A. Advisory Firm Description
Ullico Investment Advisors, Inc. (“UIA” or “Firm”) registered with the SEC in April 1990 as an
investment adviser under the Investment Advisers Act of 1940, as amended. UIA is 100% owned by
Ullico Inc., a privately held stock company. The stock of Ullico Inc. is primarily owned by pension
funds and other union-affiliated organizations.
Ullico Infrastructure Management Company, LLC (“UIMC) and UIA Investment Management, LLC
(“UIA-IM”), which are UIA subsidiaries, and UIF GP, LLC, Ullico ISCF, LLC, Ullico DIEF, LLC and
Ullico Value-Add Fund I GP LLC, which are the General Partners of private funds wholly owned by
UIA, are filing as Relying Advisers in reliance upon an umbrella registration of UIA.
B. Advisory Services Description
UIA was established to provide investment services to institutional investors. UIA offers a diverse
range of investment products in traditional equity, fixed income, and alternative investments. UIA
operates primarily across four investment groups: (i) Ullico Infrastructure Management Company,
LLC, a UIA Relying Adviser managing infrastructure investments; (ii) UIA Investment Management,
LLC, a UIA Relying Adviser providing fixed income management services; (iii) Real Estate Debt
Group, managing privately issued mortgages on commercial properties; and (iv) Real Estate Equity,
managing ownership of commercial real estate. UIA also manages multi-manager international equity
portfolios.
UIA provides investment management services to institutional investors through (i) separately managed
accounts and (ii) privately offered commingled investment funds that are exempt from the registration
requirements of the Securities Act of 1933, as amended and the Investment Company Act of 1940, as
amended (“Private Funds”). UIA-advised Private Funds include limited partnerships, insurance
company separate accounts, and collective investment funds.
In certain cases, UIA has hired unrelated investment advisers to research and select securities and
execute trades. Unrelated sub-advisers have been retained to manage one separately managed account
strategy (Domestic Small Cap Value Equity) and two of the Private Funds (Ullico Diversified
International Equity Fund and Ullico International Small Cap Fund). UIA requires that all of their
unrelated sub-advisers register with the SEC as investment advisers. UIA currently has sub-advisory
agreements with the following unrelated investment advisers:
A. ClearBridge Investments, LLC;
B. William Blair Investment Management, LLC;
C. American Century Investment Management, Inc.;
D. Dimensional Fund Advisors, L.P.;
E. Thompson, Siegel and Walmsley LLC; and
F. Leeward Investments, LLC
The Union Labor Life Insurance Company (“Union Labor Life” or “ULL”) is an affiliate of UIA,
and
an insurance company registered in 50 states and the District of Columbia. UIA has been retained as
investment adviser for several commingled insurance company separate accounts offered through a
group annuity contract issued by Union Labor Life.
In addition, UIA has been retained as an investment adviser for the Ullico J for Jobs Collective
Investment Fund (“J for Jobs CIF”) and Ullico SFA Fixed Income Collective Investment Fund (“SFA
CIF”), both of which are collective investment funds sponsored by Hand Benefits & Trust Company
(“HBT”) under the Hand Composite Employee Benefit Trust.
UIA and Acropolis Investment Management LLC (“Acropolis”) have established Ullico Retirement
Solutions, a financial product solution and investment platform, which is available to defined
contribution, individual account retirement plans offered by employers that employ bargaining unit
employees, labor organizations that employ individuals in furtherance of their exempt activities, and
trustees or other sponsors of multiemployer plans. Under the terms of the agreement with Acropolis,
UIA will receive compensation for the sales of Ullico Retirement Solutions.
C. Tailoring Advisory Services
For clients with separately managed accounts, UIA tailors advisory services to the individual needs of
the clients. Clients with separately managed accounts may impose restrictions on investing in certain
securities or types of securities. The investment advisory services provided by UIA to Private Funds
structured as limited partnerships are outlined in each Fund’s private placement memorandum, limited
partnership agreement, subscription documents, or other related documents. Investors invested in
UIA’s limited partnership Private Funds may not impose restrictions on investing in certain securities
or types of securities. UIA advises the J for Jobs and SFA CIF’s subject to limitations set forth in the
CIF’s Investment Policy Statements provided by HBT. UIA manages the Union Labor Life
commingled insurance company separate accounts subject to the investment guidelines set forth in the
Plan of Operations and disclosure memoranda.
D. Wrap Fee Program
A wrap fee program is defined by the SEC as any advisory program under which a specified fee or fees
not based directly upon transactions in a client’s account is charged for investment advisory services
(which may include portfolio management or advice concerning the selection of other investment
advisers) and the execution of client transactions. UIA does not participate in any wrap fee programs.
E. Assets Under Management
As of December 31, 2023 UIA managed $11,318,266,665 in regulatory assets under management on a
discretionary basis. UIA does not have any regulatory assets under management that are managed on
a non-discretionary basis.