Overview
I. Firm Overview
RBC Global Asset Management (U.S.) Inc.
(“RBC GAM-US” or “the Adviser”) was formed in 1983
and is registered as an Investment Adviser with the U.S.
Securities and Exchange Commission (“SEC”), pursuant
to the Investment Advisers Act of 1940, as amended (the
“Advisers Act”). RBC GAM-US is also a member of the
National Futures Association (“NFA”) and registered as a
Commodity Trading Advisor (“CTA”) with the Commodity
Futures Trading Commission (“CFTC”), pursuant to the
Commodity Exchange Act (“CEA”). The firm is an
indirect, wholly-owned subsidiary of the Royal Bank of
Canada (“RBC”). RBC is publicly held and traded on the
New York Stock Exchange and Toronto Stock
Exchange.
RBC GAM-US is a part of RBC Global Asset
Management (“RBC GAM”), the asset management
division of RBC. RBC GAM operates as a global firm
and leverages the talent and investment capabilities
across RBC GAM to create solutions for its clients.
When used herein, the RBC GAM group of companies
includes the following affiliates, all indirect, wholly-owned
subsidiaries of RBC: RBC GAM-US, RBC Global Asset
Management Inc. (“RBC GAM Inc.”), RBC Global Asset
Management (UK) Limited (“RBC GAM-UK”), RBC
Global Asset Management (Asia) Limited (“RBC GAM-
Asia”) and RBC Indigo Asset Management Inc.
This Brochure describes the investment advisory
services of RBC GAM-US. To comply with the Advisers
Act, RBC GAM-US provides this Brochure to persons
who receive or who are considering investment advisory
services from RBC GAM-US.
II. Advisory Services
RBC GAM-US seeks to develop a full understanding of
each client’s investment needs and meet those needs
with equity, fixed income and cash management
solutions. These solutions are available to a broad range
of institutional clients through the following vehicles:
• Institutional separate accounts (“Separate
Accounts”)
• Open-end investment companies registered under
the Investment Company Act of 1940, as
amended (“Mutual Funds”)
• Other pooled investment vehicles, including
private funds (“Private Funds”) and CLOs
(together with Mutual Funds collectively “Pooled
Investment Vehicles”)
• Wrap fee programs (“Wrap Fee Accounts”)
• Model Portfolios
(each an “Advisory Account”).
In some cases, RBC GAM-US utilizes non-U.S. advisory
affiliates, or such affiliates’ personnel, to perform
services through various intercompany arrangements,
including sub-advisory relationships, personnel sharing
and “participating affiliate” arrangements. In participating
affiliate arrangements, certain personnel of certain of our
non-U.S. advisory affiliates act as “associated persons”
in providing such services pursuant to a memorandum of
understanding between RBC GAM-US and such non-
U.S. advisory affiliate, and in that capacity are subject to
our supervision and oversight. We, each participating
affiliate, and any such personnel, will act according to a
series of SEC no-action relief letters mandating that
participating affiliates remain subject to the regulatory
supervision of both RBC GAM-US and the SEC.
RBC GAM-US can, in its discretion, delegate all or a
portion of its advisory or other functions (including
placing trades on behalf of Advisory Accounts) to any
affiliate that is registered with the SEC as an investment
adviser or utilize personnel under a participating affiliate
arrangement to perform such services. To the extent
RBC GAM-US delegates advisory or other functions to
affiliates that are registered with the SEC as investment
advisers, a copy of the brochure of each such affiliate is
available on the SEC’s website and will be provided to
clients or prospective clients upon request. RBC GAM-
US can also engage affiliated or unaffiliated sub-
advisers to provide advisory services to a Pooled
Investment Vehicle.
Additionally, RBC GAM-US provides investment
advisory services as an adviser, sub-adviser or Model
Portfolio Provider for investment companies, Wrap Fee
Accounts and Model Portfolio programs offered by other
investment managers or sponsors.
A. Separate Accounts
RBC GAM-US provides investment management
solutions to clients in the form of Separate Accounts.
Fees and services for each arrangement are individually
negotiated. Some Separate Account clients choose to
impose restrictions on investing in certain securities or
types of securities. Any such restrictions are specified in
the client’s written investment policy or other governing
documents. RBC GAM-US assesses compliance with
each client’s investment policy or other governing
documents through automated and manual reviews (as
discussed in Item 13, below). The fees and services for
Separate Account advisory services arrangements are
generally based upon a percentage of assets under
management. For additional information on fees, refer to