First Trust Advisors L.P. (“FTA”) was formed in 1991 as an Illinois limited partnership. The general partner of
FTA is The Charger Corporation (“Charger”). FTA has one limited partner, Grace Partners of DuPage L.P.
(“Grace”). The general partner of Grace is Charger. Grace has a number of limited partners.
FTA provides (1) supervisory and administrative services (“Portfolio Services”) to unit investment trusts (“UITs”)
sponsored by First Trust Portfolios L.P. (“FTP”), a n FTA affiliate, (2) discretionary advisory services
(“Advisory Services”) as investment advisor to open-end funds (“OEFs”), including exchange-traded funds
(“ETFs”), closed-end funds (“CEFs”), variable annuity sub-account investment funds (“VIT”) registered with the
SEC (“collectively US Funds”), undertakings for collective investment of transferable securities (“UCITs”)
registered in Ireland and funds registered in Canada through FT Portfolios Canada Co., an affiliate of FTA
(collectively with the UCITs, “Non-US Funds”) (US Funds and Non-US Funds collectively, “Institutional
Clients”), (3) Advisory Services on a discretionary basis to individuals and institutional investors through
separately managed accounts (“SMAs”) and (4) non-discretionary model portfolios (“Models”) to unaffiliated
registered investment advisors (“RIAs”) and Model program platforms (“Platforms”).
Portfolio Services – UITs
FTP sponsors the First Trust UITs. A UIT is a pooled investment vehicle in which investors own a fractional
undivided interest or unit in a portfolio of securities. FTA provides the following Portfolio Services to FTP-
sponsored UITs:
• Portfolio Supervisory Services - FTA provides ongoing monitoring of securities held in each UIT
portfolio and is responsible for determining when it may be advisable to remove a security from a
portfolio, as well as which securities should be sold to meet redemptions and pay expenses, as needed.
For certain UIT portfolios invested in certain asset classes, FTA may employ one or more sub-
portfolio supervisors at its own expense to assist in providing services to such UITs.
• Administrative Services - FTA also provides certain bookkeeping and other administrative services
to the UITs.
Advisory Services – US Funds and Non-US Funds
FTA provides discretionary Advisory Services to Institutional Clients. FTA enters into an advisory agreement
(“Advisory Agreement”) with each Institutional Client. The Advisory Agreement describes the Advisory Services
to be provided, including investment discretion, trading and proxy voting authority and the advisory fee
(“Advisory Fee”) paid to FTA by each Institutional Client.
The prospectus and statement of additional information, as applicable, of each Institutional Client (“Fund
Documents”) describes the investment management strategy, objectives and restrictions under which FTA and/or
the Sub-Advisor(s) (defined below) must manage each Institutional Client’s portfolio of securities.
Certain Institutional Clients are index-based ETFs which require FTA to manage the portfolio in compliance with
each ETF’s investment objective to seek investment results that correspond generally to the price and yield (before
the Fund’s fees and expenses) of a designated index as described in the Fund Documents.
Other Institutional Clients are actively-managed OEFs, CEFs, ETFs and Non-US Funds which require FTA to
make discretionary investment decisions on the securities in a Fund’s portfolio in compliance with each Fund’s
investment objective and strategy as described in the Fund Documents.
FTA may engage discretionary and non-discretionary sub-advisors (“Sub-Advisors”) to manage certain
Institutional Client portfolios due to the expertise of a particular Sub-Advisor in a specific asset class. Each Sub-
Advisor enters into a sub-advisory agreement (“Sub-Advisory Agreement”) with FTA, which describes the sub-
Advisory Services to be provided including investment discretion, proxy voting and trading authority, and the
sub-advisory fee paid to the Sub-Advisor by FTA for its services to the Institutional Client. Some Sub-Advisors
are affiliates of FTA.
FTA, and/or the Sub-Advisors provide Advisory/sub-Advisory Services which include securities in various asset
classes including, but not limited to:
• Domestic and foreign equity securities;
• Domestic and foreign fixed income securities (both investment grade and non-investment grade);
• U.S. government and foreign sovereign debt fixed income securities,
• Municipal securities,
• Preferred securities,
• Mortgage- and asset-backed securities,
• Real-estate investment trusts,
• Master limited partnerships,
• First Trust and/or third-party CEFs and ETFs,
• Depositary receipts,
• Commodities,
• Derivatives, and;
• Senior loans.
Discretionary and non-discretionary Sub-Advisors of Institutional Clients are subject to supervision by the relevant
board of trustees/directors, as well as FTA oversight.
Advisory Services – SMAs
SMAs are typically in programs offered by one or more RIAs, broker-dealers or other financial services firms
(“Program Sponsors”) offering a package of financial services to participants (“Participants”) in the program
(“Wrap Programs”). FTA provides discretionary Advisory Services to Wrap Program Participants who select an
FTA-advised investment strategy. Some FTA SMAs are held in structures outside of Wrap Programs. FTA
receives an Advisory Fee for Advisory Services provided to SMAs.
Advisory Agreements are entered into
with Wrap Program Participants or Program Sponsors. When a Program
Sponsor enters into an Advisory Agreement with FTA to provide Advisory Services under one or more investment
strategies to its Wrap Program Participants, it is referred to as a “single contract” relationship (“Single Contract”).
When a Wrap Program Participant enters into an Advisory Agreement directly with FTA to provide Advisory
Services under one or more of its investment strategies, it is referred to as a “dual contract” (“Dual Contract”)
relationship.
Advisory Agreements in Single and Dual Contract relationships generally include the Advisory Fee paid to FTA
for its Advisory Services, FTA investment strategies offered to Wrap Program Participants and Advisory Services
to be provided by FTA. These Advisory Agreements also include details regarding trade execution, custodian
identification, proxy voting authority and directed brokerage instructions, if any.
Participants should review their Wrap Program disclosure documents for details regarding the services included
in the fee each Participant pays to the Program Sponsor (“Wrap Fee”). FTA’s Advisory Fee is included in the
Wrap Fee paid by Participants.
Information regarding a Participant’s investment objectives and restrictions, investing experience, financial
situation, time horizon, risk tolerance and other information needed to determine if an investment strategy is
suitable for investment by such Participant’s account (“Suitability Information”) is generally provided by the
Program Sponsor at account opening and when changes occur. The Program Sponsor is generally responsible for
determining suitability, but FTA will review Suitability Information received and forward any issues regarding
the chosen investment strategy to the Program Sponsor.
SMAs outside of Wrap Programs are generally Single Contract relationships where FTA and the RIA enter into
an Advisory Agreement which describes, among other things, the Advisory Services and Advisory Fee paid under
the Advisory Agreement. The FTA strategies offered under these Advisory Agreements are generally invested in
fixed-income securities. The RIA provides FTA with Suitability Information regarding each of these investors but
is responsible for the suitability determination under the Advisory Agreement.
For any FTA investment strategy, there is no real difference between the way FTA manages discretionary
Participant accounts and the way it manages Institutional Client accounts or other non-Wrap Program SMAs.
FTA may agree to reasonable SMA client imposed restrictions on investing in certain securities or types of
securities. Such restrictions may affect the performance of such account. If FTA is unwilling to agree to such
restrictions, or if the restrictions are unreasonable, FTA will decline to manage or withdraw from managing such
account. FTA reserves the right, in its sole discretion, to decline to manage the account of any investor for any
reason.
Model Portfolios
SMA Models
FTA provides SMA Models that follow a particular investment strategy to various Model Platforms that subscribe
to FTA Models. The SMA Models are generally used as part of the management of unaffiliated RIA client
portfolios. FTA provides Models under an agreement with Program Sponsors who maintain Programs that make
models from various asset management firms available to RIAs for use in providing investment advisory services
to their clients. FTA monitors and updates each Model on a regular basis and delivers updates to the relevant
Platforms as appropriate.
FTA does not have an advisory relationship with Platforms who make FTA Models available to their RIAs or
their clients and does not invest such client assets. The RIA retains investment authority and brokerage discretion
for client portfolios following FTA Models. The RIA does not provide Suitability Information to FTA and is
responsible for suitability reviews for these accounts.
ETF Models
FTA also provides non-discretionary Models which include First Trust and/or third-party ETFs to Platforms
and/or other RIAs to provide RIAs with a foundation to build scalable asset allocation solutions for their clients
(“ETF Model Program”). In an ETF Model Program, FTA provides ETF Models under an agreement with
Platforms. FTA monitors and updates each ETF Model on a regular basis, generally quarterly, and delivers
updates to the Platforms as appropriate. The ETF Models use non-First Trust ETFs representing various other
asset classes to complete the allocations where First Trust does not offer an ETF in a particular asset class. Some
of the ETF Model portfolios provided by FTA utilize the expertise of Sub-Advisors in the ETF selection process.
These are typically no fee Models.
In ETF Model Programs FTA does not have an advisory relationship with ETF Model Program clients and does
not invest such client assets. The RIA retains investment authority and brokerage discretion for client portfolios in
the ETF Model Program. The RIA does not provide Suitability Information to FTA and is responsible for
suitability reviews for each ETF Model Program client.
If requested, FTA may also offer certain consulting and advisory services, including analyzing an existing
portfolio, providing advice regarding portfolio construction and investment strategy, etc.
Assets Under Management or Supervision
As of December 31, 2023, FTA had approximately $210.879 billion in assets under management or supervision.
Of this amount, approximately $56.895 billion was in non-discretionary client portfolios and approximately
$153.984 billion was in discretionary client portfolios.