Firm Overview
Rockefeller Financial LLC (“Rockefeller Financial” or the “Firm”), a
Delaware limited liability company is an investment adviser
registered with the U.S. Securities and Exchange Commission (the
“SEC”) and a registered broker-dealer and a member of the Financial
Industry Regulatory Authority, Inc. (“FINRA”). The Firm also does
business under the name Rockefeller Capital Management and
Rockefeller Global Family Office. Rockefeller Financial provides
comprehensive wealth management services to high net-worth and
ultra-high net worth clients. In its capacity as a broker-dealer, the
Firm will also affect securities transactions for clients, sell variable
insurance products and provide investment banking services
specifically providing strategic advice with respect to mergers,
acquisitions, and dispositions of businesses and on other types of
strategic transactions.
Rockefeller Financial is a wholly-owned subsidiary of Rockefeller
Capital Management L.P. (“RCM”). RCM was established on March
1, 2018, when Gregory J. Fleming, together with investment funds
affiliated with Viking Global Investors LP (“Viking”), acquired the
investment advisory and trust company businesses established by
the Rockefeller family. Today, RCM is majority owned by the Viking
funds, with minority stakes held by a U.S. affiliate of IGM Financial
Inc. (“IGM”), a trust representing the Rockefeller family, and current
and former members of RCM’s management and individual
members of the Rockefeller family. Viking and IGM are not involved
in the day-to-day management of RCM or the Firm. No employee,
officer, director, or other representative of Viking or IGM, or any of
their respective controlled affiliates, is a member of any committee
of RCM or the Firm that determines which products or services are
offered or sold to Firm clients.
RCM’s operating subsidiaries include: Rockefeller Financial;
Rockefeller & Co. LLC (“Rockefeller & Co.”), an investment adviser
registered with the SEC providing global family office and asset
management services through its Rockefeller Asset Management
(“RAM“) division; Rockefeller Asset Management International Ltd.
(“RAM International”), a UK limited company performing non-US
distribution and investor servicing activities for RAM to non-U.S.
intermediaries and professional clients; Rockefeller Trust Company,
N.A., a national trust bank regulated by the Comptroller of the
Currency (“RTC NA”) and The Rockefeller Trust Company
(Delaware), a limited purpose trust company regulated by the Office
of the State Bank Commissioner of the State of Delaware (“RTC
DEL”), 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 (“Rockefeller Capital
Management Insurance Services”), an insurance company licensed
in all 50 U.S. states that provides access to a broad range of personal
insurance expertise and services through numerous 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 Rockefeller Financial and the descriptions
of advisory services and other securities business practices refer to
those of Rockefeller Financial, and not to the advisory services and
business practices of its affiliates, including Rockefeller & Co., RTC NA,
RTC DEL, Rockefeller Strategic Services and Rockefeller Capital
Management Insurance Services.
Rockefeller Financial Investment Advisory Services
Rockefeller Financial provides discretionary and non-discretionary
investment advisory services (“Investment Advisory services”)
across a broad range of asset classes and investments to ultra-high
net worth and high net worth individuals, their families, family
offices and entities such as trusts, estates, endowments and
foundations, as well as pension, profit sharing and other retirement
plans, charitable organizations, corporations and other businesses,
and state or municipal government entities. Clients receive
personalized investment advice and guidance from their Private
Advisor (“PA”).
The Firm’s investment process generally begins by PAs helping
clients define their goals, objectives and risk tolerances. Once these
investment parameters are agreed upon, your PA 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 including equity
securities and fixed income products, investment managers, mutual
funds, exchange traded funds (“ETFs”), alternative investments,
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.
You are encouraged to, and are responsible for, promptly notifying
your PA in writing of any material changes in your investment
objectives or financial situation.
You may obtain information about your PA, their licenses,
educational background, employment history, and if they have had
any problems with regulators or received serious complaints from
investors through FINRA BrokerCheck, available at
https://brokercheck.finra.org or from the Securities and Exchange
Commission
at www.adviserinfo.sec.gov.
In addition, some of our PAs may hold certain professional
educational credentials, such as the Certified Financial Planner
(“CFP”) or the Chartered Financial Analysist (“CFA”) designation.
Holding a professional designation typically indicates that a PA has
completed certain courses or continuing education. However, a PA’s
professional designation does not change the obligations of the Firm
in providing investment advisory or brokerage services to you.
It is important to understand that investment advisory services and
brokerage services are separate and distinct from each other, and
each is governed by different laws and separate arrangements that
we may have with you. The specific services or investment strategies
that we provide, our relationship with you and our legal duties to
you in each arrangement are described in detail in our applicable
contracts with you.
When we act as your investment adviser, we receive either a flat
annual dollar fee or fees calculated on a percentage of assets in your
account (both discussed in more detail in Item 5 below).
Accordingly, in some cases, we and our PAs 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 also
receive payments from third parties, including from the sponsors of
the investment products in which you invest. In circumstances
where we receive a fee based on the percentage of assets in your
account, we have an incentive to recommend that you increase
the assets in your advisory accounts to increase our fees, to invest
in investment products that result in greater compensation to us
(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), to maintain cash balances in a sweep investment,
and to recommend sweep accounts that result in higher fees for
us (Please see Item 5 – Fees and Compensation below for
additional information and Item 11 – Code of Ethics, Participation
or Interest in Client Transactions and Personal Trading for
additional information regarding associated conflicts of interest).
Rockefeller Financial also separately offers brokerage account
services (“Brokerage Account services”) that give you the option of
investing through a non-discretionary, commission or transaction-
based account. When we act as broker-dealer, we are compensated
by the commissions and fees you pay us as well as through the
revenue we receive from third parties that include the sponsors of
investment products that we recommend to you. This compensation
structure leads to certain conflicts. 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 us to make on your behalf. By utilizing our
Brokerage Account services, you will be electing to have a
relationship with us under which, on a transaction-by-transaction
basis, we 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 a relationship
in which we manage your account assets on a 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 your
PA can furnish to you.
Types of Services
We generally offer several types of services including, Non-
discretionary Consulting Services, Investment Advisory Services,
Retirement Plan Investment and Consulting Services, and Financial
Planning Reports and Analyses, each as described in further detail
below, and may in the future expand these services to include
separately managed account (“SMA”) strategies offered through
dual contract arrangements through a proprietary or third-party
asset management firm.
Rockefeller Financial is the sponsor of the Rockefeller Private
Wealth Advisory Platform (the “Platform”), a wrap fee program
through which it provides discretionary and non-discretionary
investment advisory services to clients across a broad range of asset
classes and investments. In a wrap fee program, the client pays
Rockefeller Financial a single, bundled, or “wrap” fee for investment
advice, brokerage services, administrative expenses, and certain
other fees and expenses. The Wrap Fee Program is detailed in a
separate wrap fee brochure (the “Wrap Brochure”).
Strategies offered to advisory clients may not be suitable for all of
your investments and Rockefeller Financial does not represent that
any particular strategy is based on or meant to replace a
comprehensive evaluation of any client’s entire financial life
considering all of such client’s circumstances. Instead, Rockefeller
Financial’s advice and recommendations are specific to assets we
manage in your account pursuant to the client agreement applicable
to the Investment Advisory services we provide (“Client
Agreement”). We do not consider assets in accounts we do not
manage pursuant to the Client Agreement, if any, and those held
outside of your account, including assets that may be held in other
accounts at Rockefeller Financial or its affiliates.
For each of the Investment Advisory service offerings described in
this Brochure, Rockefeller Financial does not provide any custodial,
trade execution, or other account services for investments or other
assets, investments or other assets are maintained at an unaffiliated
broker-dealer, retirement administrator or other qualified custodian
(“Third-Party Custodian”). Each client is responsible for separately
making arrangements with any Third-Party Custodian for such
services and to pay any applicable commissions, charges, trails, and
other account, brokerage or custodial fees directly to the Third-Party
Custodian.
Investment Consulting Services and Investment Advisory Services
Rockefeller Financial offers non-discretionary consulting services as
well and discretionary and non-discretionary Investment Advisory
Services to institutions, endowments, pension, individuals, and
other clients. Depending on the type of client, we may provide one
or more investment advisory services, including the following:
(1) Non-Discretionary Investment Consulting Services:
•
Assist client in the preparation of investment objectives and
policies
•
Assist client in the creation of an investment policy statement
("IPS")
•
Provide client advice regarding investment of account and/or
trust fund
•
Provide client assistance with fund searches
•
Provide advice regarding third-party investment advisers
and/or managers
•
Provide client with periodic performance reporting
Rockefeller Financial does not have discretionary authority over
clients’ assets in these Third-Party Custodian 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 with the Third-Party Custodian for the implementation of,
any advice provided by Rockefeller Financial. 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.
(2) Investment Advisory Services
In connection with Investment Advisory services, the Firm, through
its PAs, provides clients with one or more discretionary or non-
discretionary investment recommendations, advice, assistance and
related services as clients and their PAs may agree, including related
to: asset allocation; existing and potential investment strategies;
existing investment holdings; the purchase or sale of securities,
funds and other investment products and services; and/or
performance, analytical or planning reports.
Rockefeller Retirement Plan Investment and Consulting Services
Rockefeller Financial offers services to plan sponsors and other
named fiduciaries (“Plan Sponsors”) of trustee directed and
participant directed retirement plans (each, a “Plan”), some of
which are subject to the Employee Retirement Income Security Act
(“ERISA”) as well as non-discretionary investment advisory services
to sponsor clients, which services encompass (1) Non-Discretionary
Investment Advisory Services, (2) Discretionary Investment
Advisory Services and/or (3) 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 a copy of the Retirement Plan Investment Consulting
Services Client Agreement ("Retirement Plan Agreement") that
contains the information required under Sec. 408(b)(2) of ERISA as
applicable.
Rockefeller Financial does not have discretion nor any authority
over the Plan’s documents. Depending on the services selected,
Rockefeller Financial may or may not have discretion with respect
to the Plan’s investment program. Whether Rockefeller Financial
has discretion and, if so, the extent of such discretion, is explicitly
stated in the relevant Agreement that you will execute with
Rockefeller Financial.
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 Rockefeller Financial of any change in Plan
Sponsor information and any change in your 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
Rockefeller Financial 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 fiduciary to retain full
discretionary authority or control over assets of the plan fiduciary.
We will solely be making recommendations to the Plan Sponsor.
We will perform these non-discretionary investment advisory
services through our PAs and charge fees as described in this Form
ADV and the Retirement Plan Agreement. 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:
•
Advice regarding establishing an IPS
•
Advice regarding selection of designated investment
alternatives (“DIAs”)
•
Advice regarding selection of third-party investment
advisers and/or managers
•
Advice regarding selection of qualified default investment
alternative (“QDIA(s)”)
•
Advice regarding investment of trust funds.
(2) Discretionary Investment Advisory Services
Rockefeller Financial provides 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 fiduciary to delegate
responsibility to Rockefeller Financial for maintaining the plan’s
designated investment alternatives and qualified default investment
alternatives in compliance with the requirements of the Employee
Retirement Income Security Act of 1974 ("ERISA"). We will perform
these investment management services, and charge fees as described
in this Form ADV and the Agreement executed with plan sponsor
clients. We will perform these services as an “investment manager” as
defined under ERISA section 3(38) and as a “fiduciary” to the plan as
defined under ERISA section 3(21), where applicable.
As part of the discretionary investment advisory services, we may
provide, based on the plan fiduciary’s instructions, the following
services:
• Creation and Management of Plan-Level Investment Policy
Statement (“IPS”)
• Selection, Monitoring and Replacement of designated
investment alternatives ("DIAs")
• Creation and Maintenance of Model Asset Allocation
Portfolios ("models")
• Selection and Replacement of third-party advisors and/or
managers
• Selection, Monitoring & Replacement of qualified default
investment alternatives ("QDIA(s)").
(3) Retirement Plan Investment Consulting Services
Rockefeller Financial Retirement Plan Consulting Services are
designed to allow our PAs to assist the Plan Sponsor in meeting its
fiduciary duties to administer the Plan in the best interests of 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 PA’s 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.
(4) Rockefeller Personalized Portfolios
In plans for which we provide Retirement Plan Investment and
Consulting Services we may also provide a web-based, managed
account services to plan participants (“Rockefeller Personalized
Portfolios”). This program is not available to all plans and depends
upon the Plan Sponsor’s selection of recordkeeper or custodian and
authorization from the plan sponsor.
Rockefeller Personalized Portfolios is a managed account service for
participants who wish to have an investment manager select their
investments from among the Plan’s available investment options and
manage their accounts for them. Participants receive a personalized
investment portfolio that reflects the Rockefeller Personalized
Portfolios investment options and the Participant’s retirement
timeframe, life stages, risk tolerance and overall financial picture,
including assets held outside the Plan (if the participant elects to
provide this information), which may be taken into consideration
when determining the allocation of assets in the participant’s account
Rockefeller Personalized Portfolios does not provide advice for,
recommend allocations of, or manage a participant’s outside or non-
Plan assets. Moreover, Rockefeller Personalized Portfolios will not
include management services for individual stocks, self-directed
brokerage accounts, guaranteed certificate funds, employer-directed
monies or in-plan annuities.
Under Rockefeller Personalized Portfolios, the Plan Sponsor will enter
into a written agreement with Rockefeller Financial and any plan
participant enrolling in the service will have to opt-in to the program.
Rockefeller Financial will have discretionary authority over allocating
the participant’s account, without participant approval of each
transaction. If the plan is subject to ERISA, we agree to be held to a
“fiduciary” standard of care with respect to our management of the
participant’s account.
Rockefeller Personalized Portfolios assets will be monitored,
rebalanced and reallocated periodically (typically quarterly) by
Rockefeller to respond to deviations resulting from market
performance. Participants will receive an account update statement
periodically and can review and update personal information at any
time by calling the Plan’s toll-free customer service number or by
visiting the Plan’s web site.
Enrolled participants must allocate all of their plan account balance
to the Rockefeller Personalized Portfolio assets. Participants are
under no obligation to use these services and are freely able to use
similar services offered by other firms. Participants may cancel their
participation in Rockefeller Personalized Portfolios at any time.
Potential Additional Retirement Services Provided Outside of the
Retirement Plan Agreement
In providing services for retirement plans, including Plans,
(“Retirement Plan Services”), Rockefeller Financial and our PAs 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
with such Plan participants or beneficiaries. If a Plan participant or
beneficiary desires to affect an IRA Rollover from a Plan to an account
advised or managed by Rockefeller Financial, the PA 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 Rockefeller Financial, we and your PA will earn
compensation on those assets, for example, through Client Fees
based on the assets in the participant or beneficiary’s 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 rollover recommendations. The fees and expenses
applicable to an IRA likely will be higher than those paid through the
Plan, and there can be other fees, including IRA termination fees.
If a PA recommends moving retirement assets to Rockefeller
Financial, 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, including, as applicable, for these reasons:
• Greater services and/or other benefits (including holistic
advice and planning) can be achieved with the Rockefeller IRA;
• Consolidation of assets and availability of consolidated
statements and performance reports would be beneficial to
you; and
•
The costs associated with Rockefeller IRA are justified by these
services and benefits.
The PA will disclose relevant information about the applicable fees
charged by Rockefeller Financial in connection with any 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 Rockefeller Financial, our affiliates and our
PAs.
Financial Planning Reports and Analyses
Upon request, Rockefeller Financial will provide clients with reports
and/or analyses 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. Those clients seeking financial
planning services will generally enter into a separate Financial
Planning Services Client Agreement with Rockefeller Financial,
which sets forth the specific financial planning services to be
provided, the reports and analyses that Rockefeller Financial will
provide, and the fees that the client agrees to pay.
The reports and analyses are for informational purposes only and are
based upon information provided by the clients, and is intended to
provide broad, general guidelines on the advantages of certain
financial planning concepts. The reports and analyses do not
constitute a recommendation of any particular technique or
strategy, or of any particular investment type or investment
opportunity.
The reports and analyses 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 the report. Rockefeller Financial will only
act upon your specific instructions. We do not undertake to
monitor your account assets in connection with providing these
financial planning reports and analyses.
Certain reports and analyses may provide projections based on
various assumptions, are hypothetical in nature, are subject to
important limitations, and are not a guarantee of investment returns.
Rockefeller Financial may also provide one or more financial
planning reports or analyses without a separate charge as part of
the overall services provided to its clients.
SMA Dual Contract Arrangements
Rockefeller Financial may also, through dual contract arrangements,
provide Clients with access to certain affiliated and/or third-party
investment managers’ separately managed account strategies
that are not available on the Firm’s Private Wealth Advisory
Platform. Clients investing through a dual contract arrangement
are expected to receive personalized investment advice and
guidance through their PA, including ongoing asset allocation,
investment manager recommendations and monitoring,
rebalancing, account review and other advice. Clients will
separately enter into discretionary advisory agreements with one
or more investment managers that will manage the Clients’
assets on a discretionary basis in
accordance with the investment strategy or strategies selected.
Investment managers available through dual contract arrangements
will be limited.
Dual contract arrangements, to the extent offered, will be offered as
either wrap fee or investment advisory fees plus commission
arrangements. In the latter arrangement, clients are charged asset-
based fees for the investment advisory services provided by
Rockefeller Financial and the investment managers. Investment
advisory fees will be calculated based on an annual percentage of
the value of a client’s assets under management. Brokerage
commissions and/or transaction fees are charged to and deducted
directly from your account for effecting securities transactions and
other brokerage and custody services.
Sub-Advisory Arrangements
The Firm also acts as sub-adviser to investment advisory firms that
manage investments on behalf of variable life insurance policies,
variable annuity policies and other variable contracts. The Firm,
through its PAs, manages accounts on a discretionary basis based on
the investment objectives, policies and other parameters as directed
by the client and/or the client’s investment adviser. The Firm is
compensated by the client’s investment adviser pursuant to an
arrangement as agreed to by the Firm and the investment adviser.
Available Service Features
Customized Advisory Services and Client Restrictions
The Firm will tailor its advisory services to the individual needs of
clients in accordance with the investment mandate for the account.
Clients should communicate to their respective PA in writing any
changes in the client’s financial situation or investment objectives,
and whether the client wishes to impose any reasonable restrictions
on the management of the account or reasonably modify existing
restrictions.
Clients may impose reasonable investment restrictions on the
management of their accounts which, if accepted by Rockefeller
Financial in writing, will apply until changed or withdrawn by the
client or until Rockefeller Financial 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.
Management by Certain Advisory Affiliates
Certain advisory accounts will receive advice from Rockefeller Asset
Management (“RAM”), a division of Rockefeller & Co., which is
actively involved in managing certain equity and fixed income
investments on the Firm’s Private Wealth Advisory Platform. These
or other advisory affiliates may provide additional services in the
future. Further, clients are from time to time offered access to
mutual funds, private funds, and other securities offered and/or
managed by RAM, Viking, or other advisory affiliates of Rockefeller
Financial.
Assets Under Management
As of December 31, 2023, Rockefeller Financial’s Regulatory Assets
Under Management were $51,821,018,176 which includes assets for
services described in this Brochure as well as the Wrap Fee Brochure.
Of those Regulatory Assets Under Management, $48,914,897,306
was managed on a discretionary basis, and $2,906,120,870 was
managed on non-discretionary basis.
