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Firm Brochure
Part 2A
Natixis Advisors, LLC (“Natixis Advisors”)
Natixis Investment Managers Solutions, a division of Natixis Advisors (“Solutions”)
Boston Office
888 Boylston Street
Boston, MA 02199
Phone: 617-449-2802
617-369-9794
Fax:
San Francisco Office
575 Market Street, Suite 2550
San Francisco, CA 94105
Phone: 617-449-2802
617-369-9794
Fax:
www.im.natixis.com
This brochure provides information about the qualifications and business practices of Natixis Advisors. If you
have any questions about the contents of this brochure, please contact us at 617-449-2838 or by email at
ADVOPS@natixis.com. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission (“SEC”) or by any state securities authority.
Additional information about Natixis Advisors is available on the SEC’s website at www.adviserinfo.sec.gov.
Registration does not imply that any particular level of skill or training has been met by Natixis Advisors or its
personnel.
January 9, 2026
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Important Note about this Brochure
This Brochure is not:
•
an offer or agreement to provide advisory services to any person;
•
an offer to sell interests (or a solicitation of an offer to purchase interests) in any fund that we advise; or
•
a complete discussion of the features, risks, or conflicts associated with any advisory service or fund.
As required by the Investment Advisers Act of 1940, as amended (the “Advisers Act”), we provide this Brochure to current
and prospective clients. We also, in our discretion, will provide this Brochure to current or prospective investors in a fund, together
with other relevant offering, governing, or disclosure documents. Additionally, this Brochure is available at the SEC’s Investment
Adviser Public Disclosure website.
Persons who receive this publicly available Brochure (whether or not from us) should be aware that it is designed solely to provide
information responsive to certain disclosure obligations under the Advisers Act. More information about our funds and advisory
services is included in the relevant account or fund documents. To the extent that there is any conflict between discussions herein
and similar or related discussions in such documents, the relevant account or fund documents shall govern and control. You should
read this Brochure and those other documents carefully and consult with tax, legal, and financial advisors before making any
investment decision.
Item 2 – Material Changes
Since the last annual update to the Form ADV Part 2A (the “Brochure”) on March 27, 2025, material
changes to this Brochure include amendments to the following items:
•
Items 4, 5, 7, 8, 12, 13, 16, and Appendices 2, 3, 5, and 6 to reflect that Natixis Advisors, LLC
(“Natixis Advisors”) no longer offers overlay portfolio management services due to the sale of its
overlay management services capabilities to Edward Jones & Co., L.P., effective January 1, 2026.
•
Item 4 – Advisory Business and Item 12 – Brokerage Practices were updated to reflect that, on
October 1, 2025, Natixis Advisors expanded its relationship with Vestmark, a key software and
operational services partner, to include non-discretionary trade execution services for its direct
indexing (AIA) and Natixis IM-affiliated SMA strategies.
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Item 3 – Table of Contents
Part 2A
Page
1
2
3
4
5
8
8
8
16
16
17
Item #
Item 1
Item 2
Item 3
Item 4
Item 5
Item 6
Item 7
Item 8
Item 9
Item 10
Item 11
21
28
29
30
30
30
31
32
39
49
Item 12
Item 13
Item 14
Item 15
Item 16
Item 17
Item 18
Appendix 1
Appendix 2
Appendix 3
Title
Firm Brochure Part 2A - Cover Page
Material Changes
Table of Contents
Advisory Business
Fees and Compensation
Performance Based Fees and Side-By-Side Management
Types of Clients
Methods of Analysis, Investment Strategies and Risk of Loss
Disciplinary Information
Other Financial Industry Activities and Affiliations
Code of Ethics, Participation or Interest in Client
Transactions, and Personal Trading
Brokerage Practices
Review of Accounts
Client Referrals and Other Compensation
Custody
Investment Discretion
Voting Client Securities/Proxy Voting
Financial Information
Investment Company Strategy List & Strategy Descriptions
Managed Account Strategy List & Strategy Descriptions
Managed Account Unbundled Program Strategy List &
Standard Fee Rates
Investment Company Strategy List & Risk Descriptions
Managed Account Strategy List & Risk Descriptions
Program Participation List
54
63
68
Appendix 4
Appendix 5
Appendix 6
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Item 4 – Advisory Business
Firm Description: Natixis Advisors, LLC (“Natixis Advisors”) was a limited partnership organized on
January 23, 1995 which was converted into a limited liability company on July 30, 2021, under the laws of the
State of Delaware. Natixis Advisors maintains a principal office located at 888 Boylston Street, Boston,
Massachusetts 02199 with an additional office at 101 Second Street, Suite 1600, San Francisco, California 94105
that supports some of the services offered by its division, Natixis Investment Managers Solutions
(“Solutions”). Solutions is not a separate legal entity. Natixis Advisors and Natixis Distribution, LLC
(“Natixis Distribution”), a FINRA registered limited purpose broker-dealer affiliate of Natixis Advisors, are
commonly referred to by the umbrella name of Natixis Investment Managers.
Principal Owners: Natixis Advisors is a direct subsidiary of Natixis Investment Managers, LLC, which,
following a modification in corporate structure that took place in January 2024, is a direct subsidiary of Natixis
Investment Managers (“Natixis IM”), an international asset management group based in Paris, France, that is
part of the Global Financial Services division of Groupe BPCE. Natixis IM is wholly owned by Natixis, a French
investment banking and financial services firm. Natixis is wholly owned by BPCE, France’s second largest
banking group. The modification in corporate structure mentioned above was the merger of Natixis Investment
Managers, LLC into Natixis Investment Managers U.S. Holdings, LLC and the subsequent name change of the
holding company to “Natixis Investment Managers, LLC.” The internal reorganization did not change the
ultimate parent of Natixis Advisors or the identity and responsibilities of, or services provided by, either Natixis
Advisors’ or Natixis Investment Managers, LLC’s personnel.
Types of Advisory Services: Natixis Advisors provides advisory services to investment company clients and
managed account clients. These relationships are described in more detail below. In addition, Natixis Advisors
creates proprietary direct indexing separately managed account strategies and multi-asset portfolios comprised
of proprietary and non-proprietary mutual funds, separately managed account sleeves and ETFs. Natixis
Advisors also provides portfolio analysis, consulting, and analytic services to investment professionals, which
services are not contingent on current or future sales or sales targets.
Investment Company Advisory Services: Natixis Advisors is the investment adviser to some of the investment
companies in the Natixis family of funds (the “Natixis Funds”). Each Natixis Fund is a registered investment
company or a series thereof. Natixis Advisors is also the investment adviser to exchange-traded funds (the
“Natixis ETFs”). Each Natixis ETF is a registered investment company.
Natixis Advisors generally subcontracts portfolio management services to one or more affiliated registered
investment advisers to act in the capacity of subadviser to Natixis Advisors, as listed on Appendix 1. As set
forth in the relevant contract, each subadviser is responsible for the day-to-day investment operations of the
Natixis Fund it subadvises. Natixis Advisors is responsible, subject to the approval of the Natixis Funds’ and
Natixis ETFs’ Board, for the selection and oversight of such subadviser. Natixis Advisors will replace
subadvisers as it deems appropriate, subject to the approval, as may be required, of the affected Natixis Funds’
and Natixis ETFs’ Board and/or the affected Natixis Funds’ and Natixis ETFs’ shareholders.
Natixis Advisors provides administrative services to the Natixis Funds, Natixis ETFs, and the Loomis Sayles
family of funds (the “Loomis Sayles Funds”) (collectively the “Funds”). Natixis Advisors also provides
marketing support services to certain Funds.
Managed Account Advisory Services: Natixis Advisors provides both discretionary and non-discretionary
investment advisory services through sponsor programs and other contractual advisory arrangements.
Natixis Advisors’ investment advisory services are often provided with assistance from affiliated registered
investment advisers (commonly referred to as model providers). Where Natixis Advisors receives
recommendations in the form of a model portfolio from a model provider but retains investment discretion,
Natixis Advisors follows the recommendations in the model portfolios provided. However, Natixis Advisors can
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substitute or otherwise deviate from the model portfolio as it considers appropriate, including to comply with
individual client guidelines or restrictions, to realize losses in taxable accounts, and to provide market exposure
during a wash sale period. Alterations made to accommodate individualized policies or restrictions as well as
trading delays and other timing issues could result in deviations between the holdings and performance of client
accounts and those of the model portfolios. See Appendix 2 for a list of the affiliated model portfolio providers
and unaffiliated model portfolio providers used by Natixis Advisors and/or model portfolio strategies provided
by each.
Bundled and Unbundled Advisory Services:
Natixis Advisors provides investment advisory services on a discretionary basis when it is granted sole or shared
authority (whether or not that authority is exercised) to determine what securities or other assets to purchase or
sell on behalf of a client account. Natixis Advisors provides discretionary investment advisory services to
managed account clients that participate in bundled and unbundled sponsor programs. Managed account
programs for which the program sponsor performed due diligence and where the client is charged a
bundled/wrapped fee are commonly referred to as “Bundled Programs.” Managed account programs for
which the program sponsor performs limited due diligence and the client is not charged a bundled/wrapped fee
are commonly referred to as “Unbundled Programs.” These sponsor programs offer managed account clients
the investment advisory services of a number of different investment managers, one of which is Natixis
Advisors. Natixis Advisors participates in programs as a discretionary manager by providing client-specific
investment advisory services.
Model Delivery Services:
Natixis Advisors provides non-discretionary investment advisory services when it is not granted sole or shared
authority to determine what securities or other assets to purchase or sell on behalf of a client account. Natixis
Advisors provides non-discretionary investment advisory services when it delivers model portfolios to program
sponsors for use in the sponsor’s program. In such arrangements, the program sponsor or adviser exercises
discretion over client accounts.
In providing the managed account advisory services outlined above, Natixis Advisors may outsource certain
non-discretionary trade execution services and activities to its third-party operational services vendor,
Vestmark Advisory Solutions, Inc. (“Vestmark”). The services provided by Vestmark may be advisory in
nature, but they are not discretionary in nature, meaning Vestmark depends on guidance and authorization
from Natixis Advisors in order to provide such services. These services may include non-discretionary trade
execution at the direction of Natixis Advisors, allocation changes, rebalancing of accounts, drift monitoring,
and tax loss harvesting of accounts based on direction from Natixis Advisors, and non-discretionary model
delivery at the direction of Natixis Advisors.
Assets Under Management: Natixis Advisors’ regulatory assets under management total $85,230,726,459 of
discretionary assets under management as of December 31, 2024.
Item 5 – Fees and Compensation
Investment Company Fees and Compensation: The advisory and administrative fees payable by the Funds to
Natixis Advisors, under relevant contracts, are expressed as a percentage of assets under management or
administration and are individually negotiated. The fees billed by Natixis Advisors to the Funds are payable by
the Funds monthly in arrears. Natixis Advisors is responsible for the payment of fees to advisers and subadvisers
of the Funds, as applicable. Natixis Advisors pays such advisers and subadvisers a percentage of the fee paid to
Natixis Advisors by the relevant Fund.
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Managed Account Fees and Compensation:
Bundled Program Fees & Compensation: Fees paid to Natixis Advisors for investment advisory services to
Bundled Program client accounts are negotiated between Natixis Advisors and the Bundled Program sponsor.
The client account minimum for a Bundled Program account is usually set by the Bundled Program sponsor.
A client in a Bundled Program will usually pay a bundled fee to the sponsor (either in advance or arrears),
calculated as a percentage of the client’s assets under management, which covers:
• Natixis Advisors’ investment advisory service fee;
• Custody fee from a Broker, dealer, sponsor firm trading venue, or other trading venue (collectively
“Brokers”) for transactions executed through the program sponsor or the program’s preferred
Broker;
• Accounting; and
•
Sponsor due diligence and other applicable program services.
Bundled Program fees can vary depending on the Bundled Program and the investment strategy selected by
the client.
Unbundled Program Fees & Compensation: Fees paid to Natixis Advisors for investment advisory services to
Unbundled Program client accounts are set by Natixis Advisors and are provided under Appendix 3. These
fees do not include other fees that a client will incur, such as custody fees, brokerage fees, accounting fees,
sponsor due diligence fees, and other applicable program fees. Unbundled Program investment advisory
service fees vary depending on the investment strategy selected by the client. The client account minimum
(initial and ongoing) for Natixis Advisors’ Unbundled Program accounts is generally set by Natixis Advisors
and is $250,000, with exceptions granted on a case-by-case basis or as otherwise determined to be appropriate.
For Unbundled Program client accounts, Natixis Advisors reserves the right to waive or discount its investment
advisory service fee on certain client accounts, including employee or related client accounts, and to waive the
account minimum or other fee thresholds for any client accounts.
Client fees in Unbundled Programs are paid either directly to Natixis Advisors by the client (upon receipt of
an invoice from Natixis Advisors) or through the Unbundled Program sponsor, the client’s registered
investment adviser, or the client’s custodian (upon receipt of an invoice delivered by Natixis Advisors).
Additionally, the investment advisory fee can vary depending on the Unbundled Program and the investment
strategy selected by the client.
Model Portfolio Services Fees & Compensation: Fees paid to Natixis Advisors for its model portfolio
investment advisory services to Bundled and Unbundled Programs are negotiated between Natixis Advisors
and the program sponsor. The program sponsors (and not the participants) are clients of Natixis Advisors
when accounts are managed by or through a sponsor. The client account minimum for a program account that
is managed using Natixis Advisors’ model portfolio is set by the program sponsor.
A client will also incur additional fees depending on whether the program is bundled or unbundled, such as
custody fees, brokerage fees, accounting fees, sponsor due diligence fees, and other applicable program fees.
Model portfolio fees are paid by clients to the sponsor, which in turn compensates Natixis Advisors. The fee
received by Natixis Advisors will vary depending on the program and investment strategy selected by the
sponsor.
Billing and Terminations: Fees paid to Natixis Advisors are calculated as a percentage of assets under
management (for discretionary services) or as a percentage of assets advised (for non- discretionary services)
and are shown as annual percentages. Natixis Advisors may also be compensated through fixed fees, or fees
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calculated as a percentage of a program sponsor’s fees. Natixis Advisors does not receive custody fees,
brokerage fees, accounting fees, or any other such fees. Fees are paid either quarterly or monthly and are billed
in accordance with the terms of the contractual relationship, either in advance or in arrears. Contracts with
program sponsors require at least sixty (60) days’ prior written notice of termination, unless otherwise stipulated
by contractual agreement. However, managed account clients that access Natixis Advisors’ services via
sponsors can generally terminate Natixis Advisors’ services immediately upon individual notice of termination
to Natixis Advisors or the sponsor. If investment advisory service fees are paid in advance, early termination
of a client account will result in a proportionate (i.e., pro-rata) return of such fees.
Model Portfolio Provider Fees & Compensation: When Natixis Advisors is responsible for retaining model
portfolio providers, Natixis Advisors compensates the model portfolio provider from the fee paid to Natixis
Advisors by the client or program sponsor, as applicable, which reduces the fees retained by Natixis Advisors.
Fee & Compensation Variation: Investment advisory services, fees, and account minimums vary from one
program to another. Natixis Advisors reserves the right, in its sole discretion, to waive its fees and account
minimum requirements, but cannot waive fees or account minimum requirements set by a third-party program
sponsor. Clients should be aware that Natixis Advisors cannot negotiate the implied commission rates payable
to the sponsor’s or client-designated Broker. Natixis Advisors is also limited in its ability to influence the trade
execution quality and the nature and quality of the services (including custodial and/or accounting services) that
program clients obtain from the sponsor. Similar or comparable services could be available at a lower aggregate
cost elsewhere on a bundled and/or unbundled basis.
In addition, while fees paid to Natixis Advisors by a Bundled Program sponsor could be lower than the
standard fee applicable to an Unbundled Program client, the overall cost to a program client is likely to be
higher than if the client engaged Natixis Advisors directly and negotiated (or allowed Natixis Advisors to
negotiate on the client’s behalf) per-transaction fees directly with a Broker. Similarly, the overall cost to a
program client will often be higher than if the client engaged a model portfolio provider directly. However,
Natixis Advisors and the model portfolio providers typically require directly managed non-program client
accounts to meet a minimum account size, which, depending on the strategy, are typically higher than the
minimum account size required by a sponsor.
Managed Accounts Holding Exchange-Traded Funds (“ETFs”): Clients should be aware that, in addition to
the expenses embedded in the ETF structure, there are certain disadvantages in selecting such strategies. These
disadvantages include, but are not limited to, the risk of (i) purchasing ETF shares at a premium and (ii) selling
ETF shares at a discount, because prices are determined by market forces and not net asset value.
Managed Accounts Holding Mutual Funds: As previously stated, Natixis Advisors provides discretionary
investment advisory services to managed account clients using model portfolios supplied by model portfolio
providers and by Natixis Advisors’ internal division. Natixis Advisors can, in its sole discretion, execute model
providers’ recommendations by purchasing shares of mutual funds and/or ETFs that conform to the relevant
model portfolio. Clients are able to purchase investment company shares directly from the investment
companies (or, with regard to ETFs, in the market) without using the investment advisory services of Natixis
Advisors. Additionally, it is common for the portfolios of managed account clients participating in a unified
managed account program to hold investment company shares in a sleeve or multiple sleeves of the client’s
unified managed account. Usually, the investment company is selected by the sponsor to be a part of the unified
managed account.. In each case, clients bear the fees and expenses associated with the Fund, including advisory
fees, in addition to any advisory or program fee.
Managed Accounts Holding Affiliated Mutual Funds or ETFs: Natixis Advisors recommends portfolios of
funds it advises to the sponsor for certain wrap fee or advisory programs. For portfolios where Natixis Advisors
acts as portfolio strategist, Natixis Advisors provides advice to the sponsor while the sponsor has ultimate
decision-making responsibility and discretionary authority for the accounts investing in the portfolios and is
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solely responsible for recommending such portfolios to investors. Natixis Advisors can construct these
portfolios solely from registered investment companies it or an Affiliate advises and/or that it distributes
through Natixis Distribution, without considering other funds or investments. Natixis Advisors receives
compensation from the portfolio’s funds for its investment advisory and other services but Natixis Advisors
does not generally assess a separate fee for its portfolio construction services.
In connection with all purchases of investment company shares for a managed account client’s portfolio, the
client could incur additional and/or higher expenses than the expenses incurred for managed accounts. In the
case of an investment company advised by Natixis Advisors or one of its investment advisory affiliates,
expenses include payments to Natixis Advisors and/or its affiliates for advisory and other services (such as
distribution and/or administrative services) provided to the investment companies.
Clients are able to purchase investment company shares directly from the investment companies (or, with
regard to ETFs, in the market) without using the investment advisory services of the sponsor..
Client Due Inquiry: Clients should conduct due inquiry related to investment advisory services, fees, and
account minimums. Due inquiry enables the client to ensure that it receives the desired level of investment
advisory services, that it is assessed a reasonable fee for those services, and that it can meet and maintain the
required account minimum. Additionally, a client should consider factors such as trading frequency and
applicable commissions for trading away, transfer taxes, and similar fees. Information about investment
advisory services, fees, and minimum account requirements can be found in the applicable program sponsor’s
disclosure document, in the client investment advisory services contract, and/or in the client’s custodial
services and brokerage contracts.
Please see Item 12 for a discussion of Natixis Advisors’ trading practices.
Item 6 - Performance Fees and Side-By-Side Management
Not Applicable.
Item 7 - Types of Clients
Natixis Advisors clients include: individuals (including high net worth individuals), banking or thrift institutions,
pension and profit sharing plans (but not plan participants), investment companies and other pooled vehicles,
charitable organizations, corporations or other businesses, state or municipal government entities, and sponsors
for which it provides model portfolios.
Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss
In managing discretionary client accounts and providing recommendations to non-discretionary clients, Natixis
Advisors (and the affiliated and unaffiliated model portfolio providers that it retains on behalf of clients) uses
various investment strategies and methods of analysis, as described below. Item 8 and its related appendices
contain a discussion of the primary risks associated with these investment strategies and are not intended to
describe in detail every possible risk associated with investing. Particular risks applicable to a client account
depend on the nature of the account, its investment strategy or strategies, and the types of securities held.
Any investment includes the risk of loss and there can be no guarantee that a particular level of return will be
achieved. While Natixis Advisors seeks to manage accounts so that risks are appropriate to the return potential
for the strategy, it is often not possible or desirable to mitigate all risks. Clients could lose some or all of their
investments and should be prepared to bear the risk of such potential losses, including through diversification.
Although Natixis Advisors does not limit its advice to particular types of investments, mandates will often be
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limited to certain types of securities (e.g., equities) or to the recommendation of investment advisers or managed
funds focused on certain types of securities and, therefore, may not be diversified. The accounts managed by
Natixis Advisors are not intended to provide a complete investment program for a client or investor and,
except with respect to pooled investment vehicles, Natixis Advisors expects that the assets it manages do not
represent all the client's assets. Clients are responsible for appropriately diversifying their assets to guard against
the risk of loss.
When dealing with a new client account, it may take several days or longer for assets of the account to be fully
invested in the selected investment strategy or strategies. Additional deposits into an existing client account can
take several days or longer to be fully invested.
When Natixis Advisors advises a new client account that is initially funded with securities (i.e., stocks, bonds,
mutual funds, exchange-traded funds, etc.) or when a client adds securities to an existing client account, Natixis
Advisors will usually liquidate non-cash holdings not contained in the strategy selected by the client. With respect
to the liquidation of non-cash holdings, the client will be solely responsible for any transaction costs, investment
losses, and/or taxes that result from such liquidations, all of which will impact performance. The type of assets
to be acquired to manage or continue to manage a client account (in accordance with the selected investment
strategy) could cause a delay in the account being fully invested. For example, delays can occur if: (i) there is
difficulty in disposing of any transferred assets; (ii) there is a need to minimize small or odd lot transactions; (iii)
there are account and/or trade reconciliation issues; or (iv) there is some unavailability or failure, outside of
Natixis Advisors’ reasonable control, of one or more of the systems utilized to manage and trade the client
account. Furthermore, client withdrawals can also be delayed due to some of the aforementioned difficulties or
due to illiquidity in the relevant market.
In certain circumstances, Natixis Advisors experiences delays in effecting transactions in client accounts or
communicating a change in a model to a model portfolio provider. Such delays may be due to issues including,
but not limited to, internal or external systems problems, communication issues, data issues, share balance
reconciliation issues, market volatility, heavy trading volumes, liquidity shortages, computer viruses, trading
halts, power interruptions, data theft, data destruction, severe or extraordinary weather conditions, earthquakes,
terrorist acts, acts of war, pandemics and other public health emergencies, or other “acts of God” and similar
circumstances. Further, Natixis Advisors can choose to hold or delay trades if Natixis Advisors considers it
prudent to do so to avoid trade or communication errors or other errors or issues. For example, if Natixis
Advisors believes that client account holdings or trading data is corrupted, stale, or inaccurate, or if holdings or
trade data cannot be reconciled, Natixis Advisors can choose to delay trading until these issues are resolved to
attempt to avoid significant trade errors that could otherwise result if trades are effected based on incorrect data.
While the ultimate effect of the types of delays referenced in this section depend upon market circumstances,
with an enhanced risk in circumstances of extreme market volatility, these delays are likely to also increase the risk
of losses and/or the risk of missing market or security appreciation. In some cases, these delays can also result
in increased dispersion between the performance results of a particular account or group of accounts managed
by Natixis Advisors and the performance results of a relevant model portfolio provider’s client accounts.
Whatever the cause of the delay in investing the client’s account or in processing a withdrawal request, Natixis
Advisors will make reasonable attempts to effect transactions in a client’s account as soon as reasonably
practicable.
Market Disruption, Health Crises, Terrorism, and Geopolitical Risk: Investment company clients and
managed account clients are subject to the risk that war, terrorism, global health crises or similar pandemics,
and other related geopolitical events may lead to increased short-term market volatility and have adverse long-
term effects on world economies and markets generally, as well as adverse effects on issuers of securities and
the value of a Fund’s or account’s investments. War, terrorism and related geopolitical events, as well as global
health crises and similar pandemics have led, and in the future may lead, to increased short-term market
volatility and may have adverse long-term effects on world economies and markets generally. Those events as
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well as other changes in world economic, political and health conditions also could adversely affect individual
issuers or related groups of issuers, securities markets, interest rates, credit ratings, inflation, investor sentiment
and other factors affecting the value of an investment company’s or managed account client’s investments. At
such times, investment company’s or managed account client’s exposure to a number of other risks described
elsewhere in this section can increase.
Investment Company Methods of Analysis, Investment Strategies, and Risk of Loss: Natixis Advisors
is the investment adviser to some of the Natixis Funds and Natixis ETFs. Each Natixis Fund and Natixis ETF
is a registered investment company or a series thereof. The advisory contract between Natixis Advisors and
the relevant Natixis Fund and Natixis ETF is terminable without penalty by the relevant Natixis Fund or
Natixis ETF on sixty (60) days' notice to Natixis Advisors, or by Natixis Advisors on ninety (90) days' notice
to the Natixis Fund or Natixis ETF. The agreement terminates automatically on assignment.
With respect to the Natixis Funds and Natixis ETFs for which Natixis Advisors acts as investment adviser,
Natixis Advisors can subcontract portfolio management services (including determination of methods of
analysis and selection of sources of information) to one or more affiliated or unaffiliated registered investment
advisers who act as subadviser to Natixis Advisors, as listed on Appendix 1. As set forth in the relevant
contract, each subadviser is responsible for the day-to-day investment operations of the Natixis Fund and/or
Natixis ETFs (or segment thereof) it subadvises. Natixis Advisors is responsible, subject to the approval of the
relevant Natixis Funds’ Board, for the selection and oversight of such subadviser. Natixis Advisors will replace
subadvisers as it deems appropriate, subject to the approval, where required, of the affected Natixis Funds’
and/or Natixis ETFs Board of Trustees and/or shareholders.
Some of the Natixis Funds are designed as multi-manager investment companies, combining the investment
styles of multiple subadvisers. Each subadviser is responsible for the management of a designated portion, or
sleeve, of the relevant multi-manager Natixis Fund. Natixis Advisors is responsible, when dealing with multi-
manager Natixis Funds, for the allocation of assets to each subadviser and sleeve of such Natixis Fund or for
selecting the subadviser that performs day-to-day investment advisory services for its allocated assets.
Shareholders should be aware that each Natixis Fund is managed according to Fund-specific investment
objectives, policies, and restrictions, and is not tailored for particular investors.
Natixis Advisors’ Solutions division is responsible for the management of several sleeves of each of the Natixis
Target Retirement Funds. Natixis Advisors’ Solutions division also fulfills its investment advisory obligations to
the sleeves by providing investment advisory expertise and trade execution services through its trade desk.
Natixis Advisors makes all investment decisions and directs the execution of all transactions allocated for
management through Solutions (subject to the investment objectives and guidelines applicable to each sleeve).
Subject to oversight by the Board of Trustees of the Funds, the Natixis Advisors’ Funds Advisory Oversight
Committee and the Due Diligence Committee monitor the performance and controls of investment company
advisers and subadvisers. For more information about the methods of analysis utilized by the subadvisers that
provide portfolio management services to the Natixis Funds and Natixis ETFs, see the relevant Natixis Funds’
and Natixis ETFs’ prospectuses and statements of additional information. Additionally, see Appendix 1 for a
description of the investment strategies of the subadvisers overseen by Natixis Advisors for the Natixis Funds
and Natixis ETFs for which Natixis Advisors acts as adviser. Appendix 4 also contains information about the
risks associated with each investment strategy.
Natixis Advisors also provides administrative services to the Natixis Funds, Natixis ETFs, and Loomis Sayles
Funds. These services include, but are not limited to, legal, compliance, treasury, office space and personnel,
including the compensation of trustees affiliated with the Funds’ administrator (i.e., Natixis Advisors).
Managed Account Methods of Analysis, Investment Strategies, and Risk of Loss: In providing
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discretionary investment advisory services to its managed account clients, Natixis Advisors utilizes investment
recommendations, including through model portfolios from model providers. Natixis Advisors can also
combine, for multi-manager and unified managed account strategies, more than one model portfolio.
The model portfolios provided to Natixis Advisors are based on a hypothetical U.S. person with a specified
minimum account size and investment strategy. Model portfolios are created using substantially the same
investment analyses, sources of information, and strategies that the model portfolio providers use in advising
their own institutional client accounts. In general, the methods and sources of information utilized by the model
portfolio providers to create the model portfolios include charting, fundamental, cyclical, and technical analysis,
third party research, company visits, and corporate rating services. However, the methods and sources of
information used by each model portfolio provider to create the model portfolios will vary.
For a more detailed description of the methods, sources of information, and investment techniques used by
each model portfolio provider, managed account clients should review each model portfolio provider’s
disclosure document, to the extent those documents are made available to the client. See Appendix 2 for a
listing of model portfolio providers and for a description of the affiliated and unaffiliated investment strategies
offered by Natixis Advisors. Not all strategies listed on Appendix 2 are available to Unbundled Program
clients.
Natixis Advisors also receives investment recommendations through its Solutions division, which develops
investment strategies by utilizing proprietary multi-factor algorithms to create direct indexing strategies
(generally, the AIA Strategies). Strategies may include full index replication, stratified sampling of an index,
optimization tools, and expected return inputs from internal analysis and third-party research providers. The
list and description of available investment strategies offered through sponsor programs is found in Appendix
2. Please see Appendix 5 for a list and a description of risks associated with Natixis Advisors’ available
investment strategies.
Natixis Advisors also receives investment recommendations from its Solutions division, which constructs
multi-asset portfolios by utilizing proprietary targeted models, optimization, and specific sampling techniques.
Solutions’ strategies include strategic, risk-aligned, objective-driven, and completion investment model
portfolios and strategies (including the Tactical Core, Tactical Core Tax Aware, Tax Managed Core, Risk
Efficient, Tactical Allocation, Tactical Alpha, and Alternative Completion Strategies). The model portfolios are
constructed and tested using a rigorous process encompassing scenario testing, simulation, and optimization.
For the Tactical Core, Tactical Core Tax Aware, Tax Managed Core, Risk Efficient, Tactical Allocation and
Tactical Alpha strategies, the general outline of the portfolio management process is as follows: (1) portfolios
are aligned to an overall degree of market risk; (2) annual strategic allocations are determined with long term
historical relationships within and across each asset class as well as reflecting more recent market behavior; (3)
allocation tilts relative to the strategic allocations are made within and across asset classes as dislocations occur
and opportunities present themselves; and (4) longer term positions are held in mutual funds whereas shorter
term positions are held in ETFs.
Finally, for the Alternative Completion strategies, the general outline of the portfolio management process is
as follows: (1) portfolios are aligned to an overall degree of market risk; (2) structural allocations to different
alternative strategies are made to achieve a high level of diversification for risk levels commensurate with the
core portfolio; and (3) market signals are used to dynamically adjust the allocations to the different strategies
and the portfolios’ overall risk profile over a time period. Please see Appendix 5 for a list and a description of
risks associated with Natixis Advisors’ available investment strategies.
Reasonable Restrictions: Natixis Advisors allows its managed account clients to impose reasonable investment
restrictions on the purchase of securities of particular issuers or types of issuers. However, model portfolios do
not manage individual client accounts or programs; clients can impose restrictions through the sponsor. In order
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to accommodate issuer-specific restrictions and guideline exposure limits, including Environmental, Social, and
Governance (“ESG”) or socially responsible investing (“SRI”), clients are asked to provide Natixis Advisors
with the name of the to-be-restricted security’s issuer, the security’s ticker symbol, and CUSIP number. In
order to apply reasonably requested SRI restrictions, Natixis Advisors employs a third-party vendor that
provides information regarding issuers that are within or outside of a client’s designated SRI restriction
category.
Natixis Advisors may also utilize research from third-party vendors that provide insight into the overall
ESG/SRI characteristics of a particular company. From the information provided, Natixis Advisors selects an
ESG/SRI category that in its sole judgment best approximates the ESG/SRI category identified by the client.
Using the third-party vendor’s standard compliance file, Natixis Advisors can restrict, as applicable, equity and
fixed income securities of those issuers identified for restriction by the client.
Unsupervised Assets: Under certain circumstances, clients can request Natixis Advisors to limit its
discretionary authority as to certain assets in the client account, while the client retains discretion over other
portions of the account. Assets over which the client retains discretion are commonly referred to as
“Unsupervised Assets.” Clients agree that Natixis Advisors will have no fiduciary obligation as to, or
discretion over, Unsupervised Assets. Natixis Advisors can agree to hold Unsupervised Assets together with
supervised assets as an accommodation to the client, but Natixis Advisors has the right to reject doing so. In
particular, clients should expect Natixis Advisors not to provide investment advice, vote proxies, or advise as to
or effect corporate action decisions with regard to such assets.
American Depositary Receipts (“ADRs”): In the case of certain investment products involving securities of
foreign issuers that are not listed on United States exchanges or over the counter markets, Natixis Advisors will
generally manage the client's portfolio by investing in ADRs, rather than in the underlying foreign securities.
Natixis Advisors typically effects transactions in ADRs using its own trading facilities unless the size of the
transaction exceeds certain limits agreed upon between Natixis Advisors and the model portfolio provider. In
investing in ADRs, Natixis Advisors can use third party electronic trading services to purchase ordinary shares
of foreign securities on the local equity market and convert such ordinary shares into ADRs. These systems
provide straight-through electronic processing of orders, including clearance and settlement. Trades occurring
through these systems are effected outside of the United States. Ticket charges/fees, foreign exchange rates,
country specific fees, and local market taxes will be included in the price of the ADR. In addition, although the
international equity strategies managed by Natixis Advisors are comprised primarily of ADRs, some ADRs
have limited liquidity on U.S. exchanges. Therefore, from time-to-time, Natixis Advisors will need to execute
international equity trades by trading ordinary shares in overseas markets and having those ordinary shares
converted to ADRs (rather than trading the ADRs on U.S. exchanges). This conversion is done only for
programs that have substantial amounts of assets and where the liquidity of the ADR itself is inadequate to
execute the trade without significant market impact.
Natixis Advisors will determine if the liquidity of a particular ADR necessitates the need to execute all or part
of the trade on a program-by-program basis by comparing the number of shares required to execute the trade
in each program with the available liquidity of the ADR and by analyzing other relevant factors. Orders whose
sizes do not exceed a certain percentage (as determined by Natixis Advisors) of the average or anticipated
trading volume of an ADR will be traded as ADRs on U.S. exchanges. However, orders that exceed a certain
percentage (as determined by Natixis Advisors) of daily volume of an ADR will be considered candidates for
trading the ordinary shares overseas and having those shares converted to ADRs. Under most circumstances,
orders that exceed a certain percentage (as determined by Natixis Advisors) of the daily volume would be
traded overseas as ordinary shares and converted to ADRs. When the number of shares is large enough to
necessitate trading in ordinaries for a specific program, that program will be removed from the normal trade
rotation sequence and executed overnight as a step-out. Non-impacted programs will remain in the trade
rotation sequence. See Item 12 for additional information on trading practices.
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Tax Harvesting:
Overview. Natixis Advisors offers tax harvesting services to its discretionary clients investing in certain
investment strategies. A tax loss harvesting process is embedded within the management of the AIA Strategies.
Tax loss harvesting involves effecting transactions in a taxable managed account to achieve tax benefits for the
client. Tax loss harvesting is designed to seek to lower a taxable client’s taxes while also seeking to generally
maintain the expected risk and return profile of an investment strategy or index, in the case of direct indexing.
When considering tax harvesting services on an as-requested basis, Natixis Advisors first reviews the account,
strategy and tax harvesting requests to ensure that Natixis Advisors has the requisite discretion, the account
and investment strategy are suitable for the service, and the request provided is clear and executable.
In managing certain AIA strategies, tax harvesting is embedded within the portfolio management process. The
specific tax harvesting process for AIA strategies may use different tools, methods, thresholds, processes, and
replacement securities than non-AIA strategies. Please see Item 8 for a description of the portfolio
management process.
Whenever providing tax harvesting services, Natixis Advisors will make reasonable efforts to accomplish tax
harvesting within stated guidelines, which are described further below. Clients should be aware that events
such as market changes or cash flows into or out of the account could increase or decrease the amounts of
losses that are realized from the client’s portfolio at any time. Additionally, clients should understand that tax
harvesting can adversely affect the investment strategy’s performance and increase its volatility. A tax-managed
strategy may cause a client portfolio to hold a security in order to achieve more favorable tax treatment or to
sell a security in order to create tax losses, either of which may prove to have performance less favorable than
what might otherwise have been achieved, either on a pre- or post-tax basis.
There is no guarantee that any harvesting technique employed by Natixis Advisors will achieve any particular
tax result. The tax consequences of tax harvesting can be difficult to determine in real time and may be
challenged after the fact by applicable tax authorities. Clients should consult tax advisors regarding potential
tax consequences and tax risks of tax harvesting, as Natixis Advisors does not provide tax advice. Natixis
Advisors will not be responsible for the tax consequences, including tax liability for gains or penalties, of any
transactions.
It is possible that different guidelines or procedures would result in a different level of tax harvesting that
would provide a greater benefit or that Natixis Advisors’ tax harvesting procedures may be ineffective.
Natixis Advisors is able to provide tax harvesting services only where it has discretion. Natixis Advisors is not
generally able to provide to, or coordinate tax harvesting with respect to, client assets invested in strategies
offered by other investment managers participating in such sponsored programs.
Natixis Advisors generally does not offer tax harvesting services for fixed income strategies or securities.
However, a client’s tax harvest request for fixed income accounts or securities will be evaluated by Natixis
Advisors on a case-by-case basis.
Natixis Advisors’ Tax Harvesting Process. When providing tax harvesting services, Natixis Advisors uses
quantitative tools to consider the tax benefit generated for clients as well as the performance impact of this
activity on the portfolio.
To effect tax harvesting in managed accounts other than those invested in AIA Strategies, Natixis Advisors
will sell investments from a client’s portfolio to realize a loss and invest the proceeds in a substitute investment
that represents the appropriate market exposure, rather than leaving those proceeds in cash. The subsequent
sale of a substitute investment after the wash sale period may itself result in a gain or loss, and such gain or
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loss may be a short-term one. The potentially weaker performance of a substitute investment and transaction
costs associated with tax harvesting could offset the potential tax benefit of tax harvesting.
Managed account clients should be aware that past performance is no guarantee of future results and that there
is no guarantee that substitute investments will perform like the loss harvested positions they are intended to
replace. The performance of the substitute investments, therefore, may be better or worse than the investments
that were sold. Substitute investments may also cause managed account clients to incur additional fees that
would not have been incurred through investments that were sold. Tax harvesting will generally increase the
transactions costs borne by managed account clients.
Wash Sales; No Coordination with Other Accounts; Tax Risks: Managed account clients should be aware that,
although Natixis Advisors will make reasonable efforts to avoid wash sales, Natixis Advisors cannot guarantee
that wash sales will not occur during tax loss harvesting activity. The wash sale rule disqualifies the realization
of a loss from selling a security if a “substantially identical” security is purchased 30 days before or after the
sale. There is limited guidance regarding what causes a security to be “substantially identical” to another
security. Therefore, there can be no assurance of how the IRS or a state or local tax authority would view the
selection of a particular substitute investment. In some cases, Natixis Advisors could execute a trade that
generates a wash sale when it believes that doing so is otherwise in the best interest of the client. Managed
account clients should be aware that the wash sale rule applies not only to transactions in the same account,
but to transactions across different accounts of the taxpayer and potentially also accounts of a taxpayer’s spouse
and household. Natixis Advisors is not able to coordinate tax harvesting with, or to monitor for potential wash
sale rule violations in connection with, any other of the taxpayer’s or the taxpayer’s spouse’s accounts, or other
associated household accounts, under Natixis Advisors’ management, accounts with the same sponsor
managed by other advisers or with any other accounts. Furthermore, since tax laws are subject to change,
future tax liabilities could increase and therefore tax loss harvesting might not result in the anticipated benefits.
Finally, there is no guarantee that the IRS or a state or local tax authority will not limit and/or prohibit
recognition of realized losses.
Client custodians may use a different tax lot/cost basis accounting methodology than Natixis Advisors, which
could cause discrepancies in the tax efficiencies estimated by Natixis Advisors.
The effectiveness of a tax loss harvesting strategy is largely dependent on each client’s entire tax and investment
profile, including, as noted, investments made outside of Natixis Advisors’ advisory services. As such, there is
a risk that the strategy used to reduce the tax liability of the client is not the most effective for every client.
Bankruptcies & Class Actions: Natixis Advisors provides investment advisory services only and will not render
legal advice or take any legal action on behalf of any client with respect to securities presently or formerly held as
assets in client accounts or any issuers thereof that become the subject of any legal proceedings, including
bankruptcies or class actions. Clients should instruct their custodian to forward all materials relating to legal
proceedings to the client (or such other agent as the client designates).
Bundled Program Participation: In Bundled Programs, the program’s sponsor performs due diligence on
Natixis Advisors and Natixis Advisors’ investment strategy. If the sponsor approves Natixis Advisors and
Natixis Advisors’ investment strategy, the approved investment strategy is presented to the sponsor’s clients
as an available investment option in the program.
In Bundled Programs, the client enters into a Program Agreement with the sponsor and the sponsor, in turn,
enters into an agreement with Natixis Advisors to provide relevant services to program clients. The sponsor
collects the bundled fee and then pays a portion of that fee to Natixis Advisors for the investment advisory
services that Natixis Advisors provides to the Bundled Program client. Some sponsors can charge Natixis
Advisors a fee to access the sponsor’s portfolio management software package, with such fees deducted by the
sponsor from the investment advisory services fee payment made to Natixis Advisors by the sponsor. Natixis
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Advisors currently participates in Bundled Programs with the sponsors listed on Appendix 6. Natixis Advisors
may participate in more than one program of a single sponsor. Even within the same sponsor, different
programs have different terms, conditions, services, features, and fees. Natixis Advisors is not responsible for
considering the merits of any particular program for any participant.
Clients should perform due inquiry on all of the features (e.g., custody, brokerage, accounting, and other services
and fees) of a program in which they choose to participate, as Natixis Advisors is not responsible for
conducting a suitability review of the sponsor, the sponsor’s program, and/or the services and fees charged to
the client. To this due end, clients should review carefully the program sponsor’s Form ADV Part 2A, and
other disclosure documents that the sponsor makes available to clients and prospects.
Unbundled Program Participation: In Unbundled Programs, the program’s sponsor performs limited due
diligence on Natixis Advisors and Natixis Advisors’ investment strategy. If the sponsor approves Natixis
Advisors and Natixis Advisors’ investment strategy, the Natixis Advisors investment strategy is presented to
the sponsor’s clients as an available investment option in the program.
In Unbundled Programs, the client enters into an investment advisory services contract with Natixis Advisors
directly, but could also enter into an agreement with a sponsor or with a registered investment adviser that
accesses Natixis Advisors’ investment strategy, for the benefit of the client, via the Unbundled Program. The
Unbundled Program sponsor may be a Broker and/or custodian to the client account. Natixis Advisors
currently participates in Unbundled Programs with the sponsors listed in Appendix 6.
Natixis Advisors can participate in more than one program of a single sponsor. Within the same sponsor,
different terms, conditions, services, features, and fees apply to each program. Natixis Advisors is not
responsible for considering the merits of any particular program for a participant.
Clients should perform due inquiry on all of the features (e.g., custody, brokerage, accounting, and other services
and fees) of a program that they select, as Natixis Advisors is not responsible for conducting a suitability review
of the sponsor, the sponsor’s program and/or the services and fees charged to the client. To this end, clients
should request and read the program sponsor’s Form ADV Part 2A and other reference documents that the
sponsor makes available to clients participating or looking to participate in the sponsor’s program.
Model Portfolio Services: Natixis Advisors provides model portfolios to sponsors that manage sponsor program
accounts. The sponsor that selects the model portfolio performs some due diligence on Natixis Advisors and
on the model portfolio provider’s investment strategy. If the sponsor approves of the model portfolio
investment strategy, the model portfolio is made available and utilized by the sponsor to manage sponsor
program accounts. Neither Natixis Advisors nor the model portfolio provider has discretionary authority over
these sponsor program accounts.
Natixis Advisors currently provides model portfolios to the sponsor firms listed on Appendix 6.
Certain Risks Associated with Cybersecurity: Investment advisers, including Natixis Advisors, must rely
in part on digital and network technologies to conduct their businesses. Such cyber networks might be subject
to a variety of possible cybersecurity incidents or similar events that could potentially result in the inadvertent
disclosure of confidential computerized data or client data to unintended parties, or the intentional
misappropriation or destruction of data by malicious hackers seeking to compromise sensitive information,
corrupt data, or cause operational disruption. Cyber-attacks might be carried out by persons using techniques
that could range from efforts to electronically circumvent network security or overwhelm websites to
intelligence gathering and social engineering functions aimed at obtaining information necessary to gain
access. Natixis Advisors maintains an information technology security policy and certain technical and
physical safeguards intended to protect the confidentiality of its internal data. Nevertheless, cyber incidents
could potentially occur, and might in some circumstances result in unauthorized access to sensitive
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information about Natixis Advisors or its clients. Natixis Advisors will seek to notify affected clients pursuant
to all applicable state and federal laws and regulations.
Item 9 – Disciplinary Information
Not Applicable.
Item 10 - Other Financial Industry Activities and Affiliations
Model Portfolio Provider Due Diligence: Natixis Advisors utilizes the services of model portfolio providers,
both affiliated and unaffiliated. Natixis Advisors conducts an initial due diligence review for certain of these
investment advisers, which focuses on the investment strategy’s performance and on the investment adviser’s
infrastructure and compliance program. For the investment advisers subject to Natixis Advisors’ due diligence
oversight program, Natixis Advisors also conducts periodic reviews to assess their compliance program,
operational relationship, and investment strategy performance. A number of internal committees of Natixis
Advisors and of its legal and compliance, operational and portfolio management personnel are involved in
reviewing information collected from potential and existing model portfolio providers. Conflicts of interest, if
any, are identified through the due diligence process, which applies equally to affiliated and unaffiliated model
portfolio providers. For investment advisers not subject to Natixis Advisors’ due diligence oversight program,
as between Natixis Advisors and the underlying managed account client, it shall be the responsibility of the
managed account client to oversee and select such investment adviser(s).
Activities of Natixis Distribution: Natixis Distribution acts as a limited purpose broker dealer and is the
underwriter/distributor of the Natixis Funds, Loomis Sayles Funds, and Vaughan Nelson Funds. Natixis
Distribution also provides placement agent services for managed accounts, private funds, and non-U.S.
collective investment vehicles advised by U.S. and non-U.S. affiliated and unaffiliated investment advisers,
including Natixis Advisors. Natixis Distribution and Natixis Advisors have an intercompany referral services
agreement, which allows Natixis Distribution to provide placement agent services pursuant to which registered
representatives (wholesalers) of Natixis Distribution solicit sponsors and financial advisors to select products
and services provided by Natixis Advisors for their clients (prospective managed account clients of Natixis
Advisors). For a full list of broker-dealer affiliates of Natixis Distribution, please see Natixis Distribution’s
Form BD. Other than as set forth herein, Natixis Advisors does not currently utilize the services (banking,
underwriting, or otherwise) of any of its U.S. and non-U.S. affiliated broker-dealers. However, certain
employees of Natixis Advisors also serve as executive officers of Natixis Distribution and certain associated
persons of Natixis Advisors are registered representatives of Natixis Distribution.
Managed Account Administrative Services: Natixis Advisors provides certain non-discretionary administrative
and compliance services, and implements certain investment recommendations, to assist AEW Capital
Management L.P. (“AEW”), an affiliated investment adviser, with AEW’s discretionary management of AEW
client accounts in the Charles Schwab Manager Account Select sponsor program (“Schwab Select”). Services
provided to AEW by Natixis Advisors include: establishing client accounts (including administration of client
specific-investment guidelines/restrictions), applying AEW’s investment recommendations at AEW’s
direction, communicating the aggregate number of securities being recommended for purchase/sale, effecting
“block” transactions, as directed by AEW, allocating such transactions among client accounts, and overseeing
settlement of such transactions. AEW Schwab Select client fees are paid by clients to Schwab and Schwab
compensates AEW. AEW, in turn, compensates Natixis Advisors for the services provided.
services and
implements certain non-discretionary
Investment Company Administrative Services: Natixis Advisors provides certain non-discretionary
administrative and compliance
investment
recommendations to assist certain sleeves of the Natixis Target Retirement Funds. Fees for such services are
paid from the subadvisory fees received by Mirova US LLC, a subadvisor to the Natixis Target Retirement
Funds.
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Affiliations: Natixis Advisors is an indirect subsidiary of Natixis IM, which owns, in addition to Natixis Advisors,
a number of other asset management and distribution and service entities (each, together with any advisory
affiliates of Natixis Advisors, a “related person”). As noted under Item 4, Natixis IM is wholly owned by
Natixis, which is wholly owned by BPCE, France’s second largest banking group. BPCE is owned by banks
comprising two autonomous and complementary retail banking networks consisting of the Caisse d’Epargne
regional savings banks and the Banque Populaire regional cooperative banks. There are several intermediate
holding companies and general partnership entities in the ownership chain between BPCE and Natixis
Advisors. In addition, Natixis IM’s parent companies, Natixis and BPCE, each own, directly or indirectly, other
investment advisers and securities and financial services firms which also engage in securities transactions.
Natixis Advisors does not presently enter into transactions, other than as described herein, with related persons
on behalf of clients. Because Natixis Advisors is affiliated with a number of asset management, distribution and
service entities, Natixis Advisors will occasionally engage in business activities with some of these entities,
subject to Natixis Advisors’ policies and procedures governing conflicts of interest. For example, Natixis
Advisors enters into relationships with related persons, which include advisory or subadvisory arrangements
(on a discretionary or non-discretionary basis), cross- marketing arrangements for the sale of separate accounts
and privately placed pooled vehicles, research sharing relationships, and personnel-sharing relationships.
Moreover, Natixis Advisors can use related persons to provide certain services to clients to the extent this is
permitted under applicable law and under Natixis Advisors’ policies and procedures. Given that related persons
are equipped to provide a number of services and investment products to Natixis Advisors’ clients, subject to
applicable law, Natixis Advisors clients can choose to engage a related person of Natixis Advisors to provide
any number of such services, including advisory, custodial, or banking services, or to invest in the investment
products provided or sponsored by a related person of Natixis Advisors. The relationships described herein
could give rise to conflicts of interest or otherwise have an adverse effect on Natixis Advisors’ clients. For
example, when acting in a commercial capacity, related persons of Natixis Advisors are expected to take
commercial steps in their own interests, which may be adverse to those of Natixis Advisors’ clients.
Given the interrelationships among Natixis Advisors and its related persons and the changing nature of Natixis
Advisors’ related persons’ businesses and affiliations, there may be other conflicts of interest that arise in the
future or that are not covered by this discussion. Although conflicts of interest naturally arise out of the services
offered, Natixis Advisors’ policies and procedures aim to mitigate potential conflicts by establishing a
framework to promote the highest standard of duty of care to its clients. All personnel and investment decisions
are governed by the fiduciary responsibility owed to Natixis Advisors’ clients.
Additional information regarding conflicts of interest arising from Natixis Advisors’ relationships and activities
with its related persons is provided under Item 11. See Appendix 2 for a list of the affiliated model portfolio
providers and unaffiliated model portfolio providers used by Natixis Advisors and/or model portfolio
strategies provided by each.
Item 11 – Code of Ethics, Participation, or Interest in Client Transactions and Personal Trading
Natixis Advisors does not knowingly engage in the purchase or sale of securities as principal with any client.
However, because Natixis Advisors has numerous related persons that engage in securities brokerage and
investment advisory activities, it is possible that such transactions could occur.
From time to time, Natixis Advisors recommends to clients the purchase or sale of securities also purchased,
owned, or sold by the Natixis Funds and Natixis ETFs. As previously noted, Natixis Advisors serves as adviser
to various investment companies comprising the Natixis Funds and Natixis ETFs. In addition, Natixis Advisors
could, from time-to-time, invest client assets in affiliated funds. It is important to note that various officers of
Natixis Advisors and its advisory affiliates are officers and/or trustees of the Funds. Natixis Advisors does not
invest in securities for its own account, except for short-term money market instruments and shares of the
Funds. Natixis Advisors or its affiliates will, from time to time, use its or their own assets to provide seed
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capital to new investment companies, other commingled funds, or other products.
The Natixis 401(k) and Retirement Account Plans, in which personnel of Natixis Advisors have an interest,
can invest in the Funds, in other investment companies, and directly in securities that are purchased or sold for
client accounts. Where appropriate, certain securities held by the Funds will also be purchased or sold or
recommended for purchase or sale, for or on behalf of clients. In no event will Natixis Advisors knowingly
recommend or cause a client to enter into transactions for the purpose of benefiting the direct or indirect
securities holdings of the Natixis 401(k) and Retirement Account Plans, or other holdings of Natixis Advisors
personnel. Further, Natixis Advisors personnel could invest for their own accounts in securities which are also
purchased or sold for Natixis Advisors’ clients.
As adviser for certain Natixis Funds, Natixis Advisors receives economic benefits in the form of increased
advisory and administration fees from such Natixis Funds where Natixis Advisors’ clients purchase shares of
the Natixis Funds. Likewise, Natixis Distribution receives additional Rule 12b-1 fees as a result of such
investments for certain share classes of the Natixis Funds and Loomis Sayles Funds. The majority of 12b-1
fees received by Natixis Distribution are passed along to certain intermediaries pursuant to the terms of a
distribution agreement.
Code of Ethics: Per Natixis Advisors’ policy, no supervised person shall engage in any act, practice, or course
of conduct that would violate the Code of Ethics, the fiduciary duty owed by Natixis Advisors and their personnel
to clients, or any applicable federal securities laws including, but not limited, to: certain sections and rules
promulgated under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”), or the provisions of Section 17(j) of the
Investment Company Act of 1940, as amended (the “1940 Act”), and Rule 17j-1 thereunder. The fundamental
position of Natixis Advisors is that the interests of clients are always placed first. Accordingly, supervised
persons’ personal financial transactions (and those of members of their family/household) and related activities
must be conducted consistently with the Code of Ethics and in such a manner as to avoid conflicts of interest
or abuse of Natixis Advisors’ position of trust and responsibility.
To comply with applicable securities laws, rules, and the Natixis Advisors Code of Ethics, certain Natixis
Advisors personnel must complete quarterly reports of security transactions made for their own accounts or
any account in which they have a direct or indirect beneficial interest (collectively, "Reporting Accounts").
Exceptions from the reporting requirements include transactions in money market instruments, direct
obligations of the United States government, and shares of non-affiliated open-end mutual funds and ETFs.
Pre-clearance procedures set forth in Natixis Advisors Code of Ethics have been established to help identify
and prevent conflicts between personal trading activities of Natixis Advisors personnel and Natixis Advisors
trading for its clients. With certain exceptions, Natixis Advisors’ personnel are prohibited from knowingly
trading in a security if such security is being traded and/or is likely to be traded on behalf of clients on that
day. Natixis Advisors personnel are also restricted from buying or selling a security for their own account
within three (3) days prior to or after a Natixis Advisors’ client trades in such security (the “7 Day Blackout
Period”). However, client account-specific transactions implementing a model portfolio are excluded from
the Code’s restrictions with respect to trades by Natixis Advisors’ Access Persons. Nevertheless, Natixis
Advisors will monitor excepted transactions to determine the level of knowledge a person may have with
respect to the model portfolio implementation transactions. The Compliance Team will investigate any trends
determined and escalate issues, where necessary, to the Ethics & Supervisory Committee for appropriate action.
Natixis Advisors personnel are prohibited from investing in initial public offerings or private placements
without prior approval.
Natixis Advisors’ Code of Ethics prohibits Natixis Advisors personnel from giving or receiving gifts with a
value in excess of one hundred dollars to or from any person that does business with or on behalf of the
Natixis Advisors. Natixis Advisors personnel are required to seek pre-approval for all external directorships
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and such personnel are subject to conflict of interest procedures and a case-by-case due diligence review.
Natixis Advisors personnel must certify annually that they have complied with Natixis Advisors' Code of Ethics
and its related procedures regarding personal trading.
A copy of Natixis Advisors’ Code of Ethics is available upon request. To obtain a copy of the Code of Ethics,
please contact Natixis Advisors via phone at 617-449-2802, or by email at ADVOPS@natixis.com.
Insider Trading Policy: Natixis Advisors’ insider trading policy states that no associate of Natixis Advisors is
permitted to purchase or sell a security while knowingly in possession of material, nonpublic information
(“MNPI”) relating to such security, or tip the information to others, or effect or recommend the purchase or
sale of a security for or to any person (including a client) on the basis of that information. Additionally, no
associate of Natixis Advisors is permitted to knowingly employ a manipulative or deceptive device with respect
to a security. Furthermore, all associates of Natixis Advisors shall comply with all applicable requirements set
forth in Natixis Advisors’ policy and shall not disclose to others, except in the normal performance of their
business duties, MNPI relating to the trading activities of client accounts. All Natixis Advisors associates are
considered access persons under Natixis Advisors Code of Ethics and must comply with the procedures for
reporting personal securities holdings and transactions as outlined in the Code of Ethics. Whenever an associate
of Natixis Advisors receives, during the normal performance of his or her duties, what he or she believes may
be MNPI about a security, or becomes aware that such information is to be or has been used by another
associate in the purchase or sale of a security, or that another associate is intending to employ or has employed
a manipulative and deceptive device, he or she shall immediately notify the General Counsel or, in his or her
absence, the Chief Compliance Officer of Natixis Advisors and refrain from disclosing the information to
anyone else, including other persons within Natixis Advisors. No Natixis Advisors associates, except in the
normal performance of his or her business duties, shall have access to the information maintained for or
generated by portfolio managers or research analysts.
Natixis Advisors takes steps to isolate effectively MNPI about securities to avoid unnecessary interruption of
the free flow of information that is essential to the efficiency of financial markets. While one subsidiary or
division of Natixis is legitimately in possession of MNPI concerning a security, Natixis as a whole could be at
risk if another subsidiary or division has effected a transaction in, or otherwise taken action relating to, that
security.
To limit exposure to insider information, no associate of Natixis Advisors shall become an officer, trustee, or
director of any company whose shares are publicly traded (except an investment company managed by or
distributed by Natixis Distribution or an affiliate of either Natixis Advisors or Natixis Distribution) without
the approval of the Chief Compliance Officer. If such approval is obtained, trading by the associate in the
securities of that company shall be subject to prior approval by the compliance officer. The associate shall not
discuss MNPI concerning that company with other associates of Natixis Advisors at any time.
Unaffiliated Investment Entities: Personnel of Natixis Advisors and its affiliates can invest for their own
account through interest in investment partnerships, venture capital vehicles, hedge funds, commingled
accounts or investment accounts managed by investment advisers not affiliated with Natixis Advisors
(“Unaffiliated Investment Entities”). Natixis Advisors personnel can purchase or sell securities or otherwise
have an interest in securities also purchased, sold, or recommended by Natixis Advisors (or its investment
advisory affiliates) for purchase or sale by Natixis Advisors' clients through Unaffiliated Investment Entities.
Natixis Advisors personnel will have no ability to influence or control transactions in securities by the
Unaffiliated Investment Entities. However, if Natixis Advisors personnel have influence or control over the
investment decisions of an Unaffiliated Investment Entity, transactions by such Unaffiliated Investment Entity
become subject to Natixis Advisors’ policies on employee trading described above. Where Natixis Advisors or
an affiliate serves as investment adviser, administrator, distributor, or subadviser to an investment company or
other pooled vehicle in which Natixis Advisors, or any of its personnel have a beneficial interest, transactions
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by personnel in shares of such mutual fund or other pooled vehicle are subject to restrictions on employee
trading. Many of the accounts managed by the affiliated subadvisers and model portfolio providers are accounts
of affiliates of Natixis Advisors (including those acting as a subadviser or model portfolio provider) or are
accounts in which the affiliates' personnel have ownership interests. Subject to applicable law and the affiliates'
policies on personal trading, these accounts can purchase or sell securities contemporaneously being purchased
or sold (or recommended for purchase or sale) by Natixis Advisors' clients.
Related Persons Transactions: In connection with providing investment management and advisory services to
its clients, Natixis Advisors acts independently of its affiliated investment advisers, except as otherwise set
forth herein, and manages the assets of each of its clients in accordance with the investment mandate selected
by such clients.
Related persons of Natixis Advisors are engaged in securities transactions. Natixis Advisors and its related
persons can invest in the same securities that Natixis Advisors recommends for, purchases for, or sells to
Natixis Advisors’ clients. Natixis Advisors and its related persons (to the extent they have independent
relationships with the client) can give advice to and take action with their own accounts or with client accounts
that can compete or conflict with the advice Natixis Advisors may give to, or an investment action Natixis
Advisors may take on behalf of another client. Further, the action could involve different timing than with
respect to the client. Since the trading activities of Natixis firms are not coordinated, each firm could trade the
same security at about the same time, on the same or opposite side of the market, thereby possibly affecting
the price, amount, or other terms of the trade execution, adversely affecting some or all clients. Similarly, one
or more clients of Natixis Advisors’ related persons could dilute or otherwise disadvantage the price or
investment strategies of another client through their own transactions in investments.
Natixis Advisors’ management on behalf of its clients could benefit Natixis Advisors or its related persons.
For example, clients can, to the extent permitted by applicable law, invest directly or indirectly in the securities
of companies in which Natixis Advisors or a related person, for itself or its clients, has an economic interest.
Clients, Natixis Advisors, or a related person on behalf its client, can engage in investment transactions which
could result in other clients being relieved of obligations or divesting certain investments. The results of the
investment activities of a client of Natixis Advisors could differ significantly from the results achieved by Natixis
Advisors for other current or future clients.
Because certain Natixis Advisors clients are related persons, Natixis Advisors has incentives to resolve conflicts
of interest in favor of certain clients over others (e.g., where Natixis Advisors has an incentive to favor one
account over another). However, Natixis Advisors has established conflicts of interest policies and procedures
that identify and manage these conflicts of interest.
Conflicts arise from Natixis Advisors’ and its related persons’ use of multiple strategies. For instance, Natixis
Advisors and its related persons can invest in distinct parts of an issuer’s capital structure. Moreover, one or
more of Natixis Advisors’ clients could own private securities or obligations of an issuer while a client of a
related person owns public securities of that same issuer. For example, Natixis Advisors or a related person
could invest in an issuer’s senior debt obligations for one client and in the same issuer’s junior debt obligations
for another client. In certain situations, such as where the issuer is financially distressed, these interests could
be adverse. Natixis Advisors or a related person could also cause a client to purchase from, or sell assets to, an
entity in which other clients may have an interest, potentially in a manner that will adversely affect such other
clients. In other cases, Natixis Advisors could receive MNPI on behalf of some of its clients, which could
prevent Natixis Advisors from buying or selling securities on behalf of other of its clients even when it would
be beneficial to do so. Conversely, Natixis Advisors could refrain from receiving MNPI on behalf of clients,
even when such receipt would benefit those clients, to prevent Natixis Advisors from being restricted from
trading on behalf of its other clients. In these situations, Natixis Advisors or its related persons, on behalf of
itself or its clients, could take actions that are adverse to some or all of Natixis Advisors’ clients. Natixis
Advisors will seek to resolve conflicts of interest described herein on a case-by-case basis, taking into
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consideration the interests of the relevant clients, the circumstances that gave rise to the conflict, and applicable
laws. There can be no assurance that conflicts of interest will be resolved in favor of a particular client’s
interests. Moreover, Natixis Advisors will not have the ability to influence the actions of its related persons.
In addition, certain related persons of Natixis Advisors engage in banking or other financial services businesses,
and in the course of conducting their business, such persons can take actions that adversely affect Natixis
Advisors’ clients. For example, a related person engaged in lending could foreclose on an issuer or security in
which Natixis Advisors’ clients have an interest. As noted above, Natixis Advisors will not have the ability to
influence the actions of its related persons.
From time to time, Natixis Advisors purchases securities in public offerings or secondary offerings on behalf
of client accounts in which a related person is a member in the underwriting syndicate. Such participation is in
accordance with Natixis Advisors’ policy and applicable law, and Natixis Advisors does not purchase directly
from such related person. Natixis Advisors does not presently knowingly enter into transactions with related
persons on behalf of clients.
Item 12 – Brokerage Practices
General Brokerage Practices: As a fiduciary, Natixis Advisors acts in the best interests of its clients and must
never engage in any fraudulent, deceptive, or manipulative transaction, practice, or course of business. Natixis
Advisors consequently strives to: adhere to any regulations prohibiting or requiring certain transactions or
practices; treat all clients fairly; maximize the value of a client’s portfolio with the client’s stated investment
objectives and constraints; seek best execution for all client transactions when it has authority to select brokers;
and ensure that any account administrative or trading errors are identified and resolved in a timely manner and
in the best interest of the client(s).
Natixis Advisors does not enter into agreements with, or make commitments to, any Broker that would bind
Natixis Advisors to compensate that Broker, directly or indirectly, for client referrals (or sales of the Funds)
through the placement of brokerage transactions. However, where permissible by law, if one or more Brokers
is believed capable of providing equivalent quality of execution with respect to a particular portfolio transaction,
Natixis Advisors can select a Broker in recognition of the past referral of the client for which the transaction is
being executed (or of other clients) or in anticipation of possible future referrals from the Broker.
In doing so, unless otherwise specifically disclosed to the client, Natixis Advisors does not pay higher
commissions, concessions or mark-ups/downs than would otherwise be obtainable from Brokers that do not
provide such referrals. Clients can, as discussed below, limit Natixis Advisors’ discretion by directing Natixis
Advisors to trade through a particular Broker, including one which referred that Client to Natixis Advisors.
Additionally, Natixis Advisors can exercise its discretion to execute transactions through any Broker, including
one that referred clients or sold Fund shares, in order to fulfill Natixis Advisors’ duty to seek best execution.
In these circumstances, Natixis Advisors follows procedures reasonably designed to ensure that such referrals
or Fund sales are not a factor in the decision to execute a trade, or a particular number of trades, through such
Broker.
There are special considerations when investing in a strategy composed of fixed income securities. Fixed
income securities are purchased from the issuer or a primary market maker acting as principal on a net basis
with no brokerage commission paid by the client. Fixed income trades are usually aggregated, and sometimes
placed, as limit orders, as directed by the model portfolio provider. When no limit order is set, Natixis Advisors’
trade desk relies upon the sponsor’s desk to present bid or ask prices. Natixis Advisors does not present bids
for fixed income trades for client- specific or client-directed transactions. Such transactions are placed with the
client-directed Broker. For fixed income trading, other factors can significantly affect Natixis Advisors’
evaluation of a Broker’s overall ability to deliver best execution. The general illiquidity of certain sectors of the
fixed income market often requires specialized Brokers who can transact large trades without causing a
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significant impact on the price of the security. Fixed income trades can also take longer to complete, and
transactions are conducted no less frequently than every two weeks. Smaller Brokers are not likely to trade in
the same volume as large Brokers and, therefore, trading costs on trades with such firms generally are higher.
Fixed income securities, as well as equity securities, can also be purchased in public offerings from underwriters
at prices, which include underwriting commissions and fees.
As Natixis Advisors handles the investment decision process for both separately managed accounts and
investment company clients, and because portfolio managers handle both types of clients simultaneously,
Natixis Advisors has established a trade rotation policy reasonably designed to treat clients fairly and equitably
over time. Additionally, with respect to managed account Broker selection, so as to oversee selected Brokers,
Natixis Advisors trading, portfolio management, and compliance personnel review Brokers, initially and on a
periodic basis, to determine whether the quality of brokerage services is satisfactory.
In this regard, internal and external execution reviews are conducted to determine whether the Broker remains
on the approved list, is identified as a Broker to watch, or is removed from the approved list. Clients should be
aware that Brokers that sell Fund shares can be on the list of approved Brokers for use in brokerage transactions
for managed account clients.
Natixis Advisors has delegated certain non-discretionary trade execution services to its operational service
provider Vestmark, which may include placing orders with broker-dealers to purchase or sell securities on
behalf of accounts. While providing this service, Vestmark adheres to the brokerage practices outlined in this
section.
Trade Errors: As a fiduciary, Natixis Advisors seeks to exercise utmost care in making and implementing
investment decisions for client accounts. Nonetheless, from time to time, a trade error can occur. When trade
errors occur, Natixis Advisors seeks to promptly correct such errors to minimize client impact. Where an error
results in net loss to a client, Natixis Advisors will reimburse the client. For this purpose, the economic effect
(including costs) of all related transactions (i.e., the erroneous trade(s) and any related corrective trade(s) or
other remedial actions) is considered. Where an error results in a net gain to a client, the client will retain the
net gain. However, when retaining the net gain is inconsistent with applicable law, creates adverse tax
consequences, or is inconsistent with a client’s policies (e.g., socially responsible investing clients), clients can
renounce the gain and, in this case, such gains may be donated to charity. Where a trade error occurs when
Natixis Advisors is providing investment advisory services to managed account clients participating in Bundled
sponsor programs, it may be required to adhere to the trade error policies of the Bundled Program sponsor.
Soft Dollars: Natixis Advisors does not participate in soft dollar arrangements. However, some of the model
portfolio providers directly hired by Natixis Advisors, some of which provide trade execution services,
participate in such arrangements. Additionally, some of the model portfolio providers hired by sponsors, over
which Natixis Advisors does not conduct due diligence, provide trade execution services and participate in soft
dollar arrangements. For information tied to the soft dollar policies of model portfolio providers, please see
the relevant model portfolio provider’s Form ADV Part 2A.
Investment Company-Specific Brokerage Practices: Natixis Advisors has investment and brokerage discretion
with respect to the Natixis Funds and Natixis ETFs for which it acts as named investment adviser. In this
regard, Natixis Advisors has the authority to determine the securities to be bought or sold, the amount of
securities to be bought or sold, which Broker to be used, and the commission rates to be paid by the Natixis
Funds and/or Natixis ETFs without obtaining specific consent from the Natixis Funds and/or Natixis ETFs.
Other than with respect to the portion of the Natixis Funds managed directly by Solutions, Natixis Advisors
does not exercise its investment or brokerage discretion on a daily basis for investment companies because it
normally contracts with subadvisers to perform these functions.
Subadvisers to the Natixis Funds and the Natixis ETFs have the authority to place portfolio transactions with
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Brokers selected by such subadvisers at commission rates negotiated by such subadvisers. Each subadviser
establishes its own brokerage policies, which are disclosed in the subadviser’s own disclosure documents and
in the respective registration statements of the Natixis Funds and the Natixis ETFs. As named investment
adviser for certain Natixis Funds and the Natixis ETFs, Natixis Advisors can encourage subadvisers to direct
brokerage for a particular Natixis Fund or can direct brokerage directly with respect to a Natixis Fund managed
by Solutions to Brokers that have agreed to use a portion of such Natixis Fund’s commissions to pay operating
expenses to defray that Natixis Fund’s expenses. The foregoing practices are subject to guidelines established
by, and overseen by, the Board of Trustees of the relevant Natixis Funds.
With respect to the investment company brokerage activities of Natixis Advisors conducted through Solutions
on behalf of the Natixis Funds, Natixis Advisors' primary objective in the selection of Brokers is to obtain the
best combination of price and execution under the particular circumstances. Best price, giving effect to
brokerage commissions, if any, and other transaction costs, is normally an important factor in selecting a
Broker. However, Natixis Advisors also takes into account the quality of brokerage services, including
timeliness and execution capability, willingness to commit capital, financial stability, and clearance and
settlement capability. Accordingly, transactions will not always be executed at the lowest available price or
commission but will be within a competitive range. Natixis Advisors’ Operations & Compliance Committee is
responsible for approving the Solutions list of Brokers eligible to trade and for reviewing trading data,
including volumes, prices, commissions, and other transaction costs as appropriate in order to monitor the
quality of trade execution.
Managed Account Specific Brokerage Practices: Natixis Advisors (or, in connection with trades implemented
by a model portfolio provider, such model portfolio provider) can, but need not, aggregate or "bunch" orders
of discretionary accounts as to which it has discretion to select Brokers in circumstances in which Natixis
Advisors (or the relevant model portfolio provider) believes that bunching could result in a more favorable
execution. Where appropriate and practicable, Natixis Advisors (or the relevant model portfolio provider) will
allocate bunched orders at the average price and costs of the aggregated order. Natixis Advisors (or the relevant
model portfolio provider) could bunch client trades with trades of pooled vehicles in which Natixis Advisors’
personnel have a beneficial interest pursuant to an allocation process that Natixis Advisors (or the relevant
model portfolio provider) in good faith considers to be fair and equitable to all clients over time. In instructing a
model portfolio provider to implement transactions for Natixis Advisors’ managed account clients, Natixis
Advisors will endeavor to communicate such instruction as promptly as possible so that the transactions can
be aggregated to the extent possible with transactions being effected by the model portfolio provider for its
other clients.
Aggregation of trades will not be possible in some cases, such as when the model portfolio recommends
transactions in ADRs and the relevant model portfolio provider is effecting transactions in the related foreign
securities or, depending on arrangements with the relevant model portfolio provider, if a client or managed
account program sponsor restricts the Broker(s) that can be used to execute transactions for that client or
program.
Further, in the event that Natixis Advisors delivers a late instruction to bunch trades to a model portfolio
provider, relative to the commencement of transactions for other clients, such trade will be effected by the
model portfolio provider as promptly as practicable. In this circumstance, it could be necessary for the model
portfolio provider to complete its transactions for other clients before effecting transactions for Natixis
Advisors' clients in order to minimize the adverse market price and liquidity impact of attempting to effect both
sets of transactions separately but contemporaneously. In such cases, Natixis Advisors’ client will not enjoy the
potential benefits that might otherwise have been obtained by bunching, including lower execution costs and
the more favorable terms executed for the model portfolio provider's clients.
Bundled Program Practices: Bundled Program sponsors grant Natixis Advisors discretion to select Brokers to
execute transactions for Bundled Program client accounts, so as to permit Natixis Advisors to fulfill its duty
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to seek best execution. As there is no separate commission charge for a Bundled Program client’s transactions
that are executed through the sponsor trade desk, the sponsor- affiliated Broker’s trade desk, or the sponsor-
designated Broker’s trade desk(due to the bundled/wrap fee), Natixis Advisors will usually execute the Bundled
Program client’s trades through the sponsor designated trade desk(s). If, in seeking to fulfill its duty to seek best
execution, Natixis Advisors decides to utilize the trade desk of a Broker not designated by the sponsor, any
separate commissions charged by such Broker will be paid by the Bundled Program client. Natixis Advisors
considers this additional charge (beyond the bundled/wrap fee) in determining whether to execute Bundled
Program clients’ trades utilizing a Broker not designated by the sponsor.
Some Bundled Program sponsors strongly encourage (or require) Natixis Advisors to effect client trades
through the sponsor, the sponsor- affiliated Broker or the sponsor-designated Broker. Where a program limits
Natixis Advisors’ ability to fulfill its duty to seek best execution’, the client accounts in the program are
considered to be “Directed Accounts.” It is strongly encouraged that each Bundled Program client review
the client- sponsor Bundled Program agreement to determine if any Broker restrictions apply.
Unbundled Program Practices: Natixis Advisors can execute transactions for Unbundled Programs with
Brokers directed by the client or the program sponsor. However, unlike a Bundled Program, an Unbundled
Program fee does not include brokerage fees. Therefore, Natixis Advisors could decide to use a Broker other
than the sponsor or its Broker affiliates if doing so is consistent with Natixis Advisors’ duty to seek best
execution. However, some Unbundled Programs provide the client the option of selecting an asset-based
custodial and brokerage fee for a fixed fee. Therefore, these Unbundled Programs could impose restrictions
on Natixis Advisors (or the relevant model portfolio provider) similar to those in Bundled Programs. If “trading
away” results in incremental and duplicative brokerage charges, Natixis Advisors (or the relevant model
portfolio provider) will typically execute the transactions with the Broker directed by the client or made
available by the Unbundled Programs sponsor, unless Natixis Advisors determines that best execution cannot
be obtained through such Broker.
Multi-Tiered Trade Rotation Policy: For its managed account and model portfolio clients, Natixis Advisors
utilizes a multi-tiered trade rotation policy that seeks to execute the securities transactions of managed account
clients (and certain model portfolio clients for which it provides trade execution) and to disseminate model
portfolios to its model portfolio clients in a fair and equitable manner over time.
Natixis Advisors utilizes a three-tier trade rotation procedure. Where one or more sponsor’s clients in the first
or second tier are expected to be investing in the same security contemporaneously, Natixis Advisors will
generate a random trade rotation list of sponsors within each tier, which includes each managed account client
or model portfolio client trading in the same security contemporaneously in the tier. Thus, for example, Natixis
Advisors will direct the execution of transactions on behalf of the managed account clients (and certain model
portfolio clients for which Natixis Advisors provides trade execution) and disseminate the model portfolios to
the model portfolio clients in the first tier according to the respective client’s placement on the first tier random
trade rotation list. After the transactions for each of the clients in the first tier are completed, Natixis Advisors
will direct the execution of transactions on behalf of the clients in the second tier according to their order on
the second tier random trade rotation list. After the transactions for each of the clients in the second tier are
completed, model portfolio information is delivered to clients in the third tier contemporaneously.
Clients that are given priority in trade rotation (i.e., clients that are in a tier that trades earlier than another tier)
and clients whose trades are bunched with institutional account trades by a model portfolio provider will
generally receive executions more aligned with investment decisions than clients whose trades are effected later.
Thus, clients in the second tier (clients that direct the use of a particular Broker) and the third tier (model
portfolio clients that either cannot meet the conditions for inclusion in the first tier or that do not permit
Natixis Advisors to provide trade execution) often receive less favorable execution. For other information
regarding Directed Brokerage, clients of Natixis Advisors should read the “Directed Brokerage” section set
forth below. For more information about the trade practices of model portfolio providers, clients of Natixis
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Advisors should read Form ADV Part 2A of the relevant model portfolio provider. Generally, model portfolio
providers will choose to exercise shared discretionary power when they are providing a model portfolio that
contains exposure to less liquid securities or when the aggregated assets of the Bundled Program have reached
a “critical mass” (i.e., trades of the Bundled Program in the marketplace would materially impact the trades
intended to be made for the model portfolio provider’s institutional accounts).
Trade Rotation Tier 1: Natixis Advisors’ managed account clients that do not direct Natixis Advisors to use
specified Brokers are included in the first tier. As noted below, certain model portfolio clients meeting specific
criteria are also included in the first tier. The managed account clients and model portfolio clients included in
the first tier will trade (or receive model portfolios on which the recipient can choose to trade), in random
order.
Trade Rotation Tier 2: Natixis Advisors’ managed account clients that direct Natixis Advisors to utilize specified
Brokers are included in the second tier. Natixis Advisors does not require any client to direct brokerage;
however, some clients choose to do so and some programs sponsored by third-parties encourage or require it.
Clients in such programs should review their program’s contractual and disclosure documents to further
understand the impact of program brokerage arrangements. These clients are placed in the second tier because
their trading activities could disadvantage other managed account clients of Natixis Advisors that do not direct
the use of specified Brokers. Trading by managed account clients that direct Natixis Advisors to utilize specified
Brokers could, for example: (i) compete in the market with the other managed account clients’ orders; (ii)
interfere with the random trade rotation program utilized by Natixis Advisors for its other managed account
clients because of delays in dealing with such specified Brokers; and/or (iii) result in “information leakage”
regarding the model portfolio transactions.
As a result, and consistent with Natixis Advisors’ policies and procedures, on days on which Natixis Advisors
(or a model portfolio provider) executes trades both for managed account clients who direct the use of a
particular Broker and clients who do not, Natixis Advisors (or a model portfolio provider) will prioritize (i.e.,
place in the first tier) orders for managed account clients who do not direct brokerage. Where Natixis Advisors
does not retain brokerage discretion, the managed account client should also review the trade rotation policy of
the sponsor or other Broker to whom the trades are directed.
Clients who do not know whether the program in which they participate requires that they direct brokerage to
a particular firm should contact their financial adviser/program sponsor. For additional disclosure relating to
managed account program clients that direct Natixis Advisors to utilize specified Brokers, please see “Directed
Brokerage,” below.
Trade Rotation Tier 3: Natixis Advisors’ model portfolio sponsor programs are generally included in the third
tier, receiving investment recommendations and/or model portfolios following the conclusion of Natixis
Advisors’ first and second tiers of trade rotation. However, a model portfolio program sponsor will be included
in Natixis Advisors’ first tier trade rotation if: (i) the sponsor agrees to coordinate trading with Natixis Advisors;
(ii) the sponsor makes commercially reasonable efforts (as practicable) to initiate trading immediately, effecting
and completing trade activity promptly within commercially reasonable standards (with consideration to
materially relevant facts, including, but not limited to, trade characteristics, liquidity factors, and general market
conditions); and (iii) the sponsor promptly informs Natixis Advisors once it has completed trading.
Additionally, model portfolio program sponsors that permit Natixis Advisors (or the relevant model portfolio
provider) to provide trade execution services will also be included in the first tier.
Prioritization of Product/Style Trades: Natixis Advisors prioritizes trades resulting from investment
product/style changes over trades resulting from account-specific needs. Investment product/style
transactions are effected on a first in, first out basis (“FIFO”) by investment product or style, as generated by a
particular subadviser’s model portfolio, with the priority of order execution subsequently performed on a
random ordering basis among the particular platforms within an investment style. Trades are bunched by
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platform (but not typically across platforms). When an order for a given program sponsor’s client account are
partially completed, allocation is generally performed on an automated pro-rata basis, subject to fund availability
and process limitations. On the other hand, client/account-specific trades, such as those that result from the
initial investment or closing of an account, tax-loss selling, and cash additions or withdrawals, are performed
as soon as practicable.
Order allocation policies can be adjusted to accommodate block transactions that become available to one
group of accounts but not another, to adjust for other considerations (such as trading during non- exchange
hours), and due to account-specific circumstances (such as availability of funds, pending withdrawals, client
restrictions, minimization of odd lots, and other relevant circumstances).
Further, models comprised solely of mutual funds and ETFs can be disseminated to all participants
simultaneously if they do not, in Natixis Advisors’ discretion, require a trade rotation process. From time to
time, certain contractual obligations will limit Natixis Advisor’s ability to ensure that securities transactions are
executed in accordance with Natixis Advisor’s three-tier trade rotation procedure, preventing securities
transactions from being effected and model portfolios from being disseminated in a fair and equitable manner
with respect to some client relationships.
Directed Brokerage: Clients can instruct Natixis Advisors (or a model portfolio provider) to use one or more
Brokers for trading their accounts or, due to requirements of program sponsors, Natixis Advisors could be
obligated to use a particular sponsor or its affiliated persons to effect trades. Clients that direct brokerage can
specify that a particular amount of commissions should be sent to those Brokers, that all business should be
directed to those Brokers, or that those Brokers should be used when all other considerations are equal. Clients
can specify that a particular Broker is to be used even though Natixis Advisors (or a model portfolio provider)
could obtain a more favorable net price and execution from another Broker in particular transactions. Clients
who direct the use of a particular Broker for transactions or that participate in Bundled Programs/Unbundled
Programs that direct Natixis Advisors to utilize such sponsor or its affiliates should understand that such
direction will prevent Natixis Advisors (or a model portfolio provider) from effectively negotiating brokerage
commissions on their behalf and from aggregating orders with other clients.
Thus, in addition to being placed in the second tier of trade rotation (as described above), clients that direct
brokerage will not necessarily achieve best execution for transactions effected through the directed Broker and
could lose possible advantages, such as volume discounts.
Directing brokerage operates as a waiver of Natixis Advisors’ (or the relevant model portfolio providers’) duty
to seek best execution for a client’s transaction. Clients that direct brokerage should therefore consider whether
commission expenses, execution, clearance, and settlement capabilities of the directed Brokers are comparable
to those that Natixis Advisors (or a model portfolio provider) could otherwise attain if Natixis Advisors (or
the model portfolio provider) were able to freely select Brokers for their accounts in accordance with Natixis
Advisors’ duty to seek best execution. Similarly, the clients could also receive less favorable execution when they
direct the use of Brokers or participate in programs that are not eligible to participate in a portion of a new issue
or other opportunity that is allocated to Natixis Advisors (or a model portfolio provider). Clients that do not
know whether the program in which they participate requires that they direct brokerage to a particular firm
should contact their program sponsor.
Step-Out Trades: Natixis Advisors or a subadviser can use step-outs for clients to satisfy client requests to direct
a portion of trades to particular Brokers, or where doing so might allow a client to obtain better execution or
to obtain securities that cannot be traded through the directed Broker(s). Step-outs are performed for the
benefit of the client and in accordance with Natixis Advisors’ best execution policy.
Model Portfolio Provider Trade Execution: Natixis Advisors does not provide trade execution services for the
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program’s clients in connection with model portfolio services provided to a sponsor. Rather, the sponsor or
another discretionary investment adviser to the client account is responsible for placing trades based on the
models. However, if Natixis Advisors is asked to provide such trade execution services (i.e., Natixis Advisors
block trades the non-discretionary accounts with Natixis Advisors’ discretionary accounts), Natixis Advisors
could be limited by the same constraints set forth in the Bundled Program and Unbundled Program sections
above, as applicable, depending on whether the program in question is a Bundled Program or an Unbundled
Program.
Model portfolio providers are not precluded from purchasing or selling for, or recommending for purchase or
sale for, other client accounts any securities that are, have been, or could in the future be recommended for
sale or purchase in the model portfolios supplied to and relied upon by Natixis Advisors. Whether or not
executed in "bunched" contemporaneous trades with trades for clients, purchases, or sales of securities by
other clients of the model portfolio providers can have an adverse effect on the value, price, performance, or
availability of securities from time to time included in model portfolios. Model portfolio providers are not
precluded, by reason of such adverse effects or other possible adverse effects, from effecting such purchases
or sales for, or recommending such purchases or sales to, their other client accounts.
Model portfolio providers manage the accounts of other clients, many of which are large institutional accounts
which employ the same or similar investment styles and strategies the model portfolio providers uses in
constructing the model portfolios supplied to Natixis Advisors. Although the model portfolios and the
transactions effected in the Natixis Advisors client accounts could reflect the recommendations being made
to, or discretionary investment advisory decisions made for, other clients of the model portfolio providers, the
model portfolio providers need not purchase or sell for any particular other client account any particular
securities included from time to time in the model portfolios. Further, a model portfolio provider need not
include in its portfolios any particular security it is buying or selling for, or recommending be bought or sold
for, any particular other client account of such model portfolio provider. Significant deviations can develop
among the holdings and performance of Natixis Advisors client accounts using model portfolios and model
portfolios themselves and the client accounts of other clients of the model portfolio providers.
This can occur for the reasons discussed above as well as due to differences in account size, cash flow, timing,
and terms of execution of trades by Natixis Advisors and the relevant model portfolio provider, individual client
needs, differences between ADRs and the underlying foreign equity securities, differences between a mutual
fund or exchange traded fund and the direct securities holdings of the model portfolio provider’s managed
account clients in the same strategy, and other factors.
Natixis Advisors (or the relevant model portfolio provider) could manage numerous accounts with similar or
identical investment objectives or accounts with different objectives that trade in the same securities. Despite
such similarities, portfolio decisions relating to clients' investments and the performance resulting from such
decisions will differ from client to client. Natixis Advisors (or the relevant model portfolio provider) will not
necessarily purchase or sell the same securities at the same time or in the same proportionate amounts for all
eligible clients. Further, in many instances, such as purchases of private placements or oversubscribed public
offerings, it might not be possible or feasible to allocate a transaction pro rata to all eligible clients. Therefore,
not all clients will necessarily participate in the same investment opportunities on the same basis.
In allocating investments among various clients (including in what sequence orders for trades are placed),
Natixis Advisors will use its best business judgment and take into account the funds available to each client,
the amount already committed by each client to a specific investment, and the relative risks of the investment.
Natixis Advisors' policy is to allocate to the extent practicable investment opportunities on a basis that Natixis
Advisors in good faith believes is fair and equitable to each client over time. Each model portfolio provider’s
trading policies are disclosed in that model portfolio provider’s Form ADV Part 2A.
27
Item 13 – Review of Accounts
Investment Company Review of Accounts: Natixis Advisors monitors the portfolio management functions
provided by the Fund subadvisers, including securities trading, brokerage practices, and compliance controls of
the subadvisers. Natixis Advisors monitors fund performance and operations daily by Fund and compliance
controls daily where applicable, assessing Fund compliance controls on a regular basis depending on the
control, but no less frequently than annually. Natixis Advisors also monitors portfolio management activities,
securities trading, brokerage practices and compliance controls of Solutions with respect to the portion of the
Natixis Target Retirement Funds managed by Solutions. Additionally, Natixis Advisors’ senior officers,
including the Funds’ Chief Compliance Officer and other legal and compliance staff, monitor the investment
performance, compliance controls, and operations of the Natixis Funds and Natixis ETFs to ensure that the
subadvisers and/or Natixis Advisors, as applicable, carry out advisory functions in accordance with contractual
arrangements and relevant securities and tax laws and regulations.
Investment Company and Shareholder Reporting: The Board of Trustees of the Natixis Funds and Natixis ETFs
receives quarterly reports on the performance and operations of the funds for which Natixis Advisors serves
as investment adviser. The Funds provide investors, directly or via intermediaries, written prospectuses
describing, among other things: the investment adviser; the fund’s objective, investment methods, purchase
and redemption of shares, risk level, and fees and expenses; and annual and semi-annual reports regarding the
fund’s portfolio, performance, and investment goals and policies. Furthermore, for their direct shareholders,
the Funds could also provide a variety of other services and deliverables that are designed to meet shareholder
needs, such as toll-free telephone access, consolidated account statements, tax information, automatic
investments and withdrawals, and check writing privileges. Finally, for their direct shareholders, the Funds also
provide extensive investor education and shareholder communications, including, but not limited to, websites,
newsletters, brochures, and retirement and other planning guides.
Managed Account Review of Accounts: Managed accounts, excluding accounts for which Natixis Advisors has
been hired to provide model portfolio provider services, are under the continuing supervision of Natixis
Advisors, through the use of systems reasonably designed to ensure that each account, subject to its investment
objectives, guidelines, and restrictions, is managed consistently with its investment mandate. Additionally,
Natixis Advisors’ compliance department, including its Chief Compliance Officer and other senior operational
and portfolio management personnel, perform a periodic review of a sample of accounts for consistency with
Natixis Advisors’ policies, brokerage instructions, legal requirements, or similar matters. On a quarterly basis,
Natixis Advisors performs a general review of performance for strategies where it has a responsibility for
manager selection. The review evaluates differences in return for the period between Natixis Advisors account
composites, their corresponding models, and model providers’ institutional performance composites.
Dispersion between accounts in the Natixis Advisors composites is evaluated as well. Position drift between
accounts and their corresponding models is monitored on a daily basis through the portfolio management
system utilized by Natixis Advisors. If the system identifies drift that exceeds pre- established tolerance levels,
trades will be executed to more closely align accounts with model targets. Natixis Advisors seeks to replicate
the process that each model provider uses to monitor account drift, and accordingly will use different drift
tolerances and rebalancing processes for different models. The performance comparison review process is
conducted under the supervision of internal committees of Natixis Advisors. Natixis Advisors also continuously
monitors client accounts utilizing model portfolios to ensure the degree of deviation in the holdings of client
accounts as compared to the related model portfolios does not exceed a predetermined maximum tolerance
trigger. If a client account exceeds a predetermined maximum tolerance trigger, Natixis Advisors will make
adjustments to such account’s holdings to align the holdings with the related model portfolio(s). Performance
reviews of client accounts are conducted in a similar manner, but under the supervision of Solutions specific
internal senior personnel.
Natixis Advisors has no specific policy with respect to the number of accounts assigned to each reviewer, which
depends on the nature and complexity of the accounts being reviewed. Natixis Advisors' Due Diligence
28
Committee also monitors the investment advisory services of the model portfolio providers that provide model
portfolios to Natixis Advisors for Natixis Advisors’ use in sponsored programs. However, Natixis Advisors
does not conduct due diligence on model portfolio providers selected and overseen exclusively by sponsors.
Appendix 2 lists the model portfolio providers (affiliated and unaffiliated) for which Natixis Advisors has due
diligence responsibility.
Client Reporting: Program sponsors are responsible for client reporting unless otherwise contractually agreed.
Natixis Advisors will supply the sponsor with certain information necessary to provide regular reports directly
to clients. Upon request or as contractually agreed, and as applicable for Unbundled Program clients, Natixis
Advisors provides investment holdings, transactions, and performance reports directly to clients on a periodic
basis. When Natixis Advisors acts as a model portfolio provider, it is the responsibility of the program sponsor
to provide reporting to its clients.
Item 14 – Client Referrals and Other Compensation
Natixis Advisors can compensate unaffiliated third parties that solicit clients whom the third party believes
would benefit from Natixis Advisor’s investment advisory services. Any arrangements whereby Natixis
Advisors compensates a third party for client referrals will be pursuant to a solicitation agreement compliant with
Rule 206(4)-1 under the Advisers Act.
Natixis Advisors can, in its discretion and out of its own assets, compensate third parties, including, but not
limited to, arrangements involving mutual fund networks or no transaction fee programs, for the sale and
marketing of shares of affiliated investment companies. These arrangements, often called “revenue sharing,”
create an incentive for a Broker or other intermediary to favor Natixis Advisors’ sponsored investment
companies over other available investments in making investment decisions for or recommendations to their
clients.
Natixis Advisors’ sales and relationship management staff can be compensated for the introduction of new
business to Natixis Advisors based upon a percentage of revenues received by the firm from the new account
for up to five years, or a percentage of the revenue generated from new client assets attributable to an individual’s
efforts. This compensation is payable from Natixis Advisors’ advisory fees and not directly by the client. The
receipt of compensation for the promotion of Natixis Advisors’ products presents a conflict of interest and
gives supervised persons an incentive to market investment products based upon the compensation received,
rather than a client’s needs. Natixis Advisors addresses these conflicts of interest by a supervisory structure that
reviews the suitability of each investment product for a prospective client when suitability responsibility falls
on Natixis Advisors.
For investment company products, a client purchases certain Natixis Advisors’ fund products through an
unaffiliated entity, although the cost to the client will likely be greater than if the product were purchased directly
through Natixis Advisors. For managed account strategies, a client purchases the investment advisory services
of Natixis Advisors through an unaffiliated entity, although the cost to the client will likely be greater than if
Natixis Advisors’ investment advisory services for a particular strategy were purchased directly through Natixis
Advisors.
Natixis Advisors may enter into a referral service agreement whereby, from time to time, a non-affiliated third
party will provide consulting, sales support, and referral services to Natixis Advisors. Natixis Advisors will
compensate the third party in the form of a percentage of asset-based advisory fees with respect to each person
or entity that becomes a Natixis Advisors client pursuant to a written agreement, as permitted by law and per
Rule 206(4)-1 of the Advisers Act. This arrangement is paid entirely out of Natixis Advisors’ resources and will
not result in higher costs to the referred client. Any such arrangements will comply with Rule 206(4)-1.
29
Item 15 – Custody
Natixis Advisors does not take custody of or have authority to obtain possession of client assets. However, due
to certain arrangements, Natixis Advisors will be deemed to have custody of client accounts within the meaning
of Rule 206(4)-2 under the Advisers Act when Natixis Advisors or one of its related persons have access to or
authority over the funds or securities of a managed account client for purposes other than issuing trading
instructions. For example, Natixis Advisors could have authority to cause a custodian to transfer cash from a
client account in payment of Natixis Advisors’ advisory fees. To the extent that Natixis Advisors is deemed to
have custody over a client’s account, the client’s qualified custodian will send periodic account statements
(generally on a quarterly basis) indicating the amounts of any funds or securities in the account as of the end of
the statement period and any transactions in the account during the statement period.
Clients should review these statements carefully and contact Natixis Advisors immediately if account statements
are not being provided by the custodian on at least a quarterly basis. As previously noted, Natixis Advisors
provides certain reports and information regarding client accounts to clients in Unbundled Programs (and can
provide reporting to other clients) separate and apart from the account statements provided by the custodian.
Clients receiving reports directly from Natixis Advisors are urged to compare carefully reports received from
Natixis Advisors to the account statements from the custodian. Clients who believe there may be a discrepancy
between the custodial statements and any reports received from Natixis Advisors should contact Natixis
Advisors immediately.
Item 16 – Investment Discretion
As discussed in Item 4, Natixis Advisors exercises investment discretion over certain client accounts. All clients
establishing discretionary accounts are required to execute an investment advisory services agreement, either
directly with Natixis Advisors or with one of the sponsors that hires Natixis Advisors to provide discretionary
investment advisory services to client accounts. The investment advisory services agreement grants Natixis
Advisors authority to act as a discretionary investment manager, including the authority to execute trades.
Natixis Advisors will accept reasonable limitations on its authority through client guideline restrictions,
provided that the restrictions are essentially consistent with Natixis Advisors’ investment process.
For Bundled Program relationships, Natixis Advisors acts as a discretionary investment adviser and selects a
non-discretionary model portfolio. Therefore, only Natixis Advisors has discretionary authority over these
client accounts. For Unbundled Program relationships, Natixis Advisors acts as a discretionary investment
adviser and selects a non-discretionary model portfolio provider. Only Natixis Advisors has discretionary
authority over these client accounts.
For Model Portfolio services, Neither Natixis Advisors nor the model portfolio provider has discretionary
authority over sponsor program accounts.
Item 17 – Voting Client Securities/Proxy Voting Summary
Natixis Advisors’ authority to vote client proxies is established by Natixis Advisors’ investment advisory
agreements or comparable documents. Natixis Advisors has a fiduciary responsibility to exercise proxy voting
authority when granted such authority. As such, when authorized to vote proxies, Natixis Advisors endeavors
to do so in accordance with the best economic interest of its clients and similarly to resolve any conflicts of
interest exclusively in the best economic interest of the clients.
In order to mitigate conflicts of interest, Natixis Advisors has contracted with Broadridge/Glass Lewis (“Glass
Lewis”), an independent third party service provider, to vote Natixis Advisors’ client proxies. Glass Lewis
maintains records, provides reports, develops models and research, and votes proxies in accordance with
instructions and guidelines provided or approved by Natixis Advisors. These instructions and guidelines shall
be consistent with the Proxy Voting Policy of Natixis Advisors, which votes “for” proposals that, in the
30
judgment of Natixis Advisors, would serve to enhance shareholder value, and votes “against” proposals that,
in the judgment of Natixis Advisors, would impair shareholder value. Glass Lewis directs Broadridge to vote
“for” or “against” specific types of routine proposals, while reserving other non-routine proposals for Natixis
Advisors to decide on a case-by-case basis. With respect to proposals decided by Natixis Advisors, a designated
member of the portfolio management team of Natixis Advisors has the responsibility to determine how the
proxies should be voted and to direct the proxy voting agent, through other operational personnel of Natixis
Advisors, to vote accordingly. In certain circumstances, Natixis Advisors may vote physical ballots sent directly
to Natixis Advisors.
Natixis Advisors reviews its proxy voting policy on a periodic basis. Additionally, on a periodic basis, Natixis
Advisors reviews reports produced by Broadridge that summarize voting activity. Furthermore, an internal
team of Natixis Advisors, which is composed of legal, compliance, portfolio management, and operational
personnel, also conducts periodic reviews of proxy voting activity and issues, if any, that could arise. Finally,
compliance conducts a random sampling review of proxy ballots to ascertain whether votes were cast in
compliance with Natixis Advisors’ proxy voting policy. Upon request, Natixis Advisors will provide clients with
a full and complete copy of the Natixis Advisors proxy voting policy and a record of how their securities were
voted. To obtain a copy of the proxy voting policy or a record of how securities were voted, a client may contact
Natixis Advisors via phone at 888-773-2454, or by email at ADVOPS@natixis.com.
Item 18 – Financial Information
Not Applicable.
31
Appendix 1
Investment Company Strategy List & Strategy Description
Investment Strategy
Subadviser
Strategy Description
Under normal market conditions, the Fund will invest primarily in common stocks and other equity securities. Equity
securities may include, for example, other exchange-traded funds (“ETFs”), notes, preferred stocks, and real estate
investment trusts (“REITs”). The Fund focuses on stocks of large-capitalization companies, but the Fund may invest
in companies of any size. The Fund normally invests across a wide range of sectors and industries. The Fund is non-
diversified, which means that it may invest a greater percentage of its assets in a particular issuer and may invest in
fewer issuers than a diversified fund. The Fund’s portfolio will hold approximately 20 to 30 securities.
Loomis, Sayles & Co., L.P.
(“Loomis")
Natixis Loomis Sayles
Focused Growth ETF
Strategy
The Fund’s portfolio manager employs a growth style of equity management that emphasizes companies with
sustainable competitive advantages versus others, long-term structural growth drivers that will lead to above-average
future cash flow growth, attractive cash flow returns on invested capital, and management teams focused on creating
long-term value for shareholders. The Fund’s portfolio manager aims to invest in companies when they trade at a
significant discount to the estimate of intrinsic value (i.e., companies with share prices trading significantly below what
the portfolio manager believes the share price should be based on proprietary discount cash flow models). The Fund
will consider selling a portfolio investment when the portfolio manager believes an unfavorable structural change
occurs within a given business or the markets in which it operates, a critical underlying investment assumption is
flawed, when a more attractive reward-to-risk opportunity becomes available, when the portfolio manager believes the
current price fully reflects intrinsic value, or for other investment reasons which the portfolio manager deems
appropriate. Although certain equity securities purchased by the Fund may be issued by domestic companies
incorporated outside of the United States, Loomis, Sayles & Company, L.P. (“Loomis Sayles” or the “Subadviser”)
does not consider these securities to be foreign securities if they are included in the U.S. equity indices published by
S&P Global Ratings or Russell Investments or if the security’s country of risk defined by Bloomberg is the United
States.
Appendix 132
Strategy Description
Investment Strategy
Subadviser
The Fund is an actively-managed exchange-traded fund (“ETF”) that seeks to achieve its investment objective by
investing in high-quality stocks and written index call option exposure. The Fund may use listed index options or equity-
linked notes to achieve the written index call option exposure.
Equity Portfolio
Under normal circumstances, the Fund invests in a diversified portfolio of U.S. large- and mid-capitalization stocks with
quality characteristics identified through certain fundamental metrics determined by Gateway Investment Advisers, LLC
(the “Subadviser”). Generally, the Subadviser believes that a high quality company is a company that has an established
business with high relative profitability characteristics and low leverage. For these purposes, large capitalization
companies are those that, at the time of purchase, generally have market capitalizations of at least $10 billion and mid-
capitalization companies are those that, at the time of purchase, generally have market capitalizations of between $2
billion and $10 billion.
The Subadviser uses a multifactor quantitative model to construct and manage the stock portfolio. The model evaluates
U.S.-exchange-traded equities that meet criteria and constraints established by the Subadviser. A quality score is assigned
to each security in the investment universe based on systematic factors including profitability and leverage. The strategy
seeks to maximize exposure to the weighted quality score, while considering active exposures to individual names, sectors,
and the market as a whole. The equity portfolio generally consists of approximately 75-150 securities. Equity securities
purchased by the Fund may include U.S. exchange-listed common stocks, preferred stocks, American Depository
Receipts and investment companies (including ETFs). The holdings may be rebalanced as frequently as desired by the
Subadviser to maintain the overall desired exposure to the quality factor.
Equity-linked notes (“ELNs”)
Gateway Investment
Advisers, LLC (“Gateway”)
Natixis Gateway Quality
Income ETF Strategy
In order to generate income, the Fund may invest in ELNs. ELNs are investment products that are structured as notes.
They are issued by financial institutions such as banks and broker-dealers or entities organized by financial institutions
to issue the ELNs. An ELN is designed to offer a return linked to specific economic characteristics identified in the note.
The Fund will generally invest in ELNs that are issued in a privately negotiated transaction, including securities offered
and sold under Rule 144A of the Securities Act of 1933 (the “Securities Act”).
The ELNs in which the Fund invests are derivative instruments. They are designed to replicate a covered call writing
strategy by combining into a single note the economic characteristics of (i) an investment in a broad market index and
(ii) index covered call writing (“Underlying Characteristics”). The ELNs are expected to provide recurring cash flow to
the Fund through this replication. They are expected to be an important source of the Fund’s return.
Investing in ELNs may reduce the Fund’s volatility. On one hand, the income from the ELNs would reduce potential
losses incurred by the Fund’s equity portfolio. However, by replicating a covered call strategy in each ELN, the ELNs
may also reduce the Fund’s ability to fully profit from potential increases in the value of its equity portfolio.
Generally, when purchasing an ELN, the Fund pays the counterparty an amount based on the Underlying Characteristics
plus the cost to structure the ELN. Upon maturity of the ELN, the Fund generally receives the par value of the ELN,
plus interest, plus or minus a return based on the return of the Underlying Characteristics. However, each ELN will be
structured so that it cannot lose more than the principal that the Fund paid when purchasing the ELN.
Other Investments
The Fund may invest in convertible securities, partnerships, when issued/delayed delivery securities and initial public
offerings (“IPOs”). The Fund may also hold cash and cash equivalents.
Appendix 133
Investment Strategy
Subadviser
Strategy Description
Under normal market conditions, the Fund primarily invests in common stocks of U.S. companies. The Fund generally
invests in securities of larger capitalization companies in any industry. Harris Associates L.P., (“Harris”) uses a value
investment philosophy in selecting equity securities, including common stocks. This value investment philosophy is based
upon the belief that, over time, a company’s stock price converges with the company’s intrinsic value. By “intrinsic value,”
Harris means its estimate of the price a knowledgeable buyer would pay to acquire the entire business. Harris believes
that investing in securities priced significantly below what Harris believes is a company’s intrinsic value presents the best
opportunity to achieve the Fund’s investment objectives.
Natixis Oakmark Strategy
Harris Associates, L.P.
(“Harris”)
Harris uses this value investment philosophy to identify companies that it believes have discounted stock prices compared
to what Harris believes are the companies’ intrinsic values. In assessing such companies, Harris looks for the following
characteristics, although not all of the companies selected will have these attributes: (1) free cash flows and intelligent
investment of excess cash; (2) earnings that are growing and are reasonably predictable; and (3) high level of company
management alignment with shareholders.
Once Harris identifies a stock that it believes is selling at a significant discount to Harris’ estimate of intrinsic value and
that the issuer has one or more of the additional qualities mentioned above, Harris generally will consider buying that
security for the Fund. Harris usually sells a security when the price approaches its estimated value or the issuer’s
fundamentals change. Harris monitors each holding and adjusts its price targets as warranted to reflect changes in the
issuer’s fundamentals. The Fund’s portfolio typically holds 30 to 60 stocks.
The Fund invests primarily in a diversified portfolio of common stocks of non-U.S. companies. The Fund may invest in
non-U.S. markets throughout the world, including emerging markets. Ordinarily, the Fund will invest in the securities of
at least five countries outside the U.S. There are no geographic limits on the Fund’s non-U.S. investments. Although the
Fund invests primarily in common stocks of non-U.S. companies it may also invest in the securities of U.S. companies.
The Fund may invest in the securities of small-, mid- and large-capitalization companies.
The Fund’s subadviser, Harris Associates L.P. (“Harris”), uses a value investment philosophy in selecting equity securities,
such as common stocks, preferred stocks, warrants, and securities convertible into common stocks and preferred stocks.
This value investment philosophy is based upon the belief that, over time, a company’s stock price converges with Harris’
estimate of its intrinsic value. By “intrinsic value,” Harris means its estimate of the price a knowledgeable buyer would
pay to acquire the entire business. Harris believes that investing in securities priced significantly below what Harris
believes is a company’s intrinsic value presents the best opportunity to achieve the Fund’s investment objective.
Harris
Natixis Oakmark
International Strategy
Harris uses this value investment philosophy to identify companies that have discounted stock prices compared to what
Harris believes are the companies’ intrinsic values. In assessing such companies, Harris looks for the following
characteristics, although not all of the companies selected will have these attributes: (1) free cash flows and intelligent
investment of excess cash; (2) earnings that are growing and are reasonably predictable; and (3) high level of company
management alignment with shareholders.
Once Harris identifies a stock that it believes is selling at a significant discount to Harris’ estimated intrinsic value and
that the issuer has one or more of the additional qualities mentioned above, Harris generally will consider buying that
security for the Fund. Harris usually sells a security when the price approaches its estimated value or the issuer’s
fundamentals change. Harris monitors each holding and adjusts its price targets as warranted to reflect changes in the
issuer’s fundamentals. The Fund’s portfolio typically holds 30 to 65 stocks.
Appendix 134
Investment Strategy
Subadviser
Strategy Description
Under normal circumstances, the Fund will invest at least 80% of its net assets (plus any borrowings made for
investment purposes) in equity securities. Equity securities may include common stocks and preferred stocks. Under
normal circumstances, the Fund will invest at least 80% of its net assets (plus any borrowings made for investment
purposes) in securities of U.S. issuers. The Fund’s approach to equity investing combines the styles of two subadvisers
in selecting securities for each of the Fund’s segments. The segments and their subadvisers are listed below.
• Harris Associates - Large Cap Value segment - Under normal circumstances, the Large Cap Value segment of the
Fund managed by Harris Associates L.P. (“Harris Associates”) will invest primarily in the common stocks of larger-
capitalization companies that Harris Associates believes are trading at a substantial discount to the company’s “intrinsic
value.” By “intrinsic value,” Harris Associates means its estimate of the price a knowledgeable buyer would pay to
acquire the entire business. Harris Associates believes that investing in securities priced significantly below what Harris
Associates believes is a company’s intrinsic value presents the best opportunity to achieve the Fund’s investment
objectives. Harris Associates usually sells a security when the price approaches its estimated value and monitors each
holding and adjusts its price targets as warranted to reflect changes in the issuer’s fundamentals. In determining
whether an issuer is a U.S. or foreign issuer for the Harris Associates – Large Cap Value segment, Harris Associates
considers various factors, including its country of domicile, the primary stock exchange on which it trades, the location
from which the majority of its revenue comes, and its reporting currency.
Multi-Manager
Natixis U.S. Equity
Opportunities Strategy
• Loomis Sayles - All Cap Growth segment - Under normal circumstances, the All Cap Growth segment of the Fund,
managed by Loomis, Sayles & Company, L.P. (“Loomis Sayles”), will invest primarily in equity securities, including
common stocks and depositary receipts. This segment may invest in companies of any size. The segment normally
invests across a wide range of sectors and industries. The segment’s portfolio manager employs a growth style of equity
management that emphasizes companies with sustainable competitive advantages versus others, long-term structural
growth drivers that will lead to above-average future cash flow growth, attractive cash flow returns on invested capital,
and management teams focused on creating long-term value for shareholders. The segment’s portfolio manager aims to
invest in companies when they trade at a significant discount to the estimate of intrinsic value (i.e., companies with
share prices trading significantly below what the portfolio manager believes the share price should be). The segment
will consider selling a portfolio investment when the portfolio manager believes an unfavorable structural change
occurs within a given business or the markets in which it operates, a critical underlying investment assumption is
flawed, when a more attractive reward-to-risk opportunity becomes available, when the portfolio manager believes the
current price fully reflects intrinsic value, or for other investment reasons which the portfolio manager deems
appropriate. Although certain equity securities purchased by the Loomis Sayles – All Cap Growth segment of the Fund
may be issued by domestic companies incorporated outside of the United States, Loomis Sayles does not consider
these securities to be foreign if they are included in the U.S. equity indices published by S&P Global Ratings or Russell
Investments or if the security’s country of risk defined by Bloomberg is the United States.
Subject to the allocation policy adopted by the Fund’s Board of Trustees, Natixis Advisors, LLC (“Natixis Advisors”)
generally allocates capital invested in the Fund equally (i.e., 50%) between its two segments. Under the allocation
policy, Natixis Advisors may also allocate capital away from or towards each segment from time to time and may
reallocate capital between the segments. Each subadviser manages its segment of the Fund’s assets in accordance with
its distinct investment style and strategy.
The Fund may also:
• Invest in securities offered in initial public offerings (“IPOs”) and securities issued pursuant to Rule 144A under the
Securities Act of 1933 (“Rule 144A securities”).
• Invest in convertible preferred stock and convertible debt securities.
• Invest in real estate investment trusts (“REITs”).
• Invest in fixed-income securities, including U.S. government bonds and below-investment grade fixed-income
securities (commonly known as “junk bonds”).
• Hold securities of foreign issuers traded over-the-counter or on foreign exchanges, including securities in emerging
markets and related currency hedging transactions.
• Invest in equity securities of Canadian issuers.
Appendix 135
Investment Strategy
Subadviser
Strategy Description
The Fund, under normal market conditions, will invest primarily in equity securities, including common stocks, preferred
stocks, limited partnership interests, interests in limited liability companies, real estate investment trusts (“REITs”) or
other trusts and similar securities. The Fund is non-diversified, which means that it may invest a greater percentage of its
assets in a particular issuer and may invest in fewer issuers than a diversified fund. Typically, the Fund’s portfolio will
hold 20 to 40 securities. The Fund may invest in companies with any market capitalization, although, it will typically focus
its investments in mid to large-capitalization companies. When opportunities present themselves, the Fund may establish
short positions in specific equity securities or indices. While the Fund typically invests in equity securities, it may also
invest in debt securities, including below investment-grade fixed-income securities (commonly known as “junk bonds”).
A fixed-income security is considered below investment- grade quality when none of the three major rating agencies
(Moody’s Investors Service, Inc., Fitch Investor Services, Inc. or S&P Global Ratings) have rated the securities in one of
their top four ratings categories.
Vaughan Nelson Investment Management, L.P. (“VNIM”) invests in companies of all market capitalizations with a focus
on those companies meeting VNIM’s return expectations.
VNIM uses a bottom-up value oriented investment process in constructing the Fund’s portfolio. VNIM seeks companies
with the following characteristics, although not all of the companies selected will have these attributes:
VNIM Select Strategy
• Companies earning a positive return on capital with stable-to-improving returns.
• Companies valued at discount to their asset value.
• Companies with an attractive and sustainable dividend level.
Vaughan Nelson
Investment
Management, L.P.
(“VNIM”)
In selecting investments for the Fund, Vaughan Nelson generally employs the following strategies:
• VNIM employs a value-driven investment philosophy that selects securities selling at a relatively low value based on
discounted cash flow models. VNIM selects companies that it believes are out-of-favor or misunderstood.
• VNIM starts with the entire U.S. exchange-traded equity investment universe. VNIM then narrows the investment
universe by using fundamental analysis to construct a portfolio of 20 to 40 securities.
• VNIM uses fundamental analysis to construct a portfolio that, in the opinion of VNIM, is made up of quality companies
with the potential to provide significant increases in share price over a three year period.
• VNIM will also employ its value driven investment philosophy to identify out-of-favor or misunderstood debt securities.
• VNIM will generally sell a security when it reaches VNIM’s price target or when the issuer shows a change in financial
condition, competitive pressures, poor management decisions or internal or external forces reducing future expected
returns from the investment thesis.
The Fund also may:
• Invest in convertible preferred stock and convertible debt securities.
• Invest in publicly traded master limited partnerships.
• Invest in foreign securities, including emerging market securities, traded in U.S. markets directly or through depositary
receipt programs such as American Depositary Receipts (“ADRs”) and Global Depositary Receipts (“GDRs”).
• Invest in REITs.
• Invest in securities offered in initial public offerings (“IPOs”) and securities issued pursuant to Rule 144A under the
Securities Act of 1933 (“Rule 114A securities”).
Appendix 136
Investment Strategy
Subadviser
Strategy Description
Under normal circumstances, the Fund will invest at least 80% of its net assets (plus any borrowings made for investment
purposes) in the equity securities, including common stocks and preferred stocks, of “small-capitalization companies.”
Equity securities may take the form of stock in corporations, limited partnership interests, interests in limited liability
companies, real estate investment trusts (“REITs”) or other trusts and other similar securities representing direct or
indirect ownership interests in business organizations. Currently, the Fund defines a small-capitalization company to be
one whose market capitalization, at the time of purchase, either falls within the capitalization range of the Russell 2000®
Value Index or is $3.5 billion or less. While the market capitalization range for the Russell 2000® Value Index fluctuates,
at December 31, 2023, it was $16.95 million to $10.58 billion. The Fund may, however, invest in companies with large
capitalizations.
Vaughan Nelson Investment Management, L.P. (“VNIM”) invests in small-capitalization companies with a focus on
those companies meeting VNIM’s return expectations. VNIM uses a bottom-up value oriented investment process in
constructing the Fund’s portfolio. VNIM seeks companies with the following characteristics, although not all of the
companies selected will have these attributes:
• Companies earning a positive return on capital with stable-to-improving returns.
• Companies valued at a discount to their asset value.
• Companies with an attractive and sustainable dividend level.
VNIM
VNIM Small Cap
Strategy
In selecting investments for the Fund, VNIM generally employs the following strategies:
• Value-driven investment philosophy that selects stocks selling at a relatively low value based on discounted cash flow
models. VNIM selects companies that it believes are out of favor or misunderstood.
• VNIM starts with an investment universe of 5,000 securities. VNIM then uses value-driven screens to create a research
universe of companies with market capitalizations of at least $100 million.
• VNIM uses fundamental analysis to construct a portfolio of 60 to 80 securities that, in the opinion of VNIM, is made
up of quality companies with the potential to provide significant increases in share price over a three year period.
VNIM will generally sell a security when it reaches VNIM s price target or when the issuer shows a change in financial
condition, competitive pressures, poor management decisions or internal or external forces reducing future expected
returns from those expected at the time of investment.
The Fund may also:
• Invest in convertible preferred stock and convertible debt securities.
• Invest in foreign securities, including emerging market securities.
• Invest in REITs.
• Invest in securities offered in initial public offerings (“IPOs”).
Appendix 137
Strategy Description
Investment Strategy
Subadviser
Under normal circumstances, the Fund will invest at least 80% of its net assets (plus any borrowings made for investment
purposes) in companies that, at the time of purchase, have market capitalizations within the capitalization range of the
Russell Midcap® Value Index, an unmanaged index that measures the performance of companies with lower price-to-
book ratios and lower forecasted growth values within the broader Russell Midcap® Index. While the market
capitalization range for the Russell Midcap® Value Index fluctuates, at December 31, 2023, it was $270.1 million to $73.3
billion. However, the Fund may invest in companies with smaller or larger capitalizations. Equity securities may take the
form of stock in corporations, limited partnership interests, interests in limited liability companies, real estate investment
trusts (“REITs”) or other trusts and similar securities representing direct or indirect ownership interests in business
organizations.
Vaughan Nelson Investment Management, L.P. (“VNIM”) invests in medium-capitalization companies with a focus on
those companies meeting VNIM’s return expectations. VNIM uses a bottom-up value oriented investment process in
constructing the Fund’s portfolio. VNIM seeks companies with the following characteristics, although not all of the
companies selected will have these attributes:
• Companies earning a positive return on capital with stable-to-improving returns.
• Companies valued at a discount to their asset value.
• Companies with an attractive and sustainable dividend level.
VNIM Mid Cap Strategy
VNIM
In selecting investments for the Fund, VNIM generally employs the following strategies:
• VNIM employs a value-driven investment philosophy that selects stocks selling at a relatively low value based on
business fundamentals, economic margin analysis and discounted cash flow models VNIM selects companies that it
believes are out of favor or misunderstood.
• VNIM uses fundamental analysis to construct a portfolio that, in the opinion of VNIM, is made up of quality companies
with the potential to provide significant increases in share price over a three year period.
• VNIM will generally sell a security when it reaches VNIM’s price target or when the issuer shows a change in financial
condition, competitive pressures, poor management decisions or internal or external forces reducing future expected
returns from those expected at the time of investment.
The Fund may also:
• Invest in foreign securities, including emerging markets securities.
• Invest in other investment companies, to the extent permitted by the Investment Company Act of 1940.
• Invest in REITs.
• Invest in securities offered in initial public offerings (“IPOs”) and securities issued pursuant to Rule 144A under the
Securities Act of 1933 (“Rule 144A securities”).
Appendix 138
Appendix 2
Managed Account Strategy List & Strategy Description
Investment Strategy
Strategy Description
Model Portfolio
Provider
AIA All Cap Growth Strategy
Solutions
This strategy seeks to gain broad market exposure to all capitalization growth segments of the U.S. equity market. This strategy
invests in a subset of securities from within an all capitalization growth universe.
AIA All Cap Value Strategy
Solutions
This strategy seeks to gain broad market exposure to all capitalization value segments of the U.S. equity market. This strategy
invests in a subset of securities from within an all capitalization value universe.
AIA All Cap 3000 Strategy
Solutions
This strategy seeks to gain broad market exposure to all capitalization segments of the U.S. equity market. This strategy invests
in a subset of securities from within an all capitalization universe.
AIA Developed ex-US Strategy
Solutions
This strategy seeks to gain broad exposure to developed market countries excluding the U.S. with a portfolio diversified ADR
using optimization. For taxable accounts, it additionally seeks to outperform on an after-tax basis through tax management.
AIA Large Cap Value Strategy
Solutions
This strategy seeks to gain broad market exposure to the large capitalization value segment of the U.S. equity market by
investing in a subset of securities from within a large capitalization value universe.
AIA Large Cap Growth Strategy
Solutions
This strategy seeks to gain broad market exposure to the large capitalization growth segment of the U.S. equity market by
investing in a subset of securities from within a large capitalization growth universe.
AIA Managed ETF Portfolio Conservative Strategy
Solutions
This strategy seeks to provide broad diversification, through investment in exchange-traded funds, across various asset classes
that may include, but are not limited to domestic and international equities, fixed income, real estate investment trusts (“REITs”)
and commodities while maintaining a conservative risk profile.
AIA Managed ETF Portfolio Moderate Strategy
Solutions
This strategy seeks to provide broad diversification, through investment in exchange-traded funds, across various asset classes
that may include, but are not limited to domestic and international equities, fixed income, REITs and commodities while
maintaining a moderate risk profile.
AIA Managed ETF Portfolio Aggressive Strategy
Solutions
This strategy seeks to provide broad diversification, through investment in exchange-traded funds, across various asset classes
that may include, but are not limited to domestic and international equities, fixed income, REITs and commodities while
maintaining a more aggressive risk profile.
AIA Managed ETF Portfolio All Equity Strategy
Solutions
This strategy seeks to provide broad diversification, through investment in exchange-traded funds, across various equity asset
classes that may include, but are not limited to domestic large, mid, small, and micro-cap equities, international developed
equities, and international emerging market equities.
AIA Managed ETF Portfolio Income Aggressive Strategy
Solutions
This strategy seeks, through investment in exchange-traded funds, higher yield consistent with broad diversification across
various asset classes while maintaining a more aggressive risk profile.
AIA Managed ETF Portfolio Income Conservative Strategy
Solutions
This strategy seeks, through investment in exchange-traded funds, higher yield consistent with broad diversification across
various asset classes while maintaining a conservative risk profile.
AIA Mid & Large Cap 1000 Strategy
Solutions
This strategy seeks to gain broad market exposure to the large and mid capitalization segments of the U.S. equity market by
investing in a subset of securities from within a large and mid-capitalization universe.
AIA Mid & Large Cap 1000 Growth Strategy
Solutions
This strategy seeks to gain broad market exposure to the large and mid capitalization segments of the U.S. equity market by
investing in a subset of securities from within a large and mid-capitalization growth universe.
Appendix 239
Strategy Description
Investment Strategy
Model
Portfolio
Provider
AIA Mid & Large Cap 1000 Value Strategy
Solutions
This strategy seeks to gain broad market exposure to the large and mid capitalization segments of the U.S. equity market by
investing in a subset of securities from within a large and mid-capitalization value universe.
AIA S&P 1000® Strategy
Solutions
This strategy seeks to provide market exposure to the mid and small capitalization segments of the U.S. equity market. This
strategy invests in a subset of securities from within the S&P 1000® Index, which combines the S&P MidCap 400® and the
S&P SmallCap 600®.
AIA S&P 1500® Strategy
Solutions
This strategy seeks to provide broad proportional market exposure to all capitalization segments of the U.S. equity market. This
strategy invests in a subset of securities from within the S&P 1500® index.
AIA S&P 400® Strategy
Solutions
This strategy seeks to gain broad market exposure to the mid-capitalization segment of the U.S. equity market. This strategy
invests in a subset of securities from within the index.
AIA S&P 500® Strategy
Solutions
This strategy seeks to gain broad market exposure to the large capitalization segment of the U.S. equity market. This strategy
invests in a subset of securities from within the index.
AIA S&P 600® Strategy
Solutions
This strategy seeks to gain broad market exposure to the small capitalization segment of the U.S. equity market. This strategy
invests in a subset of securities from within the index.
AIA S&P ADR/International Strategy
Solutions
This strategy seeks to gain broad international equity exposure without the costs and complexity of buying local shares through
the use of U.S. listed American Depositary Receipts. This strategy invests in a subset of securities from within the index.
AIA S&P Global 1500 Strategy
Solutions
This strategy seeks to gain broad market exposure to the U.S. and international equity markets through the use of U.S. stocks
and U.S. listed American Depositary Receipts. This strategy invests in a subset of securities from within the S&P 1500® and the
S&P ADR indexes.
AIA S&P Global 500 Strategy
Solutions
This strategy seeks to gain broad market exposure to the U.S. and international equity markets through the use of U.S. stocks
and U.S. listed American Depositary Receipts. This strategy invests in a subset of securities from within the S&P 500® and the
S&P ADR indexes.
AIA Small Cap Value Strategy
Solutions
This strategy seeks to gain broad market exposure to the small capitalization value segment of the U.S. equity market. This
strategy invests in a subset of securities from within a small capitalization value universe.
AIA Small Cap Growth Strategy
Solutions
This strategy seeks to gain broad market exposure to the small capitalization value segment of the U.S. equity market. This
strategy invests in a subset of securities from within a small capitalization growth universe.
AIA Small Cap 2000 Strategy
Solutions
This strategy seeks to gain broad market exposure to the small capitalization segment of the U.S. equity market. This strategy
invests in a subset of securities from within a small-capitalization universe.
AIA Sustainable & Growing Dividend Strategy
This strategy seeks to add value by investing in firms that reflect growth in their dividend stream while also focusing on
dividend sustainability. Specifically, this strategy invests in the US Large Cap market.
Solutions
AIA U.S. All Cap Equity Core Plus Strategy
Solutions
This strategy seeks long-term growth of capital and broad market exposure to the large capitalization segment of the U.S. equity
market. It typically invests in a subset of 100 securities from within the S&P 1500® index selected using an optimizer and alpha
scores provided by Vedanta Analytics. The alpha scores seek to estimate relative returns using a composite of quantitative factors
that include value, growth, profitability, momentum, and technical measures. The strategy will typically be fully invested in equities
and will not invest in private placements, commodities, options or short sales.
AIA U.S. All Cap Equity Core Plus Tax Managed Strategy
Solutions
This strategy seeks to actively realize losses while providing long-term growth of capital and broad market exposure to the large
capitalization segment of the U.S. equity market. It typically invests in a subset of 100 securities from within the S&P 1500® index
selected using an optimizer and alpha scores provided by Vedanta Analytics. The alpha scores seek to estimate relative returns
using a composite of quantitative factors that include value, growth, profitability, momentum, and technical measures. Each client
account may hold unique positions due to the tax sensitive nature of the strategy and differing client cost basis and holding
periods. The strategy will typically be fully invested in equities and will not invest in private placements, commodities, options or
short sales.
Appendix 240
Strategy Description
Investment Strategy
Model Portfolio
Provider
AIA U.S. Equity Core Plus Strategy
Solutions
This strategy seeks long-term growth of capital and broad market exposure to the large capitalization segment of the U.S. equity
market. It typically invests in securities selected using an optimizer and alpha scores provided by Vedanta Analytics. The alpha
scores seek to estimate relative returns using a composite of quantitative factors that include value, growth, profitability,
momentum, and technical measures. The strategy will typically be fully invested in equities and will not invest in private placements,
commodities, options or short sales.
AIA U.S. Equity Core Plus Tax Managed Strategy
Solutions
This strategy seeks to actively realize losses while providing long-term growth of capital and broad market exposure to the large
capitalization segment of the U.S. equity market. It typically invests in securities selected using an optimizer and alpha scores
provided by Vedanta Analytics. The alpha scores seek to estimate relative returns using a composite of quantitative factors that
include value, growth, profitability, momentum, and technical measures. Each client account may hold unique positions due to
the tax sensitive nature of the strategy and differing client cost basis and holding periods. The strategy will typically be fully
invested in equities and will not invest in private placements, commodities, options or short sales.
AIA World ex-US Strategy
Solutions
This strategy seeks to gain broad exposure to developed and emerging market countries excluding the U.S. through the use of
ADRs and GDRs using optimization. For taxable accounts, it additionally seeks to outperform on an after-tax basis through tax
management.
AIA World Strategy
Solutions
This strategy seeks to gain broad exposure to developed and emerging markets through the use of optimization. For taxable
accounts, it additionally seeks to outperform on an after-tax basis through tax management.
Natixis Tax Managed Core Balanced Strategy
Solutions
This strategy seeks to gain broad market exposure to equity markets. The actual exposure to equity markets will vary based on
the index selected. This strategy invests in a subset of securities from within the S&P Composite 500®, S&P Composite 1500®
or the S&P Global 500 indexes. For the fixed income allocation, this strategy invests in a dollar denominated municipal strategy.
The portfolios average duration will vary based on the underlying strategy selected.
AEW Diversified REIT Strategy
AEW
Investments for the strategy will generally be in publicly traded real estate related securities, including securities of companies whose
principal activities include development, ownership, construction, management or sale of real estate. Investments for the strategy
may be in common stocks, preferred stocks, warrants to purchase common stocks, debt securities convertible into common stock,
and other similar instruments. It is currently anticipated that the strategy will be invested primarily in publicly traded shares of
REITs. REITs are generally classified as Equity REITs, Mortgage REITs and Hybrid REITs. Equity REITs generally invest the
majority of their assets in real property and derive their income primarily from rents. Mortgage REITs generally invest the majority
of their assets in loans secured by real estate and derive their income primarily from interest payments. Hybrid REITs generally
combine the characteristics of Equity and Mortgage REITs. At the present time, it is intended that investments will be primarily
in Equity REITs, however, subject to specific investment restrictions in effect from time to time, investments may also be made
from time to time in: (i) Mortgage or Hybrid REITs; (ii) other real estate industry companies, including equity and/or debt
securities of such companies; and (iii) companies outside of the real estate industry but whose products and/or services are related
to the real estate industry, such as manufacturers or distributors of building supplies, financial institutions which make or service
mortgage loans, or companies with substantial real estate assets relative to their market capitalization. The adviser shall manage
the strategy in a manner consistent with these guidelines, subject to specific investment restrictions in effect from time to time
with respect to issuer diversification, sector diversification, illiquid holdings and other matters.
Harris U.S. Equity Strategy
Harris
The investment objective for the strategy is long-term capital appreciation. The strategy is developed using an in-depth, internally
generated research effort to identify potential investments. The strategy seeks to achieve high returns by identifying companies that
are trading at a discount to their intrinsic value and maintains a model portfolio comprised of these companies. The strategy will
be invested primarily in U.S. equities and will typically be fully invested. Generally no single position in the portfolio will exceed
7% of the total portfolio value, no single industry will exceed 20% of the total portfolio value, and no economic sector will exceed
35% of the total portfolio value.
Loomis Sayles Core Fixed Income Strategy
Loomis Sayles
The strategy invests primarily in investment grade fixed income securities of any maturity (including, without limitation, government,
corporate, mortgage-backed and asset-backed securities). The strategy seeks to create a portfolio that is generally similar to the
Barclays Capital (BarCap) Aggregate Bond Index with respect to weightings among segments of the investment grade bond market
and such key investment attributes (within a range) as duration, industry sectors, credit quality, and call protection. The strategy
uses proprietary credit rating system to rate bonds and to assess credit upgrade and downgrade potential independently from the
rating agencies. Normally, 100% of the portfolio is investment grade quality (at the time of purchase).
Appendix 241
Strategy Description
Investment Strategy
Model Portfolio
Provider
Loomis Sayles Core Total Return Strategy
Loomis Sayles
The strategy invests in investment grade and below investment grade fixed income securities of any maturity (including, without
limitation, government, corporate, mortgage-backed, asset-backed securities, and $USD denominated non-US debt). The strategy
seeks to outperform the Barclays Capital (BarCap) Aggregate Bond Index while maintaining a benchmark aware risk return
objective. Typically, duration is within +/- 2 years relative to the index, less than 25% of the strategy is invested in any one corporate
industry, and less than 5% is invested in any one issuer (excluding government sponsored enterprise securities). The strategy uses
proprietary credit rating system to rate bonds and to assess credit upgrade and downgrade potential independently from the rating
agencies. Portfolio construction is also driven by top-down macroeconomic analysis. Up to 10% of the portfolio may be invested
in below investment grade issues.
Loomis Sayles Intermediate Fixed Income Strategy
Loomis Sayles
The strategy seeks to create a portfolio that is believed to have credit upgrade potential, sector diversification, and minimal interest
rate risk relative to the BarCap Intermediate Government/Credit Bond Index. The strategy seeks to maintain duration within a
range of the index. The strategy uses proprietary credit research to evaluate bonds and to assess credit upgrade and downgrade
potential independently from the rating agencies. Normally, 100% of the portfolio is investment grade quality (at the time of
purchase). The portfolio management team utilizes fixed income sectors such as governments, agencies, and corporates, typically
with maturities of less than 10 years, and maintains the flexibility to overweight sectors that research indicates offer the most value.
Loomis Sayles Large Cap Growth Strategy
Loomis Sayles
The strategy seeks to invest substantially all of its assets in stocks. Investments are selected based on the portfolio manager’s
evaluation of their growth potential; current income is not a consideration. The strategy generally seeks to invest in companies with
capitalizations of $3 billion or greater that are believed to be well-managed, dominant in their respective industries and capable
of long-term earnings growth and price appreciation potential.
Loomis Sayles Small Mid Core Strategy
Loomis Sayles
The strategy typically invests in companies with market capitalizations between $100 million and $5 billion that, in the portfolio
managers’ judgment, trade at a significant discount to their intrinsic value. Exposure to stocks is spread across a variety of sectors
as the managers believe that value can be found throughout the market. The strategy is driven by rigorous fundamental and
valuation analysis and is implemented through a broad group of stocks. The strategy seeks to add value through stock selection.
The portfolio typically has a maximum position size of 5% along with sector restrictions of 25%. The portfolio seeks to maintain
a cash weight of less than 5%.
Loomis Sayles Global Growth ADR Strategy
Loomis Sayles
The strategy emphasizes companies with sustainable competitive advantages, secular long-term cash flow growth returns on
invested capital above their cost of capital and the ability to manage for profitable growth that can create long-term value for
shareholders. The strategy aims to invest in companies when they trade at a significant discount to the estimate of intrinsic
value.
Loomis Sayles Core Municipal Bond
Loomis Sayles
The Core Municipal Bond strategy seeks to provide a high level of tax-free income, after-tax return, and a lower level of price
volatility than long-term bonds.
Loomis Sayles Intermediate Municipal Bond
Loomis Sayles
The Intermediate Municipal Bond strategy seeks to provide capital stability, tax-free income, and low to moderate interest rate
volatility.
Natixis Alternative Completion Portfolio – Moderate Strategy
Natixis Advisors
This strategy is comprised of alternative mutual fund and ETF investments and the allocations to the underlying investments will
vary based on the risk profile. The strategy is built to provide diversification against the major stock and bond markets and
periodically re-balance to maintain appropriate risk exposures. The strategy intends to target the volatility of the blended benchmark
(60% S&P 500® Index / 40% Bloomberg Barclays US Aggregate Bond Index) while minimizing sensitivity to both the S&P 500®
Index and the Bloomberg Barclays US Aggregate Bond Index.
Appendix 242
Strategy Description
Investment Strategy
Model Portfolio
Provider
Natixis Clarity Partners Global Moderate Strategy
Natixis Advisors
This strategy seeks to provide diversified exposure to a wide range of asset classes on a global basis. The asset allocation
decision making is designed to identify the best opportunities in the global marketplace geared towards producing attractive
risk-adjusted returns and outperforming a global balanced index portfolio over the cycle.
Natixis Risk Efficient Conservative Strategy
Natixis Advisors
The Risk-Efficient Allocation Conservative strategy seeks to provide diversified exposure to a wide range of asset classes, including
alternatives, on a global basis. The portfolio is designed to align with a conservative risk profile while providing attractive risk-
adjusted returns relative to its benchmark. The portfolio has an actively managed core, across equity, fixed and alternative asset
classes and a passive tactical sleeve to take advantage on near term market opportunities, primarily through the use of ETFs.
Natixis Risk Efficient Moderate Strategy
Natixis Advisors
The Risk-Efficient Allocation Moderate strategy seeks to provide diversified exposure to a wide range of asset classes, including
alternatives, on a global basis. The portfolio is designed to align with a moderate risk profile while providing attractive risk-
adjusted returns relative to its benchmark. The portfolio has an actively managed core, across equity, fixed and alternative asset
classes and a passive tactical sleeve to take advantage on near term market opportunities, primarily through the use of ETFs.
Natixis Risk Efficient Growth Strategy
Natixis Advisors
The Risk-Efficient Allocation Growth strategy seeks to provide diversified exposure to a wide range of asset classes, including
alternatives, on a global basis. The portfolio is designed to align with an aggressive risk profile while providing attractive risk-
adjusted returns relative to its benchmark. The portfolio has an actively managed core, across equity, fixed and alternative asset
classes and a passive tactical sleeve to take advantage on near term market opportunities, primarily through the use of ETFs.
Natixis Total Income Strategy
Natixis Advisors
The Total Income strategy seeks to provide diversified exposure to a wide range of asset classes on a global basis. The portfolio
is designed to align with a moderately-conservative risk profile while providing attractive risk-adjusted returns and income relative
to its benchmark. The portfolio has an actively managed core, across equity, fixed and alternative asset classes and a passive
tactical sleeve to enhance the overall yield of the portfolio, primarily through the use of ETFs.
Natixis Tactical Allocation Model – All Equity Strategy
Natixis Advisors
The Natixis Tactical Allocation Model - All Equity Strategy seeks to provide diversified exposure to the equity asset class on a
global basis. The model is adjusted based on asset class and market opportunities with a goal of maximizing return with reasonable
risk. The portfolio is monitored relative to its benchmark to ensure it aligns with the appropriate risk profile. The portfolio has
a strategic core allocation across the traditional equity asset class, as well as a tactical overlay to take advantage of near term market
opportunities, primarily through the use of passive investments/ETFs.
Natixis Tactical Allocation Model – Aggressive Strategy
Natixis Advisors
The Natixis Tactical Allocation Model - Aggressive Strategy seeks to provide diversified exposure to a wide range of asset classes
on a global basis. The model is adjusted based on asset class and market opportunities with a goal of maximizing return with
reasonable risk. The portfolio is monitored relative to its benchmark to ensure it aligns with an aggressive risk profile. The
portfolio has a strategic core allocation across traditional equity and fixed-income asset classes, as well as a tactical overlay to take
advantage of near term market opportunities, primarily through the use of passive investments/ETFs.
Natixis Tactical Allocation Model – Moderately Aggressive
Strategy
Natixis Advisors
The Natixis Tactical Allocation Model - Moderately Aggressive Strategy seeks to provide diversified exposure to a wide range of
asset classes on a global basis. The model is adjusted based on asset class and market opportunities with a goal of maximizing
return with reasonable risk. The portfolio is monitored relative to its benchmark to ensure it aligns with a moderately aggressive
risk profile. The portfolio has a strategic core allocation across traditional equity and fixed-income asset classes, as well as a tactical
overlay to take advantage of near term market opportunities, primarily through the use of passive investments/ETFs.
Natixis Tactical Allocation Model – Moderate Strategy
Natixis Advisors
The Natixis Tactical Allocation Model - Moderate Strategy seeks to provide diversified exposure to a wide range of asset classes
on a global basis. The model is adjusted based on asset class and market opportunities with a goal of maximizing return with
reasonable risk. The portfolio is monitored relative to its benchmark to ensure it aligns with a moderate risk profile. The portfolio
has a strategic core allocation across traditional equity and fixed-income asset classes, as well as a tactical overlay to take advantage
of near term market opportunities, primarily through the use of passive investments/ETFs.
Appendix 243
Strategy Description
Investment Strategy
Model Portfolio
Provider
Natixis Tactical Allocation Model – Moderately Conservative
Strategy
Natixis Advisors
The Natixis Tactical Allocation Model - Moderately Conservative Strategy seeks to provide diversified exposure to a wide range
of asset classes on a global basis. The model is adjusted based on asset class and market opportunities with a goal of maximizing
return with reasonable risk. The portfolio is monitored relative to its benchmark to ensure it aligns with a moderately conservative
risk profile. The portfolio has a strategic core allocation across traditional equity and fixed-income asset classes, as well as a tactical
overlay to take advantage of near term market opportunities, primarily through the use of passive investments/ETFs.
Natixis Tactical Allocation Model – Conservative Strategy
Natixis Advisors
The Natixis Tactical Allocation Model - Conservative Strategy seeks to provide diversified exposure to a wide range of asset classes
on a global basis. The model is adjusted based on asset class and market opportunities with a goal of maximizing return with
reasonable risk. The portfolio is monitored relative to its benchmark to ensure it aligns with a conservative risk profile. The
portfolio has a strategic core allocation across traditional equity and fixed-income asset classes, as well as a tactical overlay to take
advantage of near term market opportunities, primarily through the use of passive investments/ETFs.
Natixis Tactical Alpha Model – Aggressive Strategy
Natixis Advisors
The Natixis Tactical Alpha Model - Aggressive Strategy seeks to provide diversified exposure to a wide range of asset classes,
including alternatives, on a global basis. The model is adjusted based on asset class and market opportunities with a goal of
maximizing return with reasonable risk. The portfolio is monitored relative to its benchmark to ensure it aligns with an aggressive
risk profile. The portfolio has a strategic core allocation across traditional equity and fixed-income asset classes with an alternatives
sleeve, as well as a tactical overlay to take advantage of near term market opportunities, primarily through the use of passive
investments/ETFs.
Natixis Tactical Alpha Model – Moderately Aggressive Strategy
Natixis Advisors
The Natixis Tactical Alpha Model - Moderately Aggressive Strategy seeks to provide diversified exposure to a wide range of asset
classes, including alternatives, on a global basis. The model is adjusted based on asset class and market opportunities with a goal
of maximizing return with reasonable risk. The portfolio is monitored relative to its benchmark to ensure it aligns with a
moderately aggressive risk profile. The portfolio has a strategic core allocation across traditional equity and fixed-income asset
classes with an alternatives sleeve, as well as a tactical overlay to take advantage of near term market opportunities, primarily
through the use of passive investments/ETFs.
Natixis Tactical Alpha Model – Moderate Strategy
Natixis Advisors
The Natixis Tactical Alpha Model - Moderate Strategy seeks to provide diversified exposure to a wide range of asset classes,
including alternatives, on a global basis. The model is adjusted based on asset class and market opportunities with a goal of
maximizing return with reasonable risk. The model is adjusted based on asset class and market opportunities with a goal of
maximizing return with reasonable risk. The portfolio is monitored relative to its benchmark to ensure it aligns with a moderate
risk profile. The portfolio has a strategic core allocation across traditional equity and fixed-income asset classes with an alternatives
sleeve, as well as a tactical overlay to take advantage on near term market opportunities, primarily through the use of passive
investments/ETFs.
Natixis Tactical Alpha Model – Moderately Conservative
Strategy
Natixis Advisors
The Natixis Tactical Alpha Model - Moderately Conservative Strategy seeks to provide diversified exposure to a wide range of
asset classes, including alternatives, on a global basis. The portfolio is monitored relative to its benchmark to ensure it aligns with
a moderately conservative risk profile. The model is adjusted based on asset class and market opportunities with a goal of
maximizing return with reasonable risk. The portfolio has a strategic core allocation across traditional equity and fixed-income
asset classes with an alternatives sleeve, as well as a tactical overlay to take advantage on near term market opportunities, primarily
through the use of passive investments/ETFs.
Natixis Tactical Alpha Model – Conservative Strategy
Natixis Advisors
The Natixis Tactical Alpha Model - Conservative Strategy seeks to provide diversified exposure to a wide range of asset classes,
including alternatives, on a global basis. The model is adjusted based on asset class and market opportunities with a goal of
maximizing return with reasonable risk. The portfolio is monitored relative to its benchmark to ensure it aligns with a conservative
risk profile. The portfolio has a strategic core allocation across traditional equity and fixed-income asset classes with an alternatives
sleeve, as well as a tactical overlay to take advantage on near term market opportunities, primarily through the use of passive
investments/ETFs.
Appendix 244
Strategy Description
Investment Strategy
Model Portfolio
Provider
Natixis Tactical Core Model – Aggressive Strategy
Natixis Advisors
The Natixis Tactical Core Model - Aggressive Strategy seeks to provide diversified exposure to a wide range of asset classes on a
global basis. The model is adjusted based on asset class and market opportunities with a goal of maximizing return with reasonable
risk. The portfolio is monitored relative to the Merrill strategic benchmark to ensure it aligns with an aggressive risk profile. The
portfolio has a strategic core allocation across traditional equity and fixed-income asset classes, as well as a tactical overlay to take
advantage of near term market opportunities, primarily through the use of passive investments/ETFs.
Natixis Tactical Core Model – Moderately Aggressive Strategy
Natixis Advisors
The Natixis Tactical Core Model - Moderately Aggressive Strategy seeks to provide diversified exposure to a wide range of asset
classes on a global basis. The model is adjusted based on asset class and market opportunities with a goal of maximizing return
with reasonable risk. The portfolio is monitored relative to the Merrill strategic benchmark to ensure it aligns with a moderately
aggressive risk profile. The portfolio has a strategic core allocation across traditional equity and fixed-income asset classes, as well
as a tactical overlay to take advantage of near term market opportunities, primarily through the use of passive investments/ETFs.
Natixis Tactical Core Model – Moderate Strategy
Natixis Advisors
The Natixis Tactical Core Model - Moderate Strategy seeks to provide diversified exposure to a wide range of asset classes on a
global basis. The model is adjusted based on asset class and market opportunities with a goal of maximizing return with reasonable
risk. The portfolio is monitored relative to the Merrill strategic benchmark to ensure it aligns with a moderate risk profile. The
portfolio has a strategic core allocation across traditional equity and fixed-income asset classes, as well as a tactical overlay to take
advantage of near term market opportunities, primarily through the use of passive investments/ETFs.
Natixis Tactical Core Model – Moderately Conservative Strategy
Natixis Advisors
The Natixis Tactical Core Model - Moderately Conservative Strategy seeks to provide diversified exposure to a wide range of asset
classes on a global basis. The model is adjusted based on asset class and market opportunities with a goal of maximizing return
with reasonable risk. The portfolio is monitored relative to the Merrill strategic benchmark to ensure it aligns with a moderately
conservative risk profile. The portfolio has a strategic core allocation across traditional equity and fixed-income asset classes, as
well as a tactical overlay to take advantage of near term market opportunities, primarily through the use of passive
investments/ETFs.
Natixis Tactical Core Model – Conservative Strategy
Natixis Advisors
The Natixis Tactical Core Model - Conservative Strategy seeks to provide diversified exposure to a wide range of asset classes on
a global basis. The model is adjusted based on asset class and market opportunities with a goal of maximizing return with
reasonable risk. The portfolio is monitored relative to the Merrill strategic benchmark to ensure it aligns with a conservative risk
profile. The portfolio has a strategic core allocation across traditional equity and fixed-income asset classes, as well as a tactical
overlay to take advantage of near term market opportunities, primarily through the use of passive investments/ETFs.
Natixis Tactical Core Tax Aware Model – Aggressive Strategy
Natixis Advisors
The Natixis Tactical Core Tax Aware Model - Aggressive Strategy seeks to provide diversified exposure to a wide range of asset
classes on a global basis. The model is adjusted based on asset class and market opportunities with a goal of maximizing return
with reasonable risk. The portfolio is monitored relative to the Merrill strategic benchmark to ensure it aligns with an aggressive
risk profile. The portfolio has a strategic core allocation across traditional equity and fixed-income asset classes, as well as a tactical
overlay to take advantage of near term market opportunities, primarily through the use of passive investments/ETFs.
Natixis Tactical Core Tax Aware Model – Moderately
Aggressive Strategy
Natixis Advisors
The Natixis Tactical Core Tax Aware Model - Moderately Aggressive Strategy seeks to provide diversified exposure to a wide
range of asset classes on a global basis. The model is adjusted based on asset class and market opportunities with a goal of
maximizing return with reasonable risk. The portfolio is monitored relative to the Merrill strategic benchmark to ensure it aligns
with a moderately aggressive risk profile. The portfolio has a strategic core allocation across traditional equity and fixed-income
asset classes, as well as a tactical overlay to take advantage of near term market opportunities, primarily through the use of passive
investments/ETFs.
Natixis Tactical Core Tax Aware Model – Moderate Strategy
Natixis Advisors
The Natixis Tactical Core Tax Aware Model - Moderate Strategy seeks to provide diversified exposure to a wide range of asset
classes on a global basis. The model is adjusted based on asset class and market opportunities with a goal of maximizing return
with reasonable risk. The portfolio is monitored relative to the Merrill strategic benchmark to ensure it aligns with a moderate
risk profile. The portfolio has a strategic core allocation across traditional equity and fixed-income asset classes, as well as a tactical
overlay to take advantage of near term market opportunities, primarily through the use of passive investments/ETFs.
Natixis Tactical Core Tax Aware Model – Moderately
Conservative Strategy
Natixis Advisors
The Natixis Tactical Core Tax Aware Model - Moderately Conservative Strategy seeks to provide diversified exposure to a wide
range of asset classes on a global basis. The model is adjusted based on asset class and market opportunities with a goal of
maximizing return with reasonable risk. The portfolio is monitored relative to the Merrill strategic benchmark to ensure it aligns
with a moderately conservative risk profile. The portfolio has a strategic core allocation across traditional equity and fixed-income
asset classes, as well as a tactical overlay to take advantage of near term market opportunities, primarily through the use of passive
investments/ETFs.
Appendix 245
Strategy Description
Investment Strategy
Model Portfolio
Provider
Natixis Strategic Diversified Moderately Conservative Portfolio
Strategy
Natixis Advisors
The portfolio provides diversified exposure to a mixture of equity and fixed income separately managed account strategies. The
underlying allocations include exposure to large cap growth equities, large cap value equities, small and/or mid cap equities,
international equities and fixed income securities. The allocation to the various investments is designed to provide exposure
consistent with a moderately conservative risk profile.
Natixis Strategic Diversified Moderate Portfolio Strategy
Natixis Advisors
The portfolio provides diversified exposure to a mixture of equity and fixed income separately managed account strategies. The
underlying allocations include exposure to large cap growth equities, large cap value equities, small and/or mid cap equities,
international equities and fixed income securities. The allocation to the various investments is designed to provide exposure
consistent with a moderate risk profile.
Natixis Strategic Diversified Moderately Aggressive Portfolio
Strategy
Natixis Advisors
Natixis Strategic Diversified Aggressive Portfolio Strategy
Natixis Advisors
The portfolio provides diversified exposure to a mixture of equity and fixed income separately managed account strategies. The
underlying allocations include exposure to large cap growth equities, large cap value equities, small and/or mid cap equities,
international equities and fixed income securities. The allocation to the various investments is designed to provide exposure
consistent with a moderately aggressive risk profile.
The portfolio provides diversified exposure to a mixture of equity and fixed income separately managed account strategies. The
underlying allocations include exposure to large cap growth equities, large cap value equities, small and/or mid cap equities,
international equities and fixed income securities. The allocation to the various investments is designed to provide exposure
consistent with an aggressive risk profile.
Natixis Strategic Diversified All Equity Portfolios Strategy
Natixis Advisors
The portfolio provides diversified exposure to a mixture of equity separately managed account strategies. The underlying
allocations include exposure to large cap growth equities, large cap value equities, small and/or mid cap equities, and international
equities. The allocation to the various investments is designed to provide exposure consistent with a diversified all equity risk
profile.
Mirova Global Megatrends Strategy
Mirova
Mirova Global Sustainable Equity ADR Strategy fully integrates ESG factors in asset allocation process. Starting from idea
generation; environmental, social, and technology trends are used to source ideas by building an investment universe of businesses
that offer solutions to negative trends, participate or lead positive trends, or remain neutral but offer social benefits that improve
quality of life. ESG factors are used, then, to further focus the universe seeking those companies within the investment universe
that have a neutral or a positive impact on society or the environment and have good governance. Fundamental analysis is used
in the final step to determine allocations to those names for which there's the highest conviction. The resulting portfolio is a
concentrated set of global stocks of about 50 names.
Mirova International Sustainable Equity ADR Strategy
Mirova
Under normal circumstances, the strategy invests at least 80% of its assets in equity securities, which may include common stocks,
preferred stocks, depositary receipts and real estate investment trusts (“REITS”). The strategy invests in securities of companies
located in no fewer than three countries outside the U.S. Under normal circumstances, the strategy will invest at least 65% of its
assets in securities of companies located outside the U.S. and the Adviser may invest up to 25% of its assets in securities of
companies located in emerging markets (which generally encompasses markets that are not included in the MSCI World
Developed Markets Index). The strategy may invest in growth and value companies of any size and may also invest in initial public
offerings (“IPOs”)
Mirova U.S. Sustainable Equity Strategy
Mirova
The Mirova U.S. Sustainable Equity strategy seeks long-term capital appreciation. Under normal circumstances, the strategy invests
at least 80% of its assets in equity securities, which may include common stocks, preferred stocks, depositary receipts and real
estate investment trusts (“REITs”). Under normal circumstances, the strategy will invest at least 80% of its assets in securities of
U.S. issuers incorporated in the U.S and/or listed on a U.S. stock exchange. The strategy may invest in growth and value companies
of any size, including small- and mid-capitalization companies. The strategy considers companies with a market capitalization
under 2 billion USD to be small-capitalization companies and companies with a market capitalization between 2 and 10 billion
USD to be midcapitalization companies
Appendix 246
Strategy Description
Investment Strategy
Model Portfolio
Provider
VNIM Select Strategy
VNIM
Under normal market conditions the strategy will invest primarily in companies that, at the time of purchase, have a market
capitalization within the capitalization range of the Russell 3000 Index. However, the strategy does not have any market
capitalization limits and may invest in companies with smaller or larger capitalizations. The subadviser invests in all capitalization
companies with a focus on absolute return and uses a bottom-up value oriented investment process in constructing the strategy’s
portfolio. The subadviser seeks companies with the following characteristics, although not all of the companies selected will have
these attributes: companies earning a positive economic margin with stable-to-improving returns; companies valued at a discount
to their asset value; and companies with an attractive and sustainable dividend level. In selecting investments for the strategy, the
subadviser generally employs the following strategies: a value-driven investment philosophy that selects stocks selling at a relatively
low value based on business fundamentals, economic margin analysis and discounted cash flow models; selects companies that it
believes are out-of-favor or misunderstood; uses fundamental analysis to construct a portfolio that it believes has attractive return
potential; and will generally sell a stock when it reaches the subadviser’s price target or when the issuer shows a deteriorating
financial condition due to increased competitive pressures or internal or external forces reducing future expected returns.
The strategy may also invest in convertible preferred stock and convertible debt securities; invest in foreign securities, including
those of emerging markets; invest in other investment companies, to the extent permitted by the Investment Company Act of
1940; invest in real estate investment trusts (“REITs”); and invest in securities offered in initial public offerings (“IPOs”).and Rule
144A securities.
VNIM Small Cap Strategy
VNIM
The investment objective for the strategy is long-term growth of capital. The strategy seeks to achieve high returns through
investments in small capitalization companies with a focus on absolute return. The strategy will typically be fully invested in
equities. Normally, investments will be made in companies with a market capitalization below $1.5 billion at time of purchase. The
strategy will not invest in private placements, commodities, options or short sales. Generally, no single position within the portfolio
will exceed 5% of the total portfolio at time of purchase and no single industry, as defined by Standard & Poors, will represent
more than 15% of the portfolio at time of purchase.
VNIM Mid Cap Strategy
VNIM
The investment objective for the strategy is long-term growth of capital. The strategy seeks to achieve high returns through
investments in small and mid capitalization companies with a focus on absolute return. The strategy will typically be fully invested
in equities. Normally, investments will be made in companies with a market capitalization between $1-$15 billion at time of
purchase. The strategy will not invest in private placements, commodities, options or short sales. Generally, no single position
within the portfolio will exceed 5% of the total portfolio at time of purchase.
Large-cap, International, Value, Equities.
Natixis/WCM Focused International Value Strategy
WCM Investment
Management
Large-cap, International, Growth, Equities
Natixis/WCM Focused Growth International Strategy
WCM Investment
Management
Mid-cap, U.S., Equities.
Natixis/WCM Focused Mid Cap Strategy
WCM Investment
Management
Appendix 247
Strategy Description
Investment Strategy
Small and Mid-cap, U.S., Equities.
Natixis/WCM Focused SMID Cap Strategy
Model Portfolio
Provider
WCM Investment
Management
Small and Mid-cap, U.S., Growth, Equities.
Natixis/WCM Focused U.S. Growth Strategy
WCM Investment
Management
Mid-cap, U.S., Growth, Equities.
Natixis/WCM Select U.S. Growth Strategy
WCM Investment
Management
Natixis/WCM Quality Global Growth Strategy
WCM Investment
Management
The Strategy seeks quality growth businesses with superior growth prospects, high returns on invested capital and low to no debt.
The Strategy will invest in large established multinationals, with a primary emphasis in the large cap space; while focusing its
attention on conventional growth sectors like technology, consumer discretionary, consumer staples, and health care.
Natixis Advisors shall manage a Client Account in a manner consistent with the strategy descriptions, subject to specific investment restrictions in effect from time to time with respect to issuer diversification, sector
diversification, illiquid holdings and other matters. A Client may notify Natixis Advisors at any time not to invest any funds in the account in specific securities or specific categories of securities or in either or both beyond
a certain percentage of the account and Natixis Advisors shall promptly follow those instructions. Past performance does not guarantee future returns. No assurance can be given that the Client’s objectives/targets can or
will be achieved for any particular period or market cycle.
This document may contain references to third party copyrights, indexes, and trademarks, each of which is the property of its respective owner. Such owner is not affiliated with Natixis Investment Managers or any of its
related or affiliated companies (collectively “Natixis”) and does not sponsor, endorse or participate in the provision of any Natixis services, funds or other financial products.
Appendix 248
Appendix 3
Managed Account Unbundled Program Strategy List & Standard Fee Rate
Investment Strategy
Fee Rates
Affiliated Model Portfolio
Provider
AIA Managed ETF Portfolio Conservative Strategy
Solutions
0.30% on first $500,000; 0.25% on next $4.5 Million; 0.20% thereafter
AIA Managed ETF Portfolio Moderate Strategy
Solutions
0.30% on first $500,000; 0.25% on next $4.5 Million; 0.20% thereafter
AIA Managed ETF Portfolio Aggressive Strategy
Solutions
0.30% on first $500,000; 0.25% on next $4.5 Million; 0.20% thereafter
AIA Managed ETF Portfolio All Equity Strategy
Solutions
0.30% on first $500,000; 0.25% on next $4.5 Million; 0.20% thereafter
AIA Managed ETF Portfolio Income-Conservative Strategy
Solutions
0.25% on first $500,000; 0.20% on next $4.5 Million; 0.15% thereafter
AIA Managed ETF Portfolio Income-Aggressive Strategy
Solutions
0.25% on first $500,000; 0.20% on next $4.5 Million; 0.15% thereafter
AIA S&P 400® Strategy
Solutions
AIA Mid & Large Cap 1000 Strategy
Solutions
AIA Mid & Large Cap 1000 Growth Strategy
Solutions
AIA Mid & Large Cap 1000 Value Strategy
Solutions
AIA S&P 1000® Strategy
Solutions
AIA S&P 500® Strategy
Solutions
AIA Large Cap Value Strategy
Solutions
AIA Large Cap Growth Strategy
Solutions
AIA S&P 600® Strategy
Solutions
AIA Small Cap Value Strategy
Solutions
AIA Small Cap Growth Strategy
Solutions
AIA Small Cap 2000 Strategy
Solutions
AIA S&P 1500® Strategy
Solutions
0.35% on first $5 million; 0.25% on the next $5 million; 0.20% on the next $10 million; 0.17%
on the next $30 million; 0.16% thereafter
0.30% on first $5 million; 0.20% on next $5 million; 0.15% on the next $10 million; 0.12% on
the next $30 million; 0.11% thereafter
0.31% on first $5 million; 0.21% on next $5 million; 0.16% on the next $10 million; 0.13% on
the next $30 million; 0.12% thereafter
0.31% on first $5 million; 0.21% on next $5 million; 0.16% on the next $10 million; 0.13% on
the next $30 million; 0.12% thereafter
0.35% on first $5 million; 0.25% on the next $5 million; 0.20% on the next $10 million; 0.17%
on the next $30 million; 0.16% thereafter
0.30% on first $5 million; 0.20% on next $5 million; 0.15% on the next $10 million; 0.12% on
the next $30 million; 0.11% thereafter
0.31% on first $5 million; 0.21% on next $5 million; 0.16% on the next $10 million; 0.13% on
next $30 million; 0.12% thereafter
0.31% on first $5 million; 0.21% on next $5 million; 0.16% on the next $10 million; 0.13% on
next $30 million; 0.12% thereafter
0.35% on first $5 million; 0.25% on the next $5 million; 0.20% on the next $10 million; 0.17%
on the next $30 million; 0.16% thereafter
0.36% on first $5 million; 0.26% on the next $5 million; 0.21% on the next $10 million; 0.18%
on next $30 million; 0.17% thereafter
0.36% on first $5 million; 0.26% on the next $5 million; 0.21% on the next $10 million; 0.18%
on next $30 million; 0.17% thereafter
0.35% on first $5 million; 0.25% on the next $5 million; 0.20% on the next $10 million; 0.17%
on the next $30 million; 0.16% thereafter
0.30% on first $5 million; 0.20% on next $5 million; 0.15% on the next $10 million; 0.12% on
the next $30 million; 0.11% thereafter
Appendix 349
Investment Strategy
Fee Rates
Affiliated Model Portfolio
Provider
AIA All Cap Value Strategy
Solutions
AIA All Cap Growth Strategy
Solutions
AIA All Cap 3000 Strategy
Solutions
AIA S&P ADR/International Strategy
Solutions
AIA World ex-US Strategy
Solutions
AIA Developed ex-US Strategy
Solutions
AIA S&P Global 500 Strategy
Solutions
AIA S&P Global 1500 Strategy
Solutions
AIA World Strategy
Solutions
AIA U.S. Equity Core Plus Strategy
Solutions
AIA U.S. Equity Core Plus Tax Managed Strategy
Solutions
AIA U.S. All Cap Equity Core Plus Strategy
Solutions
AIA U.S. All Cap Equity Core Plus Tax Managed Strategy
Solutions
AIA Sustainable & Growing Dividend Strategy
Solutions
Natixis Tax Managed Core Balanced Strategy
Solutions
0.31% on first $5 million; 0.21% on next $5 million; 0.16% on the next $10 million; 0.13%
on next $30 million; 0.12% thereafter
0.31% on first $5 million; 0.21% on next $5 million; 0.16% on the next $10 million; 0.13%
on next $30 million; 0.12% thereafter
0.30% on first $5 million; 0.20% on next $5 million; 0.15% on the next $10 million; 0.12%
on the next $30 million; 0.11% thereafter
0.35% on first $5 million; 0.25% on the next $5 million; 0.20% on the next $10 million;
0.17% on the next $30 million; 0.16% thereafter
0.35% on first $5 million; 0.25% on the next $5 million; 0.20% on the next $10 million;
0.17% on the next $30 million; 0.16% thereafter
0.35% on first $5 million; 0.25% on the next $5 million; 0.20% on the next $10 million;
0.17% on the next $30 million; 0.16% thereafter
0.35% on first $5 million; 0.25% on the next $5 million; 0.20% on the next $10 million;
0.17% on the next $30 million; 0.16% thereafter
0.35% on first $5 million; 0.25% on the next $5 million; 0.20% on the next $10 million;
0.17% on the next $30 million; 0.16% thereafter
0.35% on first $5 million; 0.25% on the next $5 million; 0.20% on the next $10 million;
0.17% on the next $30 million; 0.16% thereafter
0.40% on first $5 million; 0.30% on next $5 million; 0.25% on the next $10 million; 0.22%
on the next $30 million; 0.21% thereafter
0.40% on first $5 million; 0.30% on next $5 million; 0.25% on the next $10 million; 0.22%
on the next $30 million; 0.21% thereafter
0.40% on first $5 million; 0.30% on next $5 million; 0.25% on the next $10 million; 0.22%
on the next $30 million; 0.21% thereafter
0.40% on first $5 million; 0.30% on next $5 million; 0.25% on the next $10 million; 0.22%
on the next $30 million; 0.21% thereafter
0.40% on first $5 million; 0.30% on next $5 million; 0.25% on the next $10 million; 0.22%
on the next $30 million; 0.21% thereafter
0.30%
Natixis/AEW Diversified REIT Strategy
AEW
0.70% on first $25 Million; 0.60% on next $25 Million; 0.50% thereafter
Natixis/Harris U.S. Equity Strategy
Harris
0.75% on first $15 Million; 0.45% thereafter
Natixis/Loomis Sayles Core Fixed Income Strategy
Loomis Sayles
Natixis/Loomis Sayles Core Total Return Strategy
Loomis Sayles
0.43% on first $3 million; 0.40% on next $22 million; 0.37% on next $25 million; 0.35%
thereafter
0.40% on first $20 Million; 0.35% thereafter
Natixis/Loomis Sayles Intermediate Fixed Income Strategy
Loomis Sayles
Natixis/Loomis Sayles Large Cap Growth Strategy
Loomis Sayles
0.43% on first $3 Million; 0.40% on next $22 Million; 0.37% on next $25 Million;
0.35%thereafter
0.65% on first $10 Million; 0.50% thereafter
Natixis/Loomis Sayles Global Growth ADR Strategy
Loomis Sayles
0.75% on first $50 Million; 0.60% thereafter
Natixis/Loomis Sayles Small Mid Core Strategy
Loomis Sayles
1.25% on first $1 Million; 1.00% on next $4 Million; 0.80% thereafter
Appendix 350
Investment Strategy
Fee Rates
Affiliated Model Portfolio
Provider
Natixis/Loomis Sayles Core Municipal Bond
Loomis Sayles
0.38%
Natixis/Loomis Sayles Intermediate Municipal Bond
Loomis Sayles
0.38%
Natixis Alternative Completion Portfolio – Moderate Strategy
Natixis Advisors
0.10%
Natixis Clarity Partners Global Moderate Strategy
Natixis Advisors
0.10%
Natixis Risk Efficient Conservative Strategy
Natixis Advisors
0.10%
Natixis Risk Efficient Moderate Strategy
Natixis Advisors
0.10%
Natixis Risk Efficient Growth Strategy
Natixis Advisors
0.10%
Natixis Risk Efficient Income Strategy
Natixis Advisors
0.10%
Natixis Tactical Allocation Model – All Equity Strategy
Natixis Advisors
0.10%
Natixis Tactical Allocation Model – Aggressive Strategy
Natixis Advisors
0.10%
Natixis Tactical Allocation Model – Moderately Aggressive Strategy
Natixis Advisors
0.10%
Natixis Tactical Allocation Model – Moderate Strategy
Natixis Advisors
0.10%
Natixis Tactical Allocation Model – Moderately Conservative Strategy
Natixis Advisors
0.10%
Natixis Tactical Allocation Model – Conservative Strategy
Natixis Advisors
0.10%
Natixis Tactical Alpha Model – Aggressive Strategy
Natixis Advisors
0.10%
Natixis Tactical Alpha Model – Moderately Aggressive Strategy
Natixis Advisors
0.10%
Natixis Tactical Alpha Model – Moderate Strategy
Natixis Advisors
0.10%
Natixis Tactical Alpha Model – Moderately Conservative Strategy
Natixis Advisors
0.10%
Natixis Tactical Alpha Model – Conservative Strategy
Natixis Advisors
0.10%
Natixis Tactical Core Model – Aggressive Strategy
Natixis Advisors
0.10%
Natixis Tactical Core Model – Moderately Aggressive Strategy
Natixis Advisors
0.10%
Appendix 351
Investment Strategy
Fee Rates
Affiliated Model Portfolio
Provider
Natixis Tactical Core Model – Moderate Strategy
Natixis Advisors
0.10%
Natixis Tactical Core Model – Moderately Conservative Strategy
Natixis Advisors
0.10%
Natixis Tactical Core Model – Conservative Strategy
Natixis Advisors
0.10%
Natixis Tactical Core Tax Aware Model – Aggressive Strategy
Natixis Advisors
0.10%
Natixis Advisors
0.10%
Natixis Tactical Core Tax Aware Model – Moderately Aggressive
Strategy
Natixis Tactical Core Tax Aware Model – Moderate Strategy
Natixis Advisors
0.10%
Natixis Advisors
0.10%
Natixis Tactical Core Tax Aware Model – Moderately Conservative
Strategy
Natixis Tactical Core Tax Aware Model – Conservative Strategy
Natixis Advisors
0.10%
Natixis Tax Managed Core Model – Moderately Aggressive Strategy
Natixis Advisors
0.10%
Natixis Tax Managed Core Model – Moderate Strategy
Natixis Advisors
0.10%
Natixis Tax Managed Core Model – Moderately Conservative Strategy
Natixis Advisors
0.10%
Natixis Strategic Diversified Moderately Conservative Portfolio Strategy Natixis Advisors
0.41%
Natixis Strategic Diversified Moderate Portfolio Strategy
Natixis Advisors
0.41%
Natixis Strategic Diversified Moderately Aggressive Portfolio Strategy
Natixis Advisors
0.41%
Natixis Strategic Diversified Aggressive Portfolio Strategy
Natixis Advisors
0.41%
Natixis Strategic Diversified All Equity Portfolios Strategy
Natixis Advisors
0.41%
Natixis/Mirova Global Megatrends Strategy
Mirova
0.70% on first $15 Million; 0.50% thereafter
Natixis/Mirova International Sustainable Equity ADR Strategy
Mirova
0.70% on first $15 Million; 0.50% thereafter
Natixis/Mirova U.S. Sustainable Equity Strategy
Mirova
0.65% on first $15 Million; 0.45% thereafter
Natixis/VNIM Select Strategy
VNIM
1.00% on first $25 Million; 0.85% on next $25 Million; 0.75% thereafter
Natixis/VNIM Small Cap Strategy
VNIM
1.00% on first $50 Million; 0.75% thereafter
Natixis/VNIM Mid Cap Strategy
VNIM
0.75% on first $50 Million; 0.60% thereafter
Appendix 352
Investment Strategy
Fee Rates
Affiliated Model
Portfolio Provider
Natixis/WCM Focused Growth International Strategy
1.00%
Natixis/WCM Focused International Value Strategy
0.75%
Natixis/WCM Focused Mid Cap Strategy
0.75%
Natixis/WCM Focused SMID Cap Strategy
0.75%
Natixis/WCM Focused U.S. Growth Strategy
0.75%
Natixis/WCM Select U.S. Growth Strategy
0.75%
Natixis/WCM Quality Global Growth Strategy
0.65%
WCM Investment
Management
WCM Investment
Management
WCM Investment
Management
WCM Investment
Management
WCM Investment
Management
WCM Investment
Management
WCM Investment
Management
Appendix 353
Appendix 4
Investment Company Strategy List & Risk Description
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Appendix 454
Risk Descriptions
Risk is inherent in all investing. The value of your investment as well as the amount of return you receive on your investment may
fluctuate significantly from day to day and over time. You may lose part or all of your investment or your investment may not perform as
well as other similar investments. The following is a summary description of certain risks of investing.
Allocation Risk: Investment performance depends on how the strategy’s assets are allocated. The allocation may not be optimal in every market
condition. Investors could lose money on their investment in the strategy as a result of such allocation.
Authorized Participant Concentration Risk: Only an authorized participant (“Authorized Participant”) may engage in creation or redemption
transactions directly with the strategy. The Fund has a limited number of institutions that act as Authorized Participants, none of which are or will be
obligated to engage in creation or redemption transactions. To the extent that these institutions exit the business or are unable to proceed with creation
and/or redemption orders with respect to the strategy and no other Authorized Participant is able to step forward to create or redeem Creation Units,
Fund shares may trade at a discount to net asset value (“NAV”) and possibly face trading halts and/or delisting.
Below Investment Grade Fixed-Income Securities Risk: Investments in below investment grade fixed-income securities, also known as “junk
bonds,” may be subject to greater risks than other fixed-income securities, including being subject to greater levels of interest rate risk, credit/counterparty
risk (including a greater risk of default) and liquidity risk. The ability of the issuer to make principal and interest payments is predominantly speculative
for below investment grade fixed-income securities.
Convertible Securities Risk: Convertible securities have investment characteristics of both equity and debt securities. Investments in convertible
securities are subject to the usual risks associated with debt instruments, such as interest rate risk and credit risk. Convertible securities also react to
changes in the value of the common stock into which they convert, and are thus subject to many of the same risks as investing in common stock. The
Fund may convert a convertible security at an inopportune time, which may decrease the Fund’s return.
Credit/Counterparty Risk: Credit/counterparty risk is the risk that the issuer or the guarantor of a fixed-income security, or the counterparty to a
derivatives or other transaction, will be unable or unwilling to make timely payments of interest or principal or to otherwise honor its obligations. The
Fund will be subject to credit/counterparty risk with respect to the counterparties of its derivative transactions. Many of the protections afforded to
participants on organized exchanges, such as the performance guarantee of an exchange clearing house, are not available in connection with OTC
derivative transactions, such as foreign currency transactions. As a result, in instances when the strategy enters into OTC derivative transactions, the
strategy will be subject to the risk that its counterparties will not perform their obligations under the transactions and that the strategy will sustain losses
or be unable to realize gains.
Currency Risk: Fluctuations in the exchange rates between different currencies may negatively affect an investment.
Cybersecurity and Technology Risk: Failures or breaches of the electronic systems of the strategy, the Adviser, the Subadviser and the strategy’s
other service providers, market makers, listing exchange, Authorized Participants or the issuers of securities in which the strategy invests have the
ability to cause disruptions and negatively impact the strategy’s business operations, potentially resulting in financial losses to the strategy and its
shareholders.
Appendix 455
Risk Descriptions
Derivatives Risk: Derivatives are subject to changes in the value of the underlying asset or indices on which such transactions are based. There is no
guarantee that the use of derivatives will be effective or that suitable transactions will be available. Even a small investment in derivatives may give rise
to leverage risk and can have a significant impact on the investment’s exposure to securities markets values, interest rates or currency exchange rates. It
is possible that the investment’s liquid assets may be insufficient to support obligations under derivatives positions. The use of derivatives for other than
hedging purposes may be considered a speculative activity, and involves greater risks than are involved in hedging. The use of derivatives may cause the
strategy to incur losses greater than those that would have occurred had derivatives not been used. The use of derivatives such as forward currency
contracts, structured notes, futures transactions and swap transactions involves other risks, such as the credit risk relating to the other party to a derivative
contract (which is greater for forward currency contracts, swaps and other over-the-counter traded derivatives), the risk of difficulties in pricing and
valuation, the risk that changes in the value of a derivative may not correlate perfectly with relevant assets, rates or indices, liquidity risk, allocation risk
and the risk of losing more than the initial margin required to initiate derivatives positions. There is also the risk that the investment manager may be
unable to terminate or sell a derivatives position at an advantageous time or price. The Fund’s derivative counterparties may experience financial
difficulties or otherwise be unwilling or unable to honor their obligations, possibly resulting in losses to the strategy.
Emerging Markets Risk: In addition to the risks of investing in foreign investments generally, emerging markets investments are subject to greater
risks arising from political or economic instability, nationalization or confiscatory taxation, currency exchange restrictions, sanctions by the U.S.
government and an issuer’s unwillingness or inability to make principal or interest payments on its obligations. Emerging markets companies may be
smaller and have shorter operating histories than companies in developed markets.
Equity-Linked Notes Risk: When the Fund invests in ELNs, it receives cash but limits its opportunity to profit from an increase in the market value
of the instrument because of the limits relating to the written index call options exposure replicated within the particular ELN. Investing in ELNs may
be more costly to the Fund than if the Fund had invested in the underlying instruments directly. Investments in ELNs often have risks similar to the
underlying instruments being replicated, which include market risk. ELNs are derivatives and therefore are subject to derivatives risk. In addition, since
ELNs are in note form, ELNs are subject to certain debt securities risks, such as credit and counterparty risk. Should the prices of the underlying
instruments move in an unexpected manner, the Fund may not achieve the anticipated benefits of an investment in an ELN, and may realize losses,
which could be significant and could include the Fund’s entire principal investment in such ELN. Investments in ELNs are also subject to liquidity
risk, which may make ELNs difficult to sell and value. Alack of liquidity may also cause the value of the ELN to decline. In addition, ELNs may
exhibit price behavior that does not correlate with the underlying securities being replicated. The Fund’s ELN investments are subject to the risk that
issuers and/or counterparties will fail to make payments when due or default completely, which could result in a loss of all or part of the Fund’s
investment. Prices of the Fund’s ELN investments may be adversely affected if any of the issuers or counterparties it is invested in are subject to an
actual or perceived deterioration in their credit quality. As with all investments, successful use of ELNs depends in significant part on the accuracy of
the Subadviser’s analysis of the issuer’s creditworthiness and financial prospects, and of the Subadviser’s forecast as to changes in relevant economic
and financial market conditions and factors.
Appendix 456
Risk Descriptions
Equity Securities Risk: The value of the strategy’s investments in equity securities could be subject to the risks of unpredictable declines in the value
of individual securities and periods of below-average performance in individual securities or in the equity market as a whole. Securities issued in IPOs
tend to involve greater market risk than other equity securities due, in part, to public perception and the lack of publicly available information
and trading history. Rule 144A securities may be less liquid than other equity securities. Growth stocks are generally more sensitive to market movements
than other types of stocks primarily because their stock prices are based heavily on future expectations. If the an advisor’s or subadviser’s assessment of
the prospects for a company’s growth is wrong, or if their judgment of how other investors will value the company’s growth is wrong, then the price of
the company’s stock may fall or not approach the value that the advisor or subadviser has placed on it. Value stocks can perform differently from the
market as a whole and from other types of stocks. Value stocks also present the risk that their lower valuations fairly reflect their business prospects and
that investors will not agree that the stocks represent favorable investment opportunities, and they may fall out of favor with investors and underperform
growth stocks during any given period. In the event an issuer is liquidated or declares bankruptcy, the claims of owners of the issuer’s bonds and preferred
stock generally take precedence over the claims of those who own common stock. Small- and mid-capitalization and emerging growth companies may
be subject to more abrupt price movements, limited markets and less liquidity than larger, more established companies, which could adversely affect the
value of the strategy’s equity portfolio.
ESG Investing Risk: The Fund’s ESG investment approach could cause the Fund to perform differently compared to funds that do not have such an
approach or compared to the market as a whole. The Fund’s application of ESG-related considerations may affect the Fund’s exposure to certain issuers,
industries, sectors, style factors or other characteristics and may impact the relative performance of the Fund—positively or negatively—depending on
the relative performance of such investments. Views on what constitutes “ESG investing,” and therefore what investments are appropriate for a fund
that has an ESG investment approach, may differ by fund, adviser and investor. In evaluating an investment, a portfolio manager may be reliant upon
information and data that may turn out to be incomplete, inaccurate or unavailable, which may negatively impact the portfolio manager’s assessment of
an issuer’s ESG performance or the Fund’s performance generally. There is no guarantee that the Adviser’s efforts to select investments based on ESG
practices will be successful.
Focused Investment Risk: Because the strategy may invest in a small number of industries or securities, it may have more risk because the impact of
a single economic, political or regulatory occurrence may have a greater adverse impact on the strategy’s net asset value.
Foreign Securities Risk: Investments in foreign securities may be subject to greater political, economic, environmental, credit/counterparty and
information risks. The Fund’s investments in foreign securities also are subject to foreign currency fluctuations and other foreign currency-related risks.
Foreign securities may be subject to higher volatility than U.S. securities, varying degrees of regulation and limited liquidity. Foreign securities held by an
exchange traded fund (ETF) may trade on foreign exchanges that are closed when the securities exchange on which the ETF shares trade is open, which
may result in deviations between the current price of a foreign security and the last quoted price for that security (i.e., the ETF’s quote from the closed
foreign market). This could result in premiums or discounts to NAV that may be greater than those experienced by other ETFs.
Appendix 457
Risk Descriptions
Index Call Options Risk: As the seller of the index call option, the Fund may write index call options, typically on broad-based securities market
indices, with an aggregate notional value less than the market value of its broadly diversified stock portfolio. As the seller of the index call option, the
Fund receives cash(the “premium”) from the purchaser. The premium, the exercise price and the value of the index determine the gain or loss realized
by the Fund as the seller of the index call option. The Fund can also repurchase the call option prior to the expiration date, ending its obligation. In
such a case, the difference between the cost of repurchasing the option and the premium received will determine the gain or loss realized by the Fund.
Inflation-Protected Securities Risk: Inflation-protected securities are subject to the risk that the rate of inflation will be lower than expected. Inflation-
protected securities are intended to protect against inflation by adjusting the interest or principal payable on the security by an amount based upon an
index intended to measure the rate of inflation. There can be no assurance that the relevant index will accurately measure the rate of inflation, in which
case the securities may not work as intended.
Interest Rate Risk: Interest rate risk is the risk that the value of the strategy’s investments will fall if interest rates rise. Generally, the value of fixed-
income securities rises when prevailing interest rates fall and falls when interest rates rise. Interest rate risk generally is greater for funds that invest in
fixed-income securities with relatively longer durations than for funds that invest in fixed-income securities with shorter durations. In addition, an
economic downturn or period of rising interest rates could adversely affect the markets for these securities and reduce the strategy’s ability to sell them,
negatively impacting the performance of the strategy. Fiscal, economic, monetary or other governmental or central bank policies, actions or measures
have in the past, and may in the future, cause or exacerbate risks associated with interest rates, including fluctuations in interest rates.
Investments in Other Investment Companies Risk: The Fund will indirectly bear the management, service and other fees of any other investment
companies in which it invests in addition to its own expenses.
Large Capitalization Companies Risk: The securities of large-capitalization companies may be relatively mature compared to smaller companies
and therefore subject to slower growth during times of economic expansion. Large-capitalization companies may also be unable to respond quickly to
new competitive challenges, such as changes in technology and consumer tastes. The Fund’s performance may be adversely affected if securities of
large capitalization companies outperform the market as a whole because although the Fund owns large-capitalization equities through its Equity
Portfolio, the Fund also invests in ELNs with short call option spreads on large-capitalization equities (e.g., the S&P 500). Because ELNs generate
income from premiums on options sold and are subject to limited upside appreciation given their use of short call option spreads on large-
capitalization equities, the outperformance of, or volatility related to, large-capitalization companies may adversely impact the ELN’s performance,
which in turn may adversely impact Fund performance.
Large Investor Risk: Ownership of shares of the strategy may be concentrated in one or a few large investors. Such investors may redeem shares in
large quantities or on a frequent basis. Redemptions by a large investor may require the strategy to sell investments at unfavorable times or prices, may
increase realized capital gains, including short-term capital gains taxable as ordinary income, may accelerate the realization of taxable income to
shareholders, may increase transaction costs, and may otherwise negatively impact fund performance. These transactions potentially limit the use of any
capital loss carryforwards and certain other losses to offset future realized capital gains (if any). Such transactions may also increase the strategy’s expenses.
Appendix 458
Risk Descriptions
Leverage Risk: Use of derivative instruments may involve leverage. Leverage is the risk associated with securities or practices that multiply small index,
market or asset-price movements into larger changes in value. The use of leverage increases the impact of gains and losses on a fund’s returns, and may
lead to significant losses if investments are not successful.
Liquidity Risk: Liquidity risk is the risk that the strategy may be unable to find a buyer for its investments when it seeks to sell them or to receive the
price it expects. Decreases in the number of financial institutions willing to make markets in the strategy’s investments or in their capacity or willingness
to transact may increase the strategy’s exposure to this risk. Events that may lead to increased redemptions, such as market disruptions or increases in
interest rates, may also negatively impact the liquidity of the strategy’s investments when it needs to dispose of them. If the strategy is forced to sell its
investments at an unfavorable time and/or under adverse conditions in order to meet redemption requests, such sales could negatively affect the strategy.
Securities acquired in a private placement, such as Rule 144A securities, are generally subject to greater liquidity risk because they are subject to strict
restrictions on resale and there may be no liquid secondary market or ready purchaser for such securities. Non- exchange traded derivatives are generally
subject to greater liquidity risk as well. Liquidity issues may also make it difficult to value the strategy’s investments.
Management Risk: A strategy used by the investment manager may fail to produce the intended result.
Market/Issuer Risk: The market value of a Fund’s investments will move up and down, sometimes rapidly and unpredictably, based upon overall
market and economic conditions, as well as a number of reasons that directly relate to the issuers of the strategy’s investments, such as management
performance, financial condition and demand for the issuers’ goods and services.
Market Trading Risk: The Fund faces numerous market trading risks, including the potential lack of an active market for Fund shares or the Fund’s
underlying portfolio securities, losses from trading in secondary markets, periods of high volatility and disruptions in the creation/redemption process.
Any of these factors, among others, may lead to the Fund’s shares trading at a premium or discount to NAV. Accordingly, if a shareholder purchases
Fund shares at a time when the market price is at a premium to the NAV, or sells shares at a time when the market price is at a discount to the NAV,
the shareholder may sustain losses.
Mid-Capitalization Companies Risk: Compared to large-capitalization companies, mid-capitalization companies are more likely to have limited
product lines, markets or financial resources. Stocks of these companies often trade less frequently and in limited volume and their prices may fluctuate
more than stocks of large-capitalization companies. As a result, it may be relatively more difficult for the strategy to buy and sell securities of mid-
capitalization companies.
Models and Data Risk: The Subadviser utilizes various proprietary quantitative models to identify investment opportunities. There is a possibility that
one or all of the quantitative models may fail to identify profitable opportunities at any time. Furthermore, the models may incorrectly identify
opportunities and these misidentified opportunities may lead to substantial losses for the Fund. Models may be predictive in nature and such models
may result in an incorrect assessment of future events. Data used in the construction of models may prove to be inaccurate or stale, which may result in
losses for the Fund.
Appendix 459
Risk Descriptions
Mortgage-Related and Asset-Backed Securities Risk: In addition to the risks associated with investments in fixed-income securities generally (for
example, credit, liquidity and valuation risk), mortgage-related and asset-backed securities are subject to the risks of the mortgages and assets
underlying the securities as well as prepayment risk, the risk that the securities may be prepaid and result in the reinvestment of the prepaid amounts in
securities with lower yields than the prepaid obligations. Conversely, there is a risk that an unexpected rise in interest rates will extend the life of a
mortgage-related or asset-backed security beyond the expected prepayment time, typically reducing the security’s value, which is called extension risk.
The investor also may incur a loss when there is a prepayment of securities that were purchased at a premium. The investments in other asset-backed
securities are subject to risks similar to those associated with mortgage-related securities, as well as additional risks associated with the nature of the
assets and the servicing of those assets.
Municipal Securities Risk: Municipal bonds are investments issued by states, cities, public authorities or political subdivisions to raise money for public
purposes, including general obligation bonds and revenue obligations. Municipal securities are subject to information risk, liquidity risk, credit risk and
the risks that economic, political, fiscal or regulatory events, legislative changes and the enforceability of rights of municipal bond holders could adversely
affect the values of municipal bonds. Municipal obligations may be susceptible to downgrades or defaults during recessions or similar periods of economic
stress and insolvent municipalities may file for bankruptcy, which could significantly affect the rights of creditors and the value of the municipal securities.
In addition, if the municipal securities held by the strategy fail to meet certain legal requirements allowing interest distributed from such securities to be
tax-exempt, the interest received and distributed to shareholders by the strategy may be taxable.
New and Smaller Sized Fund Risk: The Fund is relatively new and has a limited operating history for investors to evaluate and may not be
successful in implementing its investment strategies. The Fund may fail to attract sufficient assets to achieve or maintain economies of scale, which
could result in the strategy being liquidated at any time without shareholder approval and at a time that may not be favorable for all shareholders.
Non-Diversification Risk: Compared with other mutual funds, the strategy may invest a greater percentage of its assets in a particular issuer and may
invest in fewer issuers. Therefore, the strategy may have more risk because changes in the value of a single security or the impact of a simple economic,
political or regulatory occurrence may have a greater adverse impact on the strategy’s net asset value.
Operational Risk - ETFs: The Fund is exposed to operational risk arising from a number of factors, including but not limited to human error,
processing and communication errors, errors of the strategy’s service providers, market makers, listing exchange, Authorized Participants, or the
issuers of securities in which the strategy invests or with which they do business, failed or inadequate processes and technology or systems failures.
Options Risk: The Fund may invest in ELNs that incorporate the characteristics of index call options. The value of the ELNs, and therefore the
Fund’s, replication of the characteristics of index options will fluctuate in response to changes in the value of the underlying securities. Writing index
call options limits the opportunity to profit from an increase in the market value of stocks in exchange for up-front cash at the time of selling the
index call option. The Fund may replicate purchasing index call options through its use of ELNs. If it does so, it also risks losing all or part of the cash
paid. Unusual market conditions or the lack of a ready market for any particular option at a specific time may reduce the effectiveness of the Fund’s
option strategies, and for these and other reasons the Fund’s option strategies may not reduce the Fund’s volatility to the extent desired.
Appendix 460
Risk Descriptions
Premium/Discount Risk: Shares of the strategy are listed for trading on the NYSE Arca, Inc. (the “NYSE Arca”) and are bought and sold in the
secondary market at market prices that may differ from their most recent NAV. The market value of the strategy’s shares will fluctuate, in some cases
materially, in response to changes in the strategy’s NAV, the intraday value of the strategy’s holdings, and the relative supply and demand for the
strategy’s shares on the exchange. Disruptions to creations and redemptions, the existence of extreme market volatility or potential lack of an active
trading market for shares may result in shares trading at a significant premium or discount to NAV and/or in a reduced liquidity of your investment.
During such periods, you may be unable to sell your shares or may incur significant losses if you sell your shares. There are various methods by which
investors can purchase and sell shares and various types of orders that may be placed. Investors should consult their financial intermediary before
purchasing or selling shares of the strategy. If a shareholder purchases shares at a time when the market price is at a premium to the NAV or sells
shares at a time when the market price is at a discount to the NAV, the shareholder may sustain losses.
REIT Risk: Investments in the real estate industry, including REITs, are particularly sensitive to economic downturns and are sensitive to factors such
as changes in real estate values, property taxes and tax laws, interest rates, cash flow of underlying real estate assets, occupancy rates, government
regulations affecting zoning, land use and rents, and the management skill and creditworthiness of the issuer. Companies in the real estate industry may
also be subject to liabilities under environmental and hazardous waste laws. In addition, the value of a REIT is affected by changes in the value of the
properties owned by the REIT or mortgage loans held by the REIT. Many REITs are highly leveraged, increasing the risk. The Fund will indirectly bear
its proportionate share of expenses, including management fees, paid by each REIT in which it invests in addition to the expenses of the strategy.
Retirement Risk: The Fund is not a complete retirement program and there is no guarantee that an investment in the strategy will provide sufficient
retirement income at or through retirement. Although the strategy will become more conservative over time (meaning that the strategy will allocate more
of its assets to fixed-income investments than equity investments as it nears the target retirement date), the strategy will continue to be exposed to
market/issuer risk and the share price of the strategy will fluctuate, even after the strategy reaches its most conservative allocation. This means that you
could lose money by investing in the strategy, including losses near, at, or after the target retirement date. In addition, your risk tolerance may change
over time, including in ways that do not correlate perfectly with the strategy’s glide path. Achieving your retirement goals will depend on many factors,
including the amount you save and the period over which you do so.
Secondary Market Trading Risk: Investors buying or selling shares of the strategy in the secondary market will pay brokerage commissions or other
charges imposed by broker-dealers as determined by that broker. Brokerage commissions are often a fixed amount and may be a significant
proportional cost for investors seeking to buy or sell relatively small amounts of shares.
Short Sale Risk: Short sales can increase the volatility of the strategy and may lower the strategy’s return or result in losses, which potentially may be
unlimited. If the strategy is unable to borrow securities in connection with a short sale at an advantageous time or price, the strategy may be limited in
its ability to pursue its short sale strategy or may incur losses. The use of short sales also exposes the strategy to leverage risk.
Appendix 461
Risk Descriptions
Small-Capitalization Companies Risk: Small-cap companies are more likely than larger companies to have limited product lines, markets or financial
resources, or to depend on a small, inexperienced management group. Stocks of these companies often trade less frequently and in limited volume and
their prices may fluctuate more than stocks of larger companies. Stocks of small-cap companies may therefore be more vulnerable to adverse
developments than those of larger companies.
Small- and Mid- Capitalization Companies Risk: Compared to companies with large market capitalization, small- and mid-capitalization companies
are more likely to have limited product lines, markets or financial resources, or to depend on a small, inexperienced management group. Securities of
these companies often trade less frequently and in limited volume and their prices may fluctuate more than stocks of large- capitalization companies.
Stocks of small- and mid-capitalization companies may therefore be more vulnerable to adverse developments than those of larger companies.
Trading Issues Risk: Trading in shares on the NYSE Arca may be halted in certain circumstances. There can be no assurance that the requirements
of the NYSE Arca necessary to maintain the listing of the strategy will continue to be met.
Valuation Risk: This is the risk that the strategy has valued certain securities at a higher price than the price at which they can be sold. This risk may
be especially pronounced for investments that may be illiquid or may become illiquid.
Appendix 462
Appendix 5
Managed Account Strategy List & Risk Description
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AIA Managed ETF Portfolio Conservative Strategy
AIA Managed ETF Portfolio Moderate Strategy
AIA Managed ETF Portfolio Aggressive Strategy
AIA Managed ETF Portfolio All Equity Strategy
AIA Managed ETF Portfolio Income-Conservative Strategy
AIA Managed ETF Portfolio Income-Aggressive Strategy
AIA S&P 400® Strategy
AIA Mid & Large Cap 1000 Strategy
AIA Mid & Large Cap 1000 Growth Strategy
AIA Mid & Large Cap 1000 Value Strategy
AIA S&P 1000® Strategy
AIA S&P 500® Strategy
AIA Large Cap Value Strategy
AIA Large Cap Growth Strategy
AIA S&P 600® Strategy
AIA Small Cap Value Strategy
AIA Small Cap Growth Strategy
AIA Small Cap 2000 Strategy
AIA S&P 1500® Strategy
AIA All Cap Value Strategy
AIA All Cap Growth Strategy
AIA All Cap 3000 Strategy
Affiliated Investment Strategies
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Appendix 563
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AIA S&P ADR/International Strategy
AIA World ex-US Strategy
AIA Developed ex-US Strategy
AIA S&P Global 500 Strategy
AIA S&P Global 1500 Strategy
AIA World Strategy
AIA U.S. Equity Core Plus Strategy
AIA U.S. Equity Core Plus Tax Managed Strategy
AIA U.S. All Cap Equity Core Plus Strategy
AIA U.S. All Cap Equity Core Plus Tax Managed Strategy
AIA Sustainable & Growing Dividend Strategy
AEW Diversified REIT Strategy
Harris Large Cap Value Strategy
Loomis Sayles Core Fixed Income Strategy
Loomis Sayles Core Total Return Strategy
Loomis Sayles Large Cap Growth Strategy
Loomis Sayles Global Growth ADR Strategy
Loomis Sayles Small Mid Core Strategy
Loomis Sayles Large Cap Value Strategy
Loomis Sayles Core Municipal Bond
Loomis Sayles Intermediate Municipal Bond
Natixis Alternative Completion Portfolio – Moderate Strategy
Natixis Clarity Partners Global Moderate Strategy
Natixis Risk Efficient Conservative Strategy
Natixis Risk Efficient Moderate Strategy
Natixis Risk Efficient Growth Strategy
Natixis Total Income Strategy
Natixis Tactical Allocation Model – All Equity Strategy
Natixis Tactical Allocation Model – Aggressive Strategy
Natixis Tactical Allocation Model – Moderately Aggressive Strategy
Natixis Tactical Allocation Model – Moderate Strategy
Natixis Tactical Allocation Model – Moderately Conservative Strategy
Natixis Tactical Allocation Model – Conservative Strategy
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Appendix 564
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Natixis Tactical Alpha Model – Aggressive Strategy
Natixis Tactical Alpha Model – Moderately Aggressive Strategy
Natixis Tactical Alpha Model – Moderate Strategy
Natixis Tactical Alpha Model – Moderately Conservative Strategy
Natixis Tactical Alpha Model – Conservative Strategy
Natixis Tactical Core Model – Aggressive Strategy
Natixis Tactical Core Model – Moderately Aggressive Strategy
Natixis Tactical Core Model – Moderate Strategy
Natixis Tactical Core Model – Moderately Conservative Strategy
Natixis Tactical Core Model – Conservative Strategy
Natixis Tactical Core Tax Aware Model – Aggressive Strategy
Natixis Tactical Core Tax Aware Model – Moderately Aggressive
Strategy
Natixis Tactical Core Tax Aware Model – Moderate Strategy
Natixis Tactical Core Tax Aware Model – Moderately Conservative
Strategy
Natixis Tactical Core Tax Aware Model – Conservative Strategy
X
Natixis Tax Managed Core Model – Moderately Aggressive Strategy
X
Natixis Tax Managed Core Model – Moderate Strategy
X
Natixis Tax Managed Core Model – Moderately Conservative Strategy
X
Natixis Strategic Diversified Moderately Conservative Portfolio Strategy X
Natixis Strategic Diversified Moderate Portfolio Strategy
X
Natixis Strategic Diversified Moderately Aggressive Portfolio Strategy
X
Natixis Strategic Diversified Aggressive Portfolio Strategy
X
Natixis Strategic Diversified All Equity Portfolios Strategy
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Natixis Tax Managed Core Balanced Strategy
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Mirova Global Megatrends Strategy
Mirova International Sustainable Equity ADR Strategy
Mirova U.S. Sustainable Equity Strategy
VNIM Select Strategy
VNIM Small Cap Strategy
VNIM Mid Cap Strategy
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Appendix 565
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Natixis/WCM Focused Growth International Strategy
Natixis/WCM Focused International Value Strategy
Natixis/WCM Focused Mid Cap Strategy
Natixis/WCM SMID Cap Strategy
Natixis/WCM Focused U.S. Growth Strategy
Natixis/WCM Select U.S. Growth Strategy
Natixis/WCM Quality Global Growth Strategy
X
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Risk Descriptions
Risk is inherent in all investing. The value of your investment as well as the amount of return you receive on your investment may fluctuate significantly from day to day and over
time. You may lose part or all of your investment or your investment may not perform as well as other similar investments. You should be prepared to bear the risk of loss, including
through diversification. The following is a summary description of certain risks of investing.
Allocation Risk: Investment performance depends on how the strategy’s assets are allocated. The allocation may not be optimal in every market condition. Investors could lose money on their
investment in the strategy as a result of such allocation.
Below Investment-Grade Fixed-Income Securities Risk: Investments in below investment-grade fixed income securities, also known as “junk bonds,” may be subject to greater risks than other
fixed-income securities, including being subject to greater levels of interest rate risk, credit risk (including a greater risk of default) and liquidity risk. The ability of the issuer to make principal and
interest payments is predominantly speculative for below investment-grade fixed-income securities.
Credit Risk: Credit risk is the risk that the issuer or the guarantor of a fixed-income security, or the counterparty to a derivatives or other transaction, will be unable or unwilling to make timely
payments of interest or principal or to otherwise honor its obligations. Below investment-grade fixed-income securities are considered predominantly speculative with respect to the ability of the
issuer to make timely principal and interest payments.
Derivatives Risk: Derivatives are subject to changes in the value of the underlying asset or indices on which such transactions are based. There is no guarantee that the use of derivatives will be
effective or that suitable transactions will be available. Even a small investment in derivatives may give rise to leverage risk and can have a significant impact on the investment’s exposure to securities
markets values, interest rates or currency exchange rates. It is possible that the investment’s liquid assets may be insufficient to support obligations under derivatives positions. The use of derivatives
for other than hedging purposes may be considered a speculative activity, and involves greater risks than are involved in hedging. The use of derivatives such as forward currency contracts, structured
notes, futures transactions and swap transactions involves other risks, such as the credit risk relating to the other party to a derivative contract (which is greater for forward currency contracts, swaps
and other over-the-counter traded derivatives), the risk of difficulties in pricing and valuation, the risk that changes in the value of a derivative may not correlate perfectly with relevant assets, rates or
indices, liquidity risk, allocation risk and the risk of losing more than the initial margin required to initiate derivatives positions. There is also the risk that the investment manager may be unable to
terminate or sell a derivatives position at an advantageous time or price. Moreover, there can be no assurance that the derivative counterparties will not experience financial difficulties, possibly resulting
in losses to the investor.
Appendix 566
Risk Descriptions
Emerging Markets Risk: Investing in emerging markets companies, which may be smaller and have shorter operating histories than companies in developed markets, involves risks in addition to,
and greater than, those generally associated with investing in companies in developed foreign markets. The extent of economic development, political stability, market depth, infrastructure, capitalization
and regulatory oversight in emerging market economies is generally less than in more developed markets.
Equity Securities Risk: The value of investments in equity securities could be subject to the risks of unpredictable declines in the value of individual securities and periods of below-average performance
in individual securities or in the equity market as a whole. Equity securities may include common stocks, preferred stocks, warrants, securities convertible into common or preferred stocks and other
equity-like interests in an entity. In the event an issuer is liquidated or declares bankruptcy, the claims of owners of the issuer’s bonds and preferred stock generally take precedence over the claims of
those who own common stock. Equity securities may take the form of stock in corporations, REITs or other trusts and other similar securities.
Fixed-Income Securities Risk: Fixed-income securities are subject to credit risk, interest rate risk and liquidity risk. Generally, the value of fixed income securities rises when prevailing interest rates
fall and falls when interest rates rise. You may lose money on your investment due to unpredictable drops in a security’s value or periods of below-average performance in a given security or in the
securities market as a whole. In addition, an economic downturn or period of rising interest rates could adversely affect the market of these securities and reduce the investment manager’s ability to
sell them. Below investment-grade fixed-income securities may be subject to these risks to a greater extent than other fixed-income securities. These securities are considered predominantly speculative
with respect to the issuer’s continuing ability to make principal and interest payments. Rule 144A securities and structured notes may be more illiquid than other fixed-income securities.
Foreign Securities Risk: Investments in foreign securities are subject to foreign currency fluctuations. Foreign securities may be subject to higher volatility than U.S. securities, varying degrees of
regulation and limited liquidity. Greater political, economic, credit and information risks are also associated with foreign securities.
Interest Rate Risk: Changes in interest rates may cause the value of investments to decrease. Generally, the value of fixed-income securities rises when prevailing interest rates fall and falls when
interest rates rise. A period of low interest rates may cause your investment to have a low or negative yield, potentially reducing the value of your investment.
Issuer Risk: The value of investments may decline for a number of reasons that directly relate to the issuer, such as management performance, financial leverage and reduced demand for the issuer’s
goods and services.
Liquidity Risk: Liquidity risk exists when particular investments are difficult to purchase or sell, possibly preventing the investment manager from selling these illiquid securities at an advantageous
price or at the time desired. A lack of liquidity may also cause the value of investments to decline. Illiquid investments may also be difficult to value. Investments in foreign securities tend to have
greater exposure to liquidity risk than domestic securities.
Management Risk: A strategy used by the investment manager may fail to produce the intended result.
Market Risk: The market value of a security will move up and down, sometimes rapidly and unpredictably, based upon a change in an issuer’s financial condition, as well as overall market and
economic conditions.
Mortgage-Related and Asset-Backed Securities Risk: In addition to the risks associated with investments in fixed-income securities generally (for example, credit, liquidity and valuation risk),
mortgage-related and asset-backed securities are subject to the risks of the mortgages and assets underlying the securities as well as prepayment risk, the risk that the securities may be prepaid and result
in the reinvestment of the prepaid amounts in securities with lower yields than the prepaid obligations. Conversely, there is a risk that an unexpected rise in interest rates will extend the life of a
mortgage-related or asset-backed security beyond the expected prepayment time, typically reducing the security’s value. The investor also may incur a loss when there is a prepayment of securities that
were purchased at a premium. The investments in other asset-backed securities are subject to risks similar to those associated with mortgage-related securities, as well as additional risks associated with
the nature of the assets and the servicing of those assets.
Real Estate Risk: The real estate industry is particularly sensitive to economic downturns. Securities of companies in the real estate industry, including REITs, are sensitive to factors
such as changes in real estate values, property taxes, interest rates, cash flow of underlying real estate assets, occupancy rates, government regulations affecting zoning, land use and
rents, and the management skill and creditworthiness of the issuer. Companies in the real estate industry may also be subject to liabilities under environmental and hazardous waste
laws. In addition, the value of a REIT is affected by changes in the value of the properties owned by the REIT or securing mortgage loans held by the REIT. Many REITs are highly
leveraged, increasing the risk. Your investment will indirectly bear its
proportionate share of expenses, including management fees, paid by each REIT in which it invests.
Small- Cap Companies Risk: These companies are more likely than larger companies to have limited product lines, markets or financial resources, or to depend on a small, inexperienced
management group. Stocks of these companies often trade less frequently and in limited volume, and their prices may fluctuate more than stocks of larger companies. Stocks of small
companies may therefore be
more vulnerable to adverse developments than those of larger companies. Small-capitalization companies in foreign countries may be relatively smaller than those in the United States.
Appendix 567
Appendix 6
Bundled, Unbundled, Model Portfolio & Overlay Program Participation
Bundled Programs
Charles Schwab & Co., Inc.
Citigroup Global Markets, Inc.
Edward D. Jones & Co., L.P.
Envestnet Asset Management, Inc.
Envestnet Portfolio Solutions, Inc.
Goldman, Sachs & Co.
Janney Montgomery Scott LLC
J.P. Morgan Securities LLC
Pershing LLC
LPL Financial LLC
Merrill Lynch (Managed Account Advisors LLC)
Raymond James & Associates, Inc.
Stifel, Nicolaus & Company, Incorporated
UBS Financial Services, Inc.
Unbundled Programs
Charles Schwab & Company, Inc.
Citi Private Bank
Dynasty Wealth Management, LLC
Fidelity Brokerage Services LLC
JP Morgan Chase Bank, N.A.
J.P. Morgan Securities LLC
Janney Montgomery Scott LLC
Pershing LLC
Merrill Lynch (Managed Account Advisors LLC)
Morgan Stanley Smith Barney LLC
Raymond James & Associates, Inc.
RBC Wealth Management, a division of RBC Capital Markets, LLC
SMArtX Advisory Solutions LLC
Stifel, Nicolaus & Company, Incorporated
UBS Financial Services, Inc.
Wells Fargo Advisors, LLC
Model Portfolio Programs
Atria Investments LLC
Citigroup Global Markets, Inc.
Envestnet Asset Management, Inc.
Fidelity Institutional Wealth Adviser LLC
FolioDynamix
J.P. Morgan Securities, LLC
Pershing LLC
LPL Financial LLC
Merrill Lynch (Managed Account Advisors LLC)
Morgan Stanley Smith Barney LLC
Pitcairn Trust Company
UBS Financial Services, Inc.
Appendix 668