Columbia Funds Variable Series Trust II |
Columbia Variable Portfolio – Balanced Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Commodity Strategy Fund: Class 1 & Class 2 |
Columbia Variable Portfolio – Core Equity Fund*: single class of shares |
Columbia Variable Portfolio – Disciplined Core Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Dividend Opportunity Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Emerging Markets Bond Fund: Class 1 & Class 2 |
Columbia Variable Portfolio – Emerging Markets Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Global Strategic Income Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Government Money Market Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – High Yield Bond Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Income Opportunities Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Intermediate Bond Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Large Cap Growth Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Large Cap Index Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Limited Duration Credit Fund: Class 1 & Class 2 |
Columbia Variable Portfolio – Mid Cap Growth Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Overseas Core Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Select Large Cap Equity Fund: Class 1 & Class 2 |
Columbia Variable Portfolio – Select Large Cap Value Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Select Mid Cap Value Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Select Small Cap Value Fund: Class 1, Class 2 & Class 3 |
Columbia Variable Portfolio – Seligman Global Technology Fund: Class 1 & Class 2 |
Columbia Variable Portfolio – U.S. Government Mortgage Fund: Class 1, Class 2 & Class 3 |
CTIVP® – American Century Diversified Bond Fund: Class 1 & Class 2 |
CTIVP® – BlackRock Global Inflation-Protected Securities Fund: Class 1, Class 2 & Class 3 |
CTIVP® – CenterSquare Real Estate Fund: Class 1 & Class 2 |
CTIVP® – Loomis Sayles Growth Fund: Class 1 & Class 2 |
CTIVP® – MFS® Value Fund: Class 1 & Class 2 |
CTIVP® – Morgan Stanley Advantage Fund: Class 1 & Class 2 |
CTIVP® – T. Rowe Price Large Cap Value Fund: Class 1 & Class 2 |
CTIVP® – TCW Core Plus Bond Fund: Class 1 & Class 2 |
CTIVP® – Victory Sycamore Established Value Fund: Class 1, Class 2 & Class 3 |
CTIVP® – Wells Fargo Short Duration Government Fund: Class 1 & Class 2 |
CTIVP® – Westfield Mid Cap Growth Fund: Class 1 & Class 2 |
Variable Portfolio – Aggressive Portfolio: Class 1, Class 2 & Class 4 |
Variable Portfolio – Conservative Portfolio: Class 1, Class 2 & Class 4 |
Variable Portfolio – Managed Volatility Moderate Growth Fund: Class 1 & Class 2 |
Variable Portfolio – Moderate Portfolio: Class 1, Class 2 & Class 4 |
Variable Portfolio – Moderately Aggressive Portfolio: Class 1, Class 2 & Class 4 |
Variable Portfolio – Moderately Conservative Portfolio: Class 1, Class 2 & Class 4 |
Variable Portfolio – Partners Core Bond Fund: Class 1 & Class 2 |
Variable Portfolio – Partners Core Equity Fund: Class 1, Class 2 & Class 3 |
Variable Portfolio – Partners International Core Equity Fund: Class 1 & Class 2 |
Variable Portfolio – Partners International Growth Fund: Class 1 & Class 2 |
Variable Portfolio – Partners International Value Fund: Class 1 & Class 2 |
Variable Portfolio – Partners Small Cap Growth Fund: Class 1 & Class 2 |
Variable Portfolio – Partners Small Cap Value Fund: Class 1, Class 2 & Class 3 |
* | This Fund is closed to new investors. |
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2 |
|
7 |
|
10 |
|
18 |
|
18 |
|
55 |
|
86 |
|
86 |
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87 |
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89 |
|
89 |
|
112 |
|
131 |
|
144 |
|
145 |
|
145 |
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147 |
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148 |
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149 |
|
155 |
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155 |
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156 |
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158 |
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158 |
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171 |
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177 |
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177 |
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180 |
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182 |
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184 |
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188 |
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188 |
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188 |
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189 |
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196 |
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197 |
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199 |
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200 |
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202 |
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202 |
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203 |
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205 |
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215 |
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237 |
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A-1 |
|
B-1 |
Statement of Additional Information – May 1, 2021 | 1 |
■ | the organization of the Trust; |
■ | the Funds' investments; |
■ | the Funds' investment adviser, investment subadviser(s) (if any) and other service providers, including roles and relationships of Ameriprise Financial and its affiliates, and conflicts of interest; |
■ | the governance of the Funds; |
■ | the Funds' brokerage practices; |
■ | the share classes offered by the Funds; |
■ | the purchase, redemption and pricing of Fund shares; and |
■ | the application of U.S. federal income tax laws. |
1933 Act | Securities Act of 1933, as amended |
1934 Act | Securities Exchange Act of 1934, as amended |
1940 Act | Investment Company Act of 1940, as amended |
American Century | American Century Investment Management, Inc. |
Ameriprise Financial | Ameriprise Financial, Inc. |
BlackRock | BlackRock Financial Management, Inc. |
BIL | BlackRock International Limited, an affiliate of BlackRock |
Board | The Trust’s Board of Trustees |
Statement of Additional Information – May 1, 2021 | 2 |
Business Day | Any day on which the NYSE is open for business. A business day typically ends at the close of regular trading on the NYSE, usually at 4:00 p.m. Eastern time. If the NYSE is scheduled to close early, the business day will be considered to end as of the time of the NYSE’s scheduled close. The Fund will not treat an intraday unscheduled disruption in NYSE trading or an intraday unscheduled closing as a close of regular trading on the NYSE for these purposes and will price its shares as of the regularly scheduled closing time for that day (typically, 4:00 p.m. Eastern time). Notwithstanding the foregoing, the NAV of Fund shares may be determined at such other time or times (in addition to or in lieu of the time set forth above) as the Fund’s Board may approve or ratify. On holidays and other days when the NYSE is closed, the Fund's NAV is not calculated and the Fund does not accept buy or sell orders. However, the value of the Fund's assets may still be affected on such days to the extent that the Fund holds foreign securities that trade on days that foreign securities markets are open. |
CEA | Commodity Exchange Act |
CenterSquare | CenterSquare Investment Management LLC |
CFTC | The United States Commodity Futures Trading Commission |
CFVST II | Columbia Funds Variable Series Trust II |
Code | Internal Revenue Code of 1986, as amended |
Codes of Ethics | The codes of ethics adopted by the Funds, the Investment Manager, Columbia Management Investment Distributors, Inc. and/or any sub-adviser, as applicable, pursuant to Rule 17j-1 under the 1940 Act |
Columbia Funds or Columbia Funds Complex | The fund complex, including the Funds, that is comprised of the registered investment companies, including traditional mutual funds, closed-end funds, and ETFs, advised by the Investment Manager or its affiliates |
Columbia Management | Columbia Management Investment Advisers, LLC |
Columbia WAM | Columbia Wanger Asset Management, LLC |
Custodian | JPMorgan Chase Bank, N.A. |
DBRS | DBRS Morningstar |
Distribution Agreement | The Distribution Agreement between the Trust, on behalf of its Funds, and the Distributor |
Distribution Plan(s) | One or more of the plans adopted by the Board pursuant to Rule 12b-1 under the 1940 Act for the distribution of the Funds’ shares |
Distributor | Columbia Management Investment Distributors, Inc. |
DST | DST Asset Manager Solutions, Inc. |
FDIC | Federal Deposit Insurance Corporation |
FHLMC | The Federal Home Loan Mortgage Corporation |
Fitch | Fitch Ratings, Inc. |
FNMA | Federal National Mortgage Association |
The Fund(s) or a Fund | One or more of the open-end management investment companies listed on the front cover of this SAI |
GNMA | Government National Mortgage Association |
ICM | Investment Counselors of Maryland, LLC |
Independent Trustees | The Trustees of the Board who are not “interested persons” (as defined in the 1940 Act) of the Funds |
Interested Trustee | A Trustee of the Board who is currently deemed to be an “interested person” (as defined in the 1940 Act) of the Funds |
Investment Manager | Columbia Management Investment Advisers, LLC |
IRS | United States Internal Revenue Service |
JPMIM | J.P. Morgan Investment Management Inc. |
Statement of Additional Information – May 1, 2021 | 3 |
JPMorgan | JPMorgan Chase Bank, N.A., the Funds' custodian |
KBRA | Kroll Bond Rating Agency |
LIBOR | London Interbank Offered Rate* |
Loomis Sayles | Loomis, Sayles & Company, L.P. |
MFS | Massachusetts Financial Services Company |
Management Agreement | The Management Agreements, as amended, if applicable, between the Trust, on behalf of the Funds, and the Investment Manager |
Moody’s | Moody’s Investors Service, Inc. |
MSIM | Morgan Stanley Investment Management Inc. |
NASDAQ | National Association of Securities Dealers Automated Quotations system |
NAV | Net asset value per share of a Fund |
NRSRO | Nationally recognized statistical ratings organization (such as, for example, Moody’s, Fitch or S&P) |
NSCC | National Securities Clearing Corporation |
NYSE | New York Stock Exchange |
Participating Insurance Companies | Life insurance companies that issue the variable annuity contracts or variable life insurance policies through separate accounts for which the Funds serve as underlying investment vehicles |
PwC | PricewaterhouseCoopers LLP |
Pzena | Pzena Investment Management, LLC |
REIT | Real estate investment trust |
REMIC | Real estate mortgage investment conduit |
RIC | A “regulated investment company,” as such term is used in the Code |
S&P | S&P Global Ratings, a division of S&P Global Inc. (“Standard & Poor’s” and “S&P” are trademarks of S&P Global Inc. and have been licensed for use by the Investment Manager. The Columbia Funds are not sponsored, endorsed, sold or promoted by S&P and S&P makes no representation regarding the advisability of investing in the Columbia Funds) |
SAI | This Statement of Additional Information, as amended and supplemented from time-to-time |
SBH | Segall Bryant & Hamill, LLC |
Schroders | Schroder Investment Management North America Inc. and Schroder Investment Management North America Limited, collectively |
Scout | Scout Investments, Inc. |
SEC | United States Securities and Exchange Commission |
Shareholder Services Agreement | The Shareholder Services Agreement between the Trust, on behalf of its Funds, and the Transfer Agent |
Shares | Shares of a Fund |
SIMNA Inc. | Schroder Investment Management North America Inc. |
SIMNA Ltd. | Schroder Investment Management North America Limited |
SOFR | Secured Overnight Financing Rate |
Subadvisory Agreement | The Subadvisory Agreement among the Trust on behalf of the Fund(s), the Investment Manager and a Fund’s investment subadviser(s), as the context may require |
Subsidiary | One or more wholly-owned subsidiaries of a Fund |
T. Rowe Price | T. Rowe Price Associates, Inc. |
TCW | TCW Investment Management Company LLC |
Threadneedle | Threadneedle International Limited |
Transfer Agent | Columbia Management Investment Services Corp. |
Statement of Additional Information – May 1, 2021 | 4 |
Treasury Regulations | Regulations promulgated under the Code by the United States Treasury Department |
Trustee(s) | One or more members of the Board |
Trust | Columbia Funds Variable Series Trust II, the registered investment company in the Columbia Funds Complex to which this SAI relates |
TSW | Thompson, Siegel & Walmsley LLC |
Victory Capital | Victory Capital Management Inc. |
VP – Managed Volatility Funds | Any variable portfolio fund that includes the words “Managed Risk,” “Managed Volatility,” or “U.S. Flexible” as part of the Fund’s name |
VP – Portfolio Navigator Funds | VP – Aggressive Portfolio, VP – Conservative Portfolio, VP – Moderate Portfolio, VP – Moderately Aggressive Portfolio and VP – Moderately Conservative Portfolio |
Walter Scott | Walter Scott & Partners Limited |
WellsCap | Wells Capital Management Incorporated |
Westfield | Westfield Capital Management Company, L.P. |
William Blair | William Blair Investment Management, LLC |
* | Please see “LIBOR Replacement Risk” in the “Information Regarding Risks” section for more information about the phaseout of LIBOR and related reference rates. |
Fund Name: | Referred to as: | |
Columbia Variable Portfolio – Balanced Fund | VP – Balanced Fund | |
Columbia Variable Portfolio – Commodity Strategy Fund | VP – Commodity Strategy Fund | |
Columbia Variable Portfolio – Core Equity Fund | VP – Core Equity Fund | |
Columbia Variable Portfolio – Disciplined Core Fund | VP – Disciplined Core Fund | |
Columbia Variable Portfolio – Dividend Opportunity Fund | VP – Dividend Opportunity Fund | |
Columbia Variable Portfolio – Emerging Markets Bond Fund | VP – Emerging Markets Bond Fund | |
Columbia Variable Portfolio – Emerging Markets Fund | VP – Emerging Markets Fund | |
Columbia Variable Portfolio – Global Strategic Income Fund | VP – Global Strategic Income Fund | |
Columbia Variable Portfolio – Government Money Market Fund | VP – Government Money Market Fund | |
Columbia Variable Portfolio – High Yield Bond Fund | VP – High Yield Bond Fund | |
Columbia Variable Portfolio – Income Opportunities Fund | VP – Income Opportunities Fund | |
Columbia Variable Portfolio – Intermediate Bond Fund | VP – Intermediate Bond Fund | |
Columbia Variable Portfolio – Large Cap Growth Fund | VP – Large Cap Growth Fund | |
Columbia Variable Portfolio – Large Cap Index Fund | VP – Large Cap Index Fund | |
Columbia Variable Portfolio – Limited Duration Credit Fund | VP – Limited Duration Credit Fund | |
Columbia Variable Portfolio – Mid Cap Growth Fund | VP – Mid Cap Growth Fund | |
Columbia Variable Portfolio – Overseas Core Fund | VP – Overseas Core Fund | |
Columbia Variable Portfolio – Select Large Cap Equity Fund | VP – Select Large Cap Equity Fund | |
Columbia Variable Portfolio – Select Large Cap Value Fund | VP – Select Large Cap Value Fund | |
Columbia Variable Portfolio – Select Mid Cap Value Fund | VP – Select Mid Cap Value Fund | |
Columbia Variable Portfolio – Select Small Cap Value Fund | VP – Select Small Cap Value Fund | |
Columbia Variable Portfolio – Seligman Global Technology Fund | VP – Seligman Global Technology Fund | |
Columbia Variable Portfolio – U.S. Government Mortgage Fund | VP – U.S. Government Mortgage Fund | |
CTIVP® – American Century Diversified Bond Fund | VP – American Century Diversified Bond Fund | |
CTIVP® – BlackRock Global Inflation-Protected Securities Fund | VP
– BlackRock Global Inflation-Protected Securities Fund | |
CTIVP® – CenterSquare Real Estate Fund | VP – CenterSquare Real Estate Fund |
Statement of Additional Information – May 1, 2021 | 5 |
Fund Name: | Referred to as: | |
CTIVP® – Loomis Sayles Growth Fund | VP – Loomis Sayles Growth Fund | |
CTIVP® – MFS® Value Fund | VP – MFS Value Fund | |
CTIVP® – Morgan Stanley Advantage Fund | VP – Morgan Stanley Advantage Fund | |
CTIVP® – T. Rowe Price Large Cap Value Fund | VP – T. Rowe Price Large Cap Value Fund | |
CTIVP® – TCW Core Plus Bond Fund | VP – TCW Core Plus Bond Fund | |
CTIVP® – Victory Sycamore Established Value Fund | VP – Victory Sycamore Established Value Fund | |
CTIVP® – Wells Fargo Short Duration Government Fund | VP – Wells Fargo Short Duration Government Fund | |
CTIVP® – Westfield Mid Cap Growth Fund | VP – Westfield Mid Cap Growth Fund | |
Variable Portfolio – Aggressive Portfolio | VP – Aggressive Portfolio | |
Variable Portfolio – Conservative Portfolio | VP – Conservative Portfolio | |
Variable Portfolio – Managed Volatility Moderate Growth Fund | VP – MV Moderate Growth Fund | |
Variable Portfolio – Moderate Portfolio | VP – Moderate Portfolio | |
Variable Portfolio – Moderately Aggressive Portfolio | VP – Moderately Aggressive Portfolio | |
Variable Portfolio – Moderately Conservative Portfolio | VP – Moderately Conservative Portfolio | |
Variable Portfolio – Partners Core Bond Fund | VP – Partners Core Bond Fund | |
Variable Portfolio – Partners Core Equity Fund | VP – Partners Core Equity Fund | |
Variable Portfolio – Partners International Core Equity Fund | VP – Partners International Core Equity Fund | |
Variable Portfolio – Partners International Growth Fund | VP – Partners International Growth Fund | |
Variable Portfolio – Partners International Value Fund | VP – Partners International Value Fund | |
Variable Portfolio – Partners Small Cap Growth Fund | VP – Partners Small Cap Growth Fund | |
Variable Portfolio – Partners Small Cap Value Fund | VP – Partners Small Cap Value Fund |
Statement of Additional Information – May 1, 2021 | 6 |
Fund | Date Began Operations* | Diversified** | Fund Investment Category*** |
VP – Aggressive Portfolio | May 7, 2010 | Yes | Fund-of-funds – Equity |
VP – American Century Diversified Bond Fund | May 7, 2010 | Yes | Fixed Income |
VP – Balanced Fund | April 30, 1986 | Yes | Flexible |
VP – BlackRock Global Inflation-Protected Securities Fund | September 13, 2004 | No | Fixed Income |
VP – CenterSquare Real Estate Fund | May 7, 2010 | Yes | Equity |
VP – Commodity Strategy Fund | April 30, 2013 | Yes | Equity |
VP – Conservative Portfolio | May 7, 2010 | Yes | Fund-of-funds – Fixed Income |
VP – Core Equity Fund | September 10, 2004 | Yes | Equity |
VP – Disciplined Core Fund | October 13, 1981 | Yes | Equity |
VP – Dividend Opportunity Fund | September 15, 1999 | Yes | Equity |
VP – Emerging Markets Bond Fund | April 30, 2012 | No | Fixed Income |
VP – Emerging Markets Fund | May 1, 2000 | Yes | Equity |
VP – Global Strategic Income Fund | May 1, 1996 | Yes | Fixed Income |
VP – Government Money Market Fund | October 31, 1981 | Yes | Money Market |
VP – High Yield Bond Fund | May 1, 1996 | Yes | Fixed Income |
VP – Income Opportunities Fund | June 1, 2004 | Yes | Fixed Income |
VP – Intermediate Bond Fund | October 13, 1981 | Yes | Fixed Income |
VP – Large Cap Growth Fund | September 15, 1999 | Yes | Equity |
VP – Large Cap Index Fund | May 1, 2000 | Yes | Equity |
VP – Limited Duration Credit Fund | May 7, 2010 | Yes | Fixed Income |
VP – Loomis Sayles Growth Fund | May 7, 2010 | Yes | Equity |
VP – MV Moderate Growth Fund | April 19, 2012 | Yes | Fund-of-funds – Equity |
VP – MFS Value Fund | May 7, 2010 | Yes | Equity |
VP – Mid Cap Growth Fund | May 1, 2001 | Yes | Equity |
VP – Moderate Portfolio | May 7, 2010 | Yes | Fund-of-funds – Equity |
VP – Moderately Aggressive Portfolio | May 7, 2010 | Yes | Fund-of-funds – Equity |
VP – Moderately Conservative Portfolio | May 7, 2010 | Yes | Fund-of-funds – Fixed Income |
VP – Morgan Stanley Advantage Fund | May 7, 2010 | Yes | Equity |
VP – Overseas Core Fund | January 13, 1992 | Yes | Equity |
VP – Partners Core Bond Fund | May 7, 2010 | Yes | Fixed Income |
VP – Partners Core Equity Fund | May 1, 2006 | Yes | Equity |
VP – Partners International Core Equity Fund | May 7, 2010 | Yes | Equity |
Statement of Additional Information – May 1, 2021 | 7 |
Fund | Date Began Operations* | Diversified** | Fund Investment Category*** |
VP – Partners International Growth Fund | May 7, 2010 | Yes | Equity |
VP – Partners International Value Fund | May 7, 2010 | Yes | Equity |
VP – Partners Small Cap Growth Fund | May 7, 2010 | Yes | Equity |
VP – Partners Small Cap Value Fund | August 14, 2001 | Yes | Equity |
VP – Select Large Cap Equity Fund | January 4, 2018 | Yes | Equity |
VP – Select Large Cap Value Fund | February 4, 2004 | Yes | Equity |
VP – Select Mid Cap Value Fund | May 2, 2005 | Yes | Equity |
VP – Select Small Cap Value Fund | September 15, 1999 | Yes | Equity |
VP – Seligman Global Technology Fund | May 1, 1996 | No | Equity |
VP – T. Rowe Price Large Cap Value Fund | May 7, 2010 | Yes | Equity |
VP – TCW Core Plus Bond Fund | May 7, 2010 | Yes | Fixed Income |
VP – U.S. Government Mortgage Fund | September 15, 1999 | Yes | Fixed Income |
VP – Victory Sycamore Established Value Fund | February 4, 2004 | Yes | Equity |
VP – Wells Fargo Short Duration Government Fund | May 7, 2010 | Yes | Fixed Income |
VP – Westfield Mid Cap Growth Fund | May 7, 2010 | Yes | Equity |
* | Certain Funds reorganized into series of the Trust. The date of operations for these Funds represents the date on which the predecessor funds began operation. |
** | A “diversified” Fund may not, with respect to 75% of its total assets, invest more than 5% of its total assets in securities of any one issuer or purchase more than 10% of the outstanding voting securities of any one issuer, except obligations issued or guaranteed by the U.S. Government, its agencies or instrumentalities and except securities of other investment companies. A “non-diversified” Fund may invest a greater percentage of its total assets in the securities of fewer issuers than a “diversified” fund, which increases the risk that a change in the value of any one investment held by the Fund could affect the overall value of the Fund more than it would affect that of a “diversified” fund holding a greater number of investments. Accordingly, a “non-diversified” Fund’s value will likely be more volatile than the value of a more diversified fund. |
*** | The Fund Investment Category is used as a convenient way to describe Funds in this SAI and should not be deemed a description of the Fund’s principal investment strategies, which are described in the Fund’s prospectus. |
Fund | Effective
Date of Name Change |
Previous Fund Name |
VP – American Century Diversified Bond Fund | May 1, 2018 | Variable Portfolio – American Century Diversified Bond Fund |
VP – BlackRock Global Inflation-Protected Securities Fund | May 1, 2018 | Variable Portfolio – BlackRock Global Inflation-Protected Securities Fund |
VP – CenterSquare Real Estate Fund | May
1, 2018 June 1, 2016 |
Variable
Portfolio – CenterSquare Real Estate Fund Variable Portfolio – Morgan Stanley Global Real Estate Fund |
VP – Global Strategic Income Fund | November 26, 2018 | Columbia Variable Portfolio - Global Bond Fund |
VP – Loomis Sayles Growth Fund | May 1, 2018 | Variable Portfolio – Loomis Sayles Growth Fund |
VP – MFS Value Fund | May 1, 2018 | Variable Portfolio – MFS Value Fund |
VP – Morgan Stanley Advantage Fund | May 1, 2018 | Variable Portfolio – Morgan Stanley Advantage Fund |
Statement of Additional Information – May 1, 2021 | 8 |
Fund | Effective
Date of Name Change |
Previous Fund Name |
VP – MV Moderate Growth Fund | May 1, 2018 | Columbia Variable Portfolio – Managed Volatility Moderate Growth Fund |
VP – Overseas Core Fund | May 1, 2018 | Columbia Variable Portfolio – Select International Equity Fund |
VP – Partners Core Bond Fund | May 1, 2017 | Variable Portfolio – J.P. Morgan Core Bond Fund |
VP – Partners Core Equity Fund | May
20, 2019 May 1, 2018 |
CTIVP®
– MFS®
Blended Research®
Core Equity Fund Variable Portfolio – MFS® Blended Research® Core Equity Fund |
VP – Partners International Core Equity Fund | May
1, 2020 May 21, 2018 May 1, 2018 |
CTIVP®
– AQR International Core Equity Fund CTIVP® – Pyramis® International Equity Fund Variable Portfolio – Pyramis International Equity Fund |
VP – Partners International Growth Fund | May
1, 2020 May 20, 2019 May 1, 2018 |
CTIVP®
– William Blair International Leaders Fund CTIVP® – Oppenheimer International Growth Fund Variable Portfolio – Oppenheimer International Growth Fund |
VP – Partners International Value Fund | May
1, 2020 May 1, 2018 |
CTIVP®
– DFA International Value Fund Variable Portfolio – DFA International Value Fund |
VP – Select Large Cap Value Fund | May 1, 2019 | Columbia Variable Portfolio – Select Large-Cap Value Fund |
VP – Select Mid Cap Value Fund | May 1, 2019 | Columbia Variable Portfolio – Mid Cap Value Fund |
VP – Select Small Cap Value Fund | May 1, 2019 | Columbia Variable Portfolio – Select Smaller-Cap Value Fund |
VP – T. Rowe Price Large Cap Value Fund | May
1, 2018 November 14, 2016 |
Variable
Portfolio – T. Rowe Price Large Cap Value Fund Variable Portfolio – NFJ Dividend Value Fund |
VP – TCW Core Plus Bond Fund | May 1, 2018 | Variable Portfolio – TCW Core Plus Bond Fund |
VP – Victory Sycamore Established Value Fund | May 1, 2018 | Variable Portfolio – Victory Sycamore Established Value Fund |
VP – Wells Fargo Short Duration Government Fund | May 1, 2018 | Variable Portfolio – Wells Fargo Short Duration Government Fund |
VP – Westfield Mid Cap Growth Fund | May
1, 2018 September 18, 2017 |
Variable
Portfolio – Westfield Mid Cap Growth Fund Variable Portfolio – Jennison Mid Cap Growth Fund |
Statement of Additional Information – May 1, 2021 | 9 |
Fund | A Buy or sell real estate |
B Buy or sell commodities |
C Issuer Diversification |
D Lending |
E Act as an underwriter |
F Borrow money |
G Issue Senior Securities |
H Concentration |
VP – Aggressive Portfolio | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – American Century Diversified Bond Fund | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – Balanced Fund | A1 | B1 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – BlackRock Global Inflation-Protected Securities Fund | A1 | B1 | — | D1 | E1 | F1 | G1 | H1 |
VP – CenterSquare Real Estate Fund | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H4 |
VP – Commodity Strategy Fund | A1 | B6 | C2 | D1 | E1 | F1 | G1 | H5 |
VP – Conservative Portfolio | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – Core Equity Fund | A1 | B1 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Disciplined Core Fund | A1 | B1 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Dividend Opportunity Fund | A1 | B1 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Emerging Markets Fund | A1 | B1 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Emerging Markets Bond Fund | A1 | B5 | — | D1 | E1 | F1 | G1 | H3 |
VP – Global Strategic Income Fund | A1 | B1 | C3 | D1 | E1 | F1 | G1 | H1 |
VP – Government Money Market Fund | A2 | A2 | C1 | D1 | E1 | F1 | G1 | — |
VP – High Yield Bond Fund | A1 | B1 | C1 | D1 | E1 | F1 | G1 | H1 |
Statement of Additional Information – May 1, 2021 | 10 |
Fund | A Buy or sell real estate |
B Buy or sell commodities |
C Issuer Diversification |
D Lending |
E Act as an underwriter |
F Borrow money |
G Issue Senior Securities |
H Concentration |
VP – Income Opportunities Fund | A1 | B1 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Intermediate Bond Fund | A1 | B1 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Large Cap Growth Fund | A1 | B1 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Large Cap Index Fund | A1 | B1 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Limited Duration Credit Fund | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – Loomis Sayles Growth Fund | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – MV Moderate Growth Fund | A1 | B1 | C2 | D1 | E1 | F1 | G1 | H6 |
VP – MFS Value Fund | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – Mid Cap Growth Fund | A1 | B1 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Moderate Portfolio | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – Moderately Aggressive Portfolio | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – Moderately Conservative Portfolio | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – Morgan Stanley Advantage Fund | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – Overseas Core Fund | A1 | B1 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Partners Core Bond Fund | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – Partners Core Equity Fund | A1 | B2 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Partners International Core Equity Fund | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – Partners International Growth Fund | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – Partners International Value Fund | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – Partners Small Cap Growth Fund | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – Partners Small Cap Value Fund | A1 | B2 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Select Large Cap Equity Fund | A4 | B7 | C2 | D3 | E3 | F3 | G1 | H7 |
VP – Select Large Cap Value Fund | A1 | B2 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Select Mid Cap Value Fund | A1 | B1 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Select Small Cap Value Fund | A1 | B1 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Seligman Global Technology Fund | A3 | B3 | — | D2 | E2 | F2 | F2 | H2 |
VP – T. Rowe Price Large Cap Value Fund | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – TCW Core Plus Bond Fund | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – U.S. Government Mortgage Fund | A1 | B1 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Victory Sycamore Established Value Fund | A1 | B2 | C1 | D1 | E1 | F1 | G1 | H1 |
VP – Wells Fargo Short Duration Government Fund | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
VP – Westfield Mid Cap Growth Fund | A1 | B4 | C2 | D1 | E1 | F1 | G1 | H1 |
A. | Buy or sell real estate |
A1 – | The Fund will not buy or sell real estate, unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the Fund from investing in securities or other instruments backed by real estate or securities of companies engaged in the real estate business or real estate investment trusts. For purposes of this policy, real estate includes real estate limited partnerships. |
A2 – | The Fund will not buy or sell real estate, commodities or commodity contracts. For purposes of this policy, real estate includes real estate limited partnerships. |
A3 – | The Fund will not purchase or hold any real estate, except the Fund may invest in securities secured by real estate or interests therein or issued by persons (including real estate investment trusts) which deal in real estate or interests therein. |
A4 – | The Fund will not buy or sell real estate, unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the Fund from investing in: (i) securities or other instruments backed by real estate or |
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interests in real estate, (ii) securities or other instruments of issuers or entities that deal in real estate or are engaged in the real estate business, (iii) real estate investment trusts (REITs) or entities similar to REITs formed under the laws of non-U.S. countries or (iv) real estate or interests in real estate acquired through the exercise of its rights as a holder of securities secured by real estate or interests therein. |
B. | Buy or sell physical commodities |
B1 – | The Fund will not buy or sell physical commodities unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the Fund from buying or selling options and futures contracts or from investing in securities or other instruments backed by, or whose value is derived from, physical commodities. |
B2 – | The Fund will not buy or sell physical commodities unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the Fund from buying or selling options, futures contracts and foreign currency or from investing in securities or other instruments backed by, or whose value is derived from, physical commodities. |
B3 – | The Fund will not purchase or sell commodities or commodity contracts, except to the extent permissible under applicable law and interpretations, as they may be amended from time to time. |
B4 – | The Fund will not buy or sell physical commodities unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the Fund from buying or selling options, futures contracts and foreign currency or from entering into forward currency contracts or from investing in securities or other instruments backed by, or whose value is derived from, physical commodities. |
B5 – | The Fund will not buy or sell commodities unless acquired as a result of ownership of securities or other instruments, except this shall not prevent the fund from transacting in derivative instruments relating to commodities, including but not limited to, buying or selling options, swap contracts or futures contracts or from investing in securities or other instruments backed by, or whose value is derived from, commodities. |
B6 – | The Fund will not buy or sell commodities, except that the Fund may to the extent consistent with its investment objective(s), invest in securities of companies that purchase or sell commodities or which invest in such programs, and purchase and sell options, forward contracts, futures contracts, and options on futures contracts and enter into swap contracts and other financial transactions relating to commodities. This restriction does not apply to foreign currency transactions including without limitation forward currency contracts. This restriction also does not prevent the Fund from investing up to 25% of its total assets in one or more wholly-owned subsidiaries (as described further herein and referred to herein collectively as the “Subsidiary”), thereby gaining exposure to the investment returns of commodities markets within the limitations of the federal tax requirements.* |
B7 – | The Fund will not purchase or sell commodities, except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
* | For purposes of the fundamental investment policy on buying and selling physical commodities above, at the time of the establishment of the restriction for certain Funds, swap contracts on financial instruments or rates were not within the understanding of the term “commodities.” Notwithstanding any federal legislation or regulatory action by the CFTC that subjects such swaps to regulation by the CFTC, these Funds will not consider such instruments to be commodities for purposes of this restriction. |
C. | Issuer Diversification*† |
C1 – | The Fund will not purchase more than 10% of the outstanding voting securities of an issuer, except that up to 25% of the Fund’s assets may be invested without regard to this 10% limitation. |
C2 – | The Fund will not purchase securities (except securities issued or guaranteed by the U.S. Government, its agencies or instrumentalities) of any one issuer if, as a result, more than 5% of its total assets will be invested in the securities of such issuer or it would own more than 10% of the voting securities of such issuer, except that: (a) up to 25% of its total assets may be invested without regard to these limitations; and (b) a Fund’s assets may be invested in the securities of one or more management investment companies to the extent permitted by the 1940 Act, the rules and regulations thereunder, or any applicable exemptive relief. |
C3 – | The Fund will not purchase more than 10% of the outstanding voting securities of an issuer, except that up to 25% of the Fund’s assets may be invested without regard to this 10% limitation. For tax-exempt Funds, for purposes of this policy, the terms of a municipal security determine the issuer. |
* | For purposes of applying the limitation set forth in its issuer diversification policy above, a Fund does not consider futures or swaps central counterparties, where the Fund has exposure to such central counterparties in the course of making investments in futures and securities, to be issuers. |
† | For purposes of applying the limitation set forth in its issuer diversification policy, under certain circumstances, a Fund may treat an investment, if any, in a municipal bond refunded with escrowed U.S. Government securities as an investment in U.S. Government securities. |
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D. | Lending |
D1 – | The Fund will not lend securities or participate in an interfund lending program if the total of all such loans would exceed 33 1⁄3% of the Fund’s total assets, except this fundamental investment policy shall not prohibit the Fund from purchasing money market securities, loans, loan participation or other debt securities, or from entering into repurchase agreements. |
D2 – | The Fund will not make loans, except as permitted by the 1940 Act or any rule thereunder, any SEC or SEC staff interpretations thereof or any exemptions therefrom which may be granted by the SEC. |
D3 – | The Fund will not make loans, except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
E. | Act as an underwriter |
E1 – | The Fund will not act as an underwriter (sell securities for others). However, under the securities laws, the Fund may be deemed to be an underwriter when it purchases securities directly from the issuer and later resells them. |
E2 – | The Fund will not underwrite the securities of other issuers, except insofar as the Fund may be deemed an underwriter under the 1933 Act in disposing of a portfolio security or in connection with investments in other investment companies. |
E3 – | The Fund will not underwrite any issue of securities issued by other persons within the meaning of the 1933 Act except when it might be deemed to be an underwriter either: (i) in connection with the disposition of a portfolio security; or (ii) in connection with the purchase of securities directly from the issuer where the Fund later resells such securities. This restriction shall not limit the Fund’s ability to invest in securities issued by other registered investment companies. |
F. | Borrowing |
F1 – | The Fund will not borrow money, except for temporary purposes (not for leveraging or investment) in an amount not exceeding 33 1⁄3% of its total assets (including the amount borrowed) less liabilities (other than borrowings) immediately after the borrowings. |
F2 – | The Fund will not issue senior securities or borrow money, except as permitted by the 1940 Act or any rule thereunder, any SEC or SEC staff interpretations thereof or any exceptions therefrom which may be granted by the SEC. For borrowing, the 1940 Act permits a fund to borrow up to 33 1⁄3% of its total assets (including the amounts borrowed) from banks, plus an additional 5% of its total assets for temporary purposes, which may be borrowed from banks or other sources. |
F3 – | The Fund will not borrow money except to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
G. | Issue senior securities |
G1 – | The Fund will not issue senior securities, except as permitted under the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
H. | Concentration* |
H1 – | The Fund will not concentrate in any one industry. According to the present interpretation by the SEC, this means that up to 25% of the Fund’s total assets, based on current market value at time of purchase, can be invested in any one industry. |
H2 – | The Fund will, under normal market conditions, invest at least 25% of the value of its total assets at the time of purchase in the securities of issuers conducting their principal business activities in the technology and related group of industries, provided that: (i) there is no limitation with respect to obligations issued or guaranteed by the U.S. Government, any state or territory of the United States or any of their agencies, instrumentalities or political subdivisions; and (ii) notwithstanding this limitation or any other fundamental investment limitation, assets may be invested in the securities of one or more management investment companies or subsidiaries to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
H3 – | While the Fund may invest 25% or more of its total assets in the securities of foreign governmental and corporate entities located in the same country, it will not invest 25% or more of its total assets in any single foreign governmental issuer. |
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H4 – | The Fund will not invest more than 25% of the market value of its total assets in the securities of issuers in any particular industry, except the Fund will invest more than 25% of the value of its total assets in securities of issuers principally engaged in the real estate industry and may invest without limit in securities issued or guaranteed by the U.S. government or any of its agencies or instrumentalities. |
H5 – | The Fund will not invest 25% or more of its total assets in securities of corporate issuers engaged in any one industry. The foregoing restriction does not apply to securities issued or guaranteed by the U.S. government or any of its agencies or instrumentalities, or repurchase agreements secured by them. In addition, the foregoing restriction shall not apply to or limit the Fund’s counterparties in commodities-related transactions. |
H6 – | The Fund will not purchase any securities which would cause 25% or more of the value of its total assets at the time of purchase to be invested in the securities of one or more issuers conducting their principal business activities in the same industry, provided that: (i) there is no limitation with respect to obligations issued or guaranteed by the U.S. Government, any state or territory of the United States or any of their agencies, instrumentalities or political subdivisions; and (ii) notwithstanding this limitation or any other fundamental investment limitation, assets may be invested in the securities of one or more management investment companies to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
H7 – | The Fund will not purchase any securities which would cause 25% or more of the value of its total assets at the time of purchase to be invested in the securities of one or more issuers conducting their principal business activities in the same industry, provided that: (i) there is no limitation with respect to obligations issued or guaranteed by the U.S. Government, any state or territory of the United States or any of their agencies, instrumentalities or political subdivisions; and (ii) notwithstanding this limitation or any other fundamental investment limitation, assets may be invested in the securities of one or more investment companies or subsidiaries to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. |
* | For purposes of applying the limitation set forth in its concentration policy, above, a Fund will generally use the industry classifications provided by the Global Industry Classification System (GICS) for classification of issuers of equity securities and the classifications provided by the Barclays Capital Aggregate Bond Index for classification of issues of fixed-income securities. A Fund does not consider futures or swaps clearinghouses or securities clearinghouses, where the Fund has exposure to such clearinghouses in the course of making investments in futures and securities, to be part of any industry. |
■ | Buy on margin or sell short or deal in options to buy or sell securities. |
■ | Purchase common stocks, preferred stocks, warrants, other equity securities, corporate bonds or debentures, state bonds, municipal bonds, or industrial revenue bonds. |
■ | Intentionally invest more than 25% of the Fund’s assets taken at market value in any particular industry, except with respect to investing in U.S. government or agency securities and bank obligations. Investments are varied according to what is judged advantageous under different economic conditions. |
■ | Purchase securities on margin except as permitted by the 1940 Act or any rule thereunder, any Securities and Exchange Commission (the “SEC”) or SEC staff interpretations thereof or any exemptions therefrom which may be granted by the SEC. |
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■ | Up to 25% of the Fund’s net assets may be invested in foreign investments. |
■ | Up to 20% of the Fund’s net assets may be invested in foreign investments. |
■ | Up to 20% of the Fund’s total assets may be invested in foreign investments. |
■ | Up to 15% of the Fund’s net assets may be invested in foreign investments. |
■ | The Fund will not (subject to the succeeding sentence) purchase any securities which would cause 25% or more of the value of its total assets at the time of purchase to be invested in the securities of one or more issuers conducting their principal business activities in the same industry, provided that: (i) there is no limitation with respect to government securities, cash and/or repurchase agreements collateralized solely by government securities or cash; and (ii) notwithstanding this limitation or any other fundamental investment limitation, assets may be invested in the securities of one or more management investment companies to the extent permitted by the 1940 Act, the rules and regulations thereunder and any applicable exemptive relief. If, at a future date, the Fund ceases to be a government money market fund and becomes a money market fund that may invest significantly in Rule 2a-7 eligible securities issued by non-government entities, the Fund may invest more than 25% of its total assets in money market instruments issued by U.S. banks or U.S. branches of foreign banks (subject to the applicable requirements of Rule 2a-7) and U.S. Government securities. |
■ | The Fund will not invest in oil, gas or other mineral exploration or development programs; provided, however, that this investment restriction shall not prohibit the fund from purchasing publicly-traded securities of companies engaging in whole or in part in such activities. |
■ | The Fund will not purchase securities from or sell securities to any of its officers or Trustees, except with respect to its own shares and as permissible under applicable statutes, rule ad regulations. |
■ | The Fund will not invest more than 5% of the value of its net assets, valued at the lower of cost or market, in warrants, of which no more than 2% of net assets may be invested in warrants and rights not listed on the New York or American Stock Exchange. For this purpose, warrants acquired by the fund in units or attached to securities may be deemed to have been purchased without cost. |
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Type of Investment | Equity and Flexible |
Funds-of-Funds – Equity and Fixed Income |
Taxable Fixed Income |
Money Market |
Asset-Backed Securities | • | • | • | • |
Bank Obligations (Domestic and Foreign) | • | • | • | • |
Collateralized Bond Obligations | • | • | • | • |
Commercial Paper | • | • | • | • |
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Type of Investment | Equity and Flexible |
Funds-of-Funds – Equity and Fixed Income |
Taxable Fixed Income |
Money Market |
Common Stock | • | • | •A | — |
Convertible Securities | • | • | • | — |
Corporate Debt Securities | • | • | • | •B |
Custody Receipts and Trust Certificates | • | • | • | • |
Debt Obligations | • | • | • | • |
Depositary Receipts | • | • | •C | — |
Derivatives | • | • | • | — |
Dollar Rolls | •D | • | • | — |
Exchange-Traded Notes | • | • | • | — |
Foreign Currency Transactions | • | • | • | — |
Foreign Securities | • | • | • | • |
Guaranteed Investment Contracts (Funding Agreements) | • | • | • | • |
High-Yield Securities | • | • | • | — |
Illiquid Investments | • | • | • | • |
Inflation-Protected Securities | • | • | • | — |
Initial Public Offerings | • | • | • | • |
Inverse Floaters | •E | • | • | — |
Investments in Other Investment Companies (Including ETFs) | • | • | • | • |
Listed Private Equity Funds | • | • | • | — |
Money Market Instruments | • | • | • | • |
Mortgage-Backed Securities | •F | • | • | • |
Municipal Securities | • | • | • | • |
Participation Interests | • | • | • | — |
Partnership Securities | • | • | • | — |
Preferred Stock | • | • | •G | — |
Private Placement and Other Restricted Securities | • | • | • | • |
Real Estate Investment Trusts | • | • | • | — |
Repurchase Agreements | • | • | • | • |
Reverse Repurchase Agreements | • | • | • | • |
Short Sales | • | • | • | — |
Sovereign Debt | • | • | • | • |
Standby Commitments | • | • | • | • |
U.S. Government and Related Obligations | • | • | • | • |
Variable- and Floating-Rate Obligations | •H | • | • | •I |
Warrants and Rights | • | • | • | — |
A. | The following Fund is not authorized to invest in Common Stock: VP – U.S. Government Mortgage Fund. |
B. | While the Fund is prohibited from investing in corporate bonds, it may invest in securities classified as corporate bonds if they meet the requirements of Rule 2a-7 of the 1940 Act. |
C. | The following Fund is not authorized to invest in Depository Receipts: VP – U.S. Government Mortgage Fund. |
D. | The following Funds are authorized to invest in Dollar Rolls: VP – Balanced Fund, VP – Commodity Strategy Fund, VP – Core Equity Fund, VP – Disciplined Core Fund and VP – Select Large Cap Equity Fund. |
E. | The following Funds are authorized to invest in Inverse Floaters: VP – Balanced Fund, VP – Commodity Strategy Fund, VP – Disciplined Core Fund and VP – Select Large Cap Equity Fund. |
F. | The following Funds are not authorized to invest in Mortgage-Backed Securities: VP – Large Cap Index Fund and VP – Select Small Cap Value Fund. |
G. | The following Fund is not authorized to invest in Preferred Stock: VP – U.S. Government Mortgage Fund. |
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H. | The following Funds are authorized to invest in Floating-Rate Loans: VP – Balanced, VP – Commodity Strategy Fund and VP – Select Large Cap Equity Fund. |
I. | The Fund is not authorized to invest in floating rate loans. This restriction is not intended to prevent the Fund from investing in variable and floating rate instruments that are permissible investments for money market funds under Rule 2a-7. |
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■ | Contingent Convertible Securities Risk. Contingent convertible securities, also known as contingent capital securities or “CoCos,” are hybrid securities that are typically issued by non-U.S. banks. CoCos have characteristics of both debt and equity |
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instruments,
although they are generally treated by the Funds as debt investments. If
certain “trigger events” occur, CoCos either convert into equity or
undergo a principal write-down or write-off. Trigger events, which are
defined by the documents governing the CoCo, may include a decline in the
issuer’s capital ratio below a specified trigger level, the share price of
the issuer falling to a particular level for a certain period of time,
other events indicating an increase in the issuer’s risk of insolvency,
and/or certain regulatory events, including changes in regulatory capital
requirements or regulatory actions related to the issuer’s solvency
prospects. | |
The value of CoCos may be influenced by the creditworthiness of the issuer and/or fluctuations in such issuer’s applicable capital ratios; supply and demand for CoCos; general market conditions and available liquidity; and economic, financial or political events impacting the issuer, its particular market or the financial markets more broadly. Due to the contingent conversion or principal write-down or write-off features, CoCos may have substantially greater risk than other securities in times of financial stress. The occurrence of an automatic conversion or write-down or write-off event may be unpredictable and the potential effects of such event could cause a Fund’s shares to lose value. The coupon payments offered by CoCos are discretionary and may be cancelled or adjusted downward by the issuer or at the request of the relevant regulatory authority at any point, for any reason, and for any length of time. As a result of the uncertainty with respect to coupon payments, the value of CoCos may be volatile and their price may decline rapidly if coupon payments are suspended. CoCos are typically structurally subordinated to traditional convertible bonds in the issuer’s capital structure. There may be circumstances under which investors in CoCos may suffer a capital loss ahead of equity holders or when equity holders do not. | |
Although one or more of the other risks described in this SAI may also apply, the risks typically associated with CoCos include: Convertible Securities Risk, Credit Risk, Foreign Securities Risk, High-Yield Investments Risk, Interest Rate Risk, Issuer Risk, and Market Risk. |
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■ | A forward foreign currency contract is a derivative (forward contract) in which the underlying reference is a country's or region’s currency. The Fund may agree to buy or sell a country's or region’s currency at a specific price on a specific date in the future. These instruments may fall in value (sometimes dramatically) due to foreign market downswings or foreign currency value fluctuations, subjecting the Fund to foreign currency risk (the risk that Fund performance may be negatively impacted by foreign currency strength or weakness relative to the U.S. dollar, particularly if the Fund exposes a significant percentage of its assets to currencies other than the U.S. dollar). The effectiveness of any currency hedging strategy by a Fund may be reduced by the Fund’s inability to precisely match forward contract amounts and the value of securities involved. Forward foreign currency contracts used for hedging may also limit any potential gain that might result from an increase or decrease in the value of the currency. The Fund may use these instruments to gain leveraged exposure to currencies, which is a speculative investment practice that increases the Fund's risk exposure and the possibility of losses. Unanticipated changes in the currency markets could result in reduced performance for the Fund. When the Fund converts its foreign currencies into U.S. dollars, it may incur currency conversion costs due to the spread between the prices at which it may buy and sell various currencies in the market. |
■ | A forward interest rate agreement is a derivative whereby the buyer locks in an interest rate at a future settlement date. If the interest rate on the settlement date exceeds the lock rate, the buyer pays the seller the difference between the two rates (based on the notional value of the agreement). If the lock rate exceeds the interest rate on the settlement date, the seller pays the buyer the difference between the two rates (based on the notional value of the agreement). The Fund may act as a buyer or a seller. |
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■ | A bond (or debt instrument) future is a derivative that is an agreement for the contract holder to buy or sell a bond or other debt instrument, a basket of bonds or other debt instrument, or the bonds or other debt instruments in an index on a specified date at a predetermined price. The buyer (long position) of a bond future is obliged to buy the underlying reference at the agreed price on expiry of the future. |
■ | A commodity-linked future is a derivative that is an agreement to buy or sell one or more commodities (such as crude oil, gasoline and natural gas), basket of commodities or indices of commodity futures at a specific date in the future at a specific price. |
■ | A currency future, also an FX future or foreign exchange future, is a derivative that is an agreement to exchange one currency for another at a specified date in the future at a price (exchange rate) that is fixed on the purchase date. |
■ | An equity future is a derivative that is an agreement for the contract holder to buy or sell a specified amount of an individual equity, a basket of equities or the securities in an equity index on a specified date at a predetermined price. |
■ | An interest rate future is a derivative that is an agreement whereby the buyer and seller agree to the future delivery of an interest-bearing instrument on a specific date at a pre-determined price. Examples include Treasury-bill futures, Treasury-bond futures and Eurodollar futures. |
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■ | A commodity-linked structured note is a derivative (structured investment) that has principal and/or interest payments based on the market price of one or more particular commodities (such as crude oil, gasoline and natural gas), a basket of commodities, indices of commodity futures or other economic variable. If payment of interest on a commodity-linked structured note is linked to the value of a particular commodity, basket of commodities, commodity index or other economic variable, the Fund might receive lower interest payments (or not receive any of the interest due) on its investments if there is a loss of value in the underlying reference. Further, to the extent that the amount of principal to be repaid upon maturity is linked to the value of a particular commodity, basket of commodities, commodity index or other economic variable, the Fund might not receive a portion (or any) of the principal at maturity of the investment or upon earlier exchange. At any time, the risk of loss associated with a particular structured note in the Fund’s portfolio may be significantly higher than the value of the note. A liquid secondary market may not exist for the commodity-linked structured notes held in the Fund’s portfolio, which may make it difficult for the notes to be sold at a price acceptable to the portfolio manager(s) or for the Fund to accurately value them. |
■ | An equity-linked note (ELN) is a derivative (structured investment) that has principal and/or interest payments based on the value of a single equity security, a basket of equity securities or an index of equity securities, and generally has risks similar to these underlying equity securities. ELNs may be leveraged or unleveraged. An ELN typically provides interest income, thereby offering a yield advantage over investing directly in an underlying equity. The Fund may purchase ELNs that trade on a securities exchange or those that trade on the over-the-counter markets, as well as in privately negotiated transactions with the issuer of the ELN. Investments in ELNs are also subject to liquidity risk, which may make ELNs difficult to sell and value. The liquidity of unlisted ELNs is normally determined by the willingness of the issuer to make a market in the ELN. While the Fund will seek to purchase ELNs only from issuers that it believes to be willing and able to repurchase the ELN at a reasonable price, there can be no assurance that the Fund will be able to sell at such a price. Furthermore, such inability to sell may impair the Fund’s ability to enter into other transactions at a time when doing so might be advantageous. The Fund’s investments in ELNs have the potential to lead to significant losses, including the amount the Fund invested in the ELN, because ELNs are subject to the market and volatility risks associated with their underlying equity. In addition, because ELNs often take the form of unsecured notes of the issuer, the Fund would be subject to the risk that the issuer may default on its obligations under the ELN, thereby subjecting the Fund to the further risk of being too concentrated in the securities (including ELNs) of that issuer. However, the Fund typically considers ELNs alongside other securities of the issuer in its assessment of issuer concentration risk. In addition, ELNs may exhibit price behavior that does not correlate with the underlying securities. ELNs may also be subject to leverage risk. The Fund may or may not hold an ELN until its maturity. ELNs also include participation notes. |
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■ | A commodity-linked swap is a derivative (swap) that is an agreement where the underlying reference is the market price of one or more particular commodities (such as crude oil, gasoline and natural gas), basket of commodities or indices of commodity futures. |
■ | A credit default swap (including a swap on a credit default index, sometimes referred to as a credit default swap index) is a derivative and special type of swap where one party pays, in effect, an insurance premium through a stream of payments to another party in exchange for the right to receive a specified return upon the occurrence of a particular credit event by one or more third parties, such as bankruptcy, default or a similar event. A credit default swap may be embedded within a structured note or other derivative instrument. Credit default swaps enable an investor to buy or sell protection against such a credit event (such as an issuer’s bankruptcy, restructuring or failure to make timely payments of interest or principal). Credit default swap indices are indices that reflect the performance of a basket of credit default swaps and are subject to the same risks as credit default swaps. If such a default were to occur, any contractual remedies that the Fund may have may be subject to bankruptcy and insolvency laws, which could delay or limit the Fund's recovery. Thus, if the counterparty under a credit default swap defaults on its obligation to make payments thereunder, as a result of its bankruptcy or otherwise, the Fund may lose such payments altogether, or collect only a portion thereof, which collection could involve costs or delays. The Fund’s return from investment in a credit default swap index may not match the return of the referenced index. Further, investment in a credit default swap index could result in losses if the referenced index does not perform as expected. Unexpected changes in the composition of the index may also affect performance of the credit default swap index. If a referenced index has a dramatic intraday move that causes a material decline in the Fund’s net assets, the terms of the Fund’s credit default swap index may permit the counterparty to immediately close out the transaction. In that event, the Fund may be unable to enter into another credit default swap index or otherwise achieve desired exposure, even if the referenced index reverses all or a portion of its intraday move. |
■ | An inflation rate swap is a derivative typically used to transfer inflation risk from one party to another through an exchange of cash flows. In an inflation rate swap, one party pays a fixed rate on a notional principal amount, while the other party pays a floating rate linked to an inflation index, such as the Consumer Price Index (CPI). |
■ | An interest rate swap is a derivative in which two parties agree to exchange interest rate cash flows, based on a specified notional amount from a fixed rate to a floating rate (or vice versa) or from one floating rate to another. Interest rate swaps can be based on various measures of interest rates, including swap rates, treasury rates, foreign interest rates and other reference rates. |
■ | Total return swaps are derivative swap transactions in which one party agrees to pay the other party an amount equal to the total return of a defined underlying reference during a specified period of time. In return, the other party would make periodic payments based on a fixed or variable interest rate or on the total return of a different underlying reference. |
■ | Contracts for differences are swap arrangements in which the parties agree that their return (or loss) will be based on the relative performance of two different groups or baskets of securities or other instruments. Often, one or both baskets will be an established securities index. The Fund’s return will be based on changes in value of theoretical long futures positions in the securities comprising one basket (with an aggregate face value equal to the notional amount of the contract for differences) and theoretical short futures positions in the securities comprising the other basket. The Fund also may use actual long and short futures positions and achieve similar market exposure by netting the payment obligations of the two contracts. If the short basket outperforms the long basket, the Fund will realize a loss – even in circumstances when the securities in both the long and short baskets appreciate in value. |
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■ | Large-Cap Stock Risk. Investments in larger, more established companies (larger companies) may involve certain risks associated with their larger size. For instance, larger companies may be less able to respond quickly to new competitive challenges, such as changes in consumer tastes or innovation from smaller competitors. Also, larger companies are sometimes less able to achieve as high growth rates as successful smaller companies, especially during extended periods of economic expansion. |
■ | Small- and Mid-Cap Stock Risk. Securities of small- and mid-cap companies can, in certain circumstances, have a higher potential for gains than securities of larger companies but are more likely to have more risk than larger companies. For example, small- and mid-cap companies may be more vulnerable to market downturns and adverse business or economic events than larger companies because they may have more limited financial resources and business operations. Small- and mid-cap companies are also more likely than larger companies to have more limited product lines and operating histories and to depend on smaller and generally less experienced management teams. Securities of small- and mid-cap companies may trade less frequently and in smaller volumes and may be less liquid and fluctuate more sharply in value than securities of larger companies. When the Fund takes significant positions in small- and mid-cap companies with limited trading volumes, the liquidation of those positions, particularly in a distressed market, could be prolonged and result in Fund investment losses that would affect the value of your investment in the Fund. In addition, some small- and mid-cap companies may not be widely followed by the investment community, which can lower the demand for their stocks. |
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Fund | Assets (millions) |
Annual
rate at each asset level |
VP – American Century Diversified Bond Fund | $0-$500 | 0.500% |
>$500-$1,000 | 0.495% | |
>$1,000-$2,000 | 0.480% | |
>$2,000-$3,000 | 0.460% | |
>$3,000-$6,000 | 0.445% | |
>$6,000-$7,500 | 0.430% | |
>$7,500-$9,000 | 0.415% | |
>$9,000-$12,000 | 0.410% | |
>$12,000-$20,000 | 0.390% | |
>$20,000-$24,000 | 0.380% | |
>$24,000-$50,000 | 0.360% | |
>$50,000 | 0.340% | |
VP – Balanced Fund | $0-$500 | 0.720% |
>$500-$1,000 | 0.670% | |
>$1,000-$1,500 | 0.620% | |
>$1,500-$3,000 | 0.570% | |
>$3,000-$6,000 | 0.550% | |
>$6,000-$12,000 | 0.530% | |
>$12,000 | 0.520% | |
VP – BlackRock Global Inflation-Protected Securities Fund | $0-$500 | 0.510% |
>$500-$1,000 | 0.505% | |
>$1,000-$2,000 | 0.475% | |
>$2,000-$3,000 | 0.450% | |
>$3,000-$6,000 | 0.415% | |
>$6,000-$7,500 | 0.390% | |
>$7,500-$9,000 | 0.375% | |
>$9,000-$10,000 | 0.370% | |
>$10,000-$12,000 | 0.360% | |
>$12,000-$15,000 | 0.350% | |
>$15,000-$20,000 | 0.340% | |
>$20,000-$24,000 | 0.330% | |
>$24,000-$50,000 | 0.310% | |
>$50,000 | 0.290% | |
VP – CenterSquare Real Estate Fund | $0-$500 | 0.750% |
>$500-$1,000 | 0.745% | |
>$1,000-$1,500 | 0.720% | |
>$1,500-$3,000 | 0.670% | |
>$3,000 | 0.660% | |
VP – Commodity Strategy Fund(a) | $0-$500 | 0.630% |
>$500-$1,000 | 0.580% | |
>$1,000-$3,000 | 0.550% | |
>$3,000-$6,000 | 0.520% | |
>$6,000-$12,000 | 0.500% | |
>$12,000 | 0.490% | |
VP – Core Equity Fund | All | 0.400% |
VP – Disciplined Core Fund VP – Select Large Cap Value Fund |
$0-$500 | 0.770% |
>$500-$1,000 | 0.715% | |
>$1,000-$3,000 | 0.615% | |
>$3,000-$6,000 | 0.600% | |
>$6,000-$12,000 | 0.580% | |
>$12,000 | 0.570% | |
VP – Dividend Opportunity Fund | $0-$500 | 0.720% |
>$500-$1,000 | 0.670% | |
>$1,000-$1,500 | 0.620% | |
>$1,500-$3,000 | 0.570% | |
>$3,000-$6,000 | 0.550% | |
>$6,000-$12,000 | 0.530% | |
>$12,000 | 0.520% |
Statement of Additional Information – May 1, 2021 | 91 |
Fund | Assets (millions) |
Annual
rate at each asset level |
VP – Emerging Markets Bond Fund | $0-$500 | 0.600% |
>$500-$1,000 | 0.590% | |
>$1,000-$2,000 | 0.575% | |
>$2,000-$3,000 | 0.555% | |
>$3,000-$6,000 | 0.530% | |
>$6,000-$7,500 | 0.505% | |
>$7,500-$9,000 | 0.490% | |
>$9,000-$10,000 | 0.481% | |
>$10,000-$12,000 | 0.469% | |
>$12,000-$15,000 | 0.459% | |
>$15,000-$20,000 | 0.449% | |
>$20,000-$24,000 | 0.433% | |
>$24,000-$50,000 | 0.414% | |
>$50,000 | 0.393% | |
VP – Emerging Markets Fund | $0-$500 | 1.100% |
>$500-$1,000 | 1.060% | |
>$1,000-$1,500 | 0.870% | |
>$1,500-$3,000 | 0.820% | |
>$3,000-$6,000 | 0.770% | |
>$6,000-$12,000 | 0.720% | |
>$12,000 | 0.700% | |
VP – Global Strategic Income Fund | $0-$500 | 0.650% |
>$500-$1,000 | 0.645% | |
>$1,000-$2,000 | 0.595% | |
>$2,000-$3,000 | 0.590% | |
>$3,000-$6,000 | 0.575% | |
>$6,000-$7,500 | 0.570% | |
>$7,500-$12,000 | 0.560% | |
>$12,000-$20,000 | 0.540% | |
>$20,000-$50,000 | 0.530% | |
>$50,000 | 0.520% | |
VP – Government Money Market Fund | $0-$500 | 0.390% |
>$500-$1,000 | 0.385% | |
>$1,000-$1,500 | 0.363% | |
>$1,500-$2,000 | 0.345% | |
>$2,000-$2,500 | 0.328% | |
>$2,500-$3,000 | 0.310% | |
>$3,000-$5,000 | 0.300% | |
>$5,000-$6,000 | 0.280% | |
>$6,000-$7,500 | 0.260% | |
>$7,500-$9,000 | 0.255% | |
>$9,000-$10,000 | 0.230% | |
>$10,000-$12,000 | 0.220% | |
>$12,000-$15,000 | 0.210% | |
>$15,000-$20,000 | 0.200% | |
>$20,000-$24,000 | 0.190% | |
>$24,000 | 0.180% | |
VP – High Yield Bond Fund VP – Income Opportunities Fund |
$0-$250 | 0.660% |
>$250-$500 | 0.645% | |
>$500-$750 | 0.635% | |
>$750-$1,000 | 0.625% | |
>$1,000-$2,000 | 0.610% | |
>$2,000-$3,000 | 0.600% | |
>$3,000-$6,000 | 0.565% | |
>$6,000-$7,500 | 0.540% | |
>$7,500-$9,000 | 0.525% | |
>$9,000-$10,000 | 0.500% | |
>$10,000-$12,000 | 0.485% | |
>$12,000-$15,000 | 0.475% | |
>$15,000-$20,000 | 0.465% | |
>$20,000-$24,000 | 0.440% | |
>$24,000-$50,000 | 0.425% | |
>$50,000 | 0.400% |
Statement of Additional Information – May 1, 2021 | 92 |
Fund | Assets (millions) |
Annual
rate at each asset level |
VP – Intermediate Bond Fund | $0-$500 | 0.500% |
VP – TCW Core Plus Bond Fund | >$500-$1,000 | 0.495% |
>$1,000-$2,000 | 0.480% | |
>$2,000-$3,000 | 0.460% | |
>$3,000-$6,000 | 0.450% | |
>$6,000-$7,500 | 0.430% | |
>$7,500-$9,000 | 0.415% | |
>$9,000-$12,000 | 0.410% | |
>$12,000-$20,000 | 0.390% | |
>$20,000-$24,000 | 0.380% | |
>$24,000-$50,000 | 0.360% | |
>$50,000 | 0.340% | |
VP – Large Cap Growth Fund | $0-$500 | 0.770% |
VP – Partners Core Equity Fund | >$500-$1,000 | 0.720% |
VP – Victory Sycamore Established Value Fund | >$1,000-$1,500 | 0.670% |
>$1,500-$3,000 | 0.620% | |
>$3,000-$6,000 | 0.600% | |
>$6,000-$12,000 | 0.580% | |
>$12,000 | 0.570% | |
VP – Large Cap Index Fund | All | 0.200% |
VP – Limited Duration Credit Fund | $0-$500 | 0.480% |
>$500-$1,000 | 0.475% | |
>$1,000-$2,000 | 0.465% | |
>$2,000-$3,000 | 0.460% | |
>$3,000-$6,000 | 0.445% | |
>$6,000-$7,500 | 0.430% | |
>$7,500-$9,000 | 0.415% | |
>$9,000-$10,000 | 0.410% | |
>$10,000-$12,000 | 0.400% | |
>$12,000-$15,000 | 0.390% | |
>$15,000-$20,000 | 0.380% | |
>$20,000-$24,000 | 0.370% | |
>$24,000-$50,000 | 0.350% | |
>$50,000 | 0.330% | |
VP – Loomis Sayles Growth Fund | $0-$500 | 0.710% |
VP – MFS Value Fund | >$500-$1,000 | 0.705% |
VP – T. Rowe Price Large Cap Value Fund | >$1,000-$2,000 | 0.650% |
>$2,000-$3,000 | 0.550% | |
>$3,000-$12,000 | 0.540% | |
>$12,000 | 0.530% | |
VP – Mid Cap Growth Fund | $0-$500 | 0.820% |
VP – Select Mid Cap Value Fund | >$500-$1,000 | 0.770% |
>$1,000-$1,500 | 0.720% | |
>$1,500-$3,000 | 0.670% | |
>$3,000-$12,000 | 0.660% | |
>$12,000 | 0.650% | |
VP – Morgan Stanley Advantage Fund | $0-$500 | 0.710% |
>$500-$1,000 | 0.705% | |
>$1,000-$1,500 | 0.650% | |
>$1,500-$2,000 | 0.600% | |
>$2,000-$3,000 | 0.550% | |
>$3,000-$12,000 | 0.540% | |
>$12,000 | 0.530% |
Statement of Additional Information – May 1, 2021 | 93 |
Fund | Assets (millions) |
Annual
rate at each asset level |
VP – Overseas Core Fund | $0-$250 | 0.880% |
>$250-$500 | 0.855% | |
>$500-$750 | 0.825% | |
>$750-$1,000 | 0.800% | |
>$1,000-$1,500 | 0.770% | |
>$1,500-$3,000 | 0.720% | |
>$3,000-$6,000 | 0.700% | |
>$6,000-$12,000 | 0.680% | |
>$12,000-$20,000 | 0.670% | |
>$20,000-$24,000 | 0.660% | |
>$24,000-$50,000 | 0.650% | |
>$50,000 | 0.620% | |
VP – Partners Core Bond Fund | $0-$500 | 0.500% |
>$500-$1,000 | 0.495% | |
>$1,000-$2,000 | 0.480% | |
>$2,000-$3,000 | 0.460% | |
>$3,000-$6,000 | 0.445% | |
>$6,000-$7,500 | 0.430% | |
>$7,500-$9,000 | 0.415% | |
>$9,000-$12,000 | 0.410% | |
>$12,000-$20,000 | 0.390% | |
>$20,000-$24,000 | 0.380% | |
>$24,000-$50,000 | 0.360% | |
>$50,000 | 0.340% | |
VP – Partners International Core Equity Fund(b) | $0-$500 | 0.870% |
VP – Partners International Value Fund | >$500-$1,000 | 0.820% |
>$1,000-$1,500 | 0.770% | |
>$1,500-$3,000 | 0.720% | |
>$3,000-$6,000 | 0.700% | |
>$6,000-$12,000 | 0.680% | |
>$12,000 | 0.670% | |
VP – Partners International Growth Fund(c) | $0-$500 | 0.920% |
>$500-$1,000 | 0.870% | |
>$1,000-$1,500 | 0.820% | |
>$1,500-$3,000 | 0.770% | |
>$3,000-$12,000 | 0.760% | |
>$12,000 | 0.750% | |
VP – Select Large Cap Equity Fund | $0-$500 | 0.770% |
>$500-$1,000 | 0.720% | |
>$1,000-$1,500 | 0.670% | |
>$1,500-$3,000 | 0.620% | |
>$3,000-$6,000 | 0.600% | |
>$6,000-$12,000 | 0.580% | |
>$12,000 | 0.570% | |
VP – Select Small Cap Value Fund | $0-$500 | 0.870% |
VP – Partners Small Cap Growth Fund | >$500-$1,000 | 0.820% |
VP – Partners Small Cap Value Fund | >$1,000-$3,000 | 0.770% |
>$3,000-$12,000 | 0.760% | |
>$12,000 | 0.750% | |
VP – Seligman Global Technology Fund | $0-$500 | 0.915% |
>$500-$1,000 | 0.910% | |
>$1,000-$3,000 | 0.905% | |
>$3,000-$4,000 | 0.865% | |
>$4,000-$6,000 | 0.815% | |
>$6,000-$12,000 | 0.765% | |
>$12,000 | 0.755% |
Statement of Additional Information – May 1, 2021 | 94 |
Fund | Assets (millions) |
Annual
rate at each asset level |
VP – U.S. Government Mortgage Fund | $0-$500 | 0.430% |
VP – Wells Fargo Short Duration Government Fund | >$500-$1,000 | 0.425% |
>$1,000-$2,000 | 0.415% | |
>$2,000-$3,000 | 0.410% | |
>$3,000-$6,000 | 0.395% | |
>$6,000-$7,500 | 0.380% | |
>$7,500-$9,000 | 0.365% | |
>$9,000-$10,000 | 0.360% | |
>$10,000-$12,000 | 0.350% | |
>$12,000-$15,000 | 0.340% | |
>$15,000-$20,000 | 0.330% | |
>$20,000-$24,000 | 0.320% | |
>$24,000-$50,000 | 0.300% | |
>$50,000 | 0.280% | |
VP – Westfield Mid Cap Growth Fund | $0-$500 | 0.810% |
>$500-$1,000 | 0.805% | |
>$1,000-$2,000 | 0.750% | |
>$2,000-$3,000 | 0.700% | |
>$3,000-$12,000 | 0.690% | |
>$12,000 | 0.680% |
(a) | When calculating asset levels for purposes of determining fee breakpoints, asset levels are based on net assets of the Fund, including assets invested in any wholly-owned subsidiary advised by the Investment Manager (“Subsidiaries”). Fees payable by the Fund under this agreement shall be reduced by any management services fees paid to the Investment Manager by any Subsidiaries under separate management agreements with the Subsidiaries. |
(b) | Effective May 1, 2018, the management fee schedule changed resulting in a fee rate decrease for all asset levels. |
(c) | Effective July 1, 2018, the management fee schedule changed resulting in a fee rate decrease for certain asset levels. |
Fund | Assets (millions) |
Annual
rate at each asset level |
VP – Aggressive Portfolio VP – Conservative Portfolio VP – Moderate Portfolio VP – Moderately Aggressive Portfolio VP – Moderately Conservative Portfolio VP – MV Moderate Growth Fund |
$0 - $500 | 0.720% |
>$500 - $1,000 | 0.670% | |
>$1,000 - $1,500 | 0.620% | |
>$1,500 - $3,000 | 0.570% | |
>$3,000 - $6,000 | 0.550% | |
>$6,000 - $12,000 | 0.530% | |
>$12,000 | 0.520% |
Statement of Additional Information – May 1, 2021 | 95 |
Management Services Fees | |||
2020 | 2019 | 2018 | |
For Funds with fiscal period ending December 31 | |||
VP – Aggressive Portfolio | $1,213,162 | $1,129,069 | $1,264,264 |
VP – American Century Diversified Bond Fund | 14,729,173 | 10,606,832 | 17,078,890 |
VP – Balanced Fund | 7,829,847 | 7,477,461 | 7,726,212 |
VP – BlackRock Global Inflation-Protected Securities Fund | 541,942 | 578,041 | 612,777 |
VP – CenterSquare Real Estate Fund | 1,893,889 | 3,811,958 | 3,316,890 |
VP – Commodity Strategy Fund | 994,692 | 2,527,621 | 2,784,979 |
VP – Conservative Portfolio | 640,938 | 563,358 | 566,496 |
VP – Core Equity Fund | 735,130 | 768,386 | 833,010 |
VP – Disciplined Core Fund | 30,575,080 | 33,524,090 | 34,505,935 |
VP – Dividend Opportunity Fund | 8,996,093 | 9,854,871 | 10,928,630 |
VP – Emerging Markets Bond Fund | 2,461,473 | 1,650,275 | 1,291,461 |
VP – Emerging Markets Fund | 4,110,742 | 4,899,467 | 6,650,856 |
VP – Global Strategic Income Fund | 690,952 | 740,869 | 840,798 |
VP – Government Money Market Fund | 1,645,686 | 1,549,508 | 1,559,441 |
VP – High Yield Bond Fund | 2,097,619 | 2,287,706 | 2,528,890 |
VP – Income Opportunities Fund | 2,281,641 | 2,261,803 | 2,285,519 |
VP – Intermediate Bond Fund | 21,906,917 | 21,572,199 | 21,886,451 |
VP – Large Cap Growth Fund | 14,494,418 | 13,196,923 | 12,978,676 |
VP – Large Cap Index Fund | 2,505,360 | 2,025,360 | 1,504,405 |
VP – Limited Duration Credit Fund | 3,530,837 | 3,661,210 | 3,756,689 |
VP – Loomis Sayles Growth Fund | 14,988,521 | 15,370,205 | 14,270,167 |
VP – MFS Value Fund | 9,676,210 | 11,038,713 | 13,720,441 |
VP – Mid Cap Growth Fund | 4,294,014 | 4,111,647 | 4,079,235 |
VP – Moderate Portfolio | 7,482,484 | 6,458,492 | 6,547,026 |
VP – Moderately Aggressive Portfolio | 4,866,795 | 3,861,872 | 3,905,274 |
VP – Moderately Conservative Portfolio | 1,608,496 | 1,495,232 | 1,485,499 |
VP – Morgan Stanley Advantage Fund | 12,657,036 | 14,940,238 | 13,425,182 |
VP – MV Moderate Growth Fund | 26,588,894 | 25,436,718 | 25,710,531 |
VP – Overseas Core Fund | 13,952,906 | 9,290,306 | 9,486,691 |
VP – Partners Core Bond Fund | 21,504,181 | 17,140,949 | 15,258,927 |
VP – Partners Core Equity Fund | 19,849,022 | 14,475,930 | 13,965,602 |
VP – Partners International Core Equity Fund | 20,839,358 | 23,133,876 | 20,565,530 |
VP – Partners International Growth Fund | 9,287,227 | 7,761,679 | 13,859,903 |
VP – Partners International Value Fund | 8,039,691 | 7,210,107 | 13,175,262 |
VP – Partners Small Cap Growth Fund | 5,292,397 | 5,404,251 | 6,013,848 |
VP – Partners Small Cap Value Fund | 5,036,977 | 6,122,700 | 6,875,779 |
VP – Select Large Cap Equity Fund | 10,211,123 | 9,017,547 | 4,672,522(a) |
Statement of Additional Information – May 1, 2021 | 96 |
Management Services Fees | |||
2020 | 2019 | 2018 | |
VP – Select Large Cap Value Fund | $11,166,412 | $9,150,135 | $9,610,985 |
VP – Select Mid Cap Value Fund | 2,297,602 | 2,462,706 | 2,459,771 |
VP – Select Small Cap Value Fund | 605,518 | 737,036 | 848,498 |
VP – Seligman Global Technology Fund | 950,209 | 777,781 | 787,475 |
VP – T. Rowe Price Large Cap Value Fund | 10,009,425 | 13,532,956 | 15,460,008 |
VP – TCW Core Plus Bond Fund | 15,079,017 | 13,305,463 | 13,647,839 |
VP – U.S. Government Mortgage Fund | 4,355,917 | 4,226,983 | 4,277,183 |
VP – Victory Sycamore Established Value Fund | 4,514,480 | 4,703,484 | 4,589,674 |
VP – Wells Fargo Short Duration Government Fund | 6,596,957 | 8,257,971 | 4,440,155 |
VP – Westfield Mid Cap Growth Fund | 4,564,897 | 4,789,091 | 4,633,435 |
(a) | For the period from January 4, 2018 (commencement of operations) to December 31, 2018. |
Statement of Additional Information – May 1, 2021 | 97 |
Fund | Subadviser | Parent Company/Other Information |
Fee Schedule or Aggregate Effective Fee Rates |
VP – American Century Diversified Bond Fund | American
Century (effective May 10, 2010) |
A | 0.090% on the first $3.5 billion, declining to 0.080% as assets increase(a) |
VP – BlackRock Global Inflation-Protected Securities Fund(b) | BlackRock (effective October 19, 2012) |
B | 0.150% on the first $250 million, declining to 0.050% as assets increase |
Sub-Subadviser: BIL (effective May 1, 2018) |
R | 50% of fee paid to BlackRock | |
VP – CenterSquare Real Estate Fund | CenterSquare (effective June 1, 2016) |
Q | 0.400% on the first $200 million, declining to 0.300% as assets increase |
VP – Commodity Strategy Fund | Threadneedle (effective April 30, 2013) |
D | 0.250% on all assets |
VP – Loomis Sayles Growth Fund | Loomis
Sayles (effective March 21, 2014) |
L | 0.265% on the first $3 billion, declining to 0.250% as assets increase(c) |
VP – MFS Value Fund | MFS (effective May 10, 2010) |
G | 0.350% on the first $100 million, declining to 0.175% as assets increase |
Statement of Additional Information – May 1, 2021 | 98 |
Fund | Subadviser | Parent Company/Other Information |
Fee Schedule or Aggregate Effective Fee Rates |
VP – Morgan Stanley Advantage Fund | MSIM (effective May 2, 2016) |
H | 0.300% on the first $500 million, declining to 0.225% as assets increase |
VP – Overseas Core Fund | Threadneedle (effective July 9, 2004) |
D | 0.350% on all assets |
VP – Partners Core Bond Fund | JPMIM (effective May 10, 2010) WellsCap (effective May 1, 2017) |
E J |
0.094%(d) |
VP – Partners Core Equity Fund | JPMIM (effective on or about May 3, 2021) T. Rowe Price (effective May 20, 2019) |
E I |
0.213%(e)(f) |
VP – Partners International Core Equity Fund(g) | SIMNA
Inc. (effective May 12, 2020) |
T | 0.315% on all assets(h) |
Sub-Subadviser:
SIMNA Ltd. (effective May 12, 2020) |
U | 63% of fee paid to SIMNA Inc. | |
VP – Partners International Growth Fund | William
Blair (effective May 20, 2019) Walter Scott (effective May 15, 2020) |
M V |
0.346% |
VP – Partners International Value Fund | Pzena (effective on or about May 3, 2021) TSW (effective May 18, 2020) |
C W |
0.344%(i) |
VP – Partners Small Cap Growth Fund | Scout (effective May 20, 2019) WellsCap (effective May 10, 2010) |
S J |
0.400%(j) |
VP – Partners Small Cap Value Fund(k) | William
Blair (effective on or about May 3, 2021) Sub-Subadviser: ICM (effective on or about May 3, 2021) SBH (effective August 20, 2014) |
M K N |
0.431%(l) |
VP – T. Rowe Price Large Cap Value Fund | T.
Rowe Price (effective November 14, 2016) |
I | 0.475% on the first $50 million, declining to 0.250% on all assets as asset levels increase(m)(e) |
VP – TCW Core Plus Bond Fund | TCW (effective March 21, 2014) |
O | 0.180% on the first $500 million, declining to 0.050% as asset levels increase(n) |
VP – Victory Sycamore Established Value Fund | Victory
Capital (effective November 16, 2012) |
P | 0.320% on the first $400 million, declining to 0.300% as assets increase |
VP – Wells Fargo Short Duration Government Fund | WellsCap (effective May 10, 2010) |
J | 0.180% on the first $500 million, declining to 0.0925% as assets increase(o) |
VP – Westfield Mid Cap Growth Fund | Westfield (effective September 18, 2017) |
F | 0.400% on assets up to $250 million, declining to 0.300% as asset levels increase |
Statement of Additional Information – May 1, 2021 | 99 |
(a) | Effective December 1, 2020, the subadvisory fee schedule changed resulting in a fee rate decrease for certain asset levels. |
(b) | BIL assists in providing day-to-day portfolio management to the Fund pursuant to the sub-subadvisory agreement with BlackRock. BlackRock will pay BIL for its services. |
(c) | Effective April 1, 2020, the subadvisory fee schedule changed resulting in a fee rate decrease for all asset levels. |
(d) | Effective January 1, 2021, the subadvisory services fee schedule for each of JPMIM and WellsCap changed. The rate shown is the estimated aggregate effective fee rate that will be paid by the Investment Manager to the subadvisers for the Fund beginning on January 1, 2021. |
(e) | Effective May 20, 2019, T. Rowe Price has agreed to a voluntary subadvisory fee waiver arrangement whereby the subadvisory fee for the Fund (or portion thereof subadvised by T. Rowe Price) is reduced by 2.5% on combined assets of VP – T. Rowe Price Large Cap Value Fund and the portion of VP – Partners Core Equity Fund subadvised by T. Rowe Price up to $1 billion, increasing to 15% as combined assets increase. |
(f) | Effective on or about May 3, 2021, JPMIM will assume day-to-day management of a portion of the Fund’s portfolio. The rate shown is the estimated aggregate effective fee rate that will be paid by the Investment Manager to the subadvisers for the Fund beginning on or about May 3, 2021. |
(g) | SIMNA Ltd. assists in providing day-to-day portfolio management to the Fund pursuant to the sub-subadvisory agreement with SIMNA Inc. SIMNA Inc. will pay SIMNA Ltd. for its services. |
(h) | Effective February 1, 2021, the subadvisory fee schedule changed resulting in a fee rate decrease for all asset levels. |
(i) | Effective on or about May 3, 2021, Pzena will assume day-to-day management of a portion of the Fund’s portfolio. The rate shown is the estimated aggregate effective fee rate that will be paid by the Investment Manager to the subadvisers for the Fund beginning on or about May 3, 2021. |
(j) | Effective January 1, 2021, the subadvisory services fee schedule for WellsCap changed. The rate shown is the estimated aggregate effective fee rate that will be paid by the Investment Manager to the subadvisers for the Fund beginning on April 30, 2021. |
(k) | ICM assists in providing day-to-day portfolio management to the Fund pursuant to the sub-subadvisory agreement with William Blair. William Blair will pay ICM for its services. |
(l) | Effective May 1, 2021, the subadvisory services fee schedule for SBH changed. Additionally, effective on or about May 3, 2021, William Blair and ICM will assume day-to-day management of a portion of the Fund’s portfolio. The rate shown is the estimated aggregate effective fee rate that will be paid by the Investment Manager to the subadvisers for the Fund beginning on or about May 3, 2021. |
(m) | Effective November 1, 2018, the subadvisory fee schedule changed resulting in a fee rate decrease for all asset levels. |
(n) | The fee is calculated based on the combined net assets of certain Columbia Funds subject to the subadviser’s investment management. |
(o) | Effective January 1, 2021, the breakpoint levels and associated fee rates changed and the assets of VP – Wells Fargo Short Duration Government Fund are aggregated with the assets of VP – Partners Core Bond Fund subadvised by WellsCap for purposes of the fee calculation. Although fee rates increased for certain breakpoint levels, the changes overall are expected to decrease the fees paid to WellsCap. |
Statement of Additional Information – May 1, 2021 | 100 |
Subadvisory Fees Paid | ||||
Fund | Subadviser | 2020 | 2019 | 2018 |
For Funds with fiscal period ending December 31 | ||||
VP – American Century Diversified Bond Fund | American Century | $3,565,012 | $2,651,716 | $4,123,735 |
VP – BlackRock Global Inflation-Protected Securities Fund | BlackRock | 159,391 | 169,991 | 179,146 |
VP – CenterSquare Real Estate Fund | CenterSquare | 954,198 | 1,726,043 | 1,519,080 |
Statement of Additional Information – May 1, 2021 | 101 |
Subadvisory Fees Paid | ||||
Fund | Subadviser | 2020 | 2019 | 2018 |
VP – Commodity Strategy Fund | Threadneedle (provided services through 12/9/2019) |
N/A | $921,466(h) | $1,102,233 |
VP – Loomis Sayles Growth Fund | Loomis Sayles | $6,018,039 | 6,285,802 | 5,705,064 |
VP – MFS Value Fund | MFS | 3,967,176 | 4,519,126 | 5,337,619 |
VP – Morgan Stanley Advantage Fund | MSIM | 4,884,737 | 5,788,992 | 5,146,660 |
VP – Overseas Core Fund | Threadneedle (provided services through 5/1/2018) |
N/A | N/A | 1,356,650(m) |
VP – Partners Core Bond Fund | Subadvisers | 5,066,566(c) | 3,985,464(c) | 3,498,972(c) |
VP – Partners Core Equity Fund | Subadvisers | 6,031,942(d) | 4,145,113(d) | 3,241,513(d),(l) |
VP – Partners International Core Equity Fund | Subadvisers | 6,900,238(g) | 6,587,518(g),(k) | 6,625,978(g),(k) |
VP – Partners International Growth Fund | Subadvisers | 3,608,581(b) | 2,939,000(b),(j) | 5,189,706(b),(j) |
VP – Partners International Value Fund | Subadvisers | 2,410,719(a) | 1,784,030(a),(i) | 3,382,486(a),(i) |
VP – Partners Small Cap Growth Fund | Subadvisers | 2,357,567(e) | 2,192,617(e) | 2,799,714(e) |
VP – Partners Small Cap Value Fund | Subadvisers | 2,678,958(f) | 3,274,721(f) | 3,698,424(f) |
VP – T. Rowe Price Large Cap Value Fund | T. Rowe Price | 3,720,533 | 4,843,071 | 6,307,215 |
VP – TCW Core Plus Bond Fund | TCW | 2,371,809 | 2,161,833 | 2,126,863 |
VP – Victory Sycamore Established Value Fund | Victory Capital | 1,878,189 | 1,959,446 | 1,898,484 |
VP – Wells Fargo Short Duration Government Fund | WellsCap | 1,871,508 | 2,350,271 | 1,245,853 |
VP – Westfield Mid Cap Growth Fund | Westfield | 1,992,728 | 2,076,033 | 2,008,389 |
(a) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2018, 2019 and 2020, which amounted to 0.210%, 0.210%, and 0.253% respectively, of the Fund’s daily net assets as of each fiscal year end. |
(b) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2018, 2019 and 2020, which amounted to 0.335%, 0.340%, and 0.346% respectively, of the Fund’s daily net assets as of each fiscal year end. |
(c) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2018, 2019, and 2020, which amounted to 0.110%, 0.110%, and 0.110%, respectively, of the Fund’s daily net assets as of each fiscal year end. |
(d) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2018, 2019, and 2020, which amounted to 0.226%, 0.198%, and 0.204% respectively, of the Fund’s daily net assets as of each fiscal year end. |
(e) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2018, 2019, and 2020, which amounted to 0.401%, 0.349%, and 0.383% respectively, of the Fund’s daily net assets as of each fiscal year end. |
(f) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2018, 2019, and 2020, which amounted to 0.460%, 0.457%, and 0.459% respectively, of the Fund’s daily net assets as of each fiscal year end. |
(g) | The fees shown represent the aggregate amount paid by the Investment Manager, with respect to the Fund, to all non-affiliated subadvisers for 2018, 2019 and 2020, which amounted to 0.263%, 0.219%, and 0.257% respectively, of the Fund’s daily net assets as of each fiscal year end. |
(h) | Threadneedle provided services to the Fund pursuant to the subadvisory agreement through December 9, 2019. Accordingly, the amount shown is for the period from January 1, 2019 to December 9, 2019. |
(i) | Dimensional Fund Advisors LP served as the sole subadviser to the Fund from November 16, 2011 to May 18, 2020. The total subadvisory fees paid to Dimensional Fund Advisors LP by the Investment Manager for the fiscal year ended December 31, 2018 and December 31, 2019 was $3,382,486 and $1,784,030, respectively. |
(j) | OppenheimerFunds Inc. served as the sole subadviser to the Fund from May 1, 2016 to May 20, 2019. William Blair served as the sole subadviser to the Fund from May 20, 2019 to May 15, 2020. The total subadvisory fees paid to OppenheimerFunds Inc. by the Investment Manager for the fiscal year ended December 31, 2018 and December 31, 2019 was $5,189,706 and $1,205,739, respectively. The total subadvisory fees paid to William Blair by the Investment Manager for the fiscal year ended December 31, 2019 was $1,733,261. |
Statement of Additional Information – May 1, 2021 | 102 |
(k) | Pyramis Global Advisors, LLC served as the sole subadviser to the Fund from May 10, 2010 to May 21, 2018. AQR Capital Management, LLC served as the sole subadviser to the Fund from May 21, 2018 to May 12, 2020. The total subadvisory fees paid to Pyramis Global Advisors, LLC by the Investment Manager for the fiscal year ended December 31, 2018 was $3,263,365. The total subadvisory fees paid to AQR Capital Management, LLC by the Investment Manager for the fiscal year ended December 31, 2018 and December 31, 2019 was $3,362,613 and $6,587,518, respectively. |
(l) | Massachusetts Financial Services Company served as the sole subadviser to the Fund From May 2, 2016 to May 20, 2019. The total subadvisory fees paid to Massachusetts Financial Services Company by the Investment Manager for the fiscal year ended December 31, 2018 was $3,241,513. |
(m) | Threadneedle provided services to the Fund pursuant to the subadvisory agreement through May 1, 2018. Accordingly, the amount shown is for the period from January 1, 2018 to May 1, 2018. |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager | Number
and type of account* |
Approximate Total Net Assets |
Performance Based Accounts** |
Potential Conflicts of Interest |
Structure
of Compensation |
Information is as of December 31, 2020, unless otherwise noted | ||||||
VP – Aggressive Portfolio | Joshua Kutin | 40
RICs 6 PIVs 29 other accounts |
$74.21
billion $0.36 million $5.94 million |
None | Columbia Management - FoF |
Columbia Management |
David Weiss | 20
RICs 10 other accounts |
$67.42
billion $1.92 million |
None | |||
Anwiti Bahuguna | 21
RICs 28 PIVs 34 other accounts |
$75.59
billion $4.08 billion $131.47 million |
None | |||
Brian Virginia | 15
RICs 9 other accounts |
$67.46
billion $3.26 million |
None | |||
VP – American Century Diversified Bond Fund | American
Century: Alejandro Aguilar |
16 RICs 2 other accounts |
$21.39 billion $563.08 million |
None |
American Century |
American Century |
Robert Gahagan | 17
RICs 2 other accounts |
$21.55
billion $563.08 million |
None | |||
Jeffrey Houston | 11
RICs 6 other accounts |
$12.98
billion $1.42 billion |
None | |||
Brian Howell | 18
RICs 7 other accounts |
$21.99
billion $1.79 billion |
None | |||
Charles Tan | 10
RICs 1 other account |
$10.74
billion $188.15 million |
None | |||
VP – Balanced Fund | Gregory Liechty | 3
RICs 10 PIVs 45 other accounts |
$6.52
billion $2.15 billion $5.79 billion |
None | Columbia Management | Columbia Management |
Guy Pope | 9
RICs 7 PIVs 87 other accounts |
$18.97
billion $1.36 billion $3.50 billion |
None | |||
Ronald Stahl | 3
RICs 10 PIVs 47 other accounts |
$6.52
billion $2.15 billion $6.06 billion |
None | |||
Jason Callan | 14
RICs 9 PIVs 7 other accounts |
$21.76
billion $13.56 billion $306.48 million |
None |
Statement of Additional Information – May 1, 2021 | 103 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager | Number
and type of account* |
Approximate Total Net Assets |
Performance Based Accounts** |
Potential Conflicts of Interest |
Structure
of Compensation |
VP – BlackRock Global Inflation-Protected Securities Fund | BlackRock: Akiva Dickstein |
24 RICs 27 PIVs 266 other accounts |
$29.32 billion $9.91 billion $101.60 billion |
6 other accounts ($2.17 B) |
BlackRock |
BlackRock |
Emanuella Enenajo | 6
RICs 3 PIVs 19 other accounts |
$4.26
billion $705.30 million $8.54 billion |
2
other accounts ($687.20 M) | |||
Sub-Subadviser:
BIL: Christopher Allen |
7
RICs 13 PIVs 23 other accounts |
$6.82
billion $15.73 billion $9.64 billion |
2
other accounts ($687.20 M) | |||
VP – CenterSquare Real Estate Fund | CenterSquare: Dean Frankel |
4 RICs 7 PIVs 59 other accounts |
$732.00 million $545.00 million $4.99 billion |
5 other accounts ($639.00 M) |
CenterSquare |
CenterSquare |
Eric Rothman | 3
RICs 3 PIVs |
$1.12
billion $392.00 million |
None | |||
VP – Commodity Strategy Fund | Matthew Ferrelli | 2
RICs 2 other accounts |
$1.13
billion $0.23 million |
None | Columbia Management | Columbia Management |
Marc Khalamayzer | 2
RICs 6 other accounts |
$1.13
billion $0.56 million |
None | |||
Ronald Stahl(f) | 4
RICs 9 PIVs 37 Other Accounts |
$7.52
billion $2.16 billion $5.45 billion |
None | |||
Gregory Liechty(f) | 4
RICs 9 PIVs 45 Other Accounts |
$7.52
billion $2.16 billion $5.99 billion |
None | |||
John Dempsey(f) | 3 Other Accounts | $0.50 million | None | |||
VP – Conservative Portfolio | Joshua Kutin | 40
RICs 6 PIVs 29 other accounts |
$75.37
billion $0.36 million $5.94 million |
None | Columbia Management - FoF |
Columbia Management |
David Weiss | 20
RICs 10 other accounts |
$68.57
billion $1.92 million |
None | |||
Anwiti Bahuguna | 21
RICs 28 PIVs 34 other accounts |
$76.74
billion $4.08 billion $131.47 million |
None | |||
Brian Virginia | 15
RICs 9 other accounts |
$68.61
billion $3.26 million |
None | |||
VP – Core Equity Fund | Peter Albanese | 6
RICs 1 PIV 59 other accounts |
$12.10
billion $31.96 million $5.86 billion |
1
other account ($290.33 M) |
Columbia Management | Columbia Management |
Raghavendran Sivaraman | 6
RICs 21 other accounts |
$12.10
billion $5.86 billion |
None | |||
VP – Disciplined Core Fund | Peter Albanese | 6
RICs 1 PIV 59 other accounts |
$7.25
billion $31.96 million $5.86 billion |
1
other account ($290.33 M) |
Columbia Management | Columbia Management |
Raghavendran Sivaraman | 6
RICs 21 other accounts |
$7.25
billion $5.86 billion |
None |
Statement of Additional Information – May 1, 2021 | 104 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager | Number
and type of account* |
Approximate Total Net Assets |
Performance Based Accounts** |
Potential Conflicts of Interest |
Structure
of Compensation |
VP – Dividend Opportunity Fund | David King | 5
RICs 6 other accounts |
$7.40
billion $28.82 million |
None | Columbia Management | Columbia Management |
Yan Jin | 5
RICs 10 other accounts |
$7.40
billion $7.11 million |
None | |||
Grace Lee | 5
RICs 8 other accounts |
$7.40
billion $2.84 million |
None | |||
VP – Emerging Markets Bond Fund | Adrian Hilton | 3
RICs 13 PIVs 18 other accounts |
$478.51
million $3.49 billion $4.67 billion |
None | Threadneedle | Threadneedle |
Christopher Cooke | 2
RICs 7 PIVs 2 other accounts |
$370.29
million $6.17 billion $390.05 million |
None | |||
VP – Emerging Markets Fund | Dara White | 3
RICs 6 PIVs 11 other accounts |
$2.06
billion $1.31 billion $3.19 billion |
None | Columbia Management | Columbia Management |
Robert Cameron | 2
RICs 3 PIVs 15 other accounts |
$1.86
billion $474.07 million $2.64 billion |
None | |||
Perry Vickery | 2
RICs 3 PIVs 14 other accounts |
$1.86
billion $472.48 million $2.72 billion |
None | |||
Derek Lin | 3
RICs 2 PIVs 12 other accounts |
$2.06
billion $450.15 million $2.64 billion |
None | |||
Darren Powell(a) | 1
RIC 3 other accounts |
$727.20
million $0.97 million |
None | |||
VP – Global Strategic Income Fund | Adrian Hilton | 3
RICs 13 PIVs 18 other accounts |
$848.85
million $3.49 billion $4.67 billion |
None | Threadneedle | Threadneedle |
Ryan Staszewski | 9
PIVs 14 other accounts |
$4.60
billion $4.94 billion |
None | |||
David Janssen(b) | 1
RIC 9 other accounts |
$894.00
million $0.21 million |
None | Columbia Management | Columbia Management | |
VP – High Yield Bond Fund | Brian Lavin | 6
RICs 1 PIV 16 other accounts |
$3.56
billion $285.78 million $2.09 billion |
None | Columbia Management | Columbia Management |
Daniel DeYoung | 4
RICs 1 PIV 5 other accounts |
$4.12
billion $5.55 billion $124.61 million |
None | |||
VP – Income Opportunities Fund | Brian Lavin | 6
RICs 1 PIV 16 other accounts |
$3.52
billion $285.78 million $2.09 billion |
None | Columbia Management | Columbia Management |
Daniel DeYoung | 4
RICs 1 PIV 5 other accounts |
$4.08
billion $5.55 billion $124.61 million |
None | |||
VP – Intermediate Bond Fund | Gene Tannuzzo | 8
RICs 1 PIV 91 other accounts |
$11.59
billion $100.79 million $1.65 billion |
None | Columbia Management | Columbia Management |
Jason Callan | 14
RICs 9 PIVs 7 other accounts |
$17.35
billion $13.56 billion $306.48 million |
None | |||
Alexandre (Alex) Christensen(b) | 6 other accounts | $0.22 million | None |
Statement of Additional Information – May 1, 2021 | 105 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager | Number
and type of account* |
Approximate Total Net Assets |
Performance Based Accounts** |
Potential Conflicts of Interest |
Structure
of Compensation |
VP – Large Cap Growth Fund | Melda Mergen | 6
RICs 18 other accounts |
$9.35
billion $732.75 million |
None | Columbia Management | Columbia Management |
Tiffany Wade(b) | 3
RICs 9 other accounts |
$3.80
billion $565.00 million |
None | |||
VP – Large Cap Index Fund | Christopher Lo | 10
RICs 1 PIV 29 other accounts |
$11.22
billion $90.91 million $2.31 billion |
None | Columbia Management | Columbia Management |
Kaiyu Zhao | 3
RICs 1 PIV |
$10.83
billion $90.91 million |
None | |||
Christopher Rowe | 3
RICs 1 PIV 9 other accounts |
$10.83
billion $90.91 million $0.25 million |
None | |||
VP – Limited Duration Credit Fund | Tom Murphy | 8
RICs 15 PIVs 28 other accounts |
$4.25
billion $23.13 billion $4.24 billion |
None | Columbia Management | Columbia Management |
Royce Wilson | 7
RICs 22 other accounts |
$4.18
billion $3.88 billion |
None | |||
John Dawson | 7
RICs 24 other accounts |
$4.18
billion $3.88 billion |
None | |||
VP – Loomis Sayles Growth Fund | Loomis
Sayles: Aziz Hamzaogullari |
32 RICs 19 PIVs 146 other accounts |
$30.80 billion $12.35 billion $31.63 billion |
1 PIV ($666.50 M) 1 other account (318.00 M) |
Loomis Sayles |
Loomis Sayles |
VP – MFS Value Fund | MFS: Katherine Cannan |
11 RICs 3 PIVs 17 other accounts |
$68.60 billion $3.80 billion $9.10 billion |
None |
MFS |
MFS |
Nevin Chitkara | 16
RICs 9 PIVs 35 other accounts |
$74.60
billion $6.80 billion $20.20 billion |
None | |||
VP – Mid Cap Growth Fund | Daniel Cole(c) | 2
RICs 1 PIV 55 other accounts |
$2.99
billion $7.58 million $19.06 million |
None | Columbia Management | Columbia Management |
Erika Maschmeyer | 2
RICs 6 other accounts |
$6.94
billion $22.37 million |
None | Columbia WAM | Columbia Management | |
John Emerson | 2
RICs 19 other accounts |
$2.19
billion $22.91 million |
None | |||
VP – Moderate Portfolio | Joshua Kutin | 40
RICs 6 PIVs 29 other accounts |
$59.14
billion $0.36 million $5.94 million |
None | Columbia Management - FoF |
Columbia Management |
David Weiss | 20
RICs 10 other accounts |
$52.35
billion $1.92 million |
None | |||
Anwiti Bahuguna | 21
RICs 28 PIVs 34 other accounts |
$60.51
billion $4.08 billion $131.47 million |
None | |||
Brian Virginia | 15
RICs 9 other accounts |
$52.38
billion $3.26 million |
None |
Statement of Additional Information – May 1, 2021 | 106 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager | Number
and type of account* |
Approximate Total Net Assets |
Performance Based Accounts** |
Potential Conflicts of Interest |
Structure
of Compensation |
VP – Moderately Aggressive Portfolio | Joshua Kutin | 40
RICs 6 PIVs 29 other accounts |
$69.09
billion $0.36 million $5.94 million |
None | Columbia Management - FoF |
Columbia Management |
David Weiss | 20
RICs 10 other accounts |
$62.29
billion $1.92 million |
None | |||
Anwiti Bahuguna | 21
RICs 28 PIVs 34 other accounts |
$70.46
billion $4.08 billion $131.47 million |
None | |||
Brian Virginia | 15
RICs 9 other accounts |
$62.33
billion $3.26 million |
None | |||
VP – Moderately Conservative Portfolio | Joshua Kutin | 40
RICs 6 PIVs 29 other accounts |
$73.61
billion $0.36 million $5.94 million |
None | Columbia Management - FoF |
Columbia Management |
David Weiss | 20
RICs 10 other accounts |
$66.82
billion $1.92 million |
None | |||
Anwiti Bahuguna | 21
RICs 28 PIVs 34 other accounts |
$74.98
billion $4.08 billion $131.47 million |
None | |||
Brian Virginia | 15
RICs 9 other accounts |
$66.85
billion $3.26 million |
None | |||
VP – Morgan Stanley Advantage Fund | MSIM: Dennis Lynch |
22 RICs 22 PIVs 17 other accounts |
$46.47 billion $29.23 billion $9.51 billion |
2 other accounts ($671.70 M) |
MSIM |
MSIM |
Sam Chainani | 21
RICs 21 PIVs 16 other accounts |
$46.45
billion $29.22 billion $9.39 billion |
2 other accounts ($671.70 M) | |||
Jason Yeung | 21
RICs 21 PIVs 16 other accounts |
$46.45
billion $29.22 billion $9.39 billion |
2 other accounts ($671.70 M) | |||
Armistead Nash | 21
RICs 21 PIVs 16 other accounts |
$46.45
billion $29.22 billion $9.39 billion |
2 other accounts ($671.70 M) | |||
David Cohen | 21
RICs 21 PIVs 16 other accounts |
$46.45
billion $29.22 billion $9.39 billion |
2 other accounts ($671.70 M) | |||
Alexander Norton | 21
RICs 21 PIVs 16 other accounts |
$46.45
billion $29.22 billion $9.39 billion |
2 other accounts ($671.70 M) | |||
VP – MV Moderate Growth Fund | Joshua Kutin | 40
RICs 6 PIVs 29 other accounts |
$60.89
billion $0.36 million $5.94 million |
None | Columbia Management - FoF |
Columbia Management |
David Weiss | 20
RICs 10 other accounts |
$54.10
billion $1.92 million |
None | |||
Anwiti Bahuguna | 21
RICs 28 PIVs 34 other accounts |
$62.27
billion $4.08 billion $131.47 million |
None | |||
Brian Virginia | 15
RICs 9 other accounts |
$54.14
billion $3.26 million |
None |
Statement of Additional Information – May 1, 2021 | 107 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager | Number
and type of account* |
Approximate Total Net Assets |
Performance Based Accounts** |
Potential Conflicts of Interest |
Structure
of Compensation |
VP – Overseas Core Fund | Fred Copper | 6
RICs 1 PIV 14 other accounts |
$3.96
billion $24.74 million $169.08 million |
None | Columbia Management | Columbia Management |
Daisuke Nomoto | 5
RICs 2 PIVs 11 other accounts |
$3.08
billion $1.28 billion $11.50 million |
None | |||
VP – Partners Core Bond Fund | JPMIM: Richard Figuly |
27 RICs 11 PIVs 15 other accounts |
$71.39 billion $17.93 billion $5.67 billion |
1 other account ($1.10 B) |
JPMIM |
JPMIM |
Steven Lear | 8
RICs 5 PIVs 9 other accounts |
$60.76
billion $14.94 billion $2.20 billion |
None | |||
Andrew Norelli | 3
RICs 3 PIVs 1 other account |
$23.53
billion $8.91 billion $785.00 million |
None | |||
Lisa Coleman | 12
RICs 18 PIVs 19 other accounts |
$20.85
billion $23.23 billion $36.31 billion |
None | |||
Thomas Hauser | 17
RICs 15 PIVs 28 other accounts |
$42.44
billion $34.23 billion $5.84 billion |
1
RIC ($86.00 M) | |||
WellsCap: Maulik Bhansali |
8 RICs 5 PIVs 32 other accounts |
$19.09 billion $3.18 billion $13.41 billion |
1 PIV ($36.97 M) 2 other accounts ($660.05 M) |
WellsCap |
WellsCap | |
Jarad Vasquez | 8
RICs 5 PIVs 32 other accounts |
$19.09
billion $3.18 billion $13.41 billion |
1
PIV ($36.97 M) 2 other accounts ($660.05 M) | |||
VP – Partners Core Equity Fund | T.
Rowe Price: Jeffrey Rottinghaus(e) |
3 RICs 8 PIVs 1 other account |
$4.92 billion $5.24 billion $2.93 million |
None |
T. Rowe Price |
T. Rowe Price |
JPMIM: Scott Davis(a) |
6 RICs 1 PIV 29 other accounts |
$25.78 billion $3.36 billion $12.48 billion |
2 other accounts ($1.22 B) |
JPMIM |
JPMIM | |
David Small(a) | 6
RICs 1 PIV 29 other accounts |
$25.78
billion $3.36 billion $12.48 billion |
2
other accounts ($1.22 B) | |||
VP – Partners International Core Equity Fund | SIMNA
Inc. Sub-Subadviser: SIMNA Ltd.: James Gautrey |
5 RICs 4 PIVs 11 other accounts |
$24.79 billion $822.60 million $3.74 billion |
2 RICs ($22.92 B) 1 PIV ($109.00 M) |
Schroders |
Schroders |
Simon Webber | 6
RICs 5 PIVs 13 other accounts |
$24.83
billion $3.40 billion $5.65 billion |
2
RICs ($22.91 B) 1 PIV ($109.00 M) 1 other account (1.75 B) |
Statement of Additional Information – May 1, 2021 | 108 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager | Number
and type of account* |
Approximate Total Net Assets |
Performance Based Accounts** |
Potential Conflicts of Interest |
Structure
of Compensation |
VP – Partners International Growth Fund | William
Blair: Simon Fennell |
10 RICs 19 PIVs 47 other accounts |
$8.47 billion $5.00 billion $13.41 billion |
None |
William Blair |
William Blair |
Kenneth McAtamney | 10
RICs 24 PIVs 45 other accounts |
$8.26
billion $4.92 billion $14.15 billion |
None | |||
Walter
Scott: Roy Leckie |
3 RICs 32 PIVs 152 other accounts |
$7.56 billion $24.90 billion $59.99 billion |
1 PIV ($39.00 M) 17 other accounts ($11.88 B) |
Walter Scott |
Walter Scott | |
Charlie Macquaker | 3
RICs 32 PIVs 152 other accounts |
$7.56
billion $24.90 billion $59.99 billion |
1
PIV ($39.00 M) 17 other accounts ($11.88 B) | |||
Jane Henderson | 3
RICs 32 PIVs 152 other accounts |
$7.56
billion $24.90 billion $59.99 billion |
1
PIV ($39.00 M) 17 other accounts ($11.88 B) | |||
VP – Partners International Value Fund | TSW: Brandon Harrell |
6 RICs 6 PIVs 13 other accounts |
$7.28 billion $1.50 billion $4.82 billion |
None |
TSW |
TSW |
Pzena: John Goetz(a) |
9 RICs 50 PIVs 49 other accounts |
$3.29 billion $13.70 billion $13.00 billion |
1 RIC ($238.10 M) 3 PIVs ($531.80 M) 2 other accounts ($401.50 M) |
Pzena |
Pzena | |
Caroline Cai(a) | 9
RICs 50 PIVs 49 other accounts |
$3.29
bilion $13.70 billion $12.75 billion |
1
RIC ($238.10 M) 3 PIVs ($531.80 M) 2 other accounts ($401.50 M) | |||
Allison Fisch(a) | 10
RICs 26 PIVs 26 other accounts |
$3.30
billion $3.69 billion $6.73 billion |
1
RIC ($238.10 M) 1 PIV ($33.60 M) |
Statement of Additional Information – May 1, 2021 | 109 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager | Number
and type of account* |
Approximate Total Net Assets |
Performance Based Accounts** |
Potential Conflicts of Interest |
Structure
of Compensation |
VP – Partners Small Cap Growth Fund | Scout: James McBride |
1 RIC 1 PIV 3 other accounts |
$375.43 million $0.90 million $12.99 million |
None |
Scout |
Scout |
Timothy Miller | 1
RIC 1 PIV 3 other accounts |
$375.43
million $0.90 million $12.99 million |
None | |||
WellsCap: Thomas Ognar |
7 RICs 6 PIVs 43 other accounts |
$11.90 billion $2.17 billion $1.54 billion |
None |
WellsCap |
WellsCap | |
Joseph Eberhardy(d) | 7
RICs 6 PIVs 43 other accounts |
$11.90
billion $2.17 billion $1.54 billion |
None | |||
Robert Gruendyke | 7
RICs 6 PIVs 43 other accounts |
$11.90
billion $2.17 billion $1.54 billion |
None | |||
David Nazaret | 2
RICs 1 PIV 2 other accounts |
$1.36
billion $69.73 million $109.01 million |
None | |||
VP – Partners Small Cap Value Fund | SBH: Mark Dickherber |
3 RICs 111 other accounts |
$508.32 million $1.92 billion |
None |
SBH |
SBH |
Shaun Nicholson | 2
RICs 62 other accounts |
$459.43
million $1.33 billion |
None | |||
William
Blair Sub-Subadviser: ICM: William Heaphy(a) |
1 RIC 13 other accounts |
$1.88 billion $1.78 billion |
1 other account ($866.45 M) |
ICM |
ICM | |
VP – Select Large Cap Equity Fund | Melda Mergen | 6
RICs 18 other accounts |
$8.96
billion $732.75 million |
None | Columbia Management | Columbia Management |
Tiffany Wade | 2
RICs 9 other accounts |
$518.34
million $569.38 million |
None | |||
VP – Select Large Cap Value Fund | Richard Rosen | 2
RICs 284 other accounts |
$1.49
billion $2.68 billion |
None | Columbia Management | Columbia Management |
Richard Taft | 2
RICs 285 other accounts |
$1.49
billion $2.68 billion |
None | |||
VP – Select Mid Cap Value Fund | Kari Montanus | 3
RICs 12 other accounts |
$2.78
billion $6.39 million |
None | Columbia Management | Columbia Management |
Jonas Patrikson | 3
RICs 14 other accounts |
$2.78
billion $5.04 million |
None | |||
VP – Select Small Cap Value Fund | Kari Montanus | 3
RICs 12 other accounts |
$3.03
billion $6.39 million |
None | Columbia Management | Columbia Management |
Jonas Patrikson | 3
RICs 14 other accounts |
$3.03
billion $5.04 million |
None |
Statement of Additional Information – May 1, 2021 | 110 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager | Number
and type of account* |
Approximate Total Net Assets |
Performance Based Accounts** |
Potential Conflicts of Interest |
Structure
of Compensation |
VP – Seligman Global Technology Fund | Paul Wick | 4
RICs 4 PIVs 5 other accounts |
$11.42
billion $1.42 billion $377.20 million |
None | Columbia Management | Columbia Management – Tech Team |
Shekhar Pramanick | 4
RICs 6 other accounts |
$11.42
billion $5.83 million |
None | |||
Sanjay Devgan | 3
RICs 4 other accounts |
$10.98
billion $3.28 million |
None | |||
Christopher Boova | 4
RICs 8 other accounts |
$11.42
billion $7.06 million |
None | |||
Vimal Patel | 4
RICs 8 other accounts |
$11.42
billion $5.75 million |
None | |||
Sanjiv Wadhwani(b) | 7 other accounts | $2.18 million | None | |||
VP – T. Rowe Price Large Cap Value Fund | T.
Rowe Price: Heather McPherson |
5 RICs 9 PIVs 18 other accounts |
$11.19 billion $2.47 billion $4.62 billion |
None |
T. Rowe Price |
T. Rowe Price |
Mark Finn | 10
RICs 15 PIVs 22 other accounts |
$49.05
billion $32.31 billion $6.08 billion |
None | |||
John Linehan | 17
RICs 18 PIVs 26 other accounts |
$37.82
billion $15.77 billion $6.44 billion |
None | |||
VP – TCW Core Plus Bond Fund | TCW: Tad Rivelle |
28 RICs 51 PIVs 212 other accounts |
$126.10 billion $22.63 billion $56.11 billion |
28 PIVs ($3.51 B) 9 other accounts ($6.59 B) |
TCW |
TCW |
Laird Landmann | 27
RICs 20 PIVs 182 other accounts |
$119.71
billion $16.57 billion $42.08 billion |
3
PIVs ($618.00 M) 7 other accounts ($4.64 B) | |||
Stephen Kane | 30
RICs 30 PIVs 195 other accounts |
$119.46
billion $19.90 billion $47.13 billion |
10
PIVs ($2.68 B) 7 other accounts ($4.64 B) | |||
Bryan Whalen | 25
RICs 42 PIVs 202 other accounts |
$118.48
billion $19.38 billion $51.45 billion |
21
PIVs ($1.45 B) 9 other accounts ($6.59 B) | |||
VP – U.S. Government Mortgage Fund | Jason Callan | 14
RICs 9 PIVs 7 other accounts |
$21.11
billion $13.56 billion $306.48 million |
None | Columbia Management | Columbia Management |
Tom Heuer | 4
RICs 5 other accounts |
$4.30
billion $4.57 million |
None | |||
Ryan Osborn | 3
RICs 6 other accounts |
$4.28
billion $1.81 million |
None |
Statement of Additional Information – May 1, 2021 | 111 |
Other Accounts Managed (excluding the Fund) | ||||||
Fund | Portfolio Manager | Number
and type of account* |
Approximate Total Net Assets |
Performance Based Accounts** |
Potential Conflicts of Interest |
Structure
of Compensation |
VP – Victory Sycamore Established Value Fund | Victory
Capital: Gary Miller |
5 RICs 4 PIVs 22 other accounts |
$21.17 billion $709.57 million $1.87 billion |
None |
Victory Capital |
Victory Capital |
Gregory Conners | 5
RICs 4 PIVs 22 other accounts |
$21.17
billion $709.57 million $1.87 billion |
None | |||
Jeffrey Graff | 5
RICs 4 PIVs 22 other accounts |
$21.17
billion $709.57 million $1.87 billion |
None | |||
James Albers | 5
RICs 4 PIVs 22 other accounts |
$21.17
billion $709.57 million $1.87 billion |
None | |||
Michael Rodarte | 5
RICs 4 PIVs 22 other accounts |
$21.17
billion $709.57 million $1.87 billion |
None | |||
VP – Wells Fargo Short Duration Government Fund | WellsCap: Maulik Bhansali |
8 RICs 5 PIVs 32 other accounts |
$19.92 billion $3.18 billion $13.41 billion |
1 PIV ($36.97 M) 2 other accounts ($660.05 M) |
WellsCap |
WellsCap |
Jarad Vasquez | 8
RICs 5 PIVs 32 other accounts |
$19.92
billion $3.18 billion $13.41 billion |
1
PIV ($36.97 M) 2 other accounts ($660.05 M) | |||
VP – Westfield Mid Cap Growth Fund | Westfield: William Muggia |
9 RICs 8 PIVs 274 other accounts |
$3.76 billion $1.42 billion $11.22 billion |
1 PIV ($37.00 M) 23 other accounts ($3.09 B) |
Westfield |
Westfield |
Richard Lee | 8
RICs 5 PIVs 221 other accounts |
$3.62
billion $1.36 billion $9.68 billion |
19
other accounts ($2.10 B) | |||
Ethan Meyers | 8
RICs 5 PIVs 221 other accounts |
$3.62
billion $1.36 billion $9.68 billion |
19
other accounts ($2.10 B) |
* | RIC refers to a Registered Investment Company; PIV refers to a Pooled Investment Vehicle. |
** | Number of accounts for which the advisory fee paid is based in part or wholly on performance and the aggregate net assets in those accounts. |
(a) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of February 28, 2021. |
(b) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of January 31, 2021. |
(c) | The portfolio manager began managing the Fund after its last fiscal year end. |
(d) | Mr. Eberhardy expects to retire from WellsCap on or about June 30, 2021. Accordingly, effective June 30, 2021, all references to Mr. Eberhardy in the SAI for the Fund are hereby removed. |
(e) | Mr. Rottinghaus expects to step down as portfolio manager of T. Rowe Price on or about April 1, 2022 and will be succeeded by Shawn Driscoll. Accordingly, effective April 1, 2022, all references to Mr. Rottinghaus in the SAI for the Fund are hereby removed. |
(f) | The portfolio manager began managing the Fund after its last fiscal year end; reporting information is provided as of March 31, 2021. |
Statement of Additional Information – May 1, 2021 | 112 |
Statement of Additional Information – May 1, 2021 | 113 |
CenterSquare: From time to time, potential conflicts of interest may arise between a portfolio manager’s management of the investments of the Fund, on the one hand, and the management of other accounts, on the other. The portfolio managers oversee the investment of various types of accounts in the same strategy, such as mutual funds, pooled investment vehicles and separate accounts for individuals and institutions. Investment decisions generally are applied to all accounts utilizing that particular strategy, taking into consideration client restrictions, instructions and individual needs. A portfolio manager may manage an account whose fees may be higher or lower than the fee charged to the Fund to provide for varying client circumstances. Management of multiple funds and accounts may create potential conflicts of interest relating to the allocation of investment opportunities, and the aggregation and allocation of client trades. Additionally, the management of the Fund and other accounts may result in a portfolio manager devoting unequal time and attention to the management of the Fund or other accounts. | |
During the normal course of managing assets for multiple clients of varying types and asset levels, the portfolio managers may encounter conflicts of interest, that could, if not properly addressed, be harmful to one or more of our clients. Those of a material nature that are encountered most frequently involve security selection, employee personal securities trading, proxy voting and the allocation of securities. To mitigate these conflicts and ensure its clients are not impacted negatively by the adverse actions of CenterSquare or its employees, CenterSquare has implemented a series of policies including, but not limited to, its Code of Ethics, which addresses avoidance of conflicts of interest and includes the firm’s personal security trading policies, which addresses personal security trading and requires the use of approved brokers, Trade Allocation/Aggregation Policy, which addresses fairness of trade allocation to client accounts, and the Proxy and Trade Error Policies which are designed to prevent and detect conflicts when they occur. CenterSquare reasonably believes that these and other policies combined with the periodic review and testing performed by its compliance professionals adequately protects the interest of its clients. A portfolio manager may also face other potential conflicts of interest in managing the Fund, and the description above is not a complete description of every conflict of interest that could be deemed to exist in managing both the Fund and the other accounts listed above. |
Columbia Management: Like other investment professionals with multiple clients, a Fund’s portfolio manager(s) may face certain potential conflicts of interest in connection with managing both the Fund and other accounts at the same time. The Investment Manager and the Funds have adopted compliance policies and procedures that attempt to address certain of the potential conflicts that portfolio managers face in this regard. Certain of these conflicts of interest are summarized below. | |
The management of accounts with different advisory fee rates and/or fee structures, including accounts that pay advisory fees based on account performance (performance fee accounts), may raise potential conflicts of interest for a portfolio manager by creating an incentive to favor higher fee accounts. | |
Potential conflicts of interest also may arise when a portfolio manager has personal investments in other accounts that may create an incentive to favor those accounts. As a general matter and subject to the Investment Manager’s Code of Ethics and certain limited exceptions, the Investment Manager’s investment professionals do not have the opportunity to invest in client accounts, other than the funds. | |
A portfolio manager who is responsible for managing multiple funds and/or accounts may devote unequal time and attention to the management of those Funds and/or accounts. The effects of this potential conflict may be more pronounced where Funds and/or accounts managed by a particular portfolio manager have different investment strategies. | |
A portfolio manager may be able to select or influence the selection of the broker/dealers that are used to execute securities transactions for the Funds. A portfolio manager’s decision as to the selection of broker/dealers could produce disproportionate costs and benefits among the Funds and the other accounts the portfolio manager manages. |
Statement of Additional Information – May 1, 2021 | 114 |
A potential conflict of interest may arise when a portfolio manager buys or sells the same securities for a Fund and other accounts. On occasions when a portfolio manager considers the purchase or sale of a security to be in the best interests of a Fund as well as other accounts, the Investment Manager’s trading desk may, to the extent consistent with applicable laws and regulations, aggregate the securities to be sold or bought in order to obtain the best execution and lower brokerage commissions, if any. Aggregation of trades may create the potential for unfairness to a Fund or another account if a portfolio manager favors one account over another in allocating the securities bought or sold. The Investment Manager and its Participating Affiliates may coordinate their trading operations for certain types of securities and transactions pursuant to personnel-sharing agreements or similar intercompany arrangements. However, typically the Investment Manager does not coordinate trading activities with a Participating Affiliate with respect to accounts of that Participating Affiliate unless such Participating Affiliate is also providing trading services for accounts managed by the Investment Manager. Similarly, a Participating Affiliate typically does not coordinate trading activities with the Investment Manager with respect to accounts of the Investment Manager unless the Investment Manager is also providing trading services for accounts managed by such Participating Affiliate. As a result, it is possible that the Investment Manager and its Participating Affiliates may trade in the same instruments at the same time, in the same or opposite direction or in different sequence, which could negatively impact the prices paid by the Fund on such instruments. Additionally, in circumstances where trading services are being provided on a coordinated basis for the Investment Manager’s accounts (including the Funds) and the accounts of one or more Participating Affiliates in accordance with applicable law, it is possible that the allocation opportunities available to the Funds may be decreased, especially for less actively traded securities, or orders may take longer to execute, which may negatively impact Fund performance. | |
“Cross trades,” in which a portfolio manager sells a particular security held by a Fund to another account (potentially saving transaction costs for both accounts), could involve a potential conflict of interest if, for example, a portfolio manager is permitted to sell a security from one account to another account at a higher price than an independent third party would pay. The Investment Manager and the Funds have adopted compliance procedures that provide that any transactions between a Fund and another account managed by the Investment Manager are to be made at a current market price, consistent with applicable laws and regulations. | |
Another potential conflict of interest may arise based on the different investment objectives and strategies of a Fund and other accounts managed by its portfolio manager(s). Depending on another account’s objectives and other factors, a portfolio manager may give advice to and make decisions for a Fund that may differ from advice given, or the timing or nature of decisions made, with respect to another account. A portfolio manager’s investment decisions are the product of many factors in addition to basic suitability for the particular account involved. Thus, a portfolio manager may buy or sell a particular security for certain accounts, and not for a Fund, even though it could have been bought or sold for the Fund at the same time. A portfolio manager also may buy a particular security for one or more accounts when one or more other accounts are selling the security (including short sales). There may be circumstances when a portfolio manager’s purchases or sales of portfolio securities for one or more accounts may have an adverse effect on other accounts, including the Funds. | |
To the extent a Fund invests in underlying funds, a portfolio manager will be subject to the potential conflicts of interest described in Potential Conflicts of Interest – Columbia Management – FOF (Fund-of-Funds) below. | |
A Fund’s portfolio manager(s) also may have other potential conflicts of interest in managing the Fund, and the description above is not a complete description of every conflict that could exist in managing the Fund and other accounts. Many of the potential conflicts of interest to which the Investment Manager’s portfolio managers are subject are essentially the same or similar to the potential conflicts of interest related to the investment management activities of the Investment Manager and its affiliates. |
Columbia Management – FoF (Fund-of-Funds): Management of funds-of-funds differs from that of the other Funds. The portfolio management process is set forth generally below and in more detail in the Funds’ prospectus. | |
Portfolio managers of the fund-of-funds may be involved in determining each funds-of-fund’s allocation among the three main asset classes (equity, fixed income and cash) and the allocation among investment categories within each asset class, as well as each funds-of-fund’s allocation among the underlying funds. |
■ | Because of the structure of the funds-of-funds, the potential conflicts of interest for the portfolio managers may be different than the potential conflicts of interest for portfolio managers who manage other Funds. |
■ | The Investment Manager and its affiliates may receive higher compensation as a result of allocations to underlying funds with higher fees. |
Statement of Additional Information – May 1, 2021 | 115 |
Statement of Additional Information – May 1, 2021 | 116 |
Statement of Additional Information – May 1, 2021 | 117 |
Statement of Additional Information – May 1, 2021 | 118 |
Statement of Additional Information – May 1, 2021 | 119 |
Statement of Additional Information – May 1, 2021 | 120 |
Statement of Additional Information – May 1, 2021 | 121 |
■ | Conflicts of interest may arise where the Company or its employees have reason to favor the interests of one client over another client. Favoritism of one client over another client constitutes a breach of fiduciary duty. |
■ | Employees are prohibited from using knowledge about pending or currently considered securities transactions for clients to profit personally, directly or indirectly, as a result of such transactions, including by purchasing or selling such securities. Conflicts raised by Personal Security Transactions also are addressed more specifically below. |
■ | If the Company determines that an employee’s Beneficial Ownership of a Security presents a material conflict, the employee may be restricted from participating in any decision-making process regarding the Security. This may be particularly true in the case of proxy voting, and employees are expected to refer to and strictly adhere to the Company’s proxy voting policies and procedures in this regard. |
■ | Employees are required to act in the best interests of the firm's clients regarding execution and other costs paid by clients for brokerage services. Employees are expected to refer to and strictly adhere to the Company’s Best Execution policies and procedures. |
■ | Access Persons are not permitted to knowingly sell to or purchase from a client any security or other property, except Securities issued by the client. |
Scout: Scout and its affiliates may have proprietary interests in, and may manage or advise with respect to, accounts or funds (including separate accounts and other funds and collective investment vehicles) that have investment objectives similar to those of the Fund and/or that engage in transactions in the same types of securities and instruments as the Fund. Scout has adopted policies and procedures to address the allocation of investment opportunities, the execution of portfolio transactions and other potential conflicts of interest that are designed to ensure that all clients are treated fair and equitably over time. Scout and its affiliates or their clients are or may be actively engaged in transactions in the same securities and instruments in which the Fund invests. Such activities could affect the prices and availability of the securities and instruments in which the Fund invests, which could have an adverse impact on the Fund’s performance. When Scout seeks to purchase or sell the same assets for their managed accounts, including the Fund, the assets actually purchased or sold may |
Statement of Additional Information – May 1, 2021 | 122 |
be allocated among the accounts on a basis determined in their good faith discretion to be equitable in accordance with Scout’s policies and procedures. In some cases, these transactions may adversely affect the size or price of the assets purchased or sold for the Fund. Further, transactions in investments by one or more other accounts or clients advised by Scout may have the effect of diluting or otherwise disadvantaging the values, prices or investment strategies of the Fund. This may occur when investment decisions regarding the Fund are based on research or other information that is also used to support decisions or advice for other accounts. When Scout or one of its other clients implements a portfolio decision or strategy on behalf of another account ahead of, or contemporaneously with, similar decisions or strategies for the Fund, market impact, liquidity constraints or other factors could result in the Fund receiving less favorable trading results and the costs of implementing such decisions or strategies could be increased or the Fund could otherwise be disadvantaged. Such transactions, particularly in respect of most proprietary accounts or customer accounts, may be executed independently of the Fund’s transactions and thus at prices or rates that may be more or less favorable than those obtained by the Fund. Employees of Scout, including investment personnel, may buy and sell securities for their own personal accounts that are also bought and sold for the Fund. Scout has adopted and enforces a Code of Ethics that requires employees to follow standards of conduct when conducting these personal transactions. | |
T. Rowe Price: Portfolio managers at T. Rowe Price and its affiliates may manage multiple accounts. These accounts may include, among others, mutual funds, separate accounts (assets managed on behalf of institutions such as pension funds, colleges and universities, and foundations), offshore funds and common trust funds. Portfolio managers make investment decisions for each portfolio based on the investment objectives, policies, practices, and other relevant investment considerations that the managers believe are applicable to that portfolio. Consequently, portfolio managers may purchase (or sell) securities for one portfolio and not another portfolio. T. Rowe Price and its affiliates have adopted brokerage and trade allocation policies and procedures that they believe are reasonably designed to address any potential conflicts associated with managing multiple accounts for multiple clients. Also, the portfolio managers’ compensation is determined in the same manner with respect to all portfolios managed by the portfolio manager. | |
The T. Rowe Price funds may, from time to time, own shares of Morningstar, Inc. Morningstar is a provider of investment research to individual and institutional investors, and publishes ratings on mutual funds, including the T. Rowe Price funds. T. Rowe Price manages the Morningstar retirement plan and acts as subadvisor to two mutual funds offered by Morningstar. In addition, T. Rowe Price and its affiliates pay Morningstar for a variety of products and services. In addition, Morningstar may provide investment consulting and investment management services to clients of T. Rowe Price or its affiliates. | |
Since the T. Rowe Price funds and other accounts have different investment objectives or strategies, potential conflicts of interest may arise in executing investment decisions or trades among client accounts. For example, if T. Rowe Price purchases a security for one account and sells the same security short for another account, such a trading pattern could disadvantage either the account that is long or short. It is possible that short sale activity could adversely affect the market value of long positions in one or more T. Rowe Price funds and other accounts (and vice versa) and create potential trading conflicts, such as when long and short positions are being executed at the same time. To mitigate these potential conflicts of interest, T. Rowe Price has implemented policies and procedures requiring trading and investment decisions to be made in accordance with T. Rowe Price’s fiduciary duties to all accounts, including the T. Rowe Price funds. Pursuant to these policies, portfolio managers are generally prohibited from managing multiple strategies where they hold the same security long in one strategy and short in another, except in certain circumstances, including where an investment oversight committee has specifically reviewed and approved the holdings or strategy. Additionally, T. Rowe Price has implemented policies and procedures that it believes are reasonably designed to ensure the fair and equitable allocation of trades, both long and short, to minimize the impact of trading activity across client accounts. T. Rowe Price monitors short sales to determine whether its procedures are working as intended and that such short sale activity is not materially impacting our trade executions and long positions for other clients. | |
TCW: TCW has policies and controls to avoid and/or mitigate conflicts of interest across its businesses. The policies and procedures in TCW’s Code of Ethics (the “Code”) serve to address or mitigate both conflicts of interest and the appearance of any conflict of interest. The Code contains several restrictions and procedures designed to eliminate conflicts of interest relating to personal investment transactions, including (i) reporting account openings, changes, or closings (including accounts in which an Access Person has a "beneficial interest"), (ii) pre-clearance of non-exempt personal investment transactions (make a personal trade request for Securities) and (iii) the completion of timely required reporting (Initial Holdings Report, Quarterly Transactions Report, Annual Holdings Report and Annual Certificate of Compliance). | |
In addition, the Code addresses potential conflicts of interest through its policies on insider trading, anti-corruption, an employee’s outside business activities, political activities and contributions, confidentiality and whistleblower provisions. | |
Conflicts of interest may also arise in the management of accounts and investment vehicles. These conflicts may raise questions that would allow TCW to allocate investment opportunities in a way that favors certain accounts or investment vehicles over other accounts or investment vehicles, or incentivize a TCW portfolio manager to receive greater |
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compensation with regard to the management of certain account or investment vehicles. TCW may give advice or take action with certain accounts or investment vehicles that could differ from the advice given or action taken on other accounts or investment vehicles. When an investment opportunity is suitable for more than one account or investment vehicle, such investments will be allocated in a manner that is fair and equitable under the circumstances to all TCW clients. As such, TCW has adopted compliance policies and procedures in its Portfolio Management Policy that helps to identify a conflict of interest and then specifies how a conflict of interest is managed. TCW’s Trading and Brokerage Policy also discusses the process of timing and method of allocations, and addresses how the firm handles affiliate transactions. | |
The respective Equity and Fixed Income Trading and Allocation Committees review trading activities on behalf of client accounts, including the allocation of investment opportunities and address any issues with regard to side-by-side management in order to ensure that all of TCW’s clients are treated on a fair and equitable basis. Further, the Portfolio Analytics Committee reviews TCW’s investment strategies, evaluates various analytics to facilitate risk assessment, changes to performance composites and benchmarks and monitors the implementation and maintenance of the Global Investment Performance Standards or GIPS® compliance. | |
TCW’s approach to handling conflicts of interest is multi-layered starting with its policies and procedures, reporting and pre-clearance processes and oversight by various committees. |
Threadneedle: Threadneedle portfolio managers may manage one or more mutual funds as well as other types of accounts, including proprietary accounts, separate accounts for institutions, and other pooled investment vehicles. Portfolio managers make investment decisions for an account or portfolio based on its investment objectives and policies, and other relevant investment considerations. A portfolio manager may manage a separate account or other pooled investment vehicle whose fees may be materially greater than the management fees paid by the Fund and may include a performance-based fee. Management of multiple funds and accounts may create potential conflicts of interest relating to the allocation of investment opportunities, and the aggregation and allocation of trades. In addition, a portfolio manager’s responsibilities at Threadneedle include working as a securities analyst. This dual role may give rise to conflicts with respect to making investment decisions for accounts that he/she manages versus communicating his/her analyses to other portfolio managers concerning securities that he/she follows as an analyst. | |
Threadneedle has a fiduciary responsibility to all of the clients for which it manages accounts. Threadneedle seeks to provide best execution of all securities transactions and to aggregate securities transactions and then allocate securities to client accounts in a fair and timely manner. Threadneedle has developed policies and procedures, including brokerage and trade allocation policies and procedures, designed to mitigate and manage the potential conflicts of interest that may arise from the management of multiple types of accounts for multiple clients. | |
TSW: Policy. All TSW associates have a duty to act for the benefit of the Firm’s clients and to act on clients’ behalf before taking action in the interest of TSW or any of its associates. | |
Background. As a SEC registered adviser, TSW and its associates are subject to various requirements under the Advisers Act and rules adopted thereunder. These requirements include various anti-fraud provisions which make it unlawful for advisers to engage in any activities which may be fraudulent, deceptive or manipulative. | |
TSW has a fiduciary responsibility to its advisory clients and as such has a duty of loyalty to act in utmost good faith, place its clients’ interests first and foremost and to make full and fair disclosure of all material facts and, information as to potential and/or actual conflicts of interests. | |
Responsibility. TSW’s CCO has the responsibility for implementing and monitoring TSW's Conflicts of Interest Policy for content and accuracy. | |
Procedure. TSW has identified several potential conflicts of interest and adopted various procedures and internal controls to review, monitor and ensure the Firm’s Conflict of Interest Policy is observed, implemented properly and amended or updated, as appropriate. TSW has identified the following potential conflicts and the specific Policy, ADV disclosure, or reference in the Associates Manual which addresses the conflict: |
■ | Trade allocation/rotation favoring proprietary accounts and/or TSW clients with higher fee schedules. TSW’s proprietary accounts and client accounts with higher fee schedules will participate in bunch trades when appropriate, on an equal basis, with other TSW clients. This is disclosed in TSW’s disclosure document. TSW’s policies are designed to ensure equitable treatment of all clients’ orders and details may be found in: |
■ | Side-by-Side Management Policy |
■ | Trading Policy –Trade Rotation & Allocations |
■ | Form ADV, Part 2A - Item 6 – Performance Based Fees and Side-by-Side Management and Item 12 – Brokerage Practices – Bunched Trades/Block Trades and Partial Fill Process |
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■ | IPO allocation favoring proprietary accounts or TSW clients with higher fee schedules or performance-based fees. TSW’s allocation policies are designed to ensure equitable treatment of all clients’ orders participating in IPOs. TSW’s four factor screening process generally requires at least three years of financial history prior to being considered for purchase which makes it less likely that a security would be introduced into a client’s account under an IPO. |
■ | Side-by-Side Management Policy |
■ | Trading Policy and Procedure-Initial Public Offerings (IPOs) |
■ | Form ADV, Part 2A - Item 6 – Performance Based Fees and Side-by-Side Management and Item 12 – Brokerage Practices – Bunched Trades / Block Trades and Partial Fill Process |
■ | Trading with an affiliate could be a conflict of interest. TSW has developed an Affiliates Policy that addresses this issue and precludes TSW from trading with its affiliates. The Director of Trading and the Trade Management Oversight Committee has responsibility for overseeing all Firm trading activity to ensure TSW does not trade with its affiliates. |
■ | Affiliates Policy |
■ | Form ADV, Part 2A – Item 10 – Other Financial Industry Activities and Affiliations - Broker-Dealer |
■ | TSW may have a conflict from specific proxy voting issues. TSW’s Proxy Voting Policy addresses potential conflicts of interest by reviewing the relationship of TSW with the issuer of each security to determine if TSW or any of its associates has any financial, business or personal relationship with the issuer, where a conflict might exist. If TSW determines that a material conflict exists, TSW will instruct ISS to vote using ISS’s standard policy guidelines which are derived independently from TSW. |
■ | Proxy Voting Policy |
■ | Form ADV, Part 2A – Item 17 - Voting Client Securities |
■ | Soft Dollar transactions benefit TSW’s research effort by allocating a portion of client’s trade commissions to brokers with whom TSW has a commission sharing arrangement (“CSA”) brokers. TSW’s Soft Dollar Policy is designed to ensure that all research and brokerage services are qualified under the eligibility guidelines of Section 28(e) of the Securities Exchange Act of 1934. All new research or brokerage services and any amendments to existing services are documented in writing. TSW’s Trade Management Oversight Committee has the responsibility to review overall trading, including transaction costs and the allocation to CSAs, to ensure TSW doesn’t misallocate more trades to CSAs for unnecessary or inappropriate services. |
■ | Soft Dollar Policy |
■ | Form ADV, Part 2A – Item 12 – Brokerage Practices – Soft Dollars |
■ | The ability of alternative strategies to short securities held in other TSW long-only accounts could result in conflicting strategies that could find TSW’s clients at odds with one another. TSW’s Trading Policy addresses this conflict by allowing certain strategies to short securities held in long only strategies with a minimum market capitalization of $10 billion. Rules are written and tested in the trading system, Charles River (“CRD”) to monitor this requirement. |
■ | Side-by-Side Management Policy |
■ | Trading Policy |
■ | Form ADV, Part 2A – Item 6 – Performance-Based Fees and Side-by-Side Management and Item 12 – Brokerage Practices |
■ | Favoring investment strategies/accounts in which TSW has additional financial interest other than standard fees (some pooled vehicles and performance-based fee accounts). TSW’s Trading Policies, including allocation procedures, are designed to ensure all strategies and accounts are treated fairly. Various restrictions are placed in CRD and tests are performed to ensure accounts in which TSW has a potentially more favorable financial interest do not take advantage of that position. |
■ | Side-by-Side Management Policy |
■ | Trading Policy – Other Trading Considerations |
■ | Form ADV, Part 2A – Item 6 – Performance-Based Fees and Side-by-Side Management |
■ | Form ADV, Part 2A – Item 10 – Other Financial Industry Activities and Affiliations |
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■ | TSW associates’ personal trading and the potential use of inside information can create conflicts but are subject to the TSW Code of Ethics and Personal Securities Transactions & Records Policy. TSW associates are required to pre-clear personal transactions as required by the Code of Ethics and transactions are monitored to ensure no associate takes advantage of any TSW client trades. |
■ | Personal Securities Transactions & Records Policy |
■ | Code of Ethics |
■ | Form ADV, Part 2A –Item 11 – Code of Ethics |
■ | Portfolio Manager Compensation could present a portfolio manager an opportunity to advantage one client or a strategy over another if his/her compensation was so incentivized. TSW’s compensation strategy is not incentivized in that way. TSW’s compensation strategy addresses this potential conflict by providing competitive base salaries commensurate with an individual’s responsibility and providing incentive bonus awards that may significantly exceed base salary. Annually, the TSW Compensation Committee is responsible for determining the discretionary bonus, utilizing an analytical and qualitative assessment process. Factors used to determine compensation are: commitment to TSW’s core values, long-term performance, the strategy’s strategic position in the overall success of TSW, and support of marketing/client service commitments. Key associates may be awarded cash bonuses, and deferred TSW equity grants. All qualified employees participate in the TSW Employees’ Retirement Plan. |
■ | Side-by-side management, where a portfolio manager is responsible for managing multiple strategies/accounts, could present instances where a portfolio manager may devote unequal time and attention to an account or strategy. TSW acknowledges that some of its portfolio managers have input to multiple strategies and client accounts. TSW feels it has addressed this specific potential conflict by adopting Side-By Side Management and Trading Policies. |
■ | Side-by-Side Management Policy |
■ | Trading Policy |
■ | Form ADV, Part 2A – Item 6 – Performance-Based Fees and Side-By-Side Management and Item 12 – Brokerage Practices |
■ | While acceptable to the SEC, paying for client referrals can result in a conflict of interest. The SEC’s Cash Solicitation Rule (Rule 206(4)-3) details the rules under which an investment adviser may compensate persons who solicit advisory clients. TSW has incorporated those rules and necessary disclosure into its Solicitor Arrangement Policy to prevent any conflict of interest. |
■ | Solicitor Arrangements Policy |
■ | Form ADV, Part 2A – Item 14 – Client Referrals and Other Compensation |
■ | Some of TSW’s related persons are managing members of pooled vehicles and as such, TSW is deemed to have custody of the assets of those vehicles, which presents an opportunity for a conflict of interest. In order to prevent any conflict, TSW has a third-party administrator provide monthly reports and annually requires the pooled vehicles to be audited by a Public Company Account Oversight Board (“PCAOB”) approved auditor, who distributes the audited financial statements to investors. |
■ | Custody Policy |
■ | Form ADV, Part 2A – Item 15 - Custody |
■ | The exchange of gifts and entertainment to or from clients or other business associates could influence a TSW associate to improperly favor such clients or other business associates in violation of the associate’s fiduciary duties. TSW associates are subject to its Code of Ethics which requires all associates to identify any gifts given or received in their quarterly compliance reporting. TSW associates are limited to receipt of gifts given or received valued at $100 and entertainment given or received valued at $250, unless approved as an exception from the CCO or Board member that is not otherwise prohibited under applicable rules. Please note that entertainment can be either in-person or virtual. |
■ | Code of Ethics |
■ | Form ADV, Part 2A – Code of Ethics |
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■ | Is likely to make a financial gain, or avoid a loss at the expense of a client; |
■ | Has an interest in the outcome of a service or transaction conducted on behalf of a client which is distinct from that client’s interest; |
■ | Has any incentive to favour the interest of one client over another; |
■ | Carries on the same business as the client; |
■ | Will receive any inducement, such as monies, goods or services, as a result of providing a service, other than the standard commission and/or fees. |
■ | Ownership. Walter Scott is a wholly owned subsidiary
within the Bank of New York Mellon Corporation group (BNY Mellon). Walter
Scott operates autonomously from BNY Mellon in terms of its investment
research, portfolio management, investment administration and other
elements that impinge directly upon the investment management services
provided to clients. The investment decisions reflected within Walter
Scott client portfolios reflect its independent investment
research. Owing to legal/stock exchange restrictions Walter Scott may be subject to aggregate ownership limits on some stocks as part of the wider BNY Mellon group. |
■ | Affiliates. Walter Scott is a research led organization.
As a group company of BNY Mellon the firm is affiliated to certain
entities, some of which are utilized by the firm for activities such as
fund administration, distribution, FX trading and IT hosted systems. All
agreements have been established and will be maintained at arm’s
length. Walter Scott acts as sub-advisor to a number of mutual funds and pooled investment vehicles operated by its affiliates both on a discretionary and non-discretionary basis. All such investment advisory services are provided under formal written agreements between both parties. |
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■ | Portfolio
Implementation. The firm’s Portfolio
Implementation team is responsible for administering Walter Scott’s
investment decisions into the structure of portfolios in line with client
mandate guidelines and restrictions. The firm’s Investment Management
Committee (IMC), which comprises senior management of the firm and the
most senior members of the investment team, reviews portfolio performance
and the dispersion of similarly mandated portfolios. For the avoidance of doubt portfolios can and do differ between clients, notwithstanding similar strategies. Reasons for such differences include, but are not limited to, the starting date of the mandate and existing portfolio composition, differences between client guidelines and restrictions, client structure, portfolio liquidity, frequency of cash flows, the size of the mandate in question and appropriateness for a particular portfolio, taking into account appropriate portfolio diversification. |
■ | Brokers. All new brokers are approved by the Trading
Oversight Group (TOG) and Investment Operations maintains a complete list
of active approved brokers for equity trading. No equity trading is
conducted with any executing brokers affiliated with BNY Mellon. Walter
Scott selects brokers regardless of whether that broker’s clearing agent
is an affiliate of BNY Mellon. In general, all securities trading is
carried out on an agency basis. Walter Scott does not use trading
commissions to pay brokers for any services other than trade execution. No
commission sharing arrangements are in place. A small number of entities with which Walter Scott has a client relationship are affiliated to entities included on Walter Scott’s authorised broker list. The TOG monitors broker usage and commission rates paid on a quarterly basis with the Risk & Compliance (R&C) team reviewing this annually. |
■ | Trading |
■ | Aggregation/Execution/Allocation of Orders. It is the general policy of the firm to aggregate purchase or sale orders of the same equity when trading for more than one client. Aggregating orders may transpire to be advantageous or disadvantageous to any particular client or group of clients. Walter Scott has policies and procedures for best execution and fair allocation. Walter Scott does not cross stock between client accounts. |
■ | Trade Rotation. Following the receipt of any subsequent orders in the same stock to an outstanding aggregated order (due to other trades having to settle prior to that order being placed or other reasons) the original aggregated order will be stopped and a new one started with the relevant changes. In the event that the aggregated order is actively working in the market when the new order/s are received the new order/s will not participate in that days allocation and will be merged into the block after that day’s trade execution has been reported and fairly allocated amongst the original participants. |
■ | Error Correction. In the event that there is a trade error resulting from an error by Walter Scott, the firm would advise the client and, where necessary and subject to the details of the specific breach, recompense the client’s portfolio with appropriate compensation. |
■ | Employee Compensation/Personal Trading |
■ | Compensation. In addition to base salaries, employees of Walter Scott are eligible to participate in the firm’s annual profit share which is a fixed percentage of the firm’s pre-incentive operating profits. For directors and some senior staff, the majority of annual compensation is the profit share. An element of this is deferred via a long-term incentive plan, largely invested in a UK domiciled long term global equity fund sponsored by BNY Mellon with Walter Scott acting as investment advisor and BNY Mellon stock. Both have a deferral period which vests on a pro-rata basis over four years. |
■ | Employee Equity
Transactions. The firm operates
strict personal trading rules restricting members of staff from purchasing
shares in any US mutual fund where Walter Scott is the sub-advisor and
staff may not use discretion to purchase individual
securities. Employees are required to pre-clear dealing transactions through the R&C team and submit quarterly declarations of their holdings at the end of each quarter. Any inherent conflicts resulting from employees or Walter Scott investing in the same products as clients are therefore managed effectively. |
■ | Outside Interests/Directorships. The firm adheres to the requirements set out by BNY Mellon in relation to outside activities, affiliations, or employment which may give the appearance of a conflict of interest or could create a direct conflict between an employee’s interests and those of the firm or its parent BNY Mellon. Employees must obtain approval from BNY Mellon Ethics Office for certain outside activities prior to proceeding or accepting the position and annual re-approval. |
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■ | Insider Trading/Market Abuse. Policies and procedures exist to prevent employees from insider trading, trading upon material nonpublic information (MNPI). Those employees who possess inside or proprietary information must preserve its confidentiality and disclose it only to other employees who have a valid business reason for receiving it. |
■ | Inducements |
■ | Gifts and Entertainment. Employees may neither give nor accept anything of value where doing so could create the appearance of a potential conflict of interest. All hospitality or gifts given or received (apart from those of de minimus value) must be declared with pre-approval required for government entities in most instances and where values may exceed the pre-determined threshold amounts. The receiving and giving of gifts and entertainment is monitored by the R&C team to ensure these do not influence staff behaviour in a way that conflicts with the interests’ of clients. |
■ | Sponsorship & Charitable Donations. Within the firm’s governance structure, the Walter Scott Giving Group is responsible for reviewing/approving all charitable donations and sponsorships. The Giving Group operates under a Terms of Reference which specifically states no sponsorship or donation for any client is permitted. |
■ | Internships/Work Placement. To ensure there is no preferential treatment given to clients and their relatives when applying or seeking internships/work placement, Walter Scott adheres to the requirements set out by BNY Mellon whereby all applications must be routed through a centralized HR process. In addition, employees are required to attest on an annual basis as part of the Code of Conduct questionnaire that they have not hired through a non-recognised HR channel. |
■ | Personal Relationships. Employees of Walter Scott may have close personal or family relationships which could be viewed as a conflict of interest. Familial relationships are disclosed as part of the HR screening process for new employees and there is an obligation to disclose any new relationships for existing employees. Members of staff are not permitted to have direct or indirect authority over the employment status of another relative nor can they be in a position to jointly control or influence transactions. |
■ | Proxy Voting. Unless instructed to the contrary by a client, Walter Scott performs proxy voting on behalf of its clients. Votes are cast in line with client specific proxy voting guidelines or in a manner consistent with the clients’ best interests without regard for any interest Walter Scott may have in the matter. Walter Scott receives documentation on forthcoming votes from custodians and ISS, however, the firm votes independently of recommendations from any intermediary. |
■ | Fees and Commissions. Walter Scott’s trading income is derived from investment management fees which align the firm’s and its clients’ interests. The majority of Walter Scott’s clients are charged fees on scales that reflect the value of assets in the client’s account. A few clients operate with performance related fees. Walter Scott does not differentiate in the management of portfolios on the basis of the method of fee calculation or by client type. |
■ | Fee Sharing Arrangements/Referral
Fees. In Australia Walter Scott is
the investment advisor for funds sponsored and distributed by Macquarie
Bank. In the event that any Australian or New Zealand investors award
Walter Scott a new portfolio and not an investment in the existing funds,
Walter Scott shares its fees with Macquarie on a prearranged
scale. Walter Scott shares fee income with certain affiliates within the wider BNY Mellon group under arrangements similar to those disclosed above. Walter Scott is solely responsible for the payment of these fees which come out of its own profits. These payments do not increase the fees paid by investors. Walter Scott does not charge or receive compensation in respect of the sale of securities, private funds, mutual funds or other investment products. However, certain employees of the firm’s affiliates receive such compensation. |
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Sub-Subadviser ICM: The portfolio managers’ management of “other accounts” may give rise to potential conflicts of interest in connection with their management of the Fund’s investments, on the one hand, and the investments of the other accounts, on the other. The other accounts include separately managed small cap portfolios (the “Small Cap Portfolios”). The Small Cap Portfolios have the same investment objective as the Fund and are managed in tandem with the Fund. Therefore, a potential conflict of interest may arise as a result of the identical investment objectives, whereby the portfolio managers could favor one account over another. Another potential conflict could include the portfolio managers’ knowledge about the size, timing and possible market impact of Fund trades, whereby a portfolio manager could use this information to the advantage of other accounts and to the disadvantage of the Fund. It is also possible that a potential conflict of interest may arise because the portfolio managers manage an account with a performance-based management fee in addition to the Fund and other accounts without a performance-based fee. In addition, Mr. Heaphy also manages a similar strategy, which includes a non-fee paying, proprietary account. This similar strategy invests in both Small and Mid-Cap stocks. However, ICM has established policies and procedures to ensure that the purchase and sale of securities among all accounts it manages are fairly and equitably allocated. |
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Portfolio Manager | Benchmark |
Christopher Allen | Varied Euro-Based Benchmarks and global inflation benchmark |
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Portfolio Manager | Benchmark |
Akiva
Dickstein Emanuella Enenajor |
A combination of market-based indices (e.g. Bloomberg Barclays US Aggregate Index, Bloomberg Barclays US Universal Index and Bloomberg Barclays Intermediate Aggregate Index), certain customized indices and certain fund industry peer groups. |
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CenterSquare: CenterSquare’s compensation structure is comprised of base pay and annual incentive compensation. Individuals’ packages are designed with the appropriate component combinations to match specific positions. |
■ | Base pay: salary is competitive and base pay levels link pay with performance and reflect the market value of the position, individual performance and company business results. |
■ | Annual Cash Bonus: the annual cash bonus plan is based on individual performance, including individual contribution to meeting business unit goals, career development goals and adherence to corporate values. The annual cash bonus plan pool is computed based on the profitability of the firm. |
■ | Equity grant awards: management has reserved equity grant awards for employees based on a number of factors including exemplary performance and contributions to the company. |
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Loomis Sayles: Loomis Sayles believes that portfolio manager compensation should be driven primarily by the delivery of consistent and superior long-term performance for its clients. Mr. Hamzaogullari’s compensation has four components: a competitive base salary, an annual incentive bonus driven by investment performance, participation in a long-term incentive plan (with an annual and post-retirement payouts), and a revenue sharing bonus if certain revenue thresholds and performance hurdles are met. Maximum variable compensation potential is a multiple of base salary and reflects performance achievements relative to peers with similar disciplines. The performance review considers the asset class, |
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manager experience, and maturity of the product. The incentive compensation is based on trailing strategy performance and is weighted at one third for the three-year period, one third for the five-year period and one third for the ten-year period. He also receives performance based compensation as portfolio manager for a private investment fund. The firm’s senior management reviews the components annually. |
In addition, Mr. Hamzaogullari participates in the Loomis Sayles profit sharing plan, in which Loomis Sayles makes a contribution to the retirement plan of each employee based on a percentage of base salary (up to a maximum amount). He may also participate in the Loomis Sayles deferred compensation plan which requires all employees to defer 50% of their annual bonus if in excess of a certain dollar amount, except for those employees who will be age 61 or older on the date the bonus is awarded. These amounts are deferred over a two-year period with 50% being paid out one year from the bonus anniversary date and the second 50% being paid out two years from the bonus anniversary date. These deferrals are deposited into an investment account on the employee’s behalf, but the employee must be here on the vesting dates in order to receive the deferred bonus. |
Fixed Income Managers |
Loomis Sayles believes that portfolio manager compensation should be driven primarily by the delivery of consistent and superior long-term performance for its clients. Portfolio manager compensation is made up primarily of three main components: base salary, variable compensation and a long-term incentive program. Although portfolio manager compensation is not directly tied to assets under management, a portfolio manager’s base salary and/or variable compensation potential may reflect the amount of assets for which the manager is responsible relative to other portfolio managers. Loomis Sayles also offers a profit sharing plan, and a defined benefit plan to all employees hired before May 3, 2003. Base salary is a fixed amount based on a combination of factors, including industry experience, firm experience, job performance and market considerations. Variable compensation is an incentive-based component and generally represents a significant multiple of base salary. Variable compensation is based on four factors: investment performance, profit growth of the firm, profit growth of the manager’s business unit and personal conduct. Investment performance is the primary component of total variable compensation and generally represents at least 60% of the total for fixed-income managers. The other three factors are used to determine the remainder of variable compensation, subject to the discretion of the firm’s CIO and senior management. The firm’s Chief Investment Officer CIO and senior management evaluate these other factors annually. |
While mutual fund performance and asset size do not directly contribute to the compensation calculation, investment performance for fixed-income managers is measured by comparing the performance of Loomis Sayles’ institutional composite (pre-tax and net of fees) in the manager’s style to the performance of an external benchmark and a customized peer group. The external benchmark used for the fund is The external benchmark used for the MM Total Return Bond Strategies Fund is the Barclays U.S. Aggregate Index. |
The customized peer group is created by Loomis Sayles and is made up of institutional managers in the particular investment style. A manager’s relative performance for the past five years, or seven years for some products, is used to calculate the amount of variable compensation payable due to performance. To ensure consistency, Loomis Sayles analyzes the five or seven year performance on a rolling three year basis. If a manager is responsible for more than one product, the rankings of each product are weighted based on relative revenue size of accounts represented in each product. |
Loomis Sayles uses both an external benchmark and a customized peer group as a point of comparison for fixed-income manager performance because it believes they represent an appropriate combination of the competitive fixed-income product universe and the investment styles offered by Loomis Sayles. |
In addition to the compensation described above, portfolio managers may receive additional compensation based on the overall growth of their strategies. |
General |
Most mutual funds do not directly contribute to a portfolio manager’s overall compensation because Loomis Sayles uses the performance of the portfolio manager’s institutional accounts compared to an institutional peer group. However, each fund managed by Loomis Sayles employs strategies endorsed by Loomis Sayles and fits into the product category for the relevant investment style. Loomis Sayles may adjust compensation if there is significant dispersion among the returns of the composite and accounts not included in the composite. |
Loomis Sayles has developed and implemented two distinct long-term incentive plans to attract and retain investment talent. The plans supplement existing compensation and apply to certain portfolio managers, certain other investment talent, and certain high-ranking officers. |
The first plan has several important components distinguishing it from traditional equity ownership plans: |
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the
plan grants units that entitle participants to an annual payment based on
a percentage of company earnings above an established threshold; upon retirement, a participant will receive a multi-year payout for his or her vested units; and participation is contingent upon signing an award agreement, which includes a non-compete covenant. |
The second plan grants participants an annual participation in company earnings; the annual amount is deferred for two years from the time of award and is only payable if the portfolio manager remains at Loomis Sayles. In this plan, there are no post-retirement payments or non-compete covenants, but there is a non-solicitation covenant. |
Senior management expects that the variable compensation portion of overall compensation will continue to remain the largest source of income for those investment professionals included in the plan(s). The plan(s) was/were initially offered to portfolio managers and overtime, the scope of eligibility widened to include other key investment professionals. Management has full discretion on what units are issued and to whom. |
Portfolio managers also participate in the Loomis Sayles profit sharing plan, in which Loomis Sayles makes a contribution to the retirement plan of each employee based on a percentage of base salary (up to a maximum amount). The portfolio managers may also participate in the Loomis Sayles defined benefit pension plan, which applies to all Loomis Sayles employees who joined the firm prior to May 3, 2003. The defined benefit is based on years of service and base compensation (up to a maximum amount). |
In addition, portfolio managers may also participate in the Loomis Sayles deferred compensation plan which requires all Loomis Sayles employees to defer 50% of their annual bonus if in excess of a certain dollar amount, except for those Loomis Sayles employees who will be age 61 or older on the date the bonus is awarded. These amounts are deferred over a two-year period with 50% being paid out one year from the bonus anniversary date and the second 50% being paid out two years from the bonus anniversary date. These deferrals are deposited into an investment account on the Loomis Sayles employee’s behalf, but the employee must be with Loomis Sayles on the vesting dates in order to receive the deferred bonus. | |
MFS: MFS’ philosophy is to align portfolio manager compensation with the goal to provide shareholders with long-term value through a collaborative investment process. Therefore, MFS uses long-term investment performance as well as contribution to the overall investment process and collaborative culture as key factors in determining portfolio manager compensation. In addition, MFS seeks to maintain total compensation programs that are competitive in the asset management industry in each geographic market where it has employees. MFS uses competitive compensation data to ensure that compensation practices are aligned with its goals of attracting, retaining, and motivating the highest-quality professionals. | |
MFS reviews portfolio manager compensation annually. In determining portfolio manager compensation, MFS uses quantitative means and qualitative means to help ensure a sustainable investment process. As of December 31, 2020, portfolio manager total cash compensation is a combination of base salary and performance bonus: | |
Base Salary – Base salary generally represents a smaller percentage of portfolio manager total cash compensation than performance bonus. | |
Performance Bonus – Generally, the performance bonus represents more than a majority of portfolio manager total cash compensation. | |
The performance bonus is based on a combination of quantitative and qualitative factors, generally with more weight given to the former and less weight given to the latter. | |
The quantitative portion is primarily based on the pre-tax performance of accounts managed by the portfolio manager over a range of fixed-length time periods, intended to provide the ability to assess performance over time periods consistent with a full market cycle and a strategy's investment horizon. The fixed-length time periods include the portfolio manager's full tenure on each fund and, when available, ten-, five-, and three-year periods. For portfolio managers who have served for less than three years, shorter-term periods, including the one-year period, will also be considered, as will performance in previous roles, if any, held at the firm. Emphasis is generally placed on longer performance periods when multiple performance periods are available. Performance is evaluated across the full set of strategies and portfolios managed by a given portfolio manager, relative to appropriate peer group universes and/or representative indices (“benchmarks”). As of December 31, 2020, the Russell 1000® Value Index was used to measure the performance of Nevin Chitkara, and Katherine Cannan for the VP – MFS Value Fund. | |
Benchmarks may include versions and components of indices, custom indices, and linked indices that combine performance of different indices for different portions of the time period, where appropriate. | |
The qualitative portion is based on the results of an annual internal peer review process (where portfolio managers are evaluated by other portfolio managers, analysts, and traders) and management’s assessment of overall portfolio manager contribution to the MFS investment process and the client experience (distinct from fund and other account performance). |
Statement of Additional Information – May 1, 2021 | 137 |
The performance bonus is generally a combination of cash and a deferred cash award. A deferred cash award is issued for a cash value and becomes payable over a three-year vesting period if the portfolio manager remains in the continuous employ of MFS or its affiliates. During the vesting period, the value of the unfunded deferred cash award will fluctuate as though the portfolio manager had invested the cash value of the award in an MFS Fund(s) selected by the portfolio manager. | |
MFS Equity Plan – Portfolio managers also typically benefit from the opportunity to participate in the MFS Equity Plan. Equity interests are awarded by management, on a discretionary basis, taking into account tenure at MFS, contribution to the investment process, and other factors. | |
Finally, portfolio managers also participate in benefit plans (including a defined contribution plan and health and other insurance plans) and programs available generally to other employees of MFS. The percentage such benefits represent of any portfolio manager’s compensation depends upon the length of the individual’s tenure at MFS and salary level, as well as other factors. | |
MSIM: Morgan Stanley’s compensation structure is based on a total reward system of base salary and incentive compensation, which is paid either in the form of cash bonus, or for employees meeting the specified deferred compensation eligibility threshold, partially as a cash bonus and partially as mandatory deferred compensation. Deferred compensation granted to Investment Management employees are generally granted as a mix of deferred cash awards under the Investment Management Alignment Plan (IMAP) and equity-based awards in the form of stock units. The portion of incentive compensation granted in the form of a deferred compensation award and the terms of such awards are determined annually by the Compensation, Management Development and Succession Committee of the Morgan Stanley Board of Directors. | |
Base salary compensation. Generally, portfolio managers receive base salary compensation based on the level of their position with MSIM. | |
Incentive compensation. In addition to base compensation, portfolio managers may receive discretionary year-end compensation. | |
Incentive compensation may include: |
■ | Cash Bonus. |
■ | Deferred Compensation: |
■ | A mandatory program that defers a portion of incentive compensation into restricted stock units or other awards based on Morgan Stanley common stock or other plans that are subject to vesting and other conditions. |
■ | IMAP is a cash-based deferred compensation plan designed to increase the alignment of participants’ interests with the interests of MSIM’ clients. For eligible employees, a portion of their deferred compensation is mandatorily deferred into IMAP on an annual basis. Awards granted under IMAP are notionally invested in referenced funds available pursuant to the plan, which are funds advised by Investment Management. Portfolio managers are required to notionally invest a minimum of 25% of their account balance in the designated funds that they manage and are included in the IMAP notional investment fund menu. |
■ | Deferred compensation awards are typically subject to vesting over a multi-year period and are subject to cancellation through the payment date for competition, cause (i.e., any act or omission that constitutes a breach of obligation to the Company, including failure to comply with internal compliance, ethics or risk management standards, and failure or refusal to perform duties satisfactorily, including supervisory and management duties), disclosure of proprietary information, and solicitation of employees or clients. Awards are also subject to clawback through the payment date if an employee’s act or omission (including with respect to direct supervisory responsibilities) causes a restatement of the Firm’s consolidated financial results, constitutes a violation of the Firm’s global risk management principles, policies and standards, or causes a loss of revenue associated with a position on which the employee was paid and the employee operated outside of internal control policies. |
■ | Revenue and profitability of the business and/or each fund/accounts managed by the portfolio manager |
■ | Revenue and profitability of the Firm |
■ | Return on equity and risk factors of both the business units and Morgan Stanley |
Statement of Additional Information – May 1, 2021 | 138 |
■ | Assets managed by the portfolio manager |
■ | External market conditions |
■ | New business development and business sustainability |
■ | Contribution to client objectives |
■ | Individual contribution and performance |
Statement of Additional Information – May 1, 2021 | 139 |
Statement of Additional Information – May 1, 2021 | 140 |
Threadneedle: Direct compensation is typically comprised of a base salary, a fixed role-based allowance paid monthly alongside salary and an annual incentive award that is paid either in the form of a cash bonus if the size of the award is under a specified threshold or, if the size of the award is over a specified threshold, the award is paid in a combination of a |
Statement of Additional Information – May 1, 2021 | 141 |
cash bonus, an equity incentive award, and fund-linked deferred compensation compliant with European regulatory requirements in its structure and delivery vehicles. Equity incentive awards are made in the form of Ameriprise Financial restricted stock, or for senior employees outside our fund management teams both Ameriprise Financial restricted stock and stock options. The investment return credited on deferred compensation is based on the performance of specified Threadneedle funds, in most cases including the funds the portfolio manager manages. | |
Base salary is typically determined based on market data relevant to the employee’s position, as well as other factors including internal equity. Base salaries are reviewed annually, and increases are typically given as promotional increases, internal equity adjustments, or market adjustments. | |
Annual incentive awards and pool funding are variable and are designed to reward: |
■ | Investment performance, both at the individual and team levels |
■ | Client requirements, in particular the alignment with clients through a mandatory deferral into the company’s own products, compliant with local regulation in particular the UCITS V requirements |
■ | Team cooperation and values |
Statement of Additional Information – May 1, 2021 | 142 |
Statement of Additional Information – May 1, 2021 | 143 |
William Blair: The compensation of William Blair’s portfolio managers is based on the firm’s mission: “to achieve success for its clients.” Messrs. Fennell and McAtamney are partners of William Blair, and compensation for partners of William Blair consists of a fixed base salary, a share of the firm’s profits and, in some instances, a discretionary bonus. The discretionary bonus as well as any potential changes to the partners’ ownership stakes are determined by the head of William Blair’s Investment Management Department, subject to the approval of William Blair’s Executive Committee and are based entirely on a qualitative assessment rather than a formula. The discretionary bonus rewards the specific accomplishments in the prior year, including short-term and long-term investment performance, quality of research ideas, and other contributions to William Blair and its clients. Changes in ownership stake are based on an individual’s sustained, multi-year contribution to long-term investment performance, and to William Blair’s revenue, profitability, intellectual capital and brand reputation. The compensation process is a subjective one that takes into account the factors described above. Portfolio managers do not receive any direct compensation based upon the performance of any individual client account and no indices are used to measure performance. In addition, there is no particular weighting or formula for evaluating the factors. |
Sub-Subadviser ICM: The Fund is managed by a team of portfolio manager & research analysts who are each responsible for researching investment opportunities for the Fund. Each team member also manages separately managed accounts that share the same investment objective as the Fund and are managed in tandem with the Fund. Each team member receives an annual salary and discretionary cash bonus from ICM. The portfolio manager’s compensation is not directly linked to the Fund’s or separate accounts’ performance. Instead, bonuses are determined based on ICM’s overall profitability, which may relate to the Fund and/or separate accounts’ asset levels, as well as other factors. These factors may include a team member’s investment ideas and strategies, and overall contribution to the success of ICM and its investment products. In addition to salary and bonuses, five of the Fund’s team members (portfolio manager William Heaphy, and analysts Gary Merwitz, Matthew Fleming, Joshua Overholt, and James Shurtleff), are members of ICM Management LLC, which owns a portion of ICM. Through these interests, Messrs. Heaphy, Merwitz, Fleming, Overholt, and Shurtleff also receive a 1/6 interest of ICM’s income distributions to ICM Management LLC. |
The compensation of William Blair’s portfolio managers is based on the firm’s mission: “Empower Colleagues, Deliver Client Success and Engage in our Communities” and compensation consists of a fixed base salary and a discretionary bonus. The discretionary bonus are ultimately determined by the head of William Blair’s Investment Management Department and William Blair’s Executive Committee, and are based on both quantitative and qualitative factors, rather than a formula. The discretionary bonus rewards the specific accomplishments in the prior year, including short-term and long-term investment performance, quality of research ideas, and other contributions to William Blair and its clients. The compensation process is a subjective one (albeit with many checks and balances and quantitative inputs) that takes into account the factors described above. Portfolio managers do not receive any direct compensation based upon the performance of any individual client account. In addition, there is no formula for evaluating the factors. Once ICM merges with William Blair, all former ICM employees’ compensation will be subject to this discretionary bonus process. |
Statement of Additional Information – May 1, 2021 | 144 |
Share Class | Distribution Fee | Service Fee | Combined Total |
Class 1 | None | None | None |
Class 2 | Up to 0.25% | 0.00% | Up to 0.25% |
Class 3 | Up to 0.125% | 0.00% | Up to 0.125% |
Class 4 | Up to 0.25% | 0.00% | Up to 0.25% |
Statement of Additional Information – May 1, 2021 | 145 |
Fund | Class 1 | Class 2 | Class 3 | Class 4 |
For Funds with fiscal period ending December 31 | ||||
VP – Aggressive Portfolio | N/A | $3,291,654 | N/A | $2,545,399 |
VP – American Century Diversified Bond Fund | N/A | 48,166 | N/A | N/A |
VP – Balanced Fund | N/A | 9 | $1,425,726 | N/A |
VP – BlackRock Global Inflation-Protected Securities Fund | N/A | 49,060 | 108,239 | N/A |
VP – CenterSquare Real Estate Fund | N/A | 64,107 | N/A | N/A |
VP – Commodity Strategy Fund | N/A | 35,451 | N/A | N/A |
VP – Conservative Portfolio | N/A | 1,580,170 | N/A | 1,499,545 |
VP – Core Equity Fund | N/A | N/A | N/A | N/A |
VP – Disciplined Core Fund | N/A | 94,570 | 1,472,017 | N/A |
VP – Dividend Opportunity Fund | N/A | 179,835 | 858,760 | N/A |
VP – Emerging Markets Bond Fund | N/A | 546,905 | N/A | N/A |
VP – Emerging Markets Fund | N/A | 141,977 | 228,065 | N/A |
VP – Global Strategic Income Fund | N/A | 25,781 | 119,972 | N/A |
VP – Government Money Market Fund | N/A | 38,416 | 58,506 | N/A |
VP – High Yield Bond Fund | N/A | 167,928 | 314,889 | N/A |
VP – Income Opportunities Fund | N/A | 87,687 | 165,815 | N/A |
VP – Intermediate Bond Fund | N/A | 158,094 | 697,975 | N/A |
VP – Large Cap Growth Fund | N/A | 349,516 | 305,375 | N/A |
VP – Large Cap Index Fund | N/A | 26,717 | 742,967 | N/A |
VP – Limited Duration Credit Fund | N/A | 170,680 | N/A | N/A |
VP – Loomis Sayles Growth Fund | N/A | 145,993 | N/A | N/A |
VP – MFS Value Fund | N/A | 147,923 | N/A | N/A |
VP – Mid Cap Growth Fund | N/A | 76,636 | 341,376 | N/A |
VP – Moderate Portfolio | N/A | 19,996,739 | N/A | 21,280,636 |
VP – Moderately Aggressive Portfolio | N/A | 9,930,098 | N/A | 8,145,812 |
VP – Moderately Conservative Portfolio | N/A | 3,696,966 | N/A | 3,742,918 |
VP – Morgan Stanley Advantage Fund | N/A | 68,589 | N/A | N/A |
VP – MV Moderate Growth Fund | N/A | 37,078,553 | N/A | N/A |
VP – Overseas Core Fund | N/A | 135,320 | 271,704 | N/A |
VP – Partners Core Bond Fund | N/A | 36,903 | N/A | N/A |
VP – Partners Core Equity Fund | N/A | 25,142 | 36,629 | N/A |
VP – Partners International Core Equity Fund | N/A | 19,280 | N/A | N/A |
VP – Partners International Growth Fund | N/A | 89,416 | N/A | N/A |
VP – Partners International Value Fund | N/A | 46,635 | N/A | N/A |
Statement of Additional Information – May 1, 2021 | 146 |
Fund | Class 1 | Class 2 | Class 3 | Class 4 |
VP – Partners Small Cap Growth Fund | N/A | $29,638 | N/A | N/A |
VP – Partners Small Cap Value Fund | N/A | 16,513 | $95,557 | N/A |
VP – Select Large Cap Equity Fund | N/A | 7 | N/A | N/A |
VP – Select Large Cap Value Fund | N/A | 72,017 | 58,800 | N/A |
VP – Select Mid Cap Value Fund | N/A | 73,551 | 67,874 | N/A |
VP – Select Small Cap Value Fund | N/A | 59,549 | 52,821 | N/A |
VP – Seligman Global Technology Fund | N/A | 146,201 | N/A | N/A |
VP – T. Rowe Price Large Cap Value Fund | N/A | 61,640 | N/A | N/A |
VP – TCW Core Plus Bond Fund | N/A | 42,006 | N/A | N/A |
VP – U.S. Government Mortgage Fund | N/A | 66,187 | 120,121 | N/A |
VP – Victory Sycamore Established Value Fund | N/A | 116,910 | 70,688 | N/A |
VP – Wells Fargo Short Duration Government Fund | N/A | 123,775 | N/A | N/A |
VP – Westfield Mid Cap Growth Fund | N/A | 62,730 | N/A | N/A |
Statement of Additional Information – May 1, 2021 | 147 |
Amounts Reimbursed | |||
2020 | 2019 | 2018 | |
For Funds with fiscal period ending December 31 | |||
VP – Aggressive Portfolio | $0 | $45,084 | $0 |
VP – American Century Diversified Bond Fund | 0 | 0 | 0 |
VP – Balanced Fund | 100,377 | 299,030 | 348,036 |
VP – BlackRock Global Inflation-Protected Securities Fund | 92,498 | 113,940 | 104,233 |
VP – CenterSquare Real Estate Fund | 0 | 0 | 0 |
VP – Commodity Strategy Fund | 0 | 0 | 0 |
VP – Conservative Portfolio | 0 | 0 | 30,349 |
VP – Core Equity Fund | 91,982 | 95,774 | 89,679 |
VP – Disciplined Core Fund | 0 | 0 | 0 |
VP – Dividend Opportunity Fund | 160,367 | 248,805 | 95,533 |
VP – Emerging Markets Bond Fund | 0 | 0 | 0 |
VP – Emerging Markets Fund | 330,239 | 231,499 | 14,894 |
VP – Global Strategic Income Fund | 281,565 | 321,838 | 268,853 |
VP – Government Money Market Fund | 198,816 | 422,904 | 527,207 |
VP – High Yield Bond Fund | 311,279 | 289,812 | 104,632 |
VP – Income Opportunities Fund | 211,276 | 208,907 | 49,400 |
VP – Intermediate Bond Fund | 0 | 0 | 0 |
VP – Large Cap Growth Fund | 0 | 0 | 0 |
VP – Large Cap Index Fund | 0 | 0 | 0 |
VP – Limited Duration Credit Fund | 84,986 | 46,807 | 0 |
VP – Loomis Sayles Growth Fund | 0 | 0 | 0 |
VP – MFS Value Fund | 0 | 0 | 0 |
Statement of Additional Information – May 1, 2021 | 148 |
Amounts Reimbursed | |||
2020 | 2019 | 2018 | |
VP – Mid Cap Growth Fund | $574,594 | $771,597 | $730,049 |
VP – Moderate Portfolio | 0 | 0 | 0 |
VP – Moderately Aggressive Portfolio | 0 | 0 | 0 |
VP – Moderately Conservative Portfolio | 189,772 | 249,739 | 92,397 |
VP – Morgan Stanley Advantage Fund | 0 | 0 | 0 |
VP – MV Moderate Growth Fund | 0 | 0 | 0 |
VP – Overseas Core Fund | 0 | 0 | 0 |
VP – Partners Core Bond Fund | 0 | 0 | 0 |
VP – Partners Core Equity Fund | 0 | 238,968 | 193,950 |
VP – Partners International Core Equity Fund | 0 | 0 | 0 |
VP – Partners International Growth Fund | 65,368 | 117,879 | 0 |
VP – Partners International Value Fund | 307,404 | 0 | 0 |
VP – Partners Small Cap Growth Fund | 47,795 | 63,773 | 58,245 |
VP – Partners Small Cap Value Fund | 102,396 | 36,475 | 20,827 |
VP – Select Large Cap Equity Fund | 577,482 | 608,660 | 404,618(a) |
VP – Select Large Cap Value Fund | 0 | 13,093 | 0 |
VP – Select Mid Cap Value Fund | 197,938 | 177,558 | 110,229 |
VP – Select Small Cap Value Fund | 159,174 | 144,870 | 156,773 |
VP – Seligman Global Technology Fund | 224,540 | 182,453 | 50,702 |
VP – T. Rowe Price Large Cap Value Fund | 0 | 0 | 0 |
VP – TCW Core Plus Bond Fund | 0 | 0 | 0 |
VP – U.S. Government Mortgage Fund | 0 | 0 | 0 |
VP – Victory Sycamore Established Value Fund | 0 | 0 | 0 |
VP – Wells Fargo Short Duration Government Fund | 0 | 0 | 0 |
VP – Westfield Mid Cap Growth Fund | 0 | 0 | 18,547 |
(a) | For the period from January 4, 2018 (commencement of operations) to December 31, 2018. |
Fees Waived | |||
2020 | 2019 | 2018 | |
For Funds with fiscal period ending December 31 | |||
VP – Government Money Market Fund | $1,435,183 | $0 | $0 |
Statement of Additional Information – May 1, 2021 | 149 |
Statement of Additional Information – May 1, 2021 | 150 |
Statement of Additional Information – May 1, 2021 | 151 |
Statement of Additional Information – May 1, 2021 | 152 |
Statement of Additional Information – May 1, 2021 | 153 |
Statement of Additional Information – May 1, 2021 | 154 |
Statement of Additional Information – May 1, 2021 | 155 |
Name, address, year of birth | Position
held with Subsidiary and length of service |
Principal occupation during past five years |
Brian
M. Engelking 5228 Ameriprise Financial Center Minneapolis, MN 55474-2405 Born 1979 |
Director
since March 2020 |
Global Lead Financial Officer – Columbia Threadneedle Investments at Ameriprise Financial, Inc. since June 2020. Previously, Vice President – Finance, Ameriprise Financial, Inc. and served in various finance leadership roles with Ameriprise Financial, Inc. since 2000. |
Christopher
O. Petersen 5228 Ameriprise Financial Center Minneapolis, MN 55474-2405 Born 1970 |
Director
since January 2015 |
See Fund Governance – Trustees – Interested Trustee Affiliated with Investment Manager. |
Statement of Additional Information – May 1, 2021 | 156 |
Subsidiary | Assets (millions) |
Annual
rate at each asset level(a) |
CVPCSF Offshore Fund, Ltd. (Subsidiary of VP – Commodity Strategy Fund) |
$0 - $500 | 0.630% |
>$500 - $1,000 | 0.580% | |
>$1,000 - $3,000 | 0.550% | |
>$3,000 - $6,000 | 0.520% | |
>$6,000 - $12,000 | 0.500% | |
>$12,000 | 0.490% |
(a) | When calculating asset levels for purposes of determining fee rate breakpoints, asset levels are based on aggregate net assets of the Fund and the Parent Fund. When calculating the fee payable under this agreement, the annual rates are based on a percentage of the average daily net assets of the Fund. |
Statement of Additional Information – May 1, 2021 | 157 |
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 |
Committee Assignments |
George
S. Batejan c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1953 |
Trustee 2017 |
Executive Vice President, Global Head of Technology and Operations, Janus Capital Group, Inc., 2010-2016 | 172 | 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 | Compliance, Contracts, Investment Oversight Committee |
Kathleen
Blatz c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1954 |
Trustee 2006 |
Attorney, specializing in arbitration and mediation; Chief Justice, Minnesota Supreme Court, 1998-2006; Associate Justice, Minnesota Supreme Court, 1996-1998; Fourth Judicial District Court Judge, Hennepin County, 1994-1996; Attorney in private practice and public service, 1984-1993; State Representative, Minnesota House of Representatives, 1979-1993, which included service on the Tax and Financial Institutions and Insurance Committees; Member and Interim Chair, Minnesota Sports Facilities Authority, January -July 2017; Interim President and Chief Executive Officer, Blue Cross and Blue Shield of Minnesota (health care insurance), February-July 2018 | 172 | Trustee, BlueCross BlueShield of Minnesota since 2009 (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; Director, Robina Foundation, 2009-2020 (Chair, 2014-2020) | Compliance, Contracts, Investment Oversight Committee |
Statement of Additional Information – May 1, 2021 | 158 |
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 |
Committee Assignments |
Pamela
G. Carlton c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1954 |
Trustee 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 at Cleary Gottlieb Steen & Hamilton LLP, 1980-1982 | 172 | Trustee, New York Presbyterian Hospital Board (Executive Committee and Chair of People Committee) since 1996; Director, DR Bank (Audit Committee) since 2017; Director, Evercore Inc. (Audit Committee, Nominating and Governance Committee) since 2019 | Contracts, Board Governance, Investment Oversight Committee |
Janet
Langford Carrig c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1957 |
Trustee 1996 |
Senior Vice President, General Counsel and Corporate Secretary, ConocoPhillips (independent energy company), September 2007-October 2018 | 170 | Director, EQT Corporation (natural gas producer) since 2019; Director, Whiting Petroleum Corporation (independent oil and gas company) since 2020 | Compliance, Contracts, Board Governance, Investment Oversight Committee |
J.
Kevin Connaughton c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1964 |
Trustee 2020(a) |
Member, FINRA National Adjudicatory Council since January 2020; Adjunct Professor of Finance, Bentley University since January 2018; 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 | 170 | Director, The Autism Project since March 2015; 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, January 2015-December 2017 | Audit, Contracts, Investment Oversight Committee |
Olive
M. Darragh c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1962 |
Trustee 2020(a) |
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; Partner, Tudor Investments, 2004-2010; Senior Partner, McKinsey & Company (consulting), 2001-2004 | 170 | Former Director, University of Edinburgh Business School (Member of US Board); former Director, Boston Public Library Foundation | Audit, Contracts, Investment Oversight Committee |
Statement of Additional Information – May 1, 2021 | 159 |
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 |
Committee Assignments |
Patricia
M. Flynn c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1950 |
Trustee 2004 |
Trustee Professor of Economics and Management, Bentley University since 1976 (also teaches and conducts research on corporate governance); Dean, McCallum Graduate School of Business, Bentley University, 1992-2002 | 172 | Trustee, MA Taxpayers Foundation since 1997; Board of Governors, Innovation Institute, MA Technology Collaborative since 2010; Board of Directors, The MA Business Roundtable 2003-2019 | Audit, Contracts, Investment Oversight Committee |
Brian
J. Gallagher c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1954 |
Trustee 2017 |
Retired; Partner with Deloitte & Touche LLP and its predecessors, 1977-2016 | 172 | Trustee, Catholic Schools Foundation since 2004 | Audit, Contracts, Investment Oversight Committee |
Douglas
A. Hacker c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1955 |
Co-Chair since 2021; Chair of CFST I and CFVIT since 2014; Trustee of CFST I and CFVIT since 1996 and CFST, CFST II, CFVST II, Columbia ETF Trust I and Columbia ETF Trust II since 2021 | 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 | 170 | Director, Spartan Nash Company (food distributor); Director, Aircastle Limited (Chair of Audit Committee) (aircraft leasing); 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 | Contracts, Board Governance, Investment Oversight Committee |
Nancy
T. Lukitsh c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1956 |
Trustee 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 | 170 | None | Contracts, Board Governance, Investment Oversight Committee |
Statement of Additional Information – May 1, 2021 | 160 |
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 |
Committee Assignments |
David
M. Moffett c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1952 |
Trustee 2011 |
Retired; Consultant to Bridgewater and Associates | 170 | Director, CSX Corporation (transportation suppliers); Director, Genworth Financial, Inc. (financial and insurance products and services); Director, PayPal Holdings Inc. (payment and data processing services); Trustee, University of Oklahoma Foundation; former Director, eBay Inc. (online trading community), 2007-2015; and former Director, CIT Bank, CIT Group Inc. (commercial and consumer finance), 2010-2016 | Audit, Contracts, Investment Oversight Committee |
Catherine
James Paglia c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1952 |
Co-Chair since 2021; Chair of CFST, CFST II, CFVST II, Columbia ETF Trust I and Columbia ETF Trust II since 2020; Trustee of CFST, CFST II, CFVST II, Columbia ETF Trust I and Columbia ETF Trust II since 2004 and CFST I and CFVIT since 2021 | 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. | 172 | Director, Valmont Industries, Inc. (irrigation systems manufacturer) since 2012; Trustee, Carleton College (on the Investment Committee); Trustee, Carnegie Endowment for International Peace (on the Investment Committee) | Contracts, Board Governance, Investment Oversight Committee |
Anthony
M. Santomero c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1946 |
Trustee 2008 |
Richard K. Mellon Professor Emeritus of Finance, The Wharton School, University of Pennsylvania, since 2002; Senior Advisor, McKinsey & Company (consulting), 2006-2008; President, Federal Reserve Bank of Philadelphia, 2000-2006; Professor of Finance, The Wharton School, University of Pennsylvania, 1972-2002 | 172 | Trustee, Penn Mutual Life Insurance Company since March 2008; Director, RenaissanceRe Holdings Ltd. since May 2008; former Director, Citigroup Inc. and Citibank, N.A., 2009-2019; former Trustee, BofA Funds Series Trust (11 funds), 2008-2011 | Contracts, Board Governance, Investment Oversight Committee |
Statement of Additional Information – May 1, 2021 | 161 |
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 |
Committee Assignments |
Minor
M. Shaw c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1947 |
Trustee 2003 |
President, Micco LLC (private investments) since 2011; President, Micco Corp. (family investment business), 1998-2011 | 172 | Director, BlueCross BlueShield of South Carolina (Chair of Compensation Committee) since April 2008; Trustee, Hollingsworth Funds (on the Investment Committee) since 2016 (previously Board Chair from 2016-2019); Former Advisory Board member, Duke Energy Corp., 2016-2020; Chair of the Duke Endowment; Chair of Greenville – Spartanburg Airport Commission; former Trustee, BofA Funds Series Trust (11 funds), 2003-2011; former Director, Piedmont Natural Gas, 2004-2016; former Director, National Association of Corporate Directors, Carolinas Chapter, 2013-2018; Chair of Daniel-Mickel Foundation | Compliance, Contracts, Investment Oversight Committee |
Natalie
A. Trunow c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1967 |
Trustee 2020(a) |
Chief Executive Officer, Millennial Portfolio Solutions LLC (asset management and consulting services) since January 2016; Non-executive Member of the Investment Committee, Sarona Asset Management Inc. (private equity firm) since September 2019; Advisor, Horizon Investments (asset management and consulting services) since August 2018; Advisor, Paradigm Asset Management since November 2016; Director of Investments, Casey Family Programs, April 2016-September 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 | 170 | Director, Health Services for Children with Special Needs, Inc.; Director, Consumer Credit Counseling Services (formerly Guidewell Financial Solutions); Independent Director, Investment Committee, Sarona Asset Management | Compliance, Contracts, Investment Oversight Committee |
Statement of Additional Information – May 1, 2021 | 162 |
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 |
Committee Assignments |
Sandra
Yeager c/o Columbia Management Investment Advisers, LLC, 225 Franklin Street, Mail Drop BX32 05228, Boston, MA 02110 1964 |
Trustee 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 | 172 | Director, NAPE Education Foundation, October 2016-October 2020 | Audit, Contracts, Investment Oversight Committee |
* | The term “Columbia Funds Complex” as used herein includes Columbia Seligman Premium Technology Growth Fund, Tri-Continental Corporation and each series of CFST, CFST I, CFST II, Columbia ETF Trust I, Columbia ETF Trust II, Columbia Funds Variable Insurance Trust (CFVIT) and Columbia Funds Variable Series Trust II (CFVST II). Messrs. Batejan, Gallagher, Petersen and Santomero and Mses. Blatz, Carlton, Flynn, Paglia, Shaw and Yeager serve as a director of Columbia Seligman Premium Technology Growth Fund and Tri-Continental Corporation. |
(a) | J. Kevin Connaughton was appointed a consultant to the Independent Trustees of CFST I and CFVIT effective March 1, 2016. Natalie A. Trunow was appointed a consultant to the Independent Trustees of CFST I and CFVIT effective September 1, 2016. Olive M. Darragh was appointed a consultant to the Independent Trustees of CFST I and CFVIT effective June 10, 2019. Shareholders of the Funds elected Mr. Connaughton and Mses. Darragh and Trunow as Trustees of CFST I, effective January 1, 2021, and of CFVIT, effective July 1, 2020. |
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 | Committee Assignments |
Christopher
O. Petersen c/o Columbia Management Investment Advisers, LLC 5228 Ameriprise Financial Center Minneapolis, MN 55474 1970 |
Trustee 2020(a) |
Vice President and Lead Chief Counsel, Ameriprise Financial, Inc. since January 2015 (previously Vice President and Chief Counsel, January 2010-December 2014); officer of Columbia Funds and affiliated funds since 2007. | 172 | None | None |
* | Interested person (as defined under the 1940 Act) by reason of being an officer, director, security holder and/or employee of the Investment Manager or Ameriprise Financial. |
(a) | Mr. Petersen serves as the President and Principal Executive Officer of the Columbia Funds (since 2015). |
Statement of Additional Information – May 1, 2021 | 163 |
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 225 Franklin Street Boston, MA 02110 1969 |
Chief Financial Officer and Principal Financial Officer (2009) and Senior Vice President (2019) | Vice President, Head of North American Operations, and Co-Head of Global Operations, Columbia Management Investment Advisers, LLC, since June 2019 (previously Vice President – Accounting and Tax, May 2010 – May 2019); senior officer of Columbia Funds and affiliated funds since 2002. |
Joseph
Beranek 5890 Ameriprise Financial Center Minneapolis, MN 55474 1965 |
Treasurer and Chief Accounting Officer (Principal Accounting Officer) (2019) and Principal Financial Officer (2020), CFST, CFST I, CFST II, CFVIT and CFVST II; Assistant Treasurer, Columbia ETF Trust I and Columbia ETF Trust II | Vice President - Mutual Fund Accounting and Financial Reporting, Columbia Management Investment Advisers, LLC, since December 2018 and March 2017, respectively (previously Vice President – Pricing and Corporate Actions, May 2010 - March 2017). |
Marybeth
Pilat 225 Franklin Street Boston, MA 02110 1968 |
Treasurer and Chief Accounting Officer (Principal Accounting Officer) and Principal Financial Officer (2020) for Columbia ETF Trust I and Columbia ETF Trust II; Assistant Treasurer, CFST, CFST I, CFST II, CFVIT and CFVST II | Vice President – Product Pricing and Administration, Columbia Management Investment Advisers, LLC, since May 2017; Director - Fund Administration, Calvert Investments, August 2015 – March 2017; Vice President - Fund Administration, Legg Mason, May 2015 - July 2015; Vice President - Fund Administration, Columbia Management Investment Advisers, LLC, May 2010 - April 2015. |
William
F. Truscott 225 Franklin Street Boston, MA 02110 1960 |
Senior Vice President (2001) | Formerly, Trustee of Columbia Funds Complex until January 1, 2021; Chief Executive Officer, Global Asset Management, Ameriprise Financial, Inc. since September 2012; Chairman of the Board and President, Columbia Management Investment Advisers, LLC since July 2004 and February 2012, respectively; Chairman of the Board and Chief Executive Officer, Columbia Management Investment Distributors, Inc. since November 2008 and February 2012, respectively; Chairman of the Board and Director, Threadneedle Asset Management Holdings, Sàrl since March 2013 and December 2008, respectively; senior executive of various entities affiliated with Columbia Threadneedle. |
Paul
B. Goucher 485 Lexington Avenue New York, NY 10017 1968 |
Senior Vice President (2011) and Assistant Secretary (2008) | Senior Vice President and Assistant General Counsel, Ameriprise Financial, Inc. since January 2017 (previously Vice President and Lead Chief Counsel, November 2008 – January 2017 and January 2013 – January 2017, respectively); Vice President, Chief Legal Officer and Assistant Secretary, Columbia Management Investment Advisers, LLC since March 2015 (previously Vice President and Assistant Secretary, May 2010 – March 2015). |
Thomas
P. McGuire 225 Franklin Street Boston, MA 02110 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; Chief Compliance Officer, Ameriprise Certificate Company, September 2010 – September 2020. |
Colin
Moore 225 Franklin Street Boston, MA 02110 1958 |
Senior Vice President (2010) | Executive Vice President and Global Chief Investment Officer, Ameriprise Financial, Inc., since July 2013; Executive Vice President and Global Chief Investment Officer, Columbia Management Investment Advisers, LLC since July 2013. |
Ryan
C. Larrenaga 225 Franklin Street Boston, MA 02110 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. |
Statement of Additional Information – May 1, 2021 | 164 |
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 |
Daniel
J. Beckman 225 Franklin Street Boston, MA 02110 1962 |
Senior Vice President (2020) | Vice President – Head of North America Product, Columbia Management Investment Advisers, LLC (since April 2015). |
Michael
E. DeFao 225 Franklin Street Boston, MA 02110 1968 |
Vice President (2011) and Assistant Secretary (2010) | Vice President and Chief Counsel, Ameriprise Financial, Inc. since May 2010. |
Lyn
Kephart-Strong 5228 Ameriprise Financial Center Minneapolis, MN 55474 1960 |
Vice President (2015) | President, Columbia Management Investment Services Corp. since October 2014; Vice President & Resolution Officer, Ameriprise Trust Company since August 2009. |
Statement of Additional Information – May 1, 2021 | 165 |
Statement of Additional Information – May 1, 2021 | 166 |
Statement of Additional Information – May 1, 2021 | 167 |
Statement of Additional Information – May 1, 2021 | 168 |
Statement of Additional Information – May 1, 2021 | 169 |
Board Member | Aggregate Dollar Range of Equity Securities in all Funds in the Columbia Funds Complex Overseen by the Trustee |
George S. Batejan | Over $100,000 |
Kathleen Blatz | Over $100,000 |
Pamela G. Carlton | Over $100,000(a) |
Janet Langford Carrig | Over $100,000(a) |
J. Kevin Connaughton | Over $100,000 |
Olive M. Darragh | Over $100,000 |
Patricia M. Flynn | Over $100,000(a) |
Brian J. Gallagher | Over $100,000(a) |
Douglas A. Hacker | Over $100,000 |
Nancy T. Lukitsh | Over $100,000 |
David M. Moffett | Over $100,000(a) |
Catherine James Paglia | Over $100,000(a) |
Anthony M. Santomero | Over $100,000(a) |
Minor M. Shaw | Over $100,000(a)(b) |
Natalie A. Trunow | Over $100,000(a) |
Sandra Yeager | Over $100,000(a) |
(a) | Includes the value of compensation payable under a Deferred Compensation Plan that is determined as if the amounts deferred had been invested, as of the date of deferral, in shares of one or more funds in the Columbia Funds Complex overseen by the Trustee as specified by the Trustee. |
(b) | Ms. Shaw invests in a Section 529 Plan managed by the Investment Manager that allocates assets to various open-end funds, including Columbia Funds. The amount shown in the table includes the value of her interest in this plan determined as if her investment in the plan were invested directly in the Columbia Fund pursuant to the plan’s target allocations. |
Statement of Additional Information – May 1, 2021 | 170 |
Board Member | Aggregate Dollar Range of Equity Securities in all Funds in the Columbia Funds Complex Overseen by the Trustee |
Christopher O. Petersen | Over $100,000(a)(b) |
(a) | Mr. Petersen invests in a Section 529 Plan managed by the Investment Manager that allocates assets to various open-end funds, including Columbia Funds. The amount shown in the table includes the value of his interest in this plan determined as if his investment in the plan were invested directly in the Columbia Fund pursuant to the plan’s target allocations. |
(b) | With respect to Mr. Petersen, this amount includes compensation payable under a Deferred Compensation Plan administered by Ameriprise Financial. |
Trustees | Total
Cash Compensation from the Columbia Funds Complex Paid to Trustee(a) |
Amount
Deferred from Total Compensation(b) |
George S. Batejan | $395,000 | $0 |
Kathleen Blatz | $395,000 | $0 |
Pamela G. Carlton | $395,000 | $118,500 |
Janet L. Carrig | $343,000 | $343,000 |
J. Kevin Connaughton(c) | $311,500 | $0 |
Olive M. Darragh(c) | $316,500 | $0 |
Patricia M. Flynn | $395,000 | $197,500 |
Brian J. Gallagher | $395,000 | $197,500 |
Douglas A. Hacker | $453,000 | $0 |
Nancy T. Lukitsh | $344,000 | $0 |
David M. Moffett | $333,000 | $333,000 |
John J. Neuhauser(d) | $334,500 | $0 |
Catherine James Paglia | $445,000 | $445,000 |
Anthony M. Santomero | $370,000 | $0 |
Minor M. Shaw | $360,000 | $180,000 |
Patrick J. Simpson(e) | $344,500 | $139,500 |
Natalie A. Trunow(c) | $311,500 | $121,500 |
Sandra Yeager | $370,000 | $185,000 |
(a) | Includes any portion of cash compensation Trustees elected to defer during the fiscal period. |
(b) | The Trustees may elect to defer a portion of the total cash compensation payable. Additional information regarding the Deferred Compensation Plan is described below. |
Statement of Additional Information – May 1, 2021 | 171 |
(c) | From January 1, 2020 to June 30, 2020, Mr. Connaughton and Mses. Darragh and Trunow received compensation from the Funds for serving as a consultant to the Independent Trustees at an annual rate of $295,000; from July 1, 2020 to December 31, 2020, the consultants received the same compensation as they would receive were they Trustees. Mr. Connaughton and Mses. Darragh and Trunow were elected as Trustees effective January 1, 2021. |
(d) | Dr. Neuhauser served as Trustee until December 31, 2020, and stopped receiving compensation from the Funds and the Columbia Funds Complex as of such date. |
(e) | Mr. Simpson served as Trustee until December 31, 2020, and stopped receiving compensation from the Funds and the Columbia Funds Complex as of such date. |
Fund | Aggregate Compensation from Fund Independent Trustees | |||
Batejan | Blatz | Carlton | Flynn | |
For Funds with fiscal period ending December 31 | ||||
VP - Aggressive Portfolio | $4,431 | $4,431 | $4,431 | $4,431 |
Amount Deferred | $0 | $0 | $1,329 | $2,216 |
VP - American Century Diversified Bond Fund | $5,457 | $5,457 | $5,457 | $5,457 |
Amount Deferred | $0 | $0 | $1,637 | $2,729 |
VP - Balanced Fund | $2,736 | $2,736 | $2,736 | $2,736 |
Amount Deferred | $0 | $0 | $821 | $1,368 |
VP - BlackRock Global Inflation-Protected Securities Fund | $1,297 | $1,297 | $1,297 | $1,297 |
Amount Deferred | $0 | $0 | $389 | $649 |
VP - CenterSquare Real Estate Fund | $1,520 | $1,520 | $1,520 | $1,520 |
Amount Deferred | $0 | $0 | $456 | $760 |
VP - Commodity Strategy Fund | $1,387 | $1,387 | $1,387 | $1,387 |
Amount Deferred | $0 | $0 | $416 | $693 |
VP - Conservative Portfolio | $2,853 | $2,853 | $2,853 | $2,853 |
Amount Deferred | $0 | $0 | $856 | $1,427 |
VP - Core Equity Fund | $1,406 | $1,406 | $1,406 | $1,406 |
Amount Deferred | $0 | $0 | $422 | $703 |
Statement of Additional Information – May 1, 2021 | 172 |
Fund | Aggregate Compensation from Fund Independent Trustees | |||
Batejan | Blatz | Carlton | Flynn | |
VP - Disciplined Core Fund | $7,930 | $7,930 | $7,930 | $7,930 |
Amount Deferred | $0 | $0 | $2,379 | $3,965 |
VP - Dividend Opportunity Fund | $3,017 | $3,017 | $3,017 | $3,017 |
Amount Deferred | $0 | $0 | $905 | $1,508 |
VP - Emerging Markets Bond Fund | $1,713 | $1,713 | $1,713 | $1,713 |
Amount Deferred | $0 | $0 | $514 | $856 |
VP - Emerging Markets Fund | $1,665 | $1,665 | $1,665 | $1,665 |
Amount Deferred | $0 | $0 | $499 | $833 |
VP - Global Strategic Income Fund | $1,298 | $1,298 | $1,298 | $1,298 |
Amount Deferred | $0 | $0 | $389 | $649 |
VP - Government Money Market Fund | $1,738 | $1,738 | $1,738 | $1,738 |
Amount Deferred | $0 | $0 | $521 | $869 |
VP - High Yield Bond Fund | $1,599 | $1,599 | $1,599 | $1,599 |
Amount Deferred | $0 | $0 | $480 | $799 |
VP - Income Opportunities Fund | $1,636 | $1,636 | $1,636 | $1,636 |
Amount Deferred | $0 | $0 | $491 | $818 |
VP - Intermediate Bond Fund | $7,706 | $7,706 | $7,706 | $7,706 |
Amount Deferred | $0 | $0 | $2,312 | $3,853 |
VP - Large Cap Growth Fund | $4,061 | $4,061 | $4,061 | $4,061 |
Amount Deferred | $0 | $0 | $1,218 | $2,030 |
VP - Large Cap Index Fund | $2,886 | $2,886 | $2,886 | $2,886 |
Amount Deferred | $0 | $0 | $866 | $1,443 |
VP - Limited Duration Credit Fund | $2,185 | $2,185 | $2,185 | $2,185 |
Amount Deferred | $0 | $0 | $656 | $1,093 |
VP - Loomis Sayles Growth Fund | $4,311 | $4,311 | $4,311 | $4,311 |
Amount Deferred | $0 | $0 | $1,293 | $2,155 |
VP - MFS Value Fund | $3,058 | $3,058 | $3,058 | $3,058 |
Amount Deferred | $0 | $0 | $917 | $1,529 |
VP - Mid Cap Growth Fund | $1,879 | $1,879 | $1,879 | $1,879 |
Amount Deferred | $0 | $0 | $564 | $939 |
VP - Moderate Portfolio | $24,287 | $24,287 | $24,287 | $24,287 |
Amount Deferred | $0 | $0 | $7,287 | $12,144 |
VP - Moderately Aggressive Portfolio | $11,329 | $11,329 | $11,329 | $11,329 |
Amount Deferred | $0 | $0 | $3,399 | $5,665 |
VP - Moderately Conservative Portfolio | $5,315 | $5,315 | $5,315 | $5,315 |
Amount Deferred | $0 | $0 | $1,595 | $2,658 |
VP - Morgan Stanley Advantage Fund | $3,883 | $3,883 | $3,883 | $3,883 |
Amount Deferred | $0 | $0 | $1,165 | $1,942 |
VP - MV Moderate Growth Fund | $21,909 | $21,909 | $21,909 | $21,909 |
Amount Deferred | $0 | $0 | $6,573 | $10,954 |
VP - Overseas Core Fund | $3,495 | $3,495 | $3,495 | $3,495 |
Amount Deferred | $0 | $0 | $1,048 | $1,747 |
VP - Partners Core Bond Fund | $7,546 | $7,546 | $7,546 | $7,546 |
Amount Deferred | $0 | $0 | $2,264 | $3,773 |
VP - Partners Core Equity Fund | $5,241 | $5,241 | $5,241 | $5,241 |
Amount Deferred | $0 | $0 | $1,572 | $2,620 |
VP - Partners International Core Equity Fund | $4,891 | $4,891 | $4,891 | $4,891 |
Amount Deferred | $0 | $0 | $1,467 | $2,446 |
VP - Partners International Growth Fund | $2,598 | $2,598 | $2,598 | $2,598 |
Amount Deferred | $0 | $0 | $779 | $1,299 |
Statement of Additional Information – May 1, 2021 | 173 |
Fund | Aggregate Compensation from Fund Independent Trustees | |||
Batejan | Blatz | Carlton | Flynn | |
VP - Partners International Value Fund | $2,468 | $2,468 | $2,468 | $2,468 |
Amount Deferred | $0 | $0 | $740 | $1,234 |
VP - Partners Small Cap Growth Fund | $1,990 | $1,990 | $1,990 | $1,990 |
Amount Deferred | $0 | $0 | $597 | $995 |
VP - Partners Small Cap Value Fund | $1,953 | $1,953 | $1,953 | $1,953 |
Amount Deferred | $0 | $0 | $586 | $977 |
VP - Select Large Cap Equity Fund | $3,082 | $3,082 | $3,082 | $3,082 |
Amount Deferred | $0 | $0 | $925 | $1,541 |
VP - Select Large Cap Value Fund | $3,353 | $3,353 | $3,353 | $3,353 |
Amount Deferred | $0 | $0 | $1,006 | $1,677 |
VP - Select Mid Cap Value Fund | $1,538 | $1,538 | $1,538 | $1,538 |
Amount Deferred | $0 | $0 | $461 | $769 |
VP - Select Small Cap Value Fund | $1,245 | $1,245 | $1,245 | $1,245 |
Amount Deferred | $0 | $0 | $374 | $623 |
VP - Seligman Global Technology Fund | $1,291 | $1,291 | $1,291 | $1,291 |
Amount Deferred | $0 | $0 | $387 | $645 |
VP - T. Rowe Price Large Cap Value Fund | $3,206 | $3,206 | $3,206 | $3,206 |
Amount Deferred | $0 | $0 | $962 | $1,603 |
VP - TCW Core Plus Bond Fund | $5,562 | $5,562 | $5,562 | $5,562 |
Amount Deferred | $0 | $0 | $1,669 | $2,781 |
VP - U.S. Government Mortgage Fund | $2,579 | $2,579 | $2,579 | $2,579 |
Amount Deferred | $0 | $0 | $774 | $1,290 |
VP - Victory Sycamore Established Value Fund | $1,973 | $1,973 | $1,973 | $1,973 |
Amount Deferred | $0 | $0 | $592 | $986 |
VP - Wells Fargo Short Duration Government Fund | $3,348 | $3,348 | $3,348 | $3,348 |
Amount Deferred | $0 | $0 | $1,005 | $1,674 |
VP - Westfield Mid Cap Growth Fund | $1,932 | $1,932 | $1,932 | $1,932 |
Amount Deferred | $0 | $0 | $579 | $966 |
Fund | Aggregate Compensation from Fund Independent Trustees | ||||
Gallagher | Paglia | Santomero | Shaw | Yeager | |
For Funds with fiscal period ending December 31 | |||||
VP - Aggressive Portfolio | $4,431 | $5,002 | $4,139 | $4,023 | $4,139 |
Amount Deferred | $2,216 | $5,002 | $0 | $2,012 | $2,070 |
VP - American Century Diversified Bond Fund | $5,457 | $6,152 | $5,094 | $4,963 | $5,094 |
Amount Deferred | $2,729 | $6,152 | $0 | $2,482 | $2,547 |
VP - Balanced Fund | $2,736 | $3,082 | $2,556 | $2,488 | $2,556 |
Amount Deferred | $1,368 | $3,082 | $0 | $1,244 | $1,278 |
VP - BlackRock Global Inflation-Protected Securities Fund | $1,297 | $1,460 | $1,211 | $1,180 | $1,211 |
Amount Deferred | $649 | $1,460 | $0 | $590 | $606 |
VP - CenterSquare Real Estate Fund | $1,520 | $1,726 | $1,423 | $1,377 | $1,423 |
Amount Deferred | $760 | $1,726 | $0 | $689 | $711 |
VP - Commodity Strategy Fund | $1,387 | $1,578 | $1,301 | $1,259 | $1,301 |
Amount Deferred | $693 | $1,578 | $0 | $630 | $651 |
VP - Conservative Portfolio | $2,853 | $3,205 | $2,663 | $2,597 | $2,663 |
Amount Deferred | $1,427 | $3,205 | $0 | $1,299 | $1,331 |
VP - Core Equity Fund | $1,406 | $1,582 | $1,312 | $1,277 | $1,312 |
Amount Deferred | $703 | $1,582 | $0 | $639 | $656 |
VP - Disciplined Core Fund | $7,930 | $8,973 | $7,410 | $7,189 | $7,410 |
Amount Deferred | $3,965 | $8,973 | $0 | $3,594 | $3,705 |
VP - Dividend Opportunity Fund | $3,017 | $3,411 | $2,819 | $2,738 | $2,819 |
Statement of Additional Information – May 1, 2021 | 174 |
Fund | Aggregate Compensation from Fund Independent Trustees | ||||
Gallagher | Paglia | Santomero | Shaw | Yeager | |
Amount Deferred | $1,508 | $3,411 | $0 | $1,369 | $1,409 |
VP - Emerging Markets Bond Fund | $1,713 | $1,921 | $1,598 | $1,558 | $1,598 |
Amount Deferred | $856 | $1,921 | $0 | $779 | $799 |
VP - Emerging Markets Fund | $1,665 | $1,875 | $1,556 | $1,515 | $1,556 |
Amount Deferred | $833 | $1,875 | $0 | $757 | $778 |
VP - Global Strategic Income Fund | $1,298 | $1,460 | $1,212 | $1,180 | $1,212 |
Amount Deferred | $649 | $1,460 | $0 | $590 | $606 |
VP - Government Money Market Fund | $1,738 | $1,948 | $1,618 | $1,578 | $1,618 |
Amount Deferred | $869 | $1,948 | $0 | $789 | $809 |
VP - High Yield Bond Fund | $1,599 | $1,802 | $1,493 | $1,452 | $1,493 |
Amount Deferred | $799 | $1,802 | $0 | $726 | $746 |
VP - Income Opportunities Fund | $1,636 | $1,843 | $1,528 | $1,487 | $1,528 |
Amount Deferred | $818 | $1,843 | $0 | $744 | $764 |
VP - Intermediate Bond Fund | $7,706 | $8,699 | $7,195 | $7,005 | $7,195 |
Amount Deferred | $3,853 | $8,699 | $0 | $3,503 | $3,598 |
VP - Large Cap Growth Fund | $4,061 | $4,567 | $3,793 | $3,692 | $3,793 |
Amount Deferred | $2,030 | $4,567 | $0 | $1,846 | $1,896 |
VP - Large Cap Index Fund | $2,886 | $3,245 | $2,694 | $2,623 | $2,694 |
Amount Deferred | $1,443 | $3,245 | $0 | $1,312 | $1,347 |
VP - Limited Duration Credit Fund | $2,185 | $2,463 | $2,040 | $1,986 | $2,040 |
Amount Deferred | $1,093 | $2,463 | $0 | $993 | $1,020 |
VP - Loomis Sayles Growth Fund | $4,311 | $4,866 | $4,031 | $3,916 | $4,031 |
Amount Deferred | $2,155 | $4,866 | $0 | $1,958 | $2,016 |
VP - MFS Value Fund | $3,058 | $3,468 | $2,871 | $2,790 | $2,871 |
Amount Deferred | $1,529 | $3,468 | $0 | $1,395 | $1,435 |
VP - Mid Cap Growth Fund | $1,879 | $2,112 | $1,754 | $1,708 | $1,754 |
Amount Deferred | $939 | $2,112 | $0 | $854 | $877 |
VP - Moderate Portfolio | $24,287 | $27,440 | $22,688 | $22,061 | $22,688 |
Amount Deferred | $12,144 | $27,440 | $0 | $11,031 | $11,344 |
VP - Moderately Aggressive Portfolio | $11,329 | $12,806 | $10,583 | $10,285 | $10,583 |
Amount Deferred | $5,665 | $12,806 | $0 | $5,142 | $5,291 |
VP - Moderately Conservative Portfolio | $5,315 | $5,999 | $4,966 | $4,832 | $4,966 |
Amount Deferred | $2,658 | $5,999 | $0 | $2,416 | $2,483 |
VP - Morgan Stanley Advantage Fund | $3,883 | $4,369 | $3,614 | $3,504 | $3,614 |
Amount Deferred | $1,942 | $4,369 | $0 | $1,752 | $1,807 |
VP - MV Moderate Growth Fund | $21,909 | $24,748 | $20,463 | $19,905 | $20,463 |
Amount Deferred | $10,954 | $24,748 | $0 | $9,952 | $10,232 |
VP - Overseas Core Fund | $3,495 | $3,852 | $3,241 | $3,170 | $3,241 |
Amount Deferred | $1,747 | $3,852 | $0 | $1,585 | $1,621 |
VP - Partners Core Bond Fund | $7,546 | $8,471 | $7,033 | $6,871 | $7,033 |
Amount Deferred | $3,773 | $8,471 | $0 | $3,436 | $3,517 |
VP - Partners Core Equity Fund | $5,241 | $5,867 | $4,885 | $4,773 | $4,885 |
Amount Deferred | $2,620 | $5,867 | $0 | $2,386 | $2,442 |
VP - Partners International Core Equity Fund | $4,891 | $5,526 | $4,572 | $4,444 | $4,572 |
Amount Deferred | $2,446 | $5,526 | $0 | $2,222 | $2,286 |
VP - Partners International Growth Fund | $2,598 | $2,921 | $2,427 | $2,361 | $2,427 |
Amount Deferred | $1,299 | $2,921 | $0 | $1,180 | $1,214 |
VP - Partners International Value Fund | $2,468 | $2,770 | $2,301 | $2,237 | $2,301 |
Amount Deferred | $1,234 | $2,770 | $0 | $1,119 | $1,151 |
VP - Partners Small Cap Growth Fund | $1,990 | $2,234 | $1,859 | $1,810 | $1,859 |
Amount Deferred | $995 | $2,234 | $0 | $905 | $929 |
Statement of Additional Information – May 1, 2021 | 175 |
Fund | Aggregate Compensation from Fund Independent Trustees | ||||
Gallagher | Paglia | Santomero | Shaw | Yeager | |
VP - Partners Small Cap Value Fund | $1,953 | $2,202 | $1,826 | $1,775 | $1,826 |
Amount Deferred | $977 | $2,202 | $0 | $888 | $913 |
VP - Select Large Cap Equity Fund | $3,082 | $3,467 | $2,878 | $2,803 | $2,878 |
Amount Deferred | $1,541 | $3,467 | $0 | $1,401 | $1,439 |
VP - Select Large Cap Value Fund | $3,353 | $3,764 | $3,128 | $3,052 | $3,128 |
Amount Deferred | $1,677 | $3,764 | $0 | $1,526 | $1,564 |
VP - Select Mid Cap Value Fund | $1,538 | $1,732 | $1,437 | $1,398 | $1,437 |
Amount Deferred | $769 | $1,732 | $0 | $699 | $718 |
VP - Select Small Cap Value Fund | $1,245 | $1,401 | $1,163 | $1,132 | $1,163 |
Amount Deferred | $623 | $1,401 | $0 | $566 | $581 |
VP - Seligman Global Technology Fund | $1,291 | $1,451 | $1,205 | $1,173 | $1,205 |
Amount Deferred | $645 | $1,451 | $0 | $587 | $602 |
VP - T. Rowe Price Large Cap Value Fund | $3,206 | $3,645 | $2,999 | $2,903 | $2,999 |
Amount Deferred | $1,603 | $3,645 | $0 | $1,452 | $1,500 |
VP - TCW Core Plus Bond Fund | $5,562 | $6,265 | $5,188 | $5,060 | $5,188 |
Amount Deferred | $2,781 | $6,265 | $0 | $2,530 | $2,594 |
VP - U.S. Government Mortgage Fund | $2,579 | $2,908 | $2,408 | $2,345 | $2,408 |
Amount Deferred | $1,290 | $2,908 | $0 | $1,172 | $1,204 |
VP - Victory Sycamore Established Value Fund | $1,973 | $2,222 | $1,842 | $1,792 | $1,842 |
Amount Deferred | $986 | $2,222 | $0 | $896 | $921 |
VP - Wells Fargo Short Duration Government Fund | $3,348 | $3,785 | $3,125 | $3,044 | $3,125 |
Amount Deferred | $1,674 | $3,785 | $0 | $1,522 | $1,563 |
VP - Westfield Mid Cap Growth Fund | $1,932 | $2,173 | $1,803 | $1,755 | $1,803 |
Amount Deferred | $966 | $2,173 | $0 | $877 | $902 |
Statement of Additional Information – May 1, 2021 | 176 |
Statement of Additional Information – May 1, 2021 | 177 |
Statement of Additional Information – May 1, 2021 | 178 |
Statement of Additional Information – May 1, 2021 | 179 |
Total Brokerage Commissions | |||
Fund | 2020 | 2019 | 2018 |
For Funds with fiscal period ending December 31 | |||
VP – Aggressive Portfolio | $174,941 | $25,683 | $55,365 |
VP – American Century Diversified Bond Fund | 134,617 | 103,168 | 134,124 |
VP – Balanced Fund | 320,199 | 240,046 | 357,414 |
VP – BlackRock Global Inflation-Protected Securities Fund | 6,042 | 5,679 | 6,426 |
VP – CenterSquare Real Estate Fund | 526,109 | 534,088 | 408,011 |
VP – Commodity Strategy Fund | 433,243 | 0 | 0 |
VP – Conservative Portfolio | 84,653 | 17,052 | 25,566 |
VP – Core Equity Fund | 98,515 | 82,779 | 96,300 |
VP – Disciplined Core Fund | 2,693,860 | 2,291,371 | 2,563,472 |
VP – Dividend Opportunity Fund | 580,012 | 525,851 | 1,664,257 |
VP – Emerging Markets Bond Fund | 4,447 | 2,074 | 1,446 |
VP – Emerging Markets Fund | 258,889 | 369,599 | 879,972 |
VP – Global Strategic Income Fund | 6,633 | 3,948 | 12,284 |
VP – Government Money Market Fund | 0 | 0 | 0 |
VP – High Yield Bond Fund | 0 | 826 | 3,530 |
Statement of Additional Information – May 1, 2021 | 180 |
Total Brokerage Commissions | |||
Fund | 2020 | 2019 | 2018 |
VP – Income Opportunities Fund | $0 | $599 | $4,234 |
VP – Intermediate Bond Fund | 508,483 | 445,121 | 300,320 |
VP – Large Cap Growth Fund | 575,465 | 320,535 | 266,935 |
VP – Large Cap Index Fund | 21,252 | 24,269 | 23,748 |
VP – Limited Duration Credit Fund | 76,933 | 65,357 | 46,576 |
VP – Loomis Sayles Growth Fund | 507,067 | 158,155 | 132,493 |
VP – MFS Value Fund | 217,447 | 176,632 | 127,570 |
VP – Mid Cap Growth Fund | 224,000 | 212,000 | 488,607 |
VP – Moderate Portfolio | 980,504 | 165,258 | 355,664 |
VP – Moderately Aggressive Portfolio | 496,345 | 68,931 | 142,490 |
VP – Moderately Conservative Portfolio | 139,584 | 34,089 | 52,978 |
VP – Morgan Stanley Advantage Fund | 479,641 | 529,131 | 598,347 |
VP – MV Moderate Growth Fund | 3,825,052 | 1,116,642 | 1,457,422 |
VP – Overseas Core Fund | 1,475,671 | 969,462 | 2,113,982 |
VP – Partners Core Bond Fund | 0 | 0 | 0 |
VP – Partners Core Equity Fund | 589,410 | 393,893 | 423,723 |
VP – Partners International Core Equity Fund | 904,800 | 614,972 | 1,491,314 |
VP – Partners International Growth Fund | 579,722 | 724,438 | 728,210 |
VP – Partners International Value Fund | 672,706 | 156,462 | 355,236 |
VP – Partners Small Cap Growth Fund | 493,824 | 688,372 | 872,236 |
VP – Partners Small Cap Value Fund | 647,816 | 1,023,662 | 894,593 |
VP – Select Large Cap Equity Fund | 617,920 | 562,246 | 369,901(a) |
VP – Select Large Cap Value Fund | 1,026,175 | 187,473 | 207,447 |
VP – Select Mid Cap Value Fund | 140,523 | 100,092 | 272,119 |
VP – Select Small Cap Value Fund | 38,631 | 41,348 | 31,429 |
VP – Seligman Global Technology Fund | 58,720 | 57,073 | 35,421 |
VP – T. Rowe Price Large Cap Value Fund | 303,420 | 268,798 | 254,894 |
VP – TCW Core Plus Bond Fund | 56,067 | 58,859 | 70,515 |
VP – U.S. Government Mortgage Fund | 110,900 | 133,447 | 48,112 |
VP – Victory Sycamore Established Value Fund | 246,219 | 243,436 | 252,119 |
VP – Wells Fargo Short Duration Government Fund | 61,251 | 56,286 | 22,583 |
VP – Westfield Mid Cap Growth Fund | 282,584 | 382,305 | 415,697 |
(a) | For the period from January 4, 2018 (commencement of operations) to December 31, 2018. |
Statement of Additional Information – May 1, 2021 | 181 |
Brokerage directed for research | ||
Fund | Amount of Transactions | Amount of Commissions Imputed or Paid |
For Funds with fiscal period ending December 31 | ||
VP – Aggressive Portfolio | $0 | $0 |
VP – American Century Diversified Bond Fund | 0 | 0 |
VP – Balanced Fund | 620,364,785 | 113,231 |
VP – BlackRock Global Inflation-Protected Securities Fund | 0 | 0 |
VP – CenterSquare Real Estate Fund | 226,448,003 | 68,749 |
VP – Commodity Strategy Fund | 0 | 0 |
VP – Conservative Portfolio | 0 | 0 |
VP – Core Equity Fund | 151,455,185 | 26,245 |
VP – Disciplined Core Fund | 4,064,084,857 | 702,001 |
VP – Dividend Opportunity Fund | 649,929,651 | 152,681 |
VP – Emerging Markets Bond Fund | 0 | 0 |
VP – Emerging Markets Fund | 40,959,511 | 56,691 |
VP – Global Strategic Income Fund | 0 | 0 |
VP – Government Money Market Fund | 0 | 0 |
VP – High Yield Bond Fund | 0 | 0 |
VP – Income Opportunities Fund | 0 | 0 |
VP – Intermediate Bond Fund | 0 | 0 |
VP – Large Cap Growth Fund | 1,757,730,138 | 197,411 |
VP – Large Cap Index Fund | 0 | 0 |
VP – Limited Duration Credit Fund | 0 | 0 |
VP – Loomis Sayles Growth Fund | 1,567,134,097 | 302,333 |
VP – MFS Value Fund | 940,709,357 | 54,456 |
Statement of Additional Information – May 1, 2021 | 182 |
Brokerage directed for research | ||
Fund | Amount of Transactions | Amount of Commissions Imputed or Paid |
VP – Mid Cap Growth Fund | $760,600,000 | $187,000 |
VP – Moderate Portfolio | 0 | 0 |
VP – Moderately Aggressive Portfolio | 0 | 0 |
VP – Moderately Conservative Portfolio | 0 | 0 |
VP – Morgan Stanley Advantage Fund | 4,275,159,944 | 79,815 |
VP – MV Moderate Growth Fund | 16,715,098 | 609 |
VP – Overseas Core Fund | 461,124,668 | 336,389 |
VP – Partners Core Bond Fund | 0 | 0 |
VP – Partners Core Equity Fund | 0 | 0 |
VP – Partners International Core Equity Fund | 0 | 0 |
VP – Partners International Growth Fund | 14,947,333 | 15,991 |
VP – Partners International Value Fund | 88,100,470 | 10,595 |
VP – Partners Small Cap Growth Fund | 369,698,946 | 262,790 |
VP – Partners Small Cap Value Fund | 280,683,893 | 326,110 |
VP – Select Large Cap Equity Fund | 1,041,510,323 | 186,072 |
VP – Select Large Cap Value Fund | 648,344,146 | 305,723 |
VP – Select Mid Cap Value Fund | 190,176,445 | 50,531 |
VP – Select Small Cap Value Fund | 29,178,549 | 13,530 |
VP – Seligman Global Technology Fund | 52,100,521 | 16,213 |
VP – T. Rowe Price Large Cap Value Fund | 0 | 0 |
VP – TCW Core Plus Bond Fund | 0 | 0 |
VP – U.S. Government Mortgage Fund | 0 | 0 |
VP – Victory Sycamore Established Value Fund | 392,180,836 | 128,038 |
VP – Wells Fargo Short Duration Government Fund | 0 | 0 |
VP – Westfield Mid Cap Growth Fund | 520,341,166 | 82,559 |
Statement of Additional Information – May 1, 2021 | 183 |
Fund | Issuer | Value
of securities owned at end of fiscal period |
For Funds with fiscal period ending December 31, 2020 | ||
VP – Aggressive Portfolio | None | N/A |
VP – American Century Diversified Bond Fund | Bear Stearns Adjustable Rate Mortgage Trust | $1,362,402 |
Citigroup Mortgage Loan Trust, Inc. | $7,511,242 | |
Citigroup, Inc. | $16,741,722 | |
Credit Suisse First Boston Mortgage-Backed Trust | $295,925 | |
Credit Suisse Group AG | $12,505,513 | |
JPMorgan Chase & Co. | $26,816,933 | |
JPMorgan Mortgage Trust | $4,573,212 | |
Morgan Stanley | $24,319,789 | |
The Goldman Sachs Group, Inc. | $30,739,914 | |
VP – Balanced Fund | Citigroup Mortgage Loan Trust, Inc. | $558,347 |
Citigroup, Inc. | $15,064,685 | |
GS Mortgage Securities Trust | $3,567,831 | |
JPMorgan Chase & Co. | $15,745,923 | |
Morgan Stanley | $13,694,442 | |
Morgan Stanley Capital I Trust | $1,975,820 | |
PNC Financial Services Group, Inc.(The) | $794,018 | |
The Goldman Sachs Group, Inc. | $1,506,218 | |
VP – BlackRock Global Inflation-Protected Securities Fund | None | N/A |
VP – CenterSquare Real Estate Fund | None | N/A |
VP – Commodity Strategy Fund | None | N/A |
VP – Conservative Portfolio | None | N/A |
VP – Core Equity Fund | Citigroup, Inc. | $4,347,030 |
Morgan Stanley | $1,802,339 | |
VP – Disciplined Core Fund | Citigroup, Inc. | $108,133,142 |
Morgan Stanley | $44,969,386 | |
VP – Dividend Opportunity Fund | JPMorgan Chase & Co. | $60,993,600 |
Morgan Stanley | $22,272,250 | |
PNC Financial Services Group, Inc.(The) | $18,997,500 | |
VP – Emerging Markets Bond Fund | None | N/A |
VP – Emerging Markets Fund | None | N/A |
VP – Global Strategic Income Fund | Citigroup, Inc. | $239,798 |
Credit Suisse Commercial Mortgage Trust | $718,183 | |
The Goldman Sachs Group, Inc. | $161,381 | |
VP – Government Money Market Fund | None | N/A |
VP – High Yield Bond Fund | None | N/A |
VP – Income Opportunities Fund | None | N/A |
Statement of Additional Information – May 1, 2021 | 184 |
Fund | Issuer | Value
of securities owned at end of fiscal period |
VP – Intermediate Bond Fund | Citigroup Mortgage Loan Trust, Inc. | $17,814,911 |
Citigroup, Inc. | $6,522,492 | |
Credit Suisse Mortgage Capital Certificates | $2,796 | |
Credit Suisse Mortgage Capital Certificates OA LLC | $28,803,865 | |
Credit Suisse Mortgage Capital Trust | $15,935,302 | |
JPMorgan Chase & Co. | $23,504,348 | |
JPMorgan Resecuritization Trust | $103,791 | |
Morgan Stanley | $7,485,030 | |
Morgan Stanley Capital I Trust | $10,210,217 | |
The Goldman Sachs Group, Inc. | $9,010,413 | |
VP – Large Cap Growth Fund | None | N/A |
VP – Large Cap Index Fund | Ameriprise Financial, Inc. | $1,032,476 |
Citigroup, Inc. | $5,781,365 | |
Franklin Resources, Inc. | $306,652 | |
Goldman Sachs Group | $4,086,186 | |
JPMorgan Chase & Co. | $17,443,788 | |
Morgan Stanley | $4,411,071 | |
PNC Financial Services Group, Inc.(The) | $2,843,069 | |
Raymond James & Associates | $525,037 | |
The Charles Schwab Corp. | $3,563,121 | |
VP – Limited Duration Credit Fund | Citigroup, Inc. | $3,787,073 |
Goldman Sachs Group | $7,377,714 | |
JPMorgan Chase & Co. | $10,736,534 | |
Morgan Stanley | $5,660,422 | |
VP – Loomis Sayles Growth Fund | None | N/A |
VP – MFS Value Fund | Citigroup, Inc. | $38,289,134 |
Goldman Sachs Group, Inc. (The) | $24,810,364 | |
JPMorgan Chase & Co. | $77,576,616 | |
Morgan Stanley | $6,630,483 | |
PNC Financial Services Group, Inc.(The) | $20,895,909 | |
VP – Mid Cap Growth Fund | None | N/A |
VP – Moderate Portfolio | None | N/A |
VP – Moderately Aggressive Portfolio | None | N/A |
VP – Moderately Conservative Portfolio | None | N/A |
VP – Morgan Stanley Advantage Fund | None | N/A |
VP – MV Moderate Growth Fund | Citigroup, Inc. | $815,312 |
JPMorgan Chase & Co. | $964,448 | |
Morgan Stanley | $598,446 | |
The Goldman Sachs Group, Inc. | $727,991 | |
VP – Overseas Core Fund | None | N/A |
Statement of Additional Information – May 1, 2021 | 185 |
Fund | Issuer | Value
of securities owned at end of fiscal period |
VP – Partners Core Bond Fund | Bear Stearns Adjustable Rate Mortgage Trust | $198,654 |
Bear Stearns Alt-A Trust | $17,603 | |
Bear Stearns Asset-Backed Securities Trust | $238,436 | |
Bear Stearns Commercial Mortgage Securities Trust | $3,215 | |
Citigroup Commercial Mortgage Trust | $6,817,931 | |
Citigroup Mortgage Loan Trust, Inc. | $376,693 | |
Citigroup, Inc. | $15,613,554 | |
Citigroup/Deutsche Bank Commercial Mortgage Trust | $9 | |
Credit Suisse AG | $1,014,576 | |
Credit Suisse Commercial Mortgage Trust | $2,557,560 | |
Credit Suisse First Boston Mortgage Securities Corp. | $91,532 | |
Credit Suisse First Boston Mortgage-Backed Pass-Through Certificates | $371,663 | |
Credit Suisse Group AG | $11,994,025 | |
Credit Suisse Group Funding Guemsey Ltd. | $2,627,829 | |
Franklin Resources, Inc. | $1,772,037 | |
GS Mortgage Securities Corp. II | $2,019,266 | |
GS Mortgage Securities Trust | $13,981,106 | |
JPMorgan Chase & Co. | $9,658,064 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $12,204 | |
JPMorgan Mortgage Trust | $366,122 | |
LB-UBS Commercial Mortgage Trust | $201 | |
Merrill Lynch Mortgage Investors Trust | $976,428 | |
Merrill Lynch/Countrywide Commercial Mortgage Trust | $3 | |
Morgan Stanley | $33,137,403 | |
Morgan Stanley Capital I Trust | $1,064,943 | |
Morgan Stanley Mortgage Loan Trust | $199,085 | |
PNC Bank NA | $599,265 | |
The Charles Schwab Corp. | $2,914,001 | |
The Goldman Sachs Group, Inc. | $25,053,445 | |
VP – Partners Core Equity Fund | Citigroup, Inc. | $1,629,119 |
Goldman Sachs Group | $12,473,483 | |
Morgan Stanley | $30,335,627 | |
Raymond James Financial, Inc. (subsidiary) | $4,179,057 | |
The Charles Schwab Corp. | $19,311,864 | |
VP – Partners International Core Equity Fund | Credit Suisse Group AG, Registered Shares | $7,462,849 |
VP – Partners International Growth Fund | None | N/A |
VP – Partners International Value Fund | Credit Suisse Group AG | $1,531,514 |
VP – Partners Small Cap Growth Fund | Primerica, Inc. | $1,246,888 |
Stifel Financial Corp. | $3,843,538 | |
VP – Partners Small Cap Value Fund | Piper Sandler Companies | $4,055,474 |
VP – Select Large Cap Equity Fund | Citigroup, Inc. | $30,370,941 |
VP – Select Large Cap Value Fund | Citigroup, Inc. | $70,779,144 |
JPMorgan Chase & Co. | $62,892,153 | |
Morgan Stanley | $62,489,149 | |
VP – Select Mid Cap Value Fund | None | N/A |
VP – Select Small Cap Value Fund | None | N/A |
Statement of Additional Information – May 1, 2021 | 186 |
Fund | Issuer | Value
of securities owned at end of fiscal period |
VP – Seligman Global Technology Fund | None | N/A |
VP – T. Rowe Price Large Cap Value Fund | Charles Schwab | $25,382,610 |
JPMorgan Chase & Co. | $22,461,274 | |
Morgan Stanley | $52,067,929 | |
The Goldman Sachs Group, Inc. | $9,836,383 | |
VP – TCW Core Plus Bond Fund | Citigroup Mortgage Loan Trust, Inc. | $415,028 |
Citigroup, Inc. | $10,997,062 | |
Credit Suisse First Boston Mortgage-Backed Pass-Through Certificates | $684,635 | |
Credit Suisse Mortgage Capital Certificates | $3,388,005 | |
GS Mortgage-Backed Securities Trust | $9,489,068 | |
JPMorgan Chase & Co. | $3,322,570 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $3,104,829 | |
JPMorgan Mortgage Acquisition Trust | $9,767,118 | |
Merrill Lynch First Franklin Mortgage Loan Trust | $2,998,034 | |
Merrill Lynch Mortgage-Backed Securities Trust | $1,118,410 | |
Morgan Stanley Mortgage Loan Trust | $884,518 | |
Raymond James Financial, Inc. (subsidiary) | $1,407,436 | |
The Goldman Sachs Group, Inc. | $4,924,931 | |
VP – U.S. Government Mortgage Fund | Citigroup Commercial Mortgage Trust | $5,095,641 |
Credit Suisse Mortgage Capital Certificates | $737,144 | |
Credit Suisse Mortgage Capital Certificates OA LLC | $5,650,929 | |
JPMorgan Chase Commercial Mortgage Securities Trust | $73,997 | |
Morgan Stanley Capital I Trust | $2,459,032 | |
VP – Victory Sycamore Established Value Fund | None | N/A |
VP – Wells Fargo Short Duration Government Fund | Citigroup Commercial Mortgage Trust | $1,233,884 |
VP – Westfield Mid Cap Growth Fund | None | N/A |
Statement of Additional Information – May 1, 2021 | 187 |
Statement of Additional Information – May 1, 2021 | 188 |
■ | For equity, alternative and flexible funds (other than the equity funds identified below) and funds-of-funds (equity and fixed income), a complete list of Fund portfolio holdings as of month-end is posted approximately, but no earlier than, 15 calendar days after such month-end. |
■ | For Columbia Small Cap Growth Fund I and Columbia Variable Portfolio – Small Company Growth Fund, a complete list of Fund portfolio holdings as of month-end is posted approximately, but no earlier than, 30 calendar days after such month-end. |
■ | For fixed-income Funds (other than money market funds), a complete list of Fund portfolio holdings as of calendar quarter-end is posted approximately, but no earlier than, 30 calendar days after such quarter-end. |
■ | For money market Funds, a complete list of Fund portfolio holdings as of month-end is posted no later than five business days after such month-end. Such month-end holdings are continuously available on the website for at least six months, together with a link to an SEC webpage where a user of the website may obtain access to the Fund’s most recent 12 months of publicly available filings on Form N-MFP. Money market Fund portfolio holdings information posted on the website, at minimum, includes with respect to each holding, the name of the issuer, the category of investment (e.g., Treasury debt, government agency debt, asset backed commercial paper, structured investment vehicle note), the CUSIP number (if any), the principal amount, the maturity date (as determined under Rule 2a-7 for purposes of calculating weighted average maturity), the final maturity date (if different from the maturity date previously described), coupon or yield and the value. The money market Funds will also disclose on the website its overall weighted average maturity, weighted average life maturity, percentage of daily liquid assets, percentage of weekly liquid assets and daily inflows and outflows. |
Statement of Additional Information – May 1, 2021 | 189 |
Statement of Additional Information – May 1, 2021 | 190 |
Identity of Recipient | Conditions/restrictions on use of information | Frequency
of Disclosure | ||
Recipients under arrangements with the Funds or Investment Manager: | ||||
Abel Noser | Used to evaluate and assess trading activity, execution and practices. | Quarterly | ||
Allvue Systems Company | Used for front office trading, bank loan analytics, and compliance. | Daily | ||
Axioma Inc. | Used as a hosted risk analytics platform designed for research, investment oversight and strategy development. | Daily | ||
BlackRock, Inc. | Used for front office trading, risk and analytics as well as back office settlements and trade routing. Used for front office trading, portfolio risk oversight, and analytics, compliance mandate monitoring and back office settlements, collateral management and account reconciliation. | Daily | ||
Bloomberg Finance L.P. | Used for portfolio analytics, statistical analysis and independent research. | Daily | ||
Bolger, Inc. | Used for commercial printing. | As Needed | ||
Boston Investors Communications Group, LLC (BICG) | Used for writing services that require disclosing portfolio holdings in advance of their dissemination to the general public. | Monthly |
Statement of Additional Information – May 1, 2021 | 191 |
Identity of Recipient | Conditions/restrictions on use of information | Frequency
of Disclosure | ||
Capital Markets Services (CMS) Group | Used for intraday post-trade information when equity exposures (either via futures or options trades) are modified beyond certain limits for certain Funds. | As Needed | ||
Castine LLC | Used to facilitate the evaluation of commission rates and to provide flexible commission reporting. | Daily | ||
Catapult ME, Inc. | Used for commercial printing. | As Needed | ||
Citigroup, Inc. | Used for mortgage decision support. | Daily | ||
Compliance Solutions Strategies LLC | Used to report returns and analytics to client facing materials. | Monthly | ||
Curtis 1000 | Used for commercial printing. | As Needed | ||
Donnelley Financial Solutions | Used to provide Edgar filing and typesetting services, and printing of prospectuses, factsheets, annual and semi-annual reports. | As Needed | ||
DS Graphics, Inc. | Used for printing of prospectuses, factsheets, annual and semi-annual reports. | As Needed | ||
Elevation Exhibits & Events | Used for trade show exhibits. | As Needed | ||
Equifax, Inc. | Used to ensure that Columbia Management does not violate the Office of Foreign Assets Control (OFAC) sanction requirements. | Daily | ||
Ernst & Young, LLP | Used to analyze PFIC investments. | Monthly | ||
FactSet Research Systems, Inc. | Used to calculate portfolio performance attribution, portfolio analytics, data for fundamental research, and general market news and analysis. | Daily | ||
Fidelity National Information Services, Inc. | Used as a portfolio accounting system. | Daily | ||
Goldman Sachs Asset Management, L.P., as agent to KPMG LLP | Holdings by Columbia Contrarian Core Fund and Columbia High Yield Bond Fund in certain audit clients of KPMG LLP to assist the accounting firm in complying with its regulatory obligations relating to independence of its audit clients. | Monthly | ||
Harte-Hanks, Inc. | Used for printing of prospectuses, factsheets, annual and semi-annual reports. | As Needed | ||
IHS Markit, Ltd. | Used for an asset database for analytics and investor reporting. | As Needed | ||
Imagine! Print Solutions | Used for commercial printing. | As Needed | ||
Institutional Shareholder Services Inc. (ISS) | Used for proxy voting administration and research on proxy matters. | Daily | ||
Intex Solutions Inc. | Used to provide mortgage analytics. | As Needed | ||
Investment Company Institute (ICI) | Disclosure of Form N-PORT data. | As Needed | ||
Investortools, Inc. | Used for municipal bond analytics, research and decision support. | As Needed | ||
JDP Marketing Services | Used to write or edit Columbia Fund shareholder reports, quarterly fund commentaries, and communications, including shareholder letters and management’s discussion of Columbia Fund performance. | As Needed |
Statement of Additional Information – May 1, 2021 | 192 |
Identity of Recipient | Conditions/restrictions on use of information | Frequency
of Disclosure | ||
John Roberts, Inc. | Used for commercial printing. | As Needed | ||
Kendall Press | Used for commercial printing. | As Needed | ||
Kessler Topaz Meltzer & Check, LLP | Used for certain foreign bankruptcy settlements. | As Needed | ||
KPMG US LLP | Used to provide tax services. | Daily | ||
Kynex, Inc. | Used to provide portfolio attribution reports for the Columbia Convertible Securities Fund. Used also for portfolio analytics. | Daily | ||
Merrill Corporation | Used for printing of prospectuses, factsheets, annual and semi-annual reports. | As Needed | ||
Morningstar Investment Services, LLC | Used for independent research and ranking of funds. Used also for statistical analysis. | As Needed | ||
NASDAQ | Used to evaluate and assess trading activity, execution and practices. | Daily | ||
R. R. Donnelley & Sons Co. | Used to provide printing of prospectuses, factsheets, annual and semi-annual reports. Used for commercial printing. | As Needed | ||
RegEd, Inc. | Used to review external and certain internal communications prior to dissemination. | Daily | ||
Sustainalytics US, Inc. | Used to: 1) validate the social impact score the Columbia analysts assigned to each municipal investment and 2) provide ESG risk ratings and other related information for each corporate bond issuer. | Quarterly | ||
S.W.I.F.T. Scrl. | Used to send trade messages via SWIFT to custodians. | Daily | ||
Thomson Reuters Corp. | Used for statistical analysis. | As Needed | ||
Visions, Inc. | Used for commercial printing. | As Needed | ||
Wilshire Associates, Inc. | Used to provide performance attribution reporting. | Daily |
Statement of Additional Information – May 1, 2021 | 193 |
Identity of Recipient | Conditions/restrictions on use of information | Frequency
of Disclosure | ||
Recipients under arrangements with subadvisers: | ||||
Abel Noser Corp. | Used by certain subadvisers for transaction cost analysis and other analytics. | Daily or Quarterly | ||
AccuSource LLC | Used by certain subadvisers for custodian reconciliation. | Daily | ||
Ashland Partners & Co. LLP | Used by certain subadvisers for audit and Global Investment Performance Standards (GIPS) evaluation. | Annually | ||
Axioma, Inc. | Used by certain subadvisers for analytics and attribution analysis. | Daily | ||
BlackRock, Inc. | Used by certain subadvisers for analytical and statistical information. Used by certain subadvisers for order management and compliance. | Daily | ||
Bloomberg Finance L.P. | Used by certain subadvisers for analytical, portfolio management, and statistical information. Used by certain subadvisers for compliance and personal trade monitoring. | Daily | ||
BNY Mellon Corp. | Used by certain subadvisers for middle-office functions. | Daily | ||
Brown Brothers Harriman & Co. | Used by certain subadvisers for electronic trade transmission and settlement. | Daily | ||
CapitalIQ | Used by certain subadvisers for market data. | Daily | ||
Citibank N.A. | Used by certain subadvisers for middle office functions. | Daily | ||
Clearwater Analytics, LLC | Used by certain subadvisers for client reporting. | Daily | ||
Commcise LLP | Used by certain subadvisers for commission tracking. Used by certain subadvisers for data to increase operational efficiencies. | Daily | ||
ComplySci | Used by certain subadvisers for compliance and personal trade monitoring. | Daily | ||
Credit Suisse Group AG | Used by certain subadvisers for analytical, portfolio management, and statistical information. | Quarterly | ||
Eagle Investment Systems, LLC | Used by certain subadvisers for portfolio accounting systems. | Daily | ||
Electra Information Systems, Inc. | Used by certain subadvisers for electronic reconciliations of portfolio holdings. | Daily or Monthly | ||
eVestment Alliance, LLC | Used by certain subadvisers for updating databases. | Quarterly | ||
Eze Castle Software LLC | Used by certain subadvisers for compliance and personal trade monitoring. | Daily | ||
FactSet Research Systems, Inc. | Used by certain subadvisers for analytical and statistical information. | Daily | ||
Fidelity ActionResponse | Used by certain subadvisers for corporate actions management. | Daily |
Statement of Additional Information – May 1, 2021 | 194 |
Identity of Recipient | Conditions/restrictions on use of information | Frequency
of Disclosure | ||
Financial Recovery Technologies Services | Used by certain subadvisers for class action monitoring services. | Quarterly | ||
FIS Brokerage Securities Services LLC | Used by certain subadvisers for confirmation and settlement of bank loan trades. | Daily | ||
FIS Financial Systems LLC | Used by certain subadvisers for corporate actions management. | Daily | ||
FundApps Ltd. | Used by certain subadvisers for global regulatory shareholding disclosure. | Daily | ||
FX Connect, LLC | Used by certain subadvisers for foreign exchange derivatives reconciliation. | Daily | ||
FX Transparency LLC | Used by certain subadvisers for foreign exchange trade cost analysis. | Quarterly | ||
Global Trading Analytics, LLC | Used by certain subadvisers for transaction cost analysis and other analytics. | Daily | ||
Goldman Sachs & Co. | Used by certain subadvisers for clearing treasury futures and swaps. | Daily | ||
ICE Data Services Inc. | Used by certain subadvisers for liquidity reporting. Used by certain subadvisers for data and pricing. | Daily | ||
IEX Astral | Used by certain subadvisers for analytical and statistical information. | Daily | ||
IHS Markit Ltd. | Used by certain subadvisers for confirmation and settlement of bank loan trades. Used by certain subadvisers for transaction cost analysis and other analytics. | Daily | ||
Infinit-O Global, Ltd. | Used by certain subadvisers for portfolio accounting systems. | Daily | ||
Institutional Shareholder Services, Inc. | Used by certain subadvisers for proxy voting administration and research services. | Daily | ||
InvestCloud | Used by certain subadvisers for client reporting. | Daily | ||
LightSpeed Data Solutions | Used by certain subadvisers for compliance and personal trade monitoring. | Daily | ||
LiquidNet, Inc. | Used by certain subadvisers for commission tracking. | Daily | ||
Microsoft Corporation | Used by certain subadvisers for analytical and statistical information. | Daily | ||
MSCI Barra Inc. | Used by certain subadvisers for analytical and statistical information. | Daily or Monthly | ||
Nex Group plc | Used by certain subadvisers for daily reconciliations on collateral management. | Daily | ||
Omgeo, LLC | Used by certain subadvisers for trade execution and SWIFT transactions. Used by certain subadvisers for analytics. | Daily | ||
Refinitiv (Refinitiv Settlement Center) | Used by certain subadvisers for analytical and statistical information. | Daily | ||
Salesforce | Used by certain subadvisers for analytical and statistical information. | Daily |
Statement of Additional Information – May 1, 2021 | 195 |
Identity of Recipient | Conditions/restrictions on use of information | Frequency
of Disclosure | ||
Schwab Compliance Technologies, Inc. | Used by certain subadvisers for compliance and personal trade monitoring. | Daily | ||
SEI Investments Co. | Used by certain subadvisers for portfolio accounting systems. | Daily | ||
Seismic Software, Inc. | Used by certain subadvisers to automate quarterly updates. | Quarterly | ||
SS&C Technologies, Inc. | Used by certain subadvisers for portfolio accounting systems. Used by certain subadvisers for SWIFT messages from custodians to facilitate automated reconciliation. | Daily | ||
State Street Bank and Trust Company | Used by certain subadvisers for middle office functions. | Daily or Monthly | ||
State Street Corp. | Used by certain subadvisers for order management and compliance. | Daily | ||
STP Investment Services, LLC | Used by certain subadvisers for portfolio accounting systems. | Daily | ||
Trade Informatics LLC | Used by certain subadvisers for asset allocation. | Daily | ||
Tradeweb Markets LLC | Used by certain subadvisers for confirming TBAs, treasuries and discount notes. | Daily | ||
TriOptima AB | Used by certain subadvisers for reconciliation services. | Daily | ||
UnaVista Solutions | Used by certain subadvisers for MiFID II transaction reporting. | Daily | ||
VERMEG Co. | Used by certain subadvisers for the management of swap counterparty exposure. | Daily | ||
Vermilion Software Ltd | Used by certain subadvisers for analytical and statistical information. | Monthly | ||
Virtu Financial, Inc. | Used by certain subadvisers for transaction cost analysis and other analytics. | Daily or Monthly |
Statement of Additional Information – May 1, 2021 | 196 |
* | Ameriprise Financial affiliate |
Statement of Additional Information – May 1, 2021 | 197 |
Statement of Additional Information – May 1, 2021 | 198 |
Statement of Additional Information – May 1, 2021 | 199 |
Statement of Additional Information – May 1, 2021 | 200 |
Statement of Additional Information – May 1, 2021 | 201 |
Statement of Additional Information – May 1, 2021 | 205 |
Statement of Additional Information – May 1, 2021 | 206 |
Statement of Additional Information – May 1, 2021 | 207 |
Fund | Total Capital Loss Carryovers |
Amount not Expiring | |
Short-term | Long-term | ||
For Funds with fiscal period ending December 31 | |||
VP – Commodity Strategy Fund | $202,612 | $202,612 | $0 |
VP – Emerging Markets Bond Fund | $19,211,570 | $5,226,491 | $13,985,079 |
VP – Global Strategic Income Fund | $7,367,170 | $2,675,172 | $4,691,998 |
VP – High Yield Bond Fund | $6,948,243 | $2,360,051 | $4,588,192 |
VP – Income Opportunities Fund | $8,555,462 | $4,867,158 | $3,688,304 |
VP – Limited Duration Credit Fund | $14,868,603 | $9,095,130 | $5,773,473 |
VP – Partners International Core Equity Fund | $60,470,173 | $30,030,875 | $30,439,298 |
VP – Partners International Value Fund | $109,138,917 | $0 | $109,138,917 |
Statement of Additional Information – May 1, 2021 | 208 |
Statement of Additional Information – May 1, 2021 | 209 |
Statement of Additional Information – May 1, 2021 | 210 |
Statement of Additional Information – May 1, 2021 | 211 |
Statement of Additional Information – May 1, 2021 | 212 |
Statement of Additional Information – May 1, 2021 | 213 |
Statement of Additional Information – May 1, 2021 | 214 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
VP – Aggressive Portfolio | RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
95.50% | 94.68% |
Class 4 | 93.53% | |||
Class 1 | 99.17% | |||
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 4 |
6.47% | N/A | |
VP – American Century Diversified Bond Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 1 |
N/A | 80.63% (a) |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
35.62% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
12.75% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
6.59% | N/A |
Statement of Additional Information – May 1, 2021 | 215 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
6.42% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
19.82% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
94.81% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
5.19% | N/A | |
VP – Balanced Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
100.00% | N/A(a) |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 1 |
91.58% | 93.18% | |
Class 3 | 93.19% | |||
RIVERSOURCE LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 1 |
8.33% | N/A | |
Class 3 | 6.81% | |||
VP – BlackRock Global Inflation-Protected Securities Fund | RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 1 |
92.03% | 93.92% |
Class 2 | 91.90% | |||
Class 3 | 94.50% | |||
RIVERSOURCE LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 1 |
5.93% | N/A | |
Class 2 | 8.10% | |||
Class 3 | 5.50% | |||
VP – CenterSquare Real Estate Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 87.87% (a) |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
11.85% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
51.15% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
29.57% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
5.92% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
95.91% | N/A |
Statement of Additional Information – May 1, 2021 | 216 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
VP – Commodity Strategy Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 82.17% (a) |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
10.46% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
54.73% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
24.74% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
7.29% | N/A | |
LINCOLN
LIFE INSURANCE COMPANY 1300 S CLINTON ST FORT WAYNE IN 46802-3518 |
Class 2 |
6.38% | N/A | |
NEW
YORK LIFE INSURANCE & ANNUITY CORP ATTN CHRISTINE DEMPSEY 169 LACKAWANNA AVE PARSIPPANY NJ 07054-1007 |
Class 2 |
52.17% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
38.09% | N/A | |
VP – Conservative Portfolio | RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
94.97% | 95.05% |
Class 4 | 95.14% | |||
Class 1 | 96.48% | |||
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
5.03% | N/A | |
VP – Core Equity Fund | RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 1 |
100.00% | 100.00% |
VP – Disciplined Core Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 57.32% (a) |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO U S FLEXIBLE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
7.38% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
15.26% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
7.80% | N/A |
Statement of Additional Information – May 1, 2021 | 217 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
26.45% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
28.05% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
93.80% | 30.54% | |
Class 3 | 93.94% | |||
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3 |
6.06% | N/A | |
VP – Dividend Opportunity Fund | DELAWARE LIFE INSURANCE COMPANY 1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 1 |
42.70% | N/A |
Class 2 | 6.52% | |||
INDEPENDENCE
LIFE AND ANNUITY CO C/O SUNLIFE FINANCIAL PO BOX 9133 WELLESLEY HILLS MA 02481-9133 |
Class 1 |
5.45% | N/A | |
KEYPORT 1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 1 |
12.82% | N/A | |
MIDLAND
NATIONAL LIFE INS CO 4350 WESTOWN PKWY WEST DES MOINES IA 50266-1036 |
Class 2 |
5.34% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
84.32% | 88.86% | |
Class 3 | 94.76% | |||
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3 |
5.24% | N/A | |
TALCOTT
RESOLUTION LIFE INSURANCE COMPANY PO BOX 5051 HARTFORD CT 06102-5051 |
Class 1 |
26.31% | N/A | |
VP – Emerging Markets Bond Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 36.43% (a) |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
5.45% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
45.18% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
16.32% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
8.07% | N/A |
Statement of Additional Information – May 1, 2021 | 218 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
ATTN:
MUTUAL FUND OPERATIONS 500 GRANT STREET ROOM 151-1010 PITTSBURGH PA 15219-2502 |
Class 1 |
18.55% | N/A | |
NEW
YORK LIFE INSURANCE & ANNUITY CORP ATTN CHRISTINE DEMPSEY 169 LACKAWANNA AVE PARSIPPANY NJ 07054-1007 |
Class 2 |
89.00% | 45.78% | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
6.18% | N/A | |
VP – Emerging Markets Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 31.96% (a) |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
9.18% | N/A | |
JPMCB
NA CUST FOR VP CONSERVATIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
12.84% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
52.88% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
13.39% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
9.96% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
94.38% | 63.77% | |
Class 3 | 94.56% | |||
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3 |
5.44% | N/A | |
VP – Global Strategic Income Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 1 |
100.00% | N/A(a) |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
90.78% | 93.97% | |
Class 3 | 94.34% | |||
RIVERSOURCE LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
9.22% | N/A | |
Class 3 | 5.66% | |||
VP – Government Money Market Fund | AMERICAN
SKANDIA LIFE ASSURANCE CO ATTN ALISON MITNICK 1 CORPORATE DRIVE 9TH FLOOR SHELTON CT 06484-6208 |
Class 1 |
5.59% | N/A |
Statement of Additional Information – May 1, 2021 | 219 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
DELAWARE
LIFE INSURANCE COMPANY 1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 1 |
44.88% | N/A | |
INDEPENDENCE
LIFE AND ANNUITY CO C/O SUNLIFE FINANCIAL PO BOX 9133 WELLESLEY HILLS MA 02481-9133 |
Class 1 |
6.71% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
31.91% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
93.03% | 73.16% | |
Class 3 | 94.47% | |||
RIVERSOURCE LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
6.97% | N/A | |
Class 3 | 5.53% | |||
VP – High Yield Bond Fund | MIDLAND
NATIONAL LIFE INS CO 4350 WESTOWN PKWY WEST DES MOINES IA 50266-1036 |
Class 2 |
6.36% | N/A |
NATIONWIDE
LIFE INSURANCE COMPANY NWVA13 C/O IPO PORTFOLIO ACCOUNTING PO BOX 182029 COLUMBUS OH 43218-2029 |
Class 2 |
19.74% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 1 |
98.31% | 89.33% | |
Class 2 | 68.97% | |||
Class 3 | 95.63% | |||
VP – Income Opportunities Fund | DELAWARE
LIFE INSURANCE COMPANY 1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2 |
8.58% | N/A |
KEYPORT 1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 1 |
5.56% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
78.47% | 80.94% | |
Class 3 | 94.48% | |||
RIVERSOURCE LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
11.56% | N/A | |
Class 3 | 5.52% | |||
TALCOTT
RESOLUTION LIFE INSURANCE COMPANY PO BOX 5051 HARTFORD CT 06102-5051 |
Class 1 |
39.35% | N/A | |
TRANSAMERICA
LIFE INSURANCE CO RETIREMENT BUILDER VARIABLE ANNUITY ACCOUNT 4333 EDGEWOOD RD NE ATTN FMD ACCOUNTING MS 4410 CEDAR RAPIDS IA 52499-0001 |
Class 1 |
6.58% | N/A | |
VARIABLE
SEPARATE ACCOUNT OF ANCHOR NATIONAL LIFE INSURANCE CO 2727-A ALLEN PARKWAY, 4-D1 ATTN: VARIABLE ANNUITY ACCOUNTING HOUSTON TX 77019-2107 |
Class 1 |
39.23% | N/A |
Statement of Additional Information – May 1, 2021 | 220 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
VP – Intermediate Bond Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 66.14% (a) |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
38.57% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
12.79% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
6.84% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
19.36% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
93.44% | N/A | |
Class 3 | 94.73% | |||
RIVERSOURCE LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
6.56% | N/A | |
Class 3 | 5.27% | |||
VP – Large Cap Growth Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 71.68% (a) |
DELAWARE
LIFE INSURANCE COMPANY 1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2 |
37.25% | N/A | |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
6.14% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
25.58% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
15.01% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
20.65% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
20.18% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
54.69% | N/A | |
Class 3 | 96.43% |
Statement of Additional Information – May 1, 2021 | 221 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
VP – Large Cap Index Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 50.26% (a) |
DELAWARE
LIFE INSURANCE COMPANY 1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2 |
90.60% | N/A | |
DELAWARE
LIFE INSURANCE COMPANY OF NEW YORK 1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2 |
9.37% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO U S FLEXIBLE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
67.13% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO U S FLEXIBLE MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
28.67% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3 |
89.86% | 42.04% | |
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3 |
10.14% | N/A | |
VP – Limited Duration Credit Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 74.53% (a) |
JPMCB
NA CUST FOR VP CONSERVATIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
5.06% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
22.03% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
7.21% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
7.81% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
11.59% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
29.23% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
90.72% | N/A |
Statement of Additional Information – May 1, 2021 | 222 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
5.01% | N/A | |
VP – Loomis Sayles Growth Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 75.55% (a) |
DELAWARE
LIFE INSURANCE COMPANY 1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2 |
24.75% | N/A | |
GE
LIFE & ANNUITY ASSURANCE CO ATTN VARIABLE ACCOUNTING 6610 W BROAD ST BLDG 3 5TH FL RICHMOND VA 23230-1702 |
Class 1 |
5.17% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO U S FLEXIBLE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
9.87% | N/A | |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
5.01% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
19.19% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
12.25% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
16.19% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
15.25% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 1 |
5.92% | N/A | |
Class 2 | 70.43% | |||
VP – MFS Value Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 91.19% (a) |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
6.76% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
26.43% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
16.58% | N/A |
Statement of Additional Information – May 1, 2021 | 223 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
24.72% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
20.47% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
94.97% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
5.03% | N/A | |
VP – Mid Cap Growth Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 30.50% (a) |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
45.05% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
41.63% | N/A | |
KANSAS
CITY LIFE INS ATTN ACCOUNTING OPERATIONS-VARIABLE PO BOX 219139 KANSAS CITY MO 64121-9139 |
Class 2 |
11.53% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
84.51% | 60.28% | |
Class 3 | 94.09% | |||
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3 |
5.91% | N/A | |
TALCOTT
RESOLUTION LIFE INSURANCE COMPANY PO BOX 5051 HARTFORD CT 06102-5051 |
Class 1 |
6.54% | N/A | |
VP – Moderate Portfolio | RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
94.10% | 94.24% |
Class 4 | 94.38% | |||
Class 1 | 97.18% | |||
RIVERSOURCE LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
5.90% | N/A | |
Class 4 | 5.62% | |||
VP – Moderately Aggressive Portfolio | RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
94.43% | 94.31% |
Class 4 | 94.12% | |||
Class 1 | 97.51% |
Statement of Additional Information – May 1, 2021 | 224 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
RIVERSOURCE LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
5.57% | N/A | |
Class 4 | 5.88% | |||
VP – Moderately Conservative Portfolio | RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
93.75% | 93.85% |
Class 4 | 93.98% | |||
Class 1 | 72.41% | |||
RIVERSOURCE LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
6.25% | N/A | |
Class 4 | 6.02% | |||
Class 1 | 27.37% | |||
VP – Morgan Stanley Advantage Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 92.74 (a) |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO U S FLEXIBLE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
11.71% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO U S FLEXIBLE MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
5.16% | N/A | |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
5.68% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
21.81% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
13.94% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
18.81% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
17.83% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
96.61% | N/A | |
VP – MV Moderate Growth Fund | RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 1 |
99.24% | 93.34% |
Class 2 | 93.34% | |||
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
6.66% | N/A |
Statement of Additional Information – May 1, 2021 | 225 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
VP – Overseas Core Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 84.69% (a) |
DELAWARE
LIFE INSURANCE COMPANY 1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2 |
7.56% | N/A | |
GE
LIFE & ANNUITY ASSURANCE CO ATTN VARIABLE ACCOUNTING 6610 W BROAD ST BLDG 3 5TH FL RICHMOND VA 23230-1702 |
Class 2 |
20.07% | N/A | |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
5.76% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
29.08% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
14.81% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
20.22% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
22.00% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
48.83% | N/A | |
Class 3 | 93.35% | |||
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3 |
6.65% | N/A | |
TALCOTT
RESOLUTION LIFE INSURANCE COMPANY PO BOX 5051 HARTFORD CT 06102-5051 |
Class 2 |
15.04% | N/A | |
VP – Partners Core Bond Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 87.04% (a) |
JPMCB
NA CUST FOR VP CONSERVATIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
7.57% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
27.79% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
10.95% | N/A |
Statement of Additional Information – May 1, 2021 | 226 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
JPMCB
NA CUST FOR VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
14.71% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
8.43% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
17.89% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
93.67% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
6.33% | N/A | |
VP – Partners Core Equity Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 84.80% (a) |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO U S FLEXIBLE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
15.18% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO U S FLEXIBLE MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
6.66% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
23.30% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
13.15% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
14.39% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
13.54% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
97.78% | N/A | |
Class 3 | 93.43% | |||
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3 |
6.57% | N/A |
Statement of Additional Information – May 1, 2021 | 227 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
VP – Partners International Core Equity Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 93.90% (a) |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
5.65% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
18.96% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
10.77% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
31.86% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
27.13% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
94.89% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
5.11% | N/A | |
VP – Partners International Growth Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 90.93% (a) |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
6.66% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
27.48% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
16.01% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
21.84% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
22.07% | N/A |
Statement of Additional Information – May 1, 2021 | 228 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
94.76% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
5.24% | N/A | |
VP – Partners International Value Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 90.93% (a) |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
7.66% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
31.54% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
18.37% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
19.36% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
16.59% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
94.16% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
5.84% | N/A | |
VP – Partners Small Cap Growth Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 86.97% (a) |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
19.16% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
8.54% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
30.61% | N/A |
Statement of Additional Information – May 1, 2021 | 229 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
30.35% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
89.06% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
10.94% | N/A | |
VP – Partners Small Cap Value Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 77.71% (a) |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
13.98% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
6.53% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
34.96% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
34.40% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
93.59% | N/A | |
Class 3 | 95.02% | |||
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
6.41% | N/A | |
VP – Select Large Cap Equity Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
100.00% | 87.87% (a) |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO U S FLEXIBLE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
6.22% | N/A | |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
5.73% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
27.75% | N/A |
Statement of Additional Information – May 1, 2021 | 230 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
14.35% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
16.71% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
17.11% | N/A | |
VP – Select Large Cap Value Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 85.93% (a) |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO U S FLEXIBLE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
9.50% | N/A | |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
5.54% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
23.31% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
13.27% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
20.35% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
17.86% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
91.59% | N/A | |
Class 3 | 97.31% | |||
VP – Select Mid Cap Value Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 59.94% (a) |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
46.97% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
43.48% | N/A |
Statement of Additional Information – May 1, 2021 | 231 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
94.43% | 32.15% | |
Class 3 | 95.81% | |||
VP – Select Small Cap Value Fund | AMERITAS
LIFE INSURANCE CORP CARRILLON ACCOUNT 5900 O ST LINCOLN NE 68510-2234 |
Class 2 |
24.19% | N/A |
GREAT-WEST
LIFE & ANNUITY FBO TRILLIUM VARIABLE ANNUITY ACCT 8515 E ORCHARD RD 2T2 GREENWOOD VLG CO 80111-5002 |
Class 1 |
15.04% | N/A | |
JEFFERSON
NATL LIFE 10350 ORMSBY PARK PL STE 600 LOUISVILLE KY 40223-6175 |
Class 1 |
68.52% | N/A | |
KANSAS
CITY LIFE INS ATTN ACCOUNTING OPERATIONS-VARIABLE PO BOX 219139 KANSAS CITY MO 64121-9139 |
Class 2 |
11.79% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 1 |
8.44% | 76.94% | |
Class 2 | 58.59% | |||
Class 3 | 95.19% | |||
VP – Seligman Global Technology Fund | GREAT-WEST LIFE & ANNUITY FBO TRILLIUM VARIABLE ANNUITY ACCT 8515 E ORCHARD RD 2T2 GREENWOOD VLG CO 80111-5002 |
Class 1 |
95.30% | 54.85% |
Class 2 | 27.55% | |||
JEFFERSON
NATL LIFE 10350 ORMSBY PARK PL STE 600 LOUISVILLE KY 40223-6175 |
Class 2 |
40.13% | N/A | |
KANSAS
CITY LIFE INS ATTN ACCOUNTING OPERATIONS-VARIABLE PO BOX 219139 KANSAS CITY MO 64121-9139 |
Class 2 |
9.57% | N/A | |
MIDLAND
NATIONAL LIFE INS CO 4350 WESTOWN PKWY WEST DES MOINES IA 50266-1036 |
Class 2 |
7.13% | N/A | |
VP – T. Rowe Price Large Cap Value Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 88.30% (a) |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO U S FLEXIBLE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
10.34% | N/A | |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
5.65% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
22.12% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
13.81% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
20.61% | N/A |
Statement of Additional Information – May 1, 2021 | 232 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
17.18% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
91.53% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
8.47% | N/A | |
VP – TCW Core Plus Bond Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 82.29% (a) |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
38.73% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
8.30% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
9.32% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
6.31% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
20.12% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
94.60% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
5.40% | N/A | |
VP – U.S. Government Mortgage Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 76.24% (a) |
DELAWARE
LIFE INSURANCE COMPANY 1601 TRAPELO ROAD SUITE 30 WALTHAM MA 02451-7360 |
Class 2 |
22.20% | N/A | |
JPMCB
NA CUST FOR VP CONSERVATIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
5.27% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
30.65% | N/A |
Statement of Additional Information – May 1, 2021 | 233 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
11.48% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
6.14% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
9.18% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
23.19% | N/A | |
MIDLAND
NATIONAL LIFE INS CO 4350 WESTOWN PKWY WEST DES MOINES IA 50266-1036 |
Class 2 |
8.76% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
61.37% | N/A | |
Class 3 | 94.30% | |||
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3 |
5.70% | N/A | |
VP – Victory Sycamore Established Value Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 73.19% (a) |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
6.47% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
29.91% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
16.08% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
22.14% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
20.39% | N/A | |
RIVERSOURCE LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 3 |
96.94% | N/A | |
Class 2 | 92.44% | |||
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
7.56% | N/A |
Statement of Additional Information – May 1, 2021 | 234 |
Fund | Shareholder Name and Address | Share Class | Percentage of Class |
Percentage
of Fund (if greater than 25%) |
VP – Wells Fargo Short Duration Government Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 81.60% (a) |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
47.70% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
14.02% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY CONSERVATIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
8.43% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
15.86% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
90.19% | N/A | |
RIVERSOURCE
LIFE NY FOR INSIDE DISTRIBUTION (LIFE OF NY) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
9.81% | N/A | |
VP – Westfield Mid Cap Growth Fund | COLUMBIA
MGMT INVESTMENT ADVSR LLC ATTN KATRINA MACBAIN 50807 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0508 |
Class 2 |
N/A | 87.72% (a) |
JPMCB
NA CUST FOR VP AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
6.07% | N/A | |
JPMCB
NA CUST FOR VP MODERATE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
25.74% | N/A | |
JPMCB
NA CUST FOR VP MODERATELY AGGRESSIVE 4 CHASE METROTECH CTR FL 3RD BROOKLYN NY 11245-0003 |
Class 1 |
14.62% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
25.73% | N/A | |
JPMCB
NA CUST FOR VARIABLE PORTFOLIO MANAGED VOLATILITY MODERATE GROWTH FUND 4 CHASE METROTECH CENTER 3RD FLOOR BROOKLYN NY 11245-0003 |
Class 1 |
23.37% | N/A | |
RIVERSOURCE
LIFE ACCOUNT FOR INSIDE DISTRIBUTION (LIFE) 222 AMERIPRISE FINANCIAL CTR MINNEAPOLIS MN 55474-0002 |
Class 2 |
95.49% | N/A |
(a) | Combination of all share classes of Columbia Management initial capital and/or affiliated funds-of-funds’ investments. |
Statement of Additional Information – May 1, 2021 | 235 |
Statement of Additional Information – May 1, 2021 | 236 |
Statement of Additional Information – May 1, 2021 | 237 |
Statement of Additional Information – May 1, 2021 | A-1 |
Statement of Additional Information – May 1, 2021 | A-2 |
Statement of Additional Information – May 1, 2021 | A-3 |
Long-Term Rating | Short-Term Rating |
AAA | F1+ |
AA+ | F1+ |
AA | F1+ |
AA– | F1+ |
A+ | F1 or F1+ |
A | F1 or F1+ |
A– | F2 or F1 |
BBB+ | F2 or F1 |
BBB | F3 or F2 |
BBB– | F3 |
BB+ | B |
BB | B |
BB– | B |
B+ | B |
B | B |
B– | B |
CCC+ / CCC / CCC– | C |
CC | C |
C | C |
RD / D | RD / D |
Statement of Additional Information – May 1, 2021 | A-4 |
Statement of Additional Information – May 1, 2021 | A-5 |
■ | There is a missed interest payment, principal payment, or preferred dividend payment, as applicable, on a rated obligation which is unlikely to be recovered. |
■ | The rated entity files for protection from creditors, is placed into receivership, or is closed by regulators such that a missed payment is likely to result. |
■ | The rated entity seeks and completes a distressed exchange, where existing rated obligations are replaced by new obligations with a diminished economic value. |
Statement of Additional Information – May 1, 2021 | A-6 |
■ | There is a missed interest payment, principal payment, or preferred dividend payment, as applicable, on a rated obligation which is unlikely to be recovered. |
■ | The rated entity files for protection from creditors, is placed into receivership, or is closed by regulators such that a missed payment is likely to result. |
■ | The rated entity seeks and completes a distressed exchange, where existing rated obligations are replaced by new obligations with a diminished economic value. |
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 |
Statement of Additional Information – May 1, 2021 | A-7 |
Statement of Additional Information – May 1, 2021 | B-1 |
■ | effectively exercise their voting rights across the full range of business normally associated with general meetings of a company in line with market best practice (e.g. the election of individual directors, discharge authorities, capital authorities, auditor appointment, major or related party transactions etc.); |
■ | place items on the agenda of general meetings, and to propose resolutions subject to reasonable limitations; |
■ | call a meeting of shareholders for the purpose of transacting the legitimate business of the company; and |
■ | Clear, consistent and effective reporting to shareholders is undertaken at regular intervals and that they remain aware of shareholder sentiment on major issues to do with the business, its strategy and performance. Where significant shareholder dissent is emerging or apparent (e.g. through the voting levels seen at General Meetings), boards should act to address that. |
■ | Boards should also allow a reasonable opportunity for the shareholders at a general meeting to ask questions about or make comments on the management of the company, and to ask the external auditor questions related to the audit. |
Statement of Additional Information – May 1, 2021 | B-2 |
Statement of Additional Information – May 1, 2021 | B-3 |
■ | subject to proper oversight by the board and regular review (e.g. audit, shareholder approval); |
■ | clearly justified and not be detrimental to the long-term interests of the company; |
■ | undertaken in the normal course of business; |
■ | undertaken on fully commercial terms; |
■ | in line with best practice; and |
■ | in the interests of all shareholders. |
Statement of Additional Information – May 1, 2021 | B-4 |
Statement of Additional Information – May 1, 2021 | B-5 |
1. | Clear, simple and understandable; |
2. | Balanced and proportionate, in respect of structure, deliverables, opportunity and the market; |
3. | Aligned with the long-term strategy, related key performance indicators and risk management discipline; |
4. | Linked robustly to the delivery of performance; |
5. | Delivering outcomes that reflect value creation and the shareholder ‘experience’; and |
6. | Structured to avoid pay for failure or the avoidance of accountability to shareholders. |
Statement of Additional Information – May 1, 2021 | B-6 |
1. | an understanding how resilient an organization’s strategy is to climate-related risks; |
2. | appropriate pricing of climate related risks and opportunities; and |
3. | a broad understanding of the financial systems’ exposure to climate related risk. |
■ | UN Global Compact |
■ | UN Guiding Principles on Business and Human Rights (the “Ruggie Principles”) |
■ | International Labour Organisation (ILO) Core Labor Standards |
Statement of Additional Information – May 1, 2021 | B-7 |