32
on Form N-1A |
(e)(1)(vii) |
3/31/2023 | |
(e)(1)(viii) |
Incorporated by Reference |
Columbia ETF Trust I |
333-209996 |
Post-Effective Amendment #37 on Form N-1A |
(e)(1)(viii) |
5/30/2024 |
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 | |||
(e)(1)(ix) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #39
on Form N-1A |
(e)(1)(ix) |
8/20/2024 | |
(f) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #20
on Form N-1A |
(f) |
2/25/2021 | |
(g)(1) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #12
on Form N-1A |
(g)(1) |
2/27/2019 | |
(g)(1)(i) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #14
on Form N-1A |
(g)(1)(i) |
5/15/2019 | |
(g)(1)(ii) |
Incorporated by
Reference |
Columbia ETF
Trust II |
333-155709 |
Post-Effective
Amendment #109
on Form N-1A |
(g)(1)(ii) |
7/26/2019 | |
(g)(1)(iii) |
Incorporated by
Reference |
Columbia ETF
Trust II |
333-155709 |
Post-Effective
Amendment #111
on Form N-1A |
(g)(1)(iii) |
7/28/2020 | |
(g)(1)(iv) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #23
on Form N-1A |
(g)(1)(iv) |
9/17/2021 | |
(g)(1)(v) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #27
on Form N-1A |
(g)(1)(v) |
3/18/2022 | |
(g)(1)(vi) |
Incorporated by
Reference |
Columbia ETF
Trust II |
333-155709 |
Post-Effective
Amendment #115
on Form N-1A |
(g)(1)(vi) |
7/26/2023 | |
(g)(1)(vii) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #39
on Form N-1A |
(g)(1)(vii) |
8/20/2024 | |
(g)(2) |
Incorporated by Reference |
Columbia ETF Trust I |
333-209996 |
Post-Effective Amendment #12 on Form N-1A |
(g)(2) |
2/27/2019 |
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)(2)(i) |
Incorporated by
Reference |
Columbia ETF
Trust II |
333-155709 |
Post-Effective
Amendment #109
on Form N-1A |
(g)(2)(i) |
7/26/2019 | |
(g)(2)(ii) |
Incorporated by
Reference |
Columbia ETF
Trust II |
333-155709 |
Post-Effective
Amendment #111
on Form N-1A |
(g)(2)(ii) |
7/28/2020 | |
(g)(2)(iii) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #23
on Form N-1A |
(g)(2)(iii) |
9/17/2021 | |
(g)(2)(iv) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #27
on Form N-1A |
(g)(2)(iv) |
3/18/2022 | |
(g)(2)(v) |
Incorporated by
Reference |
Columbia ETF
Trust II |
333-155709 |
Post-Effective
Amendment #115
on Form N-1A |
(g)(2)(v) |
7/26/2023 | |
(g)(2)(vi) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #39
on Form N-1A |
(g)(2)(vi) |
8/20/2024 | |
(h)(1) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #12
on Form N-1A |
(h)(1) |
2/27/2019 | |
(h)(1)(i) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #14
on Form N-1A |
(h)(1)(i) |
5/15/2019 | |
(h)(1)(ii) |
Incorporated by
Reference |
Columbia ETF
Trust II |
333-155709 |
Post-Effective
Amendment #109
on Form N-1A |
(h)(1)(ii) |
7/26/2019 | |
(h)(1)(iii) |
Incorporated by Reference |
Columbia ETF Trust II |
333-155709 |
Post-Effective Amendment #109 on Form N-1A |
(h)(1)(iii) |
7/26/2019 |
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)(1)(iv) |
Incorporated by
Reference |
Columbia ETF
Trust II |
333-155709 |
Post-Effective
Amendment #111
on Form N-1A |
(h)(1)(iv) |
7/28/2020 | |
(h)(1)(v) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #23
on Form N-1A |
(h)(1)(v) |
9/17/2021 | |
(h)(1)(vi) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #27
on Form N-1A |
(h)(1)(vi) |
3/18/2022 | |
(h)(1)(vii) |
Incorporated by
Reference |
Columbia ETF
Trust II |
333-155709 |
Post-Effective
Amendment #115
on Form N-1A |
(h)(1)(vii) |
7/26/2023 | |
(h)(1)(viii) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #39
on Form N-1A |
(h)(1)(viii) |
8/20/2024 | |
(h)(1)(ix) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #37
on Form N-1A |
(h)(1)(viii) |
5/30/2024 | |
(h)(2) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #12
on Form N-1A |
(h)(2) |
2/27/2019 | |
(h)(2)(i) |
Incorporated by
Reference |
Columbia ETF
Trust II |
333-155709 |
Post-Effective
Amendment #109
on Form N-1A |
(h)(2)(i) |
7/26/2019 | |
(h)(2)(ii) |
Incorporated by Reference |
Columbia ETF Trust II |
333-155709 |
Post-Effective Amendment #111 on Form N-1A |
(h)(2)(ii) |
7/28/2020 |
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 | |||
(h)(2)(iii) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #23
on Form N-1A |
(h)(2)(iii) |
9/17/2021 | |
(h)(2)(iv) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #27
on Form N-1A |
(h)(2)(iv) |
3/18/2022 | |
(h)(2)(v) |
Incorporated by
Reference |
Columbia ETF
Trust II |
333-155709 |
Post-Effective
Amendment #115
on Form N-1A |
(h)(2)(v) |
7/26/2023 | |
(h)(2)(vi) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #39
on Form N-1A |
(h)(2)(vi) |
8/20/2024 | |
(h)(3) |
Incorporated by
Reference |
Columbia Funds
Variable Series
Trust II |
333-146374 |
Post-Effective
Amendment #90
on Form N-1A |
(h)(8) |
11/8/2023 | |
(h)(4) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #5
on Form N-1A |
(h)(13) |
9/22/2017 | |
(h)(4)(i) |
|
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #23
on Form N-1A |
(h)(6)(i) |
9/17/2021 |
(h)(5) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #17
on Form N-1A |
(h)(5) |
9/25/2019 | |
(h)(6) |
Incorporated by Reference |
Columbia ETF Trust I |
333-209996 |
Post-Effective Amendment #32 on Form N-1A |
(h)(7) |
3/31/2023 |
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 | |||
(h)(7) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #25
on Form N-1A |
(h)(7) |
2/25/2022 | |
(h)(8) |
Incorporated by
Reference |
Columbia ETF
Trust II |
333-155709 |
Post-Effective
Amendment #114
on Form N-1A |
(h)(9) |
7/27/2022 | |
(h)(9) |
Incorporated by
Reference |
Columbia ETF
Trust II |
333-155709 |
Post-Effective
Amendment #115
on Form N-1A |
(h)(9)(ii) |
7/26/2023 | |
(h)(10) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #34
on Form N-1A |
(h)(11) |
2/26/2024 | |
(i)(1) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Pre-Effective
Amendment #1
on Form N-1A |
(i) |
5/31/2016 | |
(i)(2) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #5
on Form N-1A |
(i)(2) |
9/22/2017 | |
(i)(3) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #10
on Form N-1A |
(i)(3) |
7/17/2018 | |
(i)(4) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #15
on Form N-1A |
(i)(4) |
7/26/2019 | |
(i)(5) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #23
on Form N-1A |
(i)(5) |
9/17/2021 | |
(i)(6) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #27
on Form N-1A |
(i)(6) |
3/18/2022 | |
(i)(7) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #32
on Form N-1A |
(i)(7) |
3/31/2023 | |
(i)(8) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #39
on Form N-1A |
(i)(8) |
8/20/2024 | |
(j)(1) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #34
on Form N-1A |
(j) |
2/26/2024 | |
(j)(2) |
Incorporated by Reference |
Columbia ETF Trust I |
333-209996 |
Post-Effective Amendment #36 on Form N-1A |
(j)(2) |
4/24/2024 |
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 | |||
(j)(3) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #37
on Form N-1A |
(j)(3) |
5/30/2024 | |
(k) |
Omitted Financial Statements: Not
Applicable |
|
|
|
|
|
|
(l) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Pre-Effective
Amendment #1
on Form N-1A |
(l) |
5/31/2016 | |
(m)(1) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Pre-Effective
Amendment #1
on Form N-1A |
(m) |
5/31/2016 | |
(m)(1)(i) |
Incorporated by
Reference |
Columbia ETF
Trust I |
333-209996 |
Post-Effective
Amendment #39
on Form N-1A |
(m)(1)(i) |
8/20/2024 | |
(n) |
Not Applicable |
|
|
|
|
|
|
(o) |
Reserved. |
|
|
|
|
|
|
(p)(1) |
Incorporated by
Reference |
Columbia Funds
Variable Series
Trust II |
333-146374 |
Post-Effective
Amendment #68
on Form N-1A |
(p)(1) |
4/26/2019 | |
(p)(2) |
Filed Herewith |
Columbia ETF Trust I |
333-209996 |
Post-Effective Amendment #40 on Form N-1A |
(p)(2) |
12/19/2024 |
Name and Principal Business Address* |
Position and Offices with Principal Underwriter |
Positions and Offices with Registrant |
Stephen J. Kyllo |
President, Chief Operating Officer, Director, Chief Compliance Officer |
None |
Brian Schell** |
Vice President and Treasurer |
None |
Eric Parsons |
Vice President, Controller and Assistant Treasurer |
None |
Name and Principal Business Address* |
Position and Offices
with Principal
Underwriter |
Positions and Offices with Registrant |
Jason White*** |
Secretary |
None |
Richard C. Noyes |
Senior Vice President, General Counsel, Assistant Secretary |
None |
Eric Theroff^ |
Assistant Secretary |
None |
Adam Girard^^ |
Tax Officer |
None |
Liza Price |
Vice President, Managing Counsel |
None |
Jed Stahl |
Vice President, Managing Counsel |
None |
Terence Digan |
Vice President |
None |
James Stegall |
Vice President |
None |
Gary Ross |
Senior Vice President |
None |
Hilary Quinn |
Vice President |
None |
Funds FYE |
N-CEN filing date |
October 31, 2023 |
January 12, 2024 |
December 31, 2023 |
March 13, 2024 |
COLUMBIA ETF 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/
Marybeth Pilat* |
Treasurer, Chief Accounting Officer
(Principal Accounting Officer) and
Principal Financial Officer |
/s/
Douglas A. Hacker* |
Trustee |
Marybeth Pilat |
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 Marybeth Pilat pursuant to a Power of Attorney, dated January 2, 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 |
|
|
COLUMBIA ETF TRUST I
AMENDMENT NO. 11 TO THE
AMENDED AND RESTATED DECLARATION OF TRUST
WHEREAS, Section 6 of Article III of the Amended and Restated Declaration of Trust (the Declaration of Trust) of Columbia ETF Trust I (the Trust), dated April 15, 2016, as amended from time to time, authorizes the Trustees of the Trust to amend the Declaration of Trust to change the designation of any Series or class of Shares without authorization by vote of the Shareholders of the Trust.
NOW, THEREFORE, The undersigned, being at least a majority of the Trustees of Columbia ETF Trust I, do hereby certify that we have authorized the renaming of Columbia Seligman Semiconductor and Technology ETF to Columbia Semiconductor and Technology ETF and have authorized the following amendment to said Declaration of Trust:
Section 6 of Article III is hereby amended to read as follows:
Without limiting the authority of the Trustees set forth in Section 5, inter alia, to establish and designate any further Series or classes or to modify the rights and preferences of any Series or class, the following Series shall be, and are hereby, established and designated:
Columbia Diversified Fixed Income Allocation ETF
Columbia International Equity Income ETF
Columbia Multi-Sector Municipal Income ETF
Columbia Research Enhanced Core ETF
Columbia Research Enhanced Real Estate ETF
Columbia Research Enhanced Value ETF
Columbia Semiconductor and Technology ETF
Columbia Short Duration Bond ETF
Columbia Short Duration High Yield ETF
Columbia U.S. Equity Income ETF
Columbia U.S. High Yield ETF
The rest of this Section 6 remains unchanged.
[The remainder of this page intentionally left blank.]
IN WITNESS WHEREOF, the undersigned has signed this Amendment No. 11 to the Declaration of Trust on September 27, 2024.
/s/ George S. Batejan George S. Batejan |
/s/ Brian J. Gallagher Brian J. Gallagher | |
/s/ Kathleen A. Blatz Kathleen A. Blatz |
/s/ Douglas A. Hacker Douglas A. Hacker | |
/s/ Daniel J. Beckman Daniel J. Beckman |
/s/ Nancy T. Lukitsh Nancy T. Lukitsh | |
/s/ Pamela G. Carlton Pamela G. Carlton |
/s/ David M. Moffett David M. Moffett | |
/s/ Janet Langford Carrig Janet Langford Carrig |
/s/ Catherine James Paglia Catherine James Paglia | |
/s/ J. Kevin Connaughton J. Kevin Connaughton |
/s/ Natalie A. Trunow Natalie A. Trunow | |
/s/ Olive M. Darragh Olive M. Darragh |
/s/ Sandra L. Yeager Sandra L. Yeager | |
/s/ Patricia M. Flynn Patricia M. Flynn |
Registered Agent: |
Corporation Service Company 84 State Street Boston, MA 02109 |
COLUMBIA THREADNEEDLE INVESTMENTS
GLOBAL PERSONAL ACCOUNT DEALING AND
CODE OF ETHICS
Policy Type
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Global Policy | |
Last Review Date
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December 2024 | |
Related Policies
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See Appendix F-Other Policies Applicable to Covered Persons | |
Applicability and Scope |
All Covered Persons and certain household members, trusteeships and executorships of Covered Persons.
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1. POLICY STATEMENT
1.1. Keys Points
This policy covers all Firms within Columbia Threadneedle Investments (the Firms) and has been adopted by the relevant governance committee and relevant boards of regulated entities within Columbia Threadneedle Investments. The policy is designed to address compliance with laws, rules, and regulations applicable to Columbia Threadneedle Investments global business, including but not limited to Rule 204A-1 under the Investment Advisers Act (Rule 204A-1) and Rule 17j-1 under the Investment Company Act of 1940 (Rule 17j- 1), FCA Principles and Rules, Luxembourg laws and CSSF regulations, and MAS Guidelines1.
Standard of Business Conduct: The conduct of personal dealings in investments by Covered Persons (See Appendix A-Definitions for Covered Persons definition) is a matter of the utmost importance to the organization, its clients, its regulators and to employees themselves. It is essential that the Firms appropriately manage access to privileged information concerning clients portfolios, the Firms trading intentions and trading activities, and that the Firms discharge their duties in a way that does not harm the interests of clients, the Firms or breach any legal or regulatory requirements. It is important that the Firms are not seen to act on privileged information for personal gain.
Duty Owed to Clients: Various regulations applicable to the Firms impose a fiduciary duty to act in the exclusive best interest of their clients at all times recognizing their role as a Trusted Adviser. A number of specific obligations flow from the duty that is owed to clients, including:
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To act solely in the best interests of clients at all times. |
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To make full and fair disclosure of all material facts, particularly where the Firms interests may conflict with those of its clients. |
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To act in a manner which satisfies the fiduciary duty owed to clients. |
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To refrain from favouring the interest of a particular client over the interests of another client. |
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To keep all information about clients (including former clients) confidential, including the clients identity, clients securities holdings information, and other non-public information. |
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To exercise a high degree of care to ensure that adequate and accurate representations and other information is presented appropriately. |
In connection with providing investment management services to clients, this includes prohibiting any activity which directly or indirectly:
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Defrauds a client in any manner. |
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Misleads a client, including any statement that omits material facts. |
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Operates or would operate as a fraud or deceit on a client. |
1 Other global regulators may have specific regulations around the personal account dealing and information around these regulations is maintained by the Compliance Group.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
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Functions as a manipulative practice with respect to a client. |
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Functions as a manipulative practice with respect to securities. |
Specifically, the fiduciary duty owed to clients means the following outcomes must be achieved:
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To have a reasonable, independent basis for investment advice. |
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To ensure that investment advice is suitable to the clients investment objectives, needs and circumstances. |
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To refrain from effecting Personal Securities Transactions inconsistent with clients interests. |
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To obtain best execution for clients securities transactions. |
Conflicts of Interest: All Covered Persons must be vigilant in terms of identifying circumstances that may present a conflict of interest. A conflict of interest is any situation that presents an incentive to act other than in the best interest of a client or without objectivity. A conflict of interest may arise, for example, when a Covered Person engages in a transaction that potentially favors:
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The Firms interests over a clients interest |
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The interest of a Covered Person over a clients interest |
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One clients interest over another clients interest |
In addition to this Global Asset Management Personal Account Dealing and Code of Ethics Policy (Policy), the Firms have adopted various policies designed to prevent, or otherwise manage, conflicts of interest in contexts outside of personal trading. To effectively manage conflicts of interest, all Covered Persons must seek to prevent conflicts of interest, including the appearance of a conflict.
The requirements set forth in this Policy do not identify all possible conflicts of interest that may arise in relation to personal transactions. Employees are encouraged to seek assistance from Personal Trade Compliance whenever they have any questions concerning obligations under the Policy, including conflicts of interest situations or concerns.
Additional Standards of Conduct and Regulatory Requirements: Covered Persons must comply with other policies adopted by the individual Firms that are intended to promote fair and ethical standards of business conduct and comply with related regulatory requirements, including the Ameriprise Financial Global Code of Conduct. (See Appendix F-Other Policies Applicable to Covered Persons).
1.2. Specific Policy Requirements
This Policy applies to all Covered Persons and certain household members, Trusteeships and Executorships of Covered Persons. Covered Persons include:
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All global Columbia Threadneedle Investments employees and contractors. |
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
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Any other individual with a specific role (including working on a project) which compels Covered Person status due to access to proprietary information (e.g., holdings/transactions), such as the member of a staff group that provides ongoing audit, technology, finance, compliance, or legal support to Firms. |
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Any other persons that may be deemed appropriate by Compliance. |
Covered Securities Transactions/Accounts: This Policy governs a Covered Persons personal securities transactions as well as those securities transactions in which a Covered Person is deemed to have a direct or indirect Beneficial Ownership (see Appendix A-Definitions for Beneficial Ownership definition) and over which a Covered Person exercises direct or indirect influence or control (Affiliated Accounts). An account generally is covered by this Policy if it is:
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In the Covered Persons name |
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In the name of the Covered Persons spouse/partner and/or any financially dependent members of the Covered Persons household, |
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Of a partnership in which the Covered Person or a member of his/her immediate family is a partner with direct or indirect investment discretion |
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Of a trust in which the Covered Person (or a member of his/her immediate family) is a beneficiary and a trustee with direct or indirect investment discretion |
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Of a closely held corporation in which the Covered Person or a member of his/her immediate family holds shares and have direct or indirect investment discretion |
It is the responsibility of the Covered Person to seek advice in the event that it is not clear whether certain personal securities transactions are covered by this Policy.
Material Nonpublic Information: A Covered Person who is in possession of material nonpublic information (often referred to as Inside Information) about securities or financial instruments is prohibited from buying, selling, recommending or trading such securities or financial instruments. In addition, a Covered Person must not communicate or disclose such information to others who may misuse it. Material nonpublic information may include nonpublic information about a pooled investment vehicle (e.g., UCITS, open-end and closed-end mutual funds, and private funds) that are advised or sub-advised by the Firm. The Firms each have adopted specific policies that address these prohibitions, and set forth specific protocols for handling material nonpublic information (see Appendix F-Other Policies Applicable to Covered Persons)
Disclosure of Brokerage Accounts: Covered Persons must promptly disclose their brokerage accounts to their Firms Compliance group and ensure that each broker-dealer with which he/she maintains an account sends to the Compliance group, as soon as practicable, copies of all confirmations of securities transactions and of all monthly, quarterly and annual account statements. In order to comply with regulatory expectations concerning the monitoring of trading activity within Covered Persons accounts, there are requirements on where brokerage accounts may be maintained for the trading of certain types of securities. Please refer to Appendix B Limited Choice Policy for specific information by region.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
Notification of Brokerage Accounts: Covered Persons must immediately report any brokerage accounts opened by completing the following steps:
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Add the account to the Employee Compliance Manager (ECM) system using the Add Brokerage Account functionality. |
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This information will be reviewed by the Personal Trade Compliance team to ensure complying with Limited Choice policy (see Appendix B). This review may result in communications to the employee regarding action that must be taken to comply with Limited Choice. |
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Notify your broker of your association with Ameriprise Financial or Columbia Threadneedle. You are responsible for notifying your broker that you are affiliated with or employed by a broker/dealer and ensuring that Personal Trade Compliance is provided with duplicate statements and confirmations for your account(s). |
North America employees any brokerage account outside of Limited Choice brokers (as listed in Appendix B) for example, a brokerage account holding mutual funds only, must be approved by Personal Trade Compliance prior to establishing the account in order to comply with FINRA rule 3210.
Personal Trading Restrictions
Prohibition on Front Running: Covered Persons are prohibited from engaging in a Personal Securities Transaction that involves the purchase or sale of a Reportable Security when such Covered Person has knowledge that such security (1) is being considered for purchase or sale by a client account or (2) is being purchased or sold by a client account.
Prior Approval (Pre-Clearance) of Personal Security Transactions: Covered Persons must obtain approval often referred to as pre-clearance from Compliance prior to effecting a securities trade in most categories of investments. This pre-clearance requirement extends to securities transactions in all accounts for which the Covered Person has Beneficial Ownership (see Appendix A-Definitions). If the Covered Person receives pre-clearance approval, it is valid only for the duration of the locally defined approval period; in North America preclearance is good only for the day it is granted, in EMEA/APAC preclearance is good for the day granted and until the end of the following business day. If a Covered Person does not effect the pre-cleared personal trade(s) within that locally approved time period, the Covered Person must request and obtain pre-clearance for the proposed personal trade(s) again before the trade(s) are effected. If the Covered Person does not receive pre-clearance approval, he/she must not effect the requested Personal Securities Transaction (but may request approval on a subsequent day).
Covered Persons are required to obtain such pre-clearance approval for the majority of investments (e.g., stocks, bonds, Exchange Traded Funds (ETFs), closed-end funds, investment trusts). Please refer to Appendix C-Individual Security Requirements which identifies those categories of investments to which pre-clearance is or is not applicable.
Private Placements/Limited Offerings: Investments in private placement offerings require approval by the Compliance group (e.g., private placements, non-exchange traded REITs, hedge funds, fixed income new issues, unlisted structured products, non-charity crowdfunding, etc.). If approved, the approval is good for 90 days.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
Gifts and Charitable Donations: Approval is not necessary for a gift of securities to a Non-Profit Organization, but Compliance should be notified in advance and the Short-Term and 14-day Blackout rules do not apply. For gifting securities to a For-Profit Organization, individual, trust or other person or entity (other than a Non-Profit Organization), the pre-clearance requirement and 14-day Blackout rule do apply if you are purchasing the securities you intend to give. If the securities are already owned, the transfer of securities does not require pre-clearance. If you receive a gift of securities, you must update your holdings on ECM and no pre-clearance is required.
Short-Term Trading Prohibition (30 Day Holding Period):
Individual Securities at a Profit: Covered Persons are prohibited from engaging in short-term trading of Reportable Securities. This means that Covered Persons may not buy (or add to their existing position), then sell the same securities (or equivalent) within 30 calendar days if the trade would result in a gain. Covered Persons must wait until calendar day 31 (Trade Date + 30) to trade out of a position at a profit within the same account. For example, you buy 1000 shares of Security A on 1 June. On 25 June, you decide to buy another 1000 shares of the same security, Security A. If you want to sell 500 shares of Security A, you need to count the 30 days from 25 June and not 1 June.
Covered Funds and other Pooled Investment Vehicles: A Covered Person is prohibited from short term trading in any Covered Fund (e.g., mutual fund, SICAV, OEIC, or other pooled investment vehicle, see Appendix D-Covered Funds List) held for less than 30 calendar days, or a longer time if specified in the Covered Funds prospectus or similar disclosure document. Covered Persons are prohibited from engaging in market timing (short-term trading) in shares of any pooled investment vehicles and must comply with the holding period policy established by any prospectus.
Transactions exempted from short-term trading prohibitions: Money market fund investments, automated investments and withdrawal programs, and Dividend Reinvestments are not subject to the 30-day holding period.
Initial Public Offerings (IPOs) and Limited Offerings/Private Placements:
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Equity IPOs in North America are prohibited including direct purchased programs. |
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Covered Persons are required to obtain pre-clearance approval to purchase IPOs or Limited Offerings/Private Placements, including additions to existing holdings but excluding capital calls for previously approved commitments. |
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Such approval will only be granted when 1) it is determined that the investment in a private fund (if a proprietary private fund) meets the applicable banking regulatory requirements2 and 2) it is established that there is no conflict or appearance of a conflict with any Client or other possible impropriety (such as where the Security in the Limited Offering is appropriate for purchase by a Client, or when his/her participation in the Limited Offering is suggested by a person who has a business relationship with any such Company or expects to establish such a relationship). |
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The 30-day holding period also applies to IPOs. |
2 The review of applicability of banking requirements will occur during the subscription process.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
Cryptocurrency3:
Transactions: Transactions in cryptocurrency, such as Bitcoin, Ethereum, Lite Coin etc., do not require reporting. However, transactions in any publicly traded cryptocurrency tracker instrument, such as Grayscales Bitcoin Investment Trust (GBTC) and iShares Bitcoin Trust (IBIT), require pre-clearance approval and must be held and traded at an approved broker (See Appendix B - Limited Choice Policy).
Accounts: Cryptocurrency accounts are not reportable and must be at firms that offer ONLY cryptocurrency investments. Accounts at firms that also offer brokerage options are prohibited.
Initial Coin Offerings (ICOs): Participation in ICOs is prohibited.
Participation in Investment Clubs:
No Covered Person may participate in private investment clubs or other similar groups.
Derivatives:
Covered Persons are strongly discouraged from investing in any form of derivative that could give rise to an open ended, unlimited liability. Most derivative trading is subject to pre-clearance requirements, option trading guidelines and the Short-Term Trading Prohibition. (See Appendix E-Options/Short Trading Guidelines).
Frequent and Unusual Trading Activity:
Compliance monitors patterns of personal trading activity and may require additional information from a Covered Person with respect to a specific trade or series of transactions. Frequent personal trading activity is strongly discouraged. Although each situation is case specific, we generally review trading amounts over 25 trades per quarter for further analysis, which could result in corrective measures.
Columbia Wanger Asset Management (CWAM) Specific Trading Restrictions:
No CWAM Covered Person shall purchase any Reportable Security that is owned by a CWAM Client Account (excluding ETFs).
Rules applicable to Ameriprise Shares:
All employees at band level 50 and above are subject to a blackout period of trading Ameriprise shares. The blackout occurs on the first calendar day of January, April, July, and October and lasts until one full trading day after the Ameriprise earnings for the preceding quarter are publicly released. During this period employees are restricted from trading any Ameriprise shares. All applicable employees will receive emails notifying of the start and end date of the blackout.
3 Personal Trade Compliance continues to monitor the evolving digital assets/cryptocurrency space and the impact on Covered Persons under the Policy. These requirements may change if regulatory guidance or rules should be provided. All Covered Persons are encouraged to contact Personal Trade Compliance prior to transacting in any form of digital assets/cryptocurrency to ensure compliance with the latest regulatory and firm guidance/requirements.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
Additional Trading Restrictions for Investment Personnel
Rules Applicable to Portfolio Managers and other Designated Covered Persons:
14 Day Blackout Period: Portfolio Managers (and other Covered Persons specifically identified by Compliance) are not permitted to transact in any security that is purchased or sold in a client account 7 calendar days before and 7 calendar days after a client account they manage trades in that same (or equivalent) security. This means a Portfolio Manager (and other Designated Covered Persons) must wait until calendar day 8 to trade the security. Application of this rule may be applied broader based on team function and location.
Because it is a Portfolio Managers responsibility to put his/her clients interests ahead of his/her own, he/she may not delay taking appropriate action for a client account in order to avoid potential adverse consequences in his/her personal account. In certain limited instances, Compliance, at their discretion, may determine that a trade should be deemed to have not caused a black out violation (e.g., unexpected significant client redemption or inflow triggering a sale or purchase in all securities held in the client portfolio).
Rules Applicable to Research Analysts:
Centralised Research Analysts (those who publish research for the use by Columbia Threadneedle) are prohibited from engaging in a personal securities transaction that involves securities issued by issuers on their Coverage List at the security (not issuer) level. This restriction includes securities convertible into, options on, and derivatives of, such securities.
Embedded Research Analysts-should the analyst have access to place an order within a fund they will be subject to the same blackout period as a Portfolio Manager (see above).
Rules Applicable to Trading Personnel:
3 Day Blackout Period: Traders are not permitted to transact in any security that is purchased or sold in a client account 3 calendar days after the client transaction. This means a Trader must wait until calendar day 4 to trade the security. Application of this rule may be adjusted based on team function and location.
1.3. Reporting Requirements
Initial Holdings Report and Certification: Upon becoming a Covered Person under this Policy, one must disclose all securities holdings (as indicated in Appendix C-Individual Securities Requirements) in which they have Beneficial Ownership (as defined in Appendix A-Definitions). All brokerage accounts must be disclosed.
All Covered Persons are notified of this requirement and are provided with a copy of this Policy when they first become subject to the Policy. This initial certification must be completed within 10 calendar days of becoming a Covered Person, unless otherwise noted by Personal Trade Compliance. This information
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
must be current as of the date no more than 45 days prior to the date the person becomes a Covered Person.
Annual Certification: Covered Persons are also required to complete an annual accounts and holdings certification. This certification allows the Covered Person to validate the Brokerage Accounts and certain securities holdings in which they have Beneficial Ownership (as defined in Appendix A-Definitions). Covered Persons also certify that they have received, read and understand the Policy. This information must be current as of a date no more than 45 days prior to the date the report was submitted.
Quarterly Certification: On a quarterly basis, Covered Persons must also certify to securities transactions outside of a previously reported and approved Brokerage Account. The quarterly certification must be completed within 30 calendar days of the last day of the quarter.
1.4. Confidentiality
All reports and other documents and information supplied by or on behalf of any Covered Person in accordance with the requirements of this Policy will be treated as confidential, but are subject to review as provided herein and in the procedures by Legal, Compliance and other involved departments of the Firms, by Personal Trading, senior management, by representatives of relevant regulatory authority or self-regulatory authority, or otherwise as required by law, regulation, or court order.
1.5. Personal Data
Firms are subject to applicable privacy and data protection laws and regulations to ensure the security and protection of all personal data collected and processed by them. The firm sets out the general principles for handling personal data that must be followed by all staff, contractors, subsidiaries, affiliates, and associated entities within the Global Privacy Policy, Data Protection Policy, Information Security Policy, and Information Security Standards.
The firm has put in place comprehensive but proportionate governance measures to minimise the risk of personal data breaches, provide a consistent and compliant approach to privacy and data protection and to uphold the protection of personal data.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
2. ADMINISTRATIVE REQUIREMENTS
2.1. Summary of Legal and Regulatory Requirements
Regulatory rules require registered investment advisers and investment companies to adopt a code of ethics to; protect the firms clients, set forth standards of conduct, comply with applicable federal securities laws and address personal trading. SEC Rule 204A-1 under the Advisers Act (Rule 204A-1) requires each registered investment adviser to adopt a code of ethics that sets out standards of conduct expected of advisory personnel, safeguards material nonpublic information about client transactions and requires advisers access persons to report their personal securities transactions, including transactions in any mutual fund managed by the adviser.
Rule 17j-1 makes it unlawful for any affiliated person of a fund or any affiliated person of its investment adviser or principal underwriter to engage in certain enumerated types of misconduct in connection with the purchase or sale by such person of a security held or to be acquired by the fund. Each fund and its investment adviser and principal underwriter are required to adopt a written code of ethics containing provisions reasonably necessary to prevent the specified types of misconduct, and to use reasonable diligence and institute procedures reasonably necessary to prevent violations of the code.
FCA Rule COBS 11.7 requires a firm that conducts designated investment business to establish, implement and maintain adequate arrangements aimed at preventing certain activities (entering into certain personal transactions or advising anyone else to do so, or disclosing any non-public information) of any relevant person that may give rise to a conflict of interest, or who has access to inside information as defined in the Market Abuse Regulation or to other confidential information relating to clients or transactions with or for clients by virtue of an activity carried out by him on behalf of the firm.
EU & Luxembourg laws as well as CSSF regulations require management companies to establish, implement and maintain adequate arrangements aimed at preventing certain activities (entering into certain personal transactions or advising anyone else to do so, or disclosing any non-public information) of any relevant person that may give rise to a conflict of interest, or who has access to inside information as defined in the Market Abuse Regulation or to other confidential information relating to clients (incl. UCITS and alternative investment funds) or transactions with or for clients by virtue of an activity carried out on behalf of the management company.
MAS Guidelines on Risk Management Practices Internal Controls state that an institution should have adequate policies, procedures and controls to address conflict of interest situations. It should require employees to disclose such conflicts on a timely basis. These cases should be escalated to either the Board or senior management and disclosed to customers where relevant.
MAS Guidelines on Individual Accountability and Conduct the Board and senior management should ensure that a framework is in place to address the standards of conduct expected of all employees. This includes fair dealing (treating customers fairly) and management of conflicts of interest.
Code of Conduct for Persons licensed by or registered with the Securities and Futures Commission A licensed person should have a policy which has been communicated to employees in writing on whether
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
employees are permitted to deal or trade for their own accounts. Transactions of employees accounts and related accounts should be reported to and actively monitored, and procedures maintained to detect irregularities and ensure that the handling by the licensed or registered person of these transactions or orders is not prejudicial to the interests of their clients.
2.2. Roles and Responsibilities/Supervision
At least annually, each Chief Compliance Officer/Compliance Executive or delegate of the Ameriprise Global Asset Management Entities must review the adequacy of this Policy and the policies and procedures herein referenced.
2.3. Escalation for Non-Compliance
In general, a Covered Person should first discuss a compliance issue with their supervisor, department head, Chief Compliance Officer, Compliance Executive, or Personal Trade Compliance. In the event that a Covered Person does not feel comfortable discussing compliance issues through these channels, the employee may anonymously report suspected violations of law or company policy by contacting their local resources (refer to Appendix G-Resources). Employees are encouraged to report these questionable practices so that the Firms have an opportunity to address and resolve these issues before they become more significant regulatory or legal issues.
Violations/Breaches of this Policy are taken seriously and may result in disciplinary actions and/or sanctions. Disciplinary actions could be up to and including termination of employment and sanctions will vary depending on local requirements or the circumstances (e.g., depending on the severity of the violation, if a record of previous violations exists, etc.).
2.4. Monitoring/Oversight
Compliance is responsible for reviewing the personal securities transactions and holdings reports submitted under this Policy, which includes daily monitoring of employee personal trading and applicable accounts through the usage of ECM.
Escalation of matters are provided to appropriate local governance committee and/or Compliance group.
2.5. Disclosure
Columbia Threadneedle must provide information that is material about its business practices to clients and/or regulatory agencies, including information about any conflicts of interests and the policies to address such conflicts. Practices related to this Policy are publicly disclosed in accordance with local rules and regulations.
2.6. Recordkeeping
Each respective Compliance group is primarily responsible for maintaining records created with respect to this Policy and the procedures adopted to implement it. All records must be maintained for five years after the end of the fiscal year in which the documents were later of creation or last use, the first two years in an
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
easily accessible place, and up to seven years in line with Columbia Threadneedle Investments data protection policy.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
APPENDIX A - DEFINITIONS
Beneficial Owner of an account or a security includes any person who, directly or indirectly, has or shares voting or investment power. For the purposes of the Code of Ethics, a beneficial owner includes accounts held in the name of you, your spouse/partner and/or any financially dependent members of your household.)
In addition, you also have Beneficial Ownership if any of the individuals listed above:
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Is a trustee or custodian for an account (e.g., for a child or parent) |
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Exercises discretion over an account via a power of attorney arrangement or as an executor of an estate after death |
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Has another arrangement where they give advice and also have a direct or indirect ownership (e.g., treasurer of an outside organization). |
Brokerage Account: A Brokerage Account is an account held at a licensed brokerage firm in which securities on the Securities Reporting List are bought and sold (e.g., stocks, bonds, futures, options, Covered Funds). This includes employer-sponsored incentive savings plans.
Closed-End Funds: A closed-end fund is a publicly traded investment company that raises a fixed amount of capital through an IPO. The fund is then structured, listed and traded like a stock on a stock exchange.
Covered Funds: Closed-End Funds, ETFs and Open-Ended Funds for which a Columbia Threadneedle entity serves as an investment adviser or for which an affiliate of Columbia Management Investment Advisers, LLC serves as principal underwriter are considered Covered Funds.
Covered Persons includes all Columbia Threadneedle employees and contractors, any other individual with a specific role (including working on a project) which compels Covered Person status due to access to proprietary information (e.g., holdings/transactions), such as the member of a staff group that provides ongoing audit, technology, finance, compliance, or legal support to Firms, and any other persons that may be deemed appropriate by Compliance.
Private Funds: Private investment funds sponsored and managed by Columbia Threadneedle Investments entities.
Reportable Security Reportable Security includes all corporate securities, options on securities, warrants, rights, ETFs and municipal securities.
Reportable Security excludes: direct obligations of the United States government; bankers acceptances, bank certificates of deposit, commercial paper and high quality short-term debt instruments, including repurchase agreements; insurance company general accounts (short-term cash equivalent options of a variable life insurance policy); shares of a money market fund or other short-term income or short-term bond funds; shares of any open-end mutual fund, including any shares of a Reportable Fund; and futures and options on futures.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
APPENDIX B - LIMITED CHOICE POLICY
In order to comply with regulators expectations concerning the monitoring of trading activity within Covered Person accounts, Ameriprise Financial and Columbia Threadneedle Investments maintain a limited choice brokerage policy which dictates where certain types of securities must be held and traded.
The types of securities that are subject to the Limited Choice Policy are specified in Appendix C - Individual Securities Requirements. Securities not subject to the Limited Choice Policy may be held in brokerage accounts and must meet certain requirements. See Notification of Brokerage Accounts in Section 1.2 of Policy.
Each region has specific requirements that must be followed for that region:
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Ameriprise/Columbia Threadneedle North America - Ameriprise Financial Brokerage, Charles Schwab, Merrill Lynch |
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Columbia Threadneedle UK - Barclays, Hargreaves Lansdown, Interactive Brokers, Interactive Investors, AJ Bell, Fidelity International (Charles Schwab and Merrill Lynch restricted to U.S based accounts only). Employees are required to authorize the electronic feeds, when applicable, between the brokers and Columbia Threadneedle Investments. |
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Columbia Threadneedle EMEA, excluding UK -. Employees of Columbia Threadneedle EMEA must report their broker accounts on ECM prior to trading and provide contract notes to Personal Trade Compliance as soon as practicable following execution of their trade. |
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Columbia Threadneedle APAC - Employees of Columbia Threadneedle APAC must report their broker accounts on ECM prior to trading and provide contract notes (if not on an electronic feed) to Personal Trade Compliance as soon as practicable following execution of their trade. Singapore employees are encouraged to use UOB and Interactive because they do provide electronic feeds. Employees are required to authorize the electronic feeds, when applicable, between the brokers and Columbia Threadneedle Investments. |
If you maintain a brokerage account outside of the approved brokers that holds securities subject to the Limited Choice policy, you have the following options:
1. |
You may transfer the subject holdings to a like-ownership account at one of the approved brokers for your region. See Notification of Brokerage Accounts in Section 1.2 of Policy. |
2. |
You may liquidate the subject holdings (subject to the requirements in the Policy) and either hold the proceeds as cash or reinvest in non-subject securities. |
3. |
You may apply for an exception. Contact Personal Trading for more information about what may be an allowable exception and what steps need to be taken to request an exception. An exception does not make you exempt from complying with all other requirements in Policy). |
Covered Persons must comply with the Limited Choice Policy requirements within 30 days of becoming a Covered Person, unless otherwise noted by Personal Trade Compliance.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
APPENDIX C - INDIVIDUAL SECURITIES REQUIREMENTS
(Pre-clearance and Reporting)
Pre-clearance Requirements
All securities held in brokerage accounts (including 401K Alight Financial self-directed brokerage accounts and Self Investment Personal Pension funds (SIPPs)) are subject to prior approval (pre-clearance) under the Policy, including ETFs, Investment Trusts, Closed End Funds and publicly traded crypto-related securities. Additional pre-clearance requirement of Fund Pricing and Dealing Committee (FPDC) and SICAV ManCo Pricing Committee (MPC) members (applicable to EMEA only) related to Columbia Threadneedle EMEA Products.
Exceptions to the pre-clearance requirement are listed below:
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Ameriprise Financial Stock4 |
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Annuities and Life Insurance (where there is no specific investment exposure) |
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Bank products (checking/savings, CDs, etc.) |
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Currencies |
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Digital assets/cryptocurrencies (Direct investments - Bitcoin, Ethereum, etc. See pg. 7) |
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Debt securities issued by any government |
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Dividend Reinvestment Plans (DRIPS) |
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Futures |
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Money Market Funds |
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Non-Investment derivatives sporting bets only |
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Open-End Mutual Funds |
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Columbia Threadneedle - Open-End Mutual Funds (including OEICs and SICAVs) |
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Unit Investment Trusts (UITs) |
Reporting Requirements
Brokerage accounts
All brokerage accounts, including the Alight 401(k) self-directed accounts and full discretionary accounts, must be reported to Personal Trade Compliance through the ECM system. This reporting requirement applies even if the holdings in the account do not require reporting (See Holdings below).
Holdings All securities must be reported on ECM, except the following securities do not require reporting:
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Annuities (report only Covered Funds listed in Appendix D) |
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Bank products (checking/savings, CDs etc.) |
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Money Market Funds |
4 Other rules, including blackout and holding periods, still apply and there can be no speculative trading in Ameriprise Financial Stock.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
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Open-End Mutual Funds (report only Covered Funds listed in Appendix D) |
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Currencies, including Digital assets/cryptocurrencies (Direct Investments - Bitcoin, Ethereum, etc. See pg.7) |
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Futures |
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Debt securities issued by any government |
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529 plans |
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
APPENDIX D - COVERED FUNDS LIST
The Global Asset Management Personal Account Dealing and Code of Ethics Policy (Policy) speaks to certain rules concerning activity within Covered Funds. Closed-End Funds, ETFs and Mutual Funds for which Columbia Management Investment Advisers, LLC or Columbia Wanger Asset Management, LLC serves as an investment adviser or for which an affiliate of Columbia Management Investment Advisers, LLC serves as principal underwriter are considered Covered Funds. 5
The following is the list of Covered Funds as of December 2023:
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All Columbia Mutual Funds (both retail and variable), including Columbia Acorn Funds, Wanger Funds, and Multi-Manager Funds offered through Ameriprise Financial advisory programs |
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All Columbia ETFs |
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All Columbia Threadneedle EMEA and Asia Funds |
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Columbia Seligman Premium Technology Growth Fund, Inc. |
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Tri-Continental Corporation |
Third-Party Funds Sub Advised by CMIA:
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Destinations Large Cap Equity Fund |
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Efficient Enhanced Multi-Asset Fund |
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NVIT Columbia Overseas Value Fund |
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SA Focused Large Cap Value Portfolio |
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Schwab International Opportunities Fund |
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SEI Multi-Asset Inflation Manged Fund |
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SEI Multi-Asset Real Return Fund |
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VALIC Capital Appreciation Fund |
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VALIC International Value Fund |
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VY Columbia Contrarian Core Portfolio |
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VY Columbia Small Cap Value II Portfolio |
5 Under the Volcker Rule, certain employee investments/holdings in proprietary funds may need to be reviewed to ensure that the holdings meet banking exclusions and exemptions requirements. Employees identified as senior executive officers or directors may need to provide holdings data for these funds on an ad hoc basis for analysis by the GCO.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
APPENDIX E - OPTIONS/SHORT TRADING RESTRICTIONS
Short Trading-General Guidelines
Shorting individual securities is prohibited. Shorting broad-based market securities (ETFs) is permitted.
Options Trading-General Guidelines
All persons subject to the Policy should not deal in any form of derivative that could give rise to an open ended, unlimited liability.
All Covered Persons must obtain pre-clearance via ECM prior to placing an options trade.
Short term trading at a profit is prohibited under the code. Covered Persons may not trade options that will result in a gain if held less than 30 days. Covered Persons must wait trade date plus 30 days before closing the position at a profit.
Acceptable Transactions
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Options that have an expiration greater than 30 days and |
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Out of the money option contracts |
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In the money option contracts only if there is an underlying position held greater than 30 days |
Prohibited Transactions
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Options that have an expiration within 30 days |
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In the money option contracts unless there is a sufficient underlying position held greater than 30 days (100 shares per contract) |
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Buying and selling options contracts at a profit held less than 30 days |
Key Reminders
Covered Persons are required to preclear the option ticker symbol (please use the new option symbology) and not the underlying ticker.
Covered Persons are responsible for calculating the 30-day holding period (Trade date + 30 days), you must use the average cost method (ECM does not calculate the 30-day holding period).
Receiving pre-clearance does not exclude you from other personal trading rules included in the Policy.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
APPENDIX F - OTHER RELATED POLICIES APPLICABLE TO COVERED PERSONS
Ameriprise Financial Global Code of Conduct
Ameriprise Financial Handling Whistleblower Claims Policy
Ameriprise Financial Limited Choice Policy
Privacy and Information Security and Identity Theft Prevention Program NA Policy
Inside Information Global Policy
Portfolio Holdings Disclosure Global Policy
Gifts and Entertainment Global Policy
Market Manipulation Identification and Prevention Global Policy
US Political Contributions Global Policy
Outside Activities and Family Relationships Global Policy
Columbia Threadneedle Investments EMEA Other Conflicts of Interest Policies Applicable to Covered Persons:
European Market Abuse & Insider Dealing Policy
Columbia Threadneedle Investments EMEA and APAC Conflicts of Interest Policy
Threadneedle Management Luxembourg S.A. Conflicts of Interest Policy
Threadneedle Treating Customers Fairly
Whistleblowing Policy (EMEA/APAC)
Threadneedle Management Luxembourg S.A. Whistleblowing Policy
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.
APPENDIX G RESOURCES
Compliance Resources
Send email to Personal.Trading@ampf.com
Contact the Compliance Team if you are ever at doubt as to your obligations under this Policy.
Whistleblowing
Ameriprise Financial provides the Ethics Hotline Ethicspoint which is a global whistleblower hotline service, operated by third-party vendor NAVEX Global. The Ethics Hotline is a toll-free phone-based and online reporting service that provides for the confidential, anonymous submission of compliance or ethical issues and concerns at Ameriprise Financial. Call the Ethics Hotline at 800-963-6395 or report online at ampf.ethicspoints.com. Those outside of the U.S. can obtain country and access codes to call the Ethics Hotline and/or report online at ampf.ethicspoint.com.
Concerns can also be raised with certain regulators and employees are encouraged to view the Ameriprise Financial Global Code of Conduct and the Ameriprise Financial Policy Relating to the Handling of Whistleblower Claims as well as any local policies; including but not limited to, the Whistleblowing Policy (EMEA/APAC) and the Threadneedle Management Luxembourg S.A. Whistleblowing Policy.
This document is current as of the last review date but subject to change thereafter.
Columbia Threadneedle Investments (Columbia Threadneedle) is the global brand name of the Columbia and Threadneedle group of companies.