This Brochure describes the investment advisory, financial
planning and family office services offered by the Rockefeller
Global Family Office (the “Global Family Office”), a division of
Rockefeller & Co. LLC (“Rockefeller & Co.”) serving the needs of
ultra-high net worth and high net worth individuals, their
families, family offices and related entities like trusts, estates,
endowments and foundations, as well as pension and profit
sharing plans, charitable organizations, corporations and other
business entities, sovereign nations and certain non-U.S.
individuals and entities. The Global Family Office also acts as sub-
adviser to U.S. and non-U.S. investment advisers, including firms
that manage investments on behalf of variable life insurance
policies, variable annuity policies and other variable contracts.
Clients receive personalized investment advice and guidance
from their Global Family Office private advisor (“Private
Advisor”), who is supported by other professionals within the
Global Family Office and its affiliates.
Rockefeller & Co. and its affiliates offer additional investment
advisory services which are not described in this Brochure.
Specifically, Rockefeller & Co. offers investment management
services through a separate division, Rockefeller Asset
Management (“RAM”). Additionally, Rockefeller & Co.’s affiliate,
Rockefeller Financial, LLC (“Rockefeller Financial”), offers
investment advisory services to its clients and sponsors a wrap
fee platform in its capacity as a dually registered investment
adviser and broker-dealer. Separate brochures describing the
asset management services offered by RAM and the investment
advisory services and wrap fee program offered by Rockefeller
Financial are available on the SEC’s website at
www.adviserinfo.sec.gov or may be obtained by contacting us by
email a
t RCM.FormADV@rockco.com.
Firm Overview
The Global Family Office is a division of Rockefeller & Co., which
is a Delaware limited liability company that is registered with the
U.S. Securities and Exchange Commission (the “SEC”) as an
investment adviser under the Investment Advisers Act of 1940,
as amended (the “Advisers Act”). The firm also conducts
business under the name Rockefeller Capital Management and
Rockefeller Global Family Office.
Rockefeller & Co.’s history, through its predecessors, dates to
1882 when John D. Rockefeller established a New York office to
manage the Rockefeller family’s investment, personal, and
philanthropic interests. Rockefeller & Co.’s immediate
predecessor, Rockefeller & Co., Inc. was incorporated in 1979
and in 1980 registered with the SEC as an investment adviser
under the Advisers Act.
Rockefeller & Co. is now an indirect, wholly owned subsidiary of
Rockefeller Capital Management L.P. Rockefeller Capital
Management L.P. was established on March 1, 2018, when
Gregory J. Fleming, together with investment funds affiliated
with Viking Global Investors, L.P. (“Viking”), acquired the
investment advisory and trust company businesses established
by the Rockefeller family. Investment funds affiliated with Viking
own a greater than 75% economic interest in Rockefeller Capital
Management L.P. The remaining economic interests are owned
in part by a trust representing the broader Rockefeller family and
in part by the firm’s management. Please refer to Schedule A of
Rockefeller & Co.’s Form ADV Part 1A for additional information
about the ownership of the firm.
Rockefeller Capital Management L.P.’s operating subsidiaries
include: Rockefeller & Co. an investment adviser registered with
the SEC providing investment advisory and family office services
through its Global Family Office division and investment
management services through its RAM division; Rockefeller
Asset Management International Ltd. (“RAM International”), a
UK limited company performing non-US distribution and
investor servicing activities for RAM; Rockefeller Financial, a
broker-dealer and investment adviser registered with the SEC
providing private wealth management services, securities
services and strategic advice; Rockefeller Trust Company, N.A., a
national trust bank regulated by the Office of the Comptroller of
the Currency (“RTC NA”) and The Rockefeller Trust Company
(Delaware), a limited purpose trust company regulated by the
State Bank Commissioner of the State of Delaware (“RTC
Delaware”), both of which provide fiduciary services acting
either as a trustee, co-trustee, executor, co-executor, or as a
fiduciary or agent for other fiduciary relationships; Rockefeller
Strategic Services LLC (“Rockefeller Strategic Services”), which
provides strategic advisory services with respect to certain types
of business transactions not requiring registration in the U.S. as
a broker dealer; and Rockefeller Capital Management Insurance
Services, LLC (“RCM Insurance Services”), an insurance company
licensed in all 50 states that provides access to a broad range of
personal insurance expertise and services through multiple
national providers to enable effective estate planning, asset
protection or other key wealth management planning strategies
and priorities.
Unless otherwise specified, references herein to “clients” or
“you” refer to advisory clients of the Global Family Office and the
descriptions of investment advisory and family office services
and business practices in this Brochure refer to those of the
Global Family Office and not to the advisory services and
business practices of RAM or of other affiliates, including
Rockefeller Financial, RTC NA, RTC Delaware, Rockefeller
Strategic Services and RCM Insurance Services.
Investment Advisory Services
The Global Family Office makes available discretionary and non-
discretionary investment advisory services to advisory clients of
the firm across a broad range of asset classes and investments
as described below. The scope of services can vary depending
on the needs of the client.
• Discretionary Advisory Services: The Global Family
Office has full discretionary authority to make
investments in a client’s account in a manner consistent
with agreed upon investment objectives and reasonable
restrictions for the particular client account. We have the
authority to determine, without obtaining specific client
consent, the securities to be bought or sold and/or
managed strategies to be invested in/divested of, and
the amount of the securities to be bought or sold and/or
managed strategies to be invested in/divested of.
• Non-Discretionary Advisory Services: Clients engage the
Global Family Office to advise on their investments, but
the Global Family Office must obtain client consent prior
to funding, liquidating and effecting securities
transactions in their managed non-discretionary
accounts.
Please refer to Item 16 for further information about the
different types of advisory services available to clients.
Our investment advisory process generally begins by Private
Advisors helping clients define their goals, objectives, and risk
tolerances. Once these investment parameters are agreed upon,
your Private Advisor will develop or refine, in consultation with
you, an asset allocation framework, provide strategic and tactical
asset allocation advice based upon this framework, subject to
any reasonable guidelines and restrictions agreed upon in
writing with you, and provide you with recommendations on a
variety of products, which may include, equity securities and
fixed income products, investment managers, mutual funds,
exchange traded funds and alternative investments including
but not limited to structured products and variable annuities.
You will receive account statements to help inform and ensure
that the products and services are in line with your investment
parameters.
While we offer an extensive list of investment options and
strategies, the offerings are limited to those approved for sale or
recommendations at the firm. We do not offer or recommend
every investment manager, investment or strategy available in
the industry. Investment managers that Private Advisors may
recommend include both firms unaffiliated with the Global
Family Office and affiliated firms such as RAM, a division of
Rockefeller & Co. Please see Item 11 – Conflicts of Interest
below for a more comprehensive discussion of the conflicts
associated with Affiliated Investment Products (as defined
below).
You are encouraged to, and are responsible for, promptly
notifying your Private Advisor in writing of any material changes
in your objectives or financial situations.
You may obtain information about your Private Advisor, their
licenses, educational background, employment history, and
disciplinary actions with regulators in their Form ADV Part 2B and
through FINRA BrokerCheck, available at
https://brokercheck.finra.org or from the Securities and
Exchange Commission
at www.adviserinfo.sec.gov.
Some of our Private Advisors hold professional educational
credentials, such as the Certified Financial Planner (CFP) and
Chartered Financial Analyst (CFA) designations. Holding a
professional designation typically indicates that a Private Advisor
has completed certain courses or continuing education.
However, a Private Advisor’s professional designation does not
change the obligations of the Global Family Office in providing
investment advisory services to you.
It is important to understand that the investment advisory
services, family office services and executive benefits services
the Global Family Office makes available to clients are separate
and distinct from services and products offered by our affiliates
(including RAM, unless pursuant to legacy arrangements
whereby a client receives RAM’s investment management
services under their client agreement with the Global Family
Office as described below), and that our affiliated services and
products which you may use may be governed by different laws
and separate contractual arrangements between you and
Rockefeller & Co. or its affiliates. The specific services or
investment strategies that the Global Family Office provides to
you, our relationship with you and our legal duties to you are
described in detail in our contracts with you.
When we act as your investment adviser, we typically receive
fees calculated on a percentage of assets in your account (as
discussed in more detail below). Accordingly, we and our Private
Advisors typically earn more when you invest more in your
advisory account, and we earn the same advisory fee rate
regardless of how frequently you trade. We and/or our affiliates
also receive payments and other benefits from third parties,
including from the sponsors of investment products in which you
invest and from certain custodians with whom we have a
business relationship. This creates an incentive for us to
recommend that you increase the assets in your advisory
accounts to increase our fees, invest in investment products or
use services that result in greater compensation to us or our
affiliates or provide other benefits to us and/or our affiliates
(including products and services provided by us and our affiliates
or those for which we receive a portion of product-level fees that
you pay).
Certain of our Private Advisors are also registered
representatives of our affiliated broker-dealer, Rockefeller
Financial (each, a “Registered Representative”). If you enter into
a brokerage arrangement with Rockefeller Financial, our affiliate
is compensated by the commissions and fees you pay to it as well
as through the revenue it may receive from third parties that
include the sponsors of investment products held in your
brokerage account. Registered Representatives are eligible to
receive commissions from Rockefeller Financial in connection
with client brokerage transactions. This compensation structure
creates an incentive for Registered Representatives to
recommend investments in brokerage accounts that may result
in greater compensation than would be the case if held in an
advisory account or to recommend that you trade frequently in
a brokerage account. In addition, this compensation structure
creates an incentive for Rockefeller Financial to offer products
and services that we or our affiliates create, offer products and
services from companies that offer revenue to our affiliates, and
route trades to Rockefeller Financial for execution. Brokerage
account services may be more appropriate than investment
advisory services if you do not want ongoing investment advice
or management of your account, but instead desire only periodic
or on-demand recommendations and/or wish to pay
transaction-based compensation for those trades that you
authorize Rockefeller Financial to make on your behalf. By
utilizing brokerage account services of Rockefeller Financial, you
will be electing to have a relationship with Rockefeller Financial
under which, on a transaction-by-transaction basis, your
Registered Representative will assist you and give you
recommendations which are suitable for your account and in
your best interest based on information you provide to us. This
is in contrast to an advisory relationship in which we manage
your account assets on a discretionary or non-discretionary basis
and monitor your account in our capacity as an investment
adviser. For more information about Rockefeller Financial’s
brokerage services, benefits, risks, conflicts and costs, please see
the Rockefeller Financial LLC Client Relationship Brochure which
is available on our website
(www.rockco.com) or upon request
from your Registered Representative.
Private Advisors who are also Registered Representatives of
Rockefeller Financial may place transactions for their
discretionary accounts prior to soliciting the same securities in
their non-discretionary advisory and brokerage client accounts.
Please see Item 5 – Fees and Compensation and Item 11 – Code
of Ethics, Participation or Interest in Client Transactions and
Personal Trading for additional information regarding associated
conflicts of interest.
Types of Investment Advisory Programs
Investment advisory services delivered by the Global Family
Office will generally be provided using the Rockefeller Private
Wealth Advisory Program (“RPWA Platform”), a wrap fee
program sponsored by Rockefeller Financial. Clients will receive
tailored investment advisory services from their Private Advisor
utilizing the RPWA Platform which offers a wide variety of
investment options and robust reporting and technology
capabilities. Historically the Global Family Office has offered its
advisory services through an unbundled arrangement where
clients pay an advisory fee to the Global Family Office, custody
fees to their custodian, brokerage fees to brokers utilized to
execute securities transactions and other investment related
expenses (the “Legacy Platform”). The Global Family Office has
clients who receive investment advisory services under the
Legacy Platform, and the Global Family Office will generally
make this platform available to clients upon request.
• Rockefeller Private Wealth Advisory Program (RPWA
Platform): We provide personalized investment advice
and guidance to clients utilizing the investment options
and capabilities of the RPWA Platform, a wrap fee
program sponsored by our affiliate Rockefeller Financial.
Under this arrangement, our advisory clients pay either a
fixed fee or a fee calculated on a percentage of assets to
the Global Family Office to cover the investment advice
we provide as well as the trade execution services,
administrative expenses, and other fees and expenses
typically charged by Rockefeller Financial under the
RPWA Platform. A portion of this fee is then paid to
Rockefeller Financial as compensation for providing
these services. Investment management fees payable to
investment managers (including RAM) utilized in the
client’s portfolio are additional charges to the client.
Certain investment managers may elect to “trade away”
from the RPWA Platform for best execution reasons, in
which case clients utilizing such investment managers
will bear brokerage commissions in addition to the wrap
platform fee. Clients accessing investment managers
through mutual funds and other investment vehicles will
bear the fees and expenses charged by such funds and
vehicles.
Additional information about the RPWA Platform, such
as the fees and expenses that clients bear under the
platform, is provided in the Rockefeller Private Wealth
Advisor Platform Wrap Fee Brochure (the “Wrap
Brochure”). A copy of the Wrap Brochure is available on
the SEC’s Investment Adviser Public Disclosure website
(www.adviserinfo.sec.gov) and will be delivered by the
Global Family Office to clients who receive advisory
services from us under this program.
• Legacy Platform: Clients receiving personalized
investment advice and guidance under an unbundled
arrangement pay an investment advisory fee to the
Global Family Office and are separately charged custody
fees by their custodian and brokerage services fees for
transactions executed by broker-dealers for their
account and other investment related expenses.
Investment management fees payable to investment
managers, including RAM, utilized in the client’s portfolio
are additional charges to the client (except in the case of
clients subject to historic fee schedules where the fee
charged covers both the investment advisory services
provided by the Global Family Office and investment
management services provided by RAM as described in
Item 5 below.) Clients accessing investment managers
through mutual funds and other investment vehicles will
bear the fees and expenses charged by such funds and
vehicles in addition to the advisory fees they pay to the
Global Family Office.
The Global Family Office has certain business
arrangements in place with unaffiliated third party banks
and broker-dealers to serve as the qualified custodian for
client accounts, including FNZ Trust Company LLC
(formerly State Street Bank & Trust Company), JP Morgan
Private Bank, Northern Trust, Charles Schwab & Co., Inc.,
TD Ameritrade and affiliates of Associated Banc-Corp,
and will typically suggest that clients who receive our
advisory services through the Legacy Platform consider
utilizing one of these firms for custody services.
Additional information about the Global Family Office’s
business arrangements with these qualified custodians is
provided below in Item 11, Item 12, Item 14 and Item 17.
In addition to differences in the manner in which fees are
charged to clients (as described above), there are differences
between the products and services available to clients on the
RPWA Platform and the Legacy Platform. For example, the
RPWA Platform offers investment options, services, and online
access capabilities which are not available under the Legacy
Platform. Private Advisors can assist clients in understanding
these differences and in determining which arrangement is
better suited to their needs. The Global Family Office and its
Private Advisors have a financial incentive to recommend the
RPWA Platform to clients because it will increase revenue to its
affiliate, Rockefeller Financial, and potentially to themselves
under their compensation arrangements with the Global Family
Office and Rockefeller Financial. Please see Item 11 – Conflicts
of Interest below for a more comprehensive discussion of the
conflicts associated with use of the
RPWA Platform and other
services offered by the Global Family Office and its affiliates.
Additional information about the services available through the
RPWA Platform is provided in its Wrap Brochure.
Investment Consulting Services
The Global Family Office offers non-discretionary investment
consulting services to clients. Under this type of arrangement,
your Private Advisor provides investment advice on a non-
discretionary basis, including asset allocation, specific
investment buy and sell recommendations, financial planning
and other investment advice and analyses. The Global Family
Office will collect certain information from you to assist in
recommending and providing the non-discretionary advisory
services at the initiation of services and periodically thereafter.
You should provide prompt notice to the Global Family Office of
any change in your investment objectives, risk tolerance, time
horizon, financial horizon, financial information, liquidity needs,
and other suitability factors, which could materially change the
information previously provided by you and which you expect
should be used by us to provide ongoing advice.
The Global Family Office does not have discretionary authority
over client assets in investment consulting accounts. Clients
have sole discretion to accept or reject any investment advice or
strategy or any specific recommendation to purchase or sell an
individual investment. Clients are also responsible for
implementing, or arranging for the implementation, any advice
given by the Global Family Office, and to pay any applicable
commissions, charges, trails, and other account, brokerage, or
custody fees directly to their chosen custodian and other
providers. You may make investment-related decisions contrary
to the advice provided or make your own decisions without the
benefit of our advice. However, if you decide to repeatedly
disregard our investment advice, your account may be better
suited to a brokerage relationship in which you pay brokerage
commissions or other transaction-based compensation instead
of ongoing investment advisory fees.
Executive Benefit Services
Under these types of investment consulting arrangements, the
Global Family Office may contract with an employer who, as part
of that employer’s employee benefits package, engages the
Global Family Office to provide certain financial planning
services to the employer’s executives. The fees for such services
are either paid by the employer or by the employee.
Rockefeller Retirement Plan Investment and Consulting
Services
The Global Family Office offers services to plan sponsors and
other named fiduciaries (“Plan Sponsors”) of trustee directed
and participant directed retirement plans some of which are
subject to the Employee Retirement Income Security Act
("ERISA") (each, a “Plan”). We also provide nondiscretionary
investment advisory services to sponsor clients, which services
encompass (1) Non-Discretionary Investment Advisory Services
and/or (2) Retirement Plan Consulting Services to employer-
sponsored retirement plans and their participants. Depending
on the type of the Plan and the specific arrangement with the
Plan Sponsor, we may provide one or more of the below
described services. Prior to being engaged by the Plan Sponsor,
we will provide our Retirement Plan Investment Consulting
Services Client Agreement ("Retirement Plan Agreement") that
contains the information required under Sec. 408(b)(2) of ERISA
as applicable.
The Global Family Office does not have discretion nor any
authority over the Plan’s documents or in implementing any
aspect of the Plan’s investment program. It is the Sponsor’s
responsibility to adhere to the IPS in managing its Retirement
Plan and the menu of investment options made available to Plan
participants.
We will collect certain information from you to assist in
recommending and providing the services selected at the
initiation of services and periodically thereafter. You should
provide prompt written notice to the Global Family Office of any
change in Plan Sponsor information and any change in the Plan’s
investment objectives, guidelines, or similar information, which
could materially change the information previously provided by
you and which you expect should be used by us to provide any
advice.
(1) Non-Discretionary Investment Advisory Services
The Global Family Office provides non-discretionary investment
advisory services to Plan Sponsor clients with respect to
investments or other assets held at one or more third party
custodians. These services are designed to allow the Plan
Sponsor to retain full discretionary authority or control over
assets of the Plan. We will solely be making recommendations
to the Plan Sponsor. We will perform these non-discretionary
investment advisory services through our Private Advisors and
charge fees as described in this Form ADV and our Retirement
Plan Agreement with you. If the Plan is covered by ERISA, we will
perform these investment advisory services to the Plan as a
“fiduciary” defined under ERISA Section 3(21).
The Plan Sponsor may engage us to perform one or more of the
following non-discretionary investment advisory services to the
Plan:
• Advice regarding establishing an investment policy
statement (“IPS”)
• Advice regarding selection of designated investment
alternatives (“DIAs”)
• Advice regarding selection of third-party advisors
and/or managers
• Advice regarding selection of qualified default
investment alternative (“QDIA(s)”)
• Advice regarding investment of trust funds
(2) Retirement Plan Investment Consulting Services
The Global Family Office’s Retirement Plan Consulting Services
are designed to allow our Private Advisors to assist the Plan
Sponsor in meeting its fiduciary duties to administer the Plan in
the best interests of the Plan participants and their beneficiaries.
Retirement Plan Consulting Services are performed so that they
would not be considered “investment advice” under ERISA.
The Plan Sponsor may elect for our Private Advisors to assist with
a number of Retirement Plan Consulting Services related to
administrative support, service provider support, investment
monitoring support and participant services. Depending on the
specific client needs, services can range from assisting plan
fiduciaries with committee policies/procedures, fiduciary
education, and assistance with covered services providers.
Additionally, services may include assisting the plan committee
with monitoring investment performance and assistance with
participant enrollment meetings and participant investment
education.
Potential Additional Retirement Services Provided Outside of
the Retirement Plan Agreement
In providing services for retirement plans, including Plans, the
Global Family Office may establish a separate client relationship
with one or more Plan participants or beneficiaries. Such
separate client relationships develop in various ways, including,
without limitation:
• as a result of a decision by the Plan participant or
beneficiary to purchase services from us not involving the
use of Plan assets;
• as part of an individual or family financial plan for which
any specific recommendations concerning the allocation
of assets or investment recommendations relating to
assets held outside of the Plan; or
• through a rollover of an Individual Retirement Account
("IRA Rollover").
If we are providing services to Plan participants or beneficiaries
separate from our providing services for their Plans as part of our
Retirement Plan Services, we will do so through a separate
agreement. If a Plan participant or beneficiary desires to affect
an IRA Rollover from the Plan to an account advised or managed
by the Global Family Office, the Private Advisor will have a
conflict of interest if his/her fees in connection with providing
services to such participant or beneficiary are reasonably
expected to be higher than those we would otherwise receive in
connection with the Retirement Plan Services. If a Plan
participant or beneficiary desires to affect an IRA Rollover from
the Plan to an account advised or managed by the Global Family
Office, we and your Private Advisor will earn compensation on
those assets, for example, through Client Fees based on the
assets in your account, and third-party payments disclosed in
this Brochure. This creates an incentive for us to recommend and
encourage the rollover of assets from the Plan to us. We mitigate
these conflicts by disclosing them and by establishing policies
and procedures, and risk-based supervision to review these
securities recommendations. The fees charged for an IRA likely
will be higher than those paid through the Plan, and there can be
other fees, including IRA termination fees.
If the Global Family Office or a Private Advisor recommends
moving retirement assets to the Global Family Office, he or she
is required to consider, based on the information you provide,
whether you will be giving up certain investment-related
benefits at the Plan or other financial institution, such as the
effects of breakpoints, rights of accumulation, and index annuity
caps, and has determined that the recommendation is in your
best interest for these reasons:
• Greater services and/or other benefits (including holistic
advice and planning) can be achieved with the IRA;
• Consolidation of assets and availability of consolidated
statements and performance reports would be beneficial
to you; and
• The costs associated with the IRA are justified by these
services and benefits.
The Private Advisor will disclose information about the
applicable fees charged by the Global Family Office in connection
with such IRA Rollover prior to opening an IRA account. Any
decision to effect a rollover or about what to do with the rollover
assets remain that of the Plan participant or beneficiary alone.
In providing these optional services, we may offer participants
and beneficiaries information on other financial and retirement
products or services offered by the Global Family Office and our
affiliates.
Family Office Services
Clients may also engage the Global Family Office for all or some
of the family office services described below. Certain of these
services are also made available to clients of Rockefeller
Financial.
• Investment Planning: Asset allocation design and
recommended implementation. Investment
administration. Performance reporting. Alternative
investment planning (private equity, real estate, and
hedge funds). Coordination of multiple investment
relationships and advisors.
• Trustee Services and Estate Planning: Sophisticated
wealth transfer planning. Summary and analysis of estate
plan. Testamentary document reviews and tailored
advice regarding estate planning documents. GRATs,
LLCs and other estate freeze techniques. Family
education on basic and advanced concepts.
• Philanthropy Advisory: Foundation formation and
administration. Donor advised fund planning. Use of
appreciated securities for charitable purposes. Pledge
design and maintenance.
• Insurance Advisory: Ongoing planning and analysis of life,
health, disability and property and casualty insurance.
Evaluation of overall risk issues.
• Multi-Generational Financial Planning: Unified financial
snapshot, education planning, family educational
meetings, and many other topics.
• Bill Payment and Activity Reporting: Bill payment and
payroll services for client and related entities (e.g.,
individuals, foundation, corporations, LLCs, partnerships,
trusts).
• Cash Flow Management and Budgeting: Long-term and
short-term cash flow planning and analysis. Cash flow
projections. Expense forecasting and budgeting. Ongoing
review of net free cash flow.
• Tax Planning and Preparation: Preparation of family
individual income and gift tax returns. Preparation of
partnership, trust, and foundation returns. Income tax
planning based on multi-year projections with the goal of
minimizing tax liabilities. Charitable, tax loss, investment
interest expense and multi-state tax planning.
Account Opening Process
In order for the Global Family Office to be your investment
adviser, clients must execute an investment advisory agreement
or investment consulting agreement with Rockefeller & Co. and,
if receiving family office services, a separate family office
services agreement (each, a “Client Agreement”). Each Client
Agreement sets forth the terms upon which investment advisory
services, investment consulting services and/or family office
services will be provided to the Client.
Rockefeller & Co. does not custody client funds and/or securities
on behalf of Global Family Office clients. Client assets will be
maintained with banks or broker-dealers that serve as
custodians of the funds and/or securities of the firm’s clients (the
“Custodian”).
Available Service Features
Customized Advisory Services and Client Restrictions
As discussed above, the Global Family Office will tailor its
advisory services to the individual needs of clients in accordance
with the investment mandate for the account and the
investment options available through the RPWM Platform or the
Legacy Platform. Clients should communicate to their respective
Private Advisor in writing any changes in the client’s financial
situation or investment objectives.
Clients may impose reasonable investment restrictions on the
management of their accounts which, if accepted by the Global
Family Office in writing, will apply until changed or withdrawn by
the client or until the Global Family Office determines that the
restriction is no longer reasonable or prevents the efficient
management of the account. Client imposed investment
restrictions will not apply to investments held through
investments in mutual funds and other comingled investment
vehicles, which have their own stated investment objectives and
policies.
We reserve the right to deem any proposed investment
restriction to be unreasonable and to not accept the proposed
investment restriction. If one or more investment restrictions is
determined to be unreasonable, we may not be able to accept
management of the account. If you elect to restrict investments,
you accept any effect such restrictions may have on the
investment performance and diversification of your portfolio.
The performance of accounts with investment restrictions or
screens will differ from, and may be lower than, the performance
of accounts without such restrictions or screens.
Affiliated Investment Products and Affiliated Services
Providers
The Global Family Office makes available to clients equity and
fixed income strategies managed by RAM, a division of
Rockefeller & Co. Clients may participate in these strategies
through separately managed account arrangements, model
delivery platforms, registered investment companies, private
funds and offshore vehicles advised or sub-advised by RAM.
Please refer to RAM’s Form ADV Part 2A for additional
information about the investment strategies it makes available
to clients and its business practices. From time to time the
Global Family Office expects to make available and/or
recommend to eligible clients certain private funds and other
investment vehicles sponsored by Viking, which as described
above has a controlling interest in Rockefeller Capital
Management LP. The Global Family Office may also recommend
the investment products sponsored by investment managers in
which Rockefeller & Co. or its affiliates is a minority owner or has
a profits interest in, such as Breakout Capital (as described in
Item 11).
In order to provide access to third party investment managers,
including both traditional and alternative investments such as
hedge funds, private equity funds, venture capital funds, etc. as
well as direct private equity investments, Rockefeller & Co.
establishes funds of funds and feeder vehicles to facilitate client
investments in such opportunities. Information about the
investment objective, investment program, fees, risk
considerations and conflicts of interest, will be disclosed to
clients in each fund’s confidential private offering memorandum
or prospectus.
Clients of the Global Family Office may be referred to affiliated
companies for services, including but not limited to brokerage
services from Rockefeller Financial, fiduciary services from RTC
NA or RTC Delaware, strategic advisory services from Rockefeller
Strategic Services or Rockefeller Financial, and insurance
products from RCM Insurance Services.
Use of investment strategies, investment funds and other
investment products managed by Rockefeller & Co., including its
RAM division (“Affiliated Investment Products”), Viking and
Breakout Capital, as well as services offered by affiliates of the
Global Family Office (collectively, “Affiliated Service Providers”)
raises conflicts of interest between the Global Family Office and
its clients. Please see Item 11 – Conflicts of Interest below for a
more comprehensive discussion of the conflicts associated with
Affiliated Investment Products.
Financial Planning Reports and Analysis
The Global Family Office will provide clients who receive
comprehensive Global Family Office Services and other clients
who engage the firm for financial planning services, reports
and/or analysis on one or more financial planning topics,
including cash flows, income needs, asset allocation, retirement
and life insurance assessments, charitable giving, estate and
wealth transfer, and business succession.
The Global Family Office may provide financial planning reports
or analyses to clients, including: (1) on a one-time or annual fee
basis, either at a fixed dollar amount, hourly rate, or on a
percentage of assets covered in the reports, or a combination of
those methods, or (2) without a separate charge as part of the
overall services provided to a client. In addition, the Global
Family Office also offers financial planning as a component of the
Global Family Office Counseling program for which clients pay a
bundled fee. Please refer to Item 5 for additional information
about the fees charged for financial planning as well as the
Global Family Office Counseling service.
The reports and analysis are for informational purposes only and
are based upon information provided by participating clients and
provide broad, general guidelines on the advantages of certain
financial planning concepts. The reports and analysis do not
constitute a recommendation of any particular technique or of
any particular investment.
The reports and analysis do not provide on-going investment
advice and are current only as of the date of each respective
report. It is each client’s responsibility to determine what action,
if any, you wish to take based on the information provided, and
you are not required to transact business with us if you choose
to implement any aspects of a report. If requested, the Global
Family Office will only act upon your specific instructions.
Certain reports and analyses may provide projections based on
various assumptions and are therefore hypothetical in nature
and not a guarantee of investment returns.
Regulatory Assets Under Management
As of December 31, 2022, Rockefeller & Co.’s regulatory assets
under management were:
• Regulatory Assets under Management:
$22,661,080,363
• Discretionary Assets: $20,066,555,373
• Non-Discretionary Assets: $2,594,524,990
The firm’s regulatory assets under management comprise assets
managed by both the RAM and Global Family Office divisions of
Rockefeller & Co.