Aon  Investments USA Inc.  is a registered investment 
adviser with the U.S. Securities and Exchange 
Commission (“SEC”); a Commodity Pool Operator 
(“CPO”) and a Commodity Trading Advisor (“CTA”) 
registered with the Commodity Futures Trading 
Commission (“CFTC”); and is a member of the National 
Futures Association (“NFA”) with its principal place of 
business located in Chicago, Illinois. References to “we”, 
“us”, “our”, “the firm”, “AIUSA” and “Aon” refer to Aon 
Investments USA Inc.  unless the context otherwise 
requires.  
We  provide professional investment advisory and 
consulting services to institutional clients including, but 
not limited to, defined benefit and defined contribution 
plans (public and private), not-for-profit organizations, 
insurance companies,  and registered investment 
advisers/wealth managers. Beginning in 2018, the firm 
began operating under the umbrella brand name, “Aon”. 
In March 2020, the firm changed its legal business name 
from Aon Hewitt Investment Consulting, Inc.to  Aon 
Investments USA Inc. The firm is wholly owned by Aon 
Consulting, Inc.  (“Aon Consulting”), an indirect 
subsidiary of its ultimate parent, Aon plc. Aon plc shares 
are listed on the New York Stock Exchange (symbol: 
AON).  
AIUSA  is headquartered in Chicago, Illinois  and has 
offices across the U.S. We  provide  discretionary 
investment management and  non-discretionary 
investment advice and certain actuarial related services 
related to clients’ investment programs and operations, 
including:  
o  Investment Policy Planning and Asset Allocation; 
o  Wealth Management  
o  Manager Evaluation and Selection;  
o  Performance Review and Manager Monitoring;  
o  Alternative Asset Advisory Services;  
o  Outsourced Chief Investment Officer  Services; 
o  Pension Risk Management; 
o  Direct Investment Funds;  
o  Bespoke Services; and 
o  Other Services.  
Additional information regarding each of the above 
services is provided below. In addition to the services 
listed,  we  offer related services including defined 
contribution services and asset transition services.  
Investment Policy Planning and Asset Allocation  
We help clients to:  
o  Define and control risk for their specific 
requirements;  
o  Diversify their investment portfolio(s);  
o  Develop investment objectives and a statements of 
investment policy;  
o  Meet cash flow needs; and  
o  Conduct scenario analyses on their portfolio(s) as 
well as evaluate alternative portfolios.  
Our Investment Policy Services Team (“IPS Team”) 
Investment Manager Research (“IMR Team”) and Global 
Asset Allocation Team (“GAA Team”), collectively 
referred to in this section as the “Teams”, are composed 
of investment professionals with backgrounds in 
investment management, economics, and actuarial 
science. The Teams are responsible for maintaining our 
proprietary  investment views and capital market 
assumptions.  
The Teams also provide timely, proactive advice and 
research to our investment consultants regarding the 
potential investment implications of changes in capital 
markets and our capital market assumptions. Additional 
responsibilities include coordinating with our 
investment consultants to provide clients with top-
down, strategic investment advice; researching new 
investment strategies; and monitoring portfolio 
positions from an asset allocation perspective.  
Certain clients hire us to construct dynamic “de-risking” 
glide paths to help bring their pension plans to a fully 
funded status while reducing uncompensated risks, with 
the goal of reducing the economic cost of plan benefits. 
The dynamic “de-risking” glide path is directly 
incorporated into the client’s investment policy to 
formalize the strategy, permit execution, and seek to 
ensure the appropriate  levels of oversight within the 
client’s governance structure.  
Wealth Management 
The  Wealth Management Team  provides non-
discretionary model portfolios (“Model Portfolios”), 
manager selection, strategic asset allocation advice, and 
related advisory services to certain institutional and 
retail  advisory firms  not affiliated with Aon, including 
certain open-end mutual fund companies and wrap-fee 
program sponsors in connection with third-party wrap-
fee programs.  
We do not sponsor any wrap-fee programs, but we may 
provide non-discretionary investment advisory services 
to sponsors of wrap-fee programs.  Under  such 
arrangements, we provide Model Portfolios containing 
our current investment recommendations based on 
clients’  model portfolio investment policy statements 
and strategic goals or other parameters as agreed to 
between  Aon  and  such  client. Although we provide 
recommendations, we do not have the authority to 
implement those recommendations. Ultimately, clients 
retain discretion and remain responsible for asset 
allocation determinations and securities selections. 
Clients  also maintain responsibility for effecting all 
security transactions in connection with such asset 
allocation  determinations  and securities selections, 
which means a  client’s  portfolio(s)  may materially 
diverge from the Model Portfolio created for such client. 
There may be differences between the Model Portfolio 
and the portfolios managed by our Wealth Management 
Team for other Aon clients. We receive a fee from our 
clients  as an investment adviser for the services 
provided in these programs.  
Manager Evaluation and Selection  
We  rely  on investment research generated by the 
Investment Manager Research Team (“IMR Team”). The 
IMR Team  is  primarily focused on  researching and 
evaluating non-affiliated investment managers 
worldwide and consists of investment professionals 
from AIUSA and its global investment advisory affiliates. 
Our  IMR  Team monitors and rates non-affiliated 
investment managers’ strategies. Certain of the 
investment managers the  IMR  Team reviews may 
participate in the Aon  Wealth Insights Series 
Conferences or similar Aon hosted events (collectively, 
the “AWIS Conferences”), which are sponsored by Aon 
Consulting and further described below. Participation in 
the AWIS Conferences is not and may not be considered 
in the IMR Team’s investment manager evaluation and 
selection process. Please see “Other Services” below for 
additional detail and Item 5 – Fees and Compensation 
for information related to indirect compensation AIUSA 
and/or its affiliates may receive in relation to the AWIS 
Conferences.  
The  IMR  Team identifies  and evaluates investment 
managers and strategies across  various asset classes, 
including equities, fixed income, real estate equity and 
debt, private equity and debt, and alternative asset 
classes.  Qualitative ongoing periodic due diligence is 
then conducted on buy-rated and certain qualified-rated 
managers. (A discussion of AIUSA’s manager ratings is 
contained in the section below entitled “Performance 
Review and Manager Monitoring”.) The IMR Team also 
conducts  periodic quantitative screens on its manager 
universe, including investment managers that are not 
currently classified as buy-rated  or qualified-rated 
managers.  As part of its evaluation of an investment 
manager, the IMR Team has an agreement with Aon’s 
operational risk consulting practice, the Operational 
Risk  Solutions and Analytics (“ORSA”) Group  of Aon 
Consulting to provide due diligence reviews assessing an 
investment manager’s non-investment risks relating to 
its business structure,  activities, operations, and 
compliance practices.  The  IMR  Team includes several 
former investment fund managers, which we believe 
provides further insight into investment managers. The 
research generated by the IMR Team is shared among 
Aon’s investment advisory affiliates. 
The  IMR  Team establishes model building block 
portfolios to guide our investment professionals in 
reviewing the number and types of managers, funds, 
and separate account strategies used by clients. The IMR 
Team building block portfolios take into consideration 
an analysis of factors such as efficiency, costs, and 
management oversight. Further, the IMR  Team’s due 
diligence process is leveraged by our discretionary and 
non-discretionary investment advisory teams to screen, 
interview, and select manager candidates that meet 
each client’s needs.  
Performance Review and Manager Monitoring  
Our manager research efforts are driven by several 
factors including, but not limited to, efforts to identify 
new investment strategies or approaches, monitor 
investment strategies to which we have assigned a 
rating, and monitor strategies in which clients invest. We 
conduct both qualitative and quantitative research and 
screening on investment strategies.  
Qualitative research includes ongoing discussions and 
periodic due diligence meetings with investment 
managers to assess investment strategies offered by the 
relevant firm. Qualitative research is performed on 
strategies in which we assign a “buy” recommendation. 
Qualitative research also  is  performed on select 
“qualified”, “not  recommended”,  or “sell” rated 
strategies depending on client requirements or  at  the 
IMR Team’s discretion.  
For those strategies rated with our quantitative process, 
including “not  recommended” rated strategies held in 
client portfolios, the quantitative assessment is updated 
quarterly  and  serves as a monitoring tool and 
information source for our researchers, consultants, 
and/or clients that may utilize the strategies  in their 
portfolio(s).  In certain instances, the quantitative 
assessment may be updated less frequently than 
quarterly due to factors outside of our control. These 
factors include but are not limited to insufficient or 
incomplete data provided by third parties.  
Assessments, whether qualitative or quantitative, focus 
on  a firm’s overall  business/organization, staffing, 
investment process, risk management, operational 
considerations, performance, and terms and conditions, 
(as they relate to use of a firm’s strategies or pooled fund 
offerings). When evaluating investment strategies for a 
client, the IMR  Team also considers the  prospective 
investment in the context of the client’s investment 
objectives and guidelines. We inform clients of 
important developments and, when appropriate, may 
recommend changing investment managers, 
investment strategies,  or the asset allocation to such 
investment managers or strategies.  
Certain investments with liquidity constraints (which 
generally include private funds  and closed-end funds) 
are monitored by the IMR Team by reviewing manager 
quarterly reporting and financial statements, and to the 
extent necessary, periodic calls  to ensure that the 
manager continues to adhere to
                                        
                                        
                                             the strategy. 
Alternative Asset Advisory Services  
Our Global  Liquid Alternatives  (Hedge Funds),  Private 
Equity, and Real Estate Teams (collectively the “Global 
Alternatives Team”) are sub-groups  of the IMR  Team 
discussed above  in the section entitled “Manager 
Evaluation and Selection”. Members of the Real Estate 
Team are dual-hatted colleagues who provide services 
to both AIUSA  and The Townsend Group  (“TTG”), a 
separately registered investment advisory affiliate of 
AIUSA.  
The Global Alternatives Team is responsible for 
maintaining qualitative assessments on buy-rated 
alternative asset manager strategies and keeping 
abreast of the conditions in these markets.  
We provide both discretionary and non-discretionary 
investment advisory services on strategies such as 
private equity, real estate, venture capital 
arrangements, hedge funds, leveraged buyout funds, 
and distressed securities funds.  
With the exception of mutual funds, exchange-traded 
funds, and non-public securities, we do not typically 
provide advice or recommendations on specific 
securities investments. In designing a  client’s 
investment policy, we will typically consider various 
types of investments unless directed  by the client  in 
writing to  exclude or limit specific investments.  Our 
investment recommendations are not limited to any 
specific product or service offered by any particular 
broker-dealer, insurance company, or asset manager.  
Because some types of alternative investments involve 
an additional degree of risk, alternative investment 
strategies will only be recommended to qualified clients 
when  such  recommendation is consistent with the 
client's stated investment objectives, including its 
tolerance for risk, liquidity, and suitability.  
Hedge Fund Advisory Services  
We develop  and monitor a  client’s asset allocation 
structure(s)  in  liquid alternatives or opportunistic 
strategies (e.g., real and absolute return, global tactical 
asset allocation, long/short equity including market 
neutral and 130/30 style funds, commodities, convertible 
arbitrage, and funds-of-funds). We seek to integrate our 
understanding of each client’s goals, risk tolerances, and 
risk qualities of existing portfolios with our manager 
research and monitoring capabilities. We take a broad 
perspective on this opportunity set, covering not only a 
wide variety of hedge funds, but also those strategies 
that use “hedge fund like” approaches to investing. We 
typically conduct on-site and/or  virtual  manager 
meetings annually  on buy-rated strategies  with a due 
diligence process that includes an  examination of 
investment strategy,  fund leadership/management, 
performance, and other factors. Operational  due 
diligence is conducted by ORSA in order for a strategy to 
receive a buy rating. 
Private Equity Advisory Services  
We review and develop a client’s private equity 
investment policy, asset allocation, and portfolio design. 
We conduct global private equity fund selection and due 
diligence reviews within each relevant sub-sector.  We 
provide clients with performance reporting, portfolio 
analysis, and comprehensive portfolio company review. 
We educate clients on secondary sale processes and 
evaluate their portfolio construction decisions. We 
provide private equity education and market analysis, 
including commentary on current issues. We 
recommend commingled private equity investment 
funds as well as separate accounts that are structured 
and classified to meet client needs. From time to time, 
we may engage external counsel to assist in conducting 
due diligence on private equity funds on behalf of 
clients. We may also assist the client in the negotiation 
of  business  terms  for private equity funds.  We  do not 
provide  legal, accounting, valuation,  or tax advice to 
clients under any circumstances  in connection with 
these services. Clients are responsible for obtaining their 
own legal, accounting and tax advice. On occasion, we 
assist clients in hiring a secondary broker, evaluating 
secondary bids  and coordinating administrative 
collection of documents. Under no circumstances does 
Aon act as a Secondary broker nor contact any potential 
buyers. From time-to-time clients may request a list of 
service providers that can assist them in conducting due 
diligence; Aon may provide list(s)  of service providers 
upon request as a courtesy but does not recommend or 
advise on the suitability of such service providers. 
Additionally,  Aon is not compensated by service 
providers for inclusion on any such list.    
Real Estate Advisory Services  
We leverage our real estate research, which is conducted 
by  TTG  to consult with  clients on the  development, 
implementation,  and monitoring of  their real estate 
portfolio investment objectives, programs, and policies 
and to select managers for our real estate funds. Our real 
estate investment strategic planning and 
implementation services include:  
o  Investment pacing, size, and strategy 
diversification;  
o  Investment vehicle analysis and planning;  
o  Property and portfolio leverage planning;  
o  Manager search, selection, and monitoring;  
o  Performance measurement and attribution analysis;  
o  Topical real estate research and market analysis; 
and  
o  Transition structure and terms modeling, analysis, 
and fee negotiations.  
We will not consult or make recommendations to clients 
related to investment solutions offered by TTG.  
Outsourced Chief Investment Officer (“OCIO”) 
We  design and manage clients’ investment portfolios 
through our OCIO solutions. For these client 
relationships, we are delegated the authority to hire 
investment managers, terminate the services of 
investment managers, select investments, and 
rebalance portfolio assets subject to the client's 
investment policy statement and other terms outlined in 
the investment management  agreement. Please see 
Item 16 for more information about our OCIO solutions.  
Our OCIO solutions are dedicated to the development, 
implementation,  and execution of  solutions  for our 
clients  within  the  guidelines  of each  client  and its 
Investment Policy Statement  (or other investment 
guidelines). These  solutions  also generally utilize 
investment strategies designated as “buy-rated” by the 
IMR Team. (A discussion of AIUSA’s manager ratings is 
contained in the section above entitled “Performance 
Review and Manager Monitoring”.) The OCIO solutions 
team  utilizes  a variety of investment managers and 
investment vehicles.  
Our Portfolio Implementation  team leverages the 
expertise of individuals with backgrounds in investment 
management and actuarial science. The team is 
responsible for managing portfolio  risk in general, 
including performing asset-liability analyses, 
monitoring portfolio positions from an asset-liability 
perspective, and designing custom interest rate risk 
management portfolios utilizing derivative strategies.  
Certain clients that receive non-discretionary 
investment advisory services may also have a portion of 
their portfolio(s)  managed by our OCIO team.  In such 
cases, we  provide non-discretionary (ERISA Section 
3(21)) advisory services and  exercise discretionary 
management authority (ERISA Section 3(38)  with 
respect to the  portion of the client’s portfolio(s) for 
which  such client delegates investment discretion to 
AIUSA.  AIUSA  qualifies as a “Qualified  Professional 
Asset  Manager” under the U.S. Department of Labor 
(“DOL”) Prohibited Transaction Class Exemption 84-14. 
As part of our OCIO solutions, clients may delegate to 
AIUSA the authority to invest in funds for which AIUSA 
or an affiliate serves as fund  sponsor or investment 
adviser (“Aon Funds”) if such funds are suitable for the 
client.  Client authorization  to utilize Aon Funds  is not 
required as part of our OCIO solutions, and we believe 
that  we  can  offer scaled pricing to clients investing in 
Aon Funds that may not otherwise be available to such 
clients.  Aon Funds consistently reflect our investment 
beliefs in terms of managers and portfolio structure. For 
clients that do not want to utilize Aon Funds (as a part of 
their OCIO solution) they should notify AIUSA in writing. 
Our non-discretionary investment advisory services do 
not  include  any advice or recommendation as to the 
prudence  of using AIUSA’s  OCIO  solutions  or other 
AIUSA services or products.  
Bespoke Services  
Some clients  elect to customize their investment 
portfolios to reflect unique and specific needs and goals, 
such as by imposing reasonable investment restrictions 
on certain securities, industries, or sectors or managing 
a portfolio to a tax-efficient mandate.  
Certain clients may also contract with AIUSA for 
consulting services related to responsible  investing.  
Investment strategies focused on responsible investing 
may seek to, among other objectives, achieve 
sustainability-related outcomes, achieve exposure to 
particular responsible investing characteristics or 
themes, and/or screen out certain companies and 
industries.  Responsible  investing services may be 
utilized through non-discretionary investment services, 
OCIO services, and/or  in limited circumstances as a 
stand-alone offering.   
Other Services 
AIUSA, in conjunction with certain of its global affiliates 
participates in the  AWIS  Conferences.  The  AWIS 
Conferences provide educational meetings and events. 
AIUSA also uses the AWIS Conferences as a format to 
identify prospective clients. These meetings and events 
may be attended by both prospective and current AIUSA 
clients, as well as investment management firms and 
investment service providers.     
AIUSA Regulatory Assets Under Management  
As of December 31, 2023, we had approximately $118.5 
billion of regulatory assets under management. 
Assets Under Advisement (“AUA”) may appear in client 
and  sales materials in addition to  AIUSA’s  regulatory 
Assets Under Management (“AUM”). AUA is presented 
when, due to the nature of the contractual agreements 
with  certain  clients,  we  provide consultative advice to 
our clients in a non-discretionary capacity and do  not 
maintain  discretionary authority over the clients’ 
portfolio(s). In such relationships, the clients  maintain 
the ability and authority to manage and allocate assets 
within their own portfolio(s) independent of our advice. 
Therefore,  these clients are not reflected within 
regulatory assets under management. Instead, these 
engagements are represented as part of AIUSA’s AUA. 
In the instance that AUA is listed in client or sales 
materials it will be accompanied by relevant disclosure 
indicating how AUA has been calculated.