General Description of Firm Wilmington Trust Investment Advisors, Inc. (“WTIA,” “our,” “we” or the “Firm”), founded in 1995, is a wholly owned direct subsidiary of Manufacturers and Traders Trust Company (“M&T Bank”), which is a subsidiary of M&T Bank Corporation, a publicly traded bank holding company (NYSE: MTB). WTIA principally provides investment management services to institutional clients, including to its affiliates, Wilmington Trust, N.A. (“WTNA”), Wilmington Trust Company (“WTC”), M&T Bank, and other subsidiaries of M&T Bank Corporation and their clients. Wilmington Trust is a registered service mark used by certain subsidiaries of M&T Bank Corporation (together “Wilmington Trust”). Wilmington Investment Management is a branding name used for investment management-related services offered by the following Wilmington Trust entities: M&T Bank, WTC, WTNA, WTIA, Wilmington Funds Management Corporation (“WFMC”), and Wilmington Trust Investment Management, LLC (“WTIM”). M&T Bank, through its subsidiaries and affiliates, offers a full range of financial services including investment advisory, corporate and retail banking in the communities of the Northeastern and Mid- Atlantic regions, and also offers certain services (including institutional investment management) to clients throughout the U.S. Description of Advisory Services WTIA provides asset management and other investment advisory services to clients including institutions, individuals, high net worth persons, pension plans, defined contribution plans, private foundations, and mutual funds. WTIA offers discretionary and non-discretionary investment management and other advisory services with respect to the following primary areas:
• Equity investing in U.S., developed, developing, and emerging markets small-, and large- capitalization companies
• Fixed income investing in investment grade corporate, municipal and government bonds, U.S. high-yield bonds, emerging markets bonds, and enhanced cash strategies
• Asset allocation strategy investing, including manager selection and portfolio construction using an open architecture approach. Such portfolios are constructed using proprietary asset allocation models that draw upon the Firm's in-house equity and fixed income strengths, supplemented with strategies and products from third party managers
• Alternative asset class investing, including advising with respect to liquid alternatives, hedge funds, private equity funds, and real asset strategies
• Model portfolios based on certain of our investment strategies (“Model Delivery”) that are managed and offered to both affiliated and external financial institutions either directly or through third-party providers that operate platforms or programs. Model Delivery investment portfolio recipients implement WTIA’s recommendations at their discretion. WTIA generally does not have investment discretion or trading responsibilities in connection with Model Delivery arrangements
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Non-discretionary investment advisory services for Defined Contribution Plans using a consultative approach. WTIA provides recommendations to assist plan sponsors in creating an appropriate investment menu for their plan participants
• Non-discretionary Investment Consulting Services including Investment Policy Statement review and development, asset allocation, and manager recommendations. Among other things, WTIA:
• Provides manager and fund research services to M&T Bank, WTNA, and WTC in connection with those affiliates’ Wealth Advisory Services and other offerings
• Serves as the principal sub-adviser to certain portfolios of the Wilmington Funds, an open-end investment company, registered under the Investment Company Act of 1940, and advised by WTIA’s affiliate WFMC
• Acts as a non-discretionary provider of a series of model investment portfolios made available by LPL Financial LLC (“LPL”) to participants in LPL’s Manager Select wrap fee program. Subject to a networking arrangement between LPL and M&T Bank, M&T Bank personnel, acting in their capacity as investment adviser representatives of LPL, recommend the Manager Select program and these models to clients. Additionally, pursuant to an intercompany agreement, WTIA leases members of its investment advisory and other staff to certain of its affiliates, including M&T Bank, WTC, WTNA, WFMC, WTIM, Wilmington Trust Asset Management, LLC (“WTAM”), and People’s United Advisors, Inc., whereby such personnel, as employees of those entities, perform a variety of investment management, research, analytical, due diligence and similar functions to support the activities of such affiliates, including in connection with the Wilmington Funds (“Fund Services”) managed by WFMC, and private funds managed by WTAM. WTIA also leases designated personnel from one or more of WTC, WTNA, and/or M&T to perform certain Fund Services, provide investment management and other services, and/or perform other functions, as employees of WTIA. It is WTIA’s policy to obtain and follow a clear statement of investment policy for each client account, based upon the client’s investment objectives, financial circumstances, investment restrictions, risk tolerance, and other information provided by the client. Clients may impose reasonable investment restrictions limiting investment in certain securities or types of securities. Such investment restrictions are subject to acceptance by WTIA. The advice provided by WTIA in the capacity as an Outsourced Chief Investment Officer combines the services of an investment consultant with the discretionary authority to implement and execute asset allocation, manager selection and investment vehicle decisions within the guidelines of a client’s applicable investment policy statement. As of December 31, 2023, WTIA had $ $16,435,124,934 in discretionary assets under management and $ $61,804,032 in non-discretionary assets under management for a total of $ $16,496,928,966 in total assets under management.