Thornburg Investment Management, Inc. (“Thornburg”) is a privately held investment management company
based in Santa Fe, New Mexico and organized as a corporation under the laws of Delaware. Thornburg is
registered as an investment adviser with the U.S. Securities and Exchange Commission (“SEC”), holds a
foreign financial service license in Australia, files international adviser exemptions in several Canadian
provinces, and is the parent of non-U.S. entities that are registered in Hong Kong and China. Garrett
Thornburg founded Thornburg in 1982 and currently beneficially owns 100% of Thornburg’s voting shares. As
of December 31, 2023, Thornburg managed $41,832,394,631 in client assets on a discretionary basis and
$1,106,115,969 in UMA/model assets.
Thornburg provides discretionary portfolio management and investment services to a number of client types,
including:
• Thornburg Investment Trust (the “Trust”), a diversified, open-end management investment company
registered under the Investment Company Act of 1940, and having a number of separate publicly
available investment portfolios represented by separate series of shares (each, a “Fund,” and
together, the “Thornburg Mutual Funds”);
• Thornburg Income Builder Opportunities Trust (“TBLD”), a diversified, closed-end management
investment company registered under the Investment Company Act of 1940;
• Thornburg Global Investment plc (“TGI”), an umbrella investment company with several sub-funds,
authorized and regulated by the Central Bank of Ireland pursuant to the European Communities
(Undertakings for Collective Investment in Transferable Securities) Regulations, 2011, as amended.
• registered investment companies as to which Thornburg is a subadviser;
• separate accounts for institutional clients (“Institutional Separate Accounts”);
• separate accounts for private clients (“Private Client Separate Accounts” and together with
Institutional Separate Accounts, “Separate Accounts”);
• separate accounts for clients in third party wrap fee programs (“Wrap Programs” and “Wrap
Program Accounts”); and
• private investment funds and other non-SEC registered investment vehicles (“Other Pooled
Investment Vehicles”).
Thornburg also provides nondiscretionary advice in unified managed account programs (“UMA Programs”).
Additional detail about each of these client types is provided in Item 7, Types of Clients, below.
Except
for certain relationships, including Wrap Programs as discussed below, Thornburg generally performs
advisory services for each client under the terms of an investment advisory agreement with that client.
Thornburg offers clients a range of investment strategies, which can include the Thornburg Mutual Funds.
Within a given investment strategy – and consistent with the stated investment objectives, policies and
restrictions of that investment strategy – Thornburg typically exercises exclusive investment discretion
regarding the purchase or sale of securities or other investments. Thornburg may also agree to manage a
client’s account subject to certain reasonable restrictions that the client imposes on the inclusion of specific
securities, or types of securities, within that account. Additional detail about Thornburg’s investment
strategies is provided in Item 8, Methods of Analysis, Investment Strategies and Risk of Loss, below.
Thornburg has also been retained as an investment manager under a number of Wrap Programs established
by certain unaffiliated sponsors. Wrap Program clients typically enter into an investment advisory agreement
with the sponsor and the sponsor enters into a sub-advisory agreement with Thornburg to provide portfolio
management services to the Wrap Program clients. The sponsor is responsible for analyzing the financial
needs of each particular Wrap Program client and determining that Thornburg’s portfolio management
services are suitable for that client. With some exceptions, Thornburg manages Wrap Program accounts in a
manner that is generally similar to Private Client Separate Accounts. Differences include limited flexibility of
Wrap Program accounts to customize investment guidelines and certain Wrap Program sponsors may not
allow their clients to hold securities issued by the sponsor.
Clients Subject to ERISA. To the extent a client account is subject to the Employee Retirement Income
Security Act of 1974 (“ERISA”), the client must inform Thornburg of any employer securities the client is not
permitted to own under ERISA. In addition, in order to rely on the class exemption for qualified professional
asset managers, the client must provide Thornburg with the name(s) of any “party in interest” as defined in
Section 3(14) of ERISA and every party with the authority to appoint or terminate Thornburg as investment
adviser or to negotiate the terms of an investment management agreement with Thornburg.