TAM (originally WRL Investment Management, Inc.) was incorporated in Florida in 1996 and has been registered with the SEC
as an investment adviser since 1996. SEC registration does not imply a certain level of skill or training. TAM provides investment
management services to investment companies that are registered under the U.S. Investment Company Act of 1940, as amended
(the “1940 Act”), unregistered pooled investment vehicles, and an affiliated recordkeeper and administrator.
TAM is directly owned by Transamerica Life Insurance Company (“TLIC”) (77%) and AUSA Holding, LLC (“AUSA”) (23%),
both of which are indirect, wholly owned subsidiaries of Aegon Ltd. TLIC is wholly owned by Commonwealth General
Corporation (“Commonwealth”). Commonwealth and AUSA are wholly owned by Transamerica Corporation (DE), a financial
services holding company whose primary emphasis is on life and health insurance, and annuity and investment products.
Transamerica Corporation (DE) is wholly owned by Aegon International B.V., which is wholly owned by Aegon Ltd., a Bermuda
exempted company with liability limited by shares and a publicly traded international insurance group.
Advisory Services
The Fund Complex
TAM primarily sponsors and provides continuous and regular investment management services to investment companies
registered under the 1940 Act in the “Fund Complex” consisting of Transamerica Funds (“TF”) and Transamerica Series Trust
(“TST”), (each a “Fund” and collectively, the “Funds”). TAM supervises each Fund’s investments, conducts its investment
program and provides supervisory, compliance and administrative services to each of those Funds.
TAM is responsible for all aspects of the day-to-day management of certain asset allocation series of TF (Transamerica Asset
Allocation Horizon Funds) and TST (Transamerica 60/40 Allocation VP). In managing these Funds, TAM selects the
combination and amount of the underlying funds and the relative amounts to be invested in each underlying fund based on the
objectives and principal strategies of the asset allocation Funds. TAM is also responsible for all aspects of the day-to-day
management of Transamerica Stock Index, a series of TF, which invests substantially all of its investable assets in securities
through an underlying unaffiliated master fund having substantially the same investment goals and strategies. For each of the
other Funds in the Fund Complex, TAM currently acts as a “manager of managers” and hires subadvisers to furnish day-to-day
investment advice and recommendations. When acting as a manager of managers, TAM provides investment management
services that include, without limitation, the design and development of each Fund and its investment strategy and the ongoing
review and evaluation of that investment strategy including recommending changes in strategy where it believes appropriate or
advisable; the selection of one or more subadvisers for each Fund employing a combination of quantitative and qualitative
screens, research, analysis and due diligence; negotiation of sub-advisory agreements and fees; oversight and monitoring of
subadvisers and recommending changes to subadvisers where it believes appropriate or advisable; recommending Fund
combinations and liquidations where it believes appropriate or advisable; selection and oversight of transition managers, as
needed; regular supervision of the Funds’ investments; regular review and evaluation of subadviser performance; daily
monitoring of the subadvisers’ buying and selling of securities for the Funds; regular review of holdings; ongoing trade oversight
and analysis; regular monitoring to ensure adherence to investment process; regular calls and periodic on-site visits with
subadvisers; portfolio construction and asset allocation when using multiple subadvisers for a Fund; risk management oversight
and analysis; oversight of negotiation of investment documentation and agreements; design, development, implementation and
regular monitoring of the valuation process; design, development, implementation, and regular monitoring of derivatives risk
management; design, development, implementation, and regular monitoring of liquidity risk management; periodic due diligence
reviews of pricing vendors and vendor methodology; design, development, implementation and regular monitoring of the
compliance process; respond to regulatory inquiries and determine appropriate litigation strategy, as needed; review of
subadvisers’ proxy voting policies and procedures; oversight of preparation, and review, of materials for meetings of the Funds’
Board, participation in these meetings and preparation of regular communications with the Board; oversight of preparation, and
review, of prospectuses, shareholder reports and other disclosure materials and regulatory filings for the Funds; oversight of other
service providers to the Funds, such as the custodian, the transfer agent, the Funds’ independent accounting firm and legal
counsel; supervision of the performance of recordkeeping and shareholder relations functions for the Funds; and oversight of
cash management services. TAM uses a variety of quantitative and qualitative tools to carry out its investment management
services.
TAM’s investment management services also include the provision of supervisory and administrative services to each series of
TF and TST. These services include performing certain administrative services for the Funds and supervising and overseeing the
administrative, clerical, recordkeeping and bookkeeping services provided to the Funds by State Street Bank and Trust Company
(“State Street”), to whom TAM has outsourced the provision of certain services as described below; to the extent agreed upon
by TAM and the Funds from time to time, monitoring and verifying the custodian’s daily calculation of net asset values;
shareholder relations functions; compliance services; valuation services; assisting in due diligence and in oversight and
monitoring of certain activities of subadvisers and certain aspects of Fund investments; assisting with Fund combinations and
liquidations; oversight of the preparation and filing, and review, of all returns and reports, in connection with federal, state and
local taxes; oversight and review of regulatory reporting; supervising and coordinating the Funds’ custodian and dividend
disbursing agent and monitoring their services to the Funds; assisting the Funds in preparing reports to shareholders; acting as
liaison with the Funds’ independent public accountants and providing, upon request, analyses, fiscal year summaries and other
audit related services; assisting in the preparation of agendas and supporting documents for and minutes of meetings of the Funds’
Board and committees of the Board; assisting in the preparation of regular communications with the Board; and providing
personnel and office space, telephones and other office equipment as necessary in order for
TAM to perform supervisory and
administrative services to the Funds.
TAM also acts as investment manager to a wholly-owned subsidiary of a TST Fund, which is organized as a company under the
laws of the Cayman Islands (a “Subsidiary”). The Subsidiary has the same investment objective as the corresponding parent
Fund and is sub-advised by the same subadviser as the corresponding parent Fund.
Collective Investment Trusts
Transamerica Asset Management, Inc. Collective Investment Trust
TAM serves as the investment adviser to a privately-offered pooled investment vehicle, that is not registered under the 1940
Act, Transamerica Asset Management, Inc. Collective Investment Trust (“TTC Trust”), organized as a collective investment
trust for certain eligible plans. Transamerica Trust Company (“TTC”), an affiliate of TAM, is the trustee of TTC Trust.
For each of the following series of the TTC Trust (the “Direct Series”), TAM tenders non-discretionary investment advice to
TTC as the trustee of the TTC Trust and recommends underlying funds and the relative amounts to be invested in each
underlying fund based on the objectives and principal strategies of the particular series:
Transamerica Core Bond - Collective Trust Fund
Transamerica Short Term Bond - Collective Trust Fund
Transamerica High Yield Bond - Collective Trust Fund
Transamerica International Equity - Collective Trust Fund
Transamerica Large Core ESG - Collective Trust Fund
Transamerica Large Value Opportunities - Collective Trust Fund
Transamerica Mid Cap Growth - Collective Trust Fund
Transamerica Mid Cap Value Opportunities - Collective Trust Fund
Transamerica Government Money Market - Collective Trust Fund
Transamerica Stock Index - Collective Trust Fund
Each Direct Series currently invests in a series TF or, for Transamerica Stock Index – Collective Trust Fund, a third-party
collective investment trust fund. TTC reserves the right to withdraw the assets of each Direct Series from the Directs Series’
underlying fund or funds and pursue the Direct Series’ investment goal by investing directly in securities or in another
investment vehicle.
For each of the following series of the TTC Trust (the “Asset Allocation Series”), TAM tenders non-discretionary investment
advice to TTC as the trustee of the TTC Trust by recommending risk-based asset allocation models for each series:
Transamerica Asset Allocation – Long Horizon - Collective Trust Fund
Transamerica Asset Allocation – Intermediate/Long Horizon - Collective Trust Fund
Transamerica Asset Allocation – Intermediate Horizon - Collective Trust Fund
Transamerica Asset Allocation – Short/Intermediate Horizon - Collective Trust Fund
Transamerica Asset Allocation – Short Horizon - Collective Trust Fund
Transamerica ESG Balanced Allocation - Collective Trust - Collective Trust Fund
TTC has contracted with a third-party investment adviser, Leafhouse Financial Advisors, LLC, (“Leafhouse”) to determine
each Asset Allocation Series’ underlying investments. TTC retains final and complete authority to accept or reject TAM’s and
Leafhouse’s recommendations.
Great Gray Trust Company, LLC Collective Investment Funds
TAM also serves as an investment adviser to certain series (each, a “GG CIT” and collectively, “GG CITs”) of the Great Gray
Trust Company, LLC Collective Investment Funds (“Great Gray Funds”), a privately-offered pooled investment vehicle that
is not registered under the 1940 Act, which provides for the collective investment of certain qualified retirement plan assets.
TAM assists the trustee of the Great Gray Funds, Great Gray Trust Company, LLC (“Great Gray”), in the management of the
GG CITs.
In its role as an investment adviser, TAM’s duties include recommending and monitoring one or more investment subadvisers
to each GG CIT (each, a “GG CIT Subadviser” and collectively, as applicable, the “GG CIT Subadvisers”), recommending
and monitoring allocations among GG CIT Subadvisers for applicable GG CITs, and recommending changes to the investment
objectives of applicable GG CITs. Great Gray retains final and complete authority to accept or reject TAM’s recommendations.
Investment Scorecard Program
TAM has entered into an agreement with Transamerica Retirement Solutions, LLC (“TRS”), an affiliated recordkeeper, and
TLIC, an affiliated life insurance company, to review the results of quantitative screens performed by TRS on a limited universe
of mutual funds and other investment options for the affiliated recordkeeper using a combination of quantitative and/or qualitative
analysis.
The review process is a combination of quantitative and/or qualitative analysis. The quantitative review examines trailing
performance periods, consistency of performance, risk or volatility, expenses, style/market cap consistency, and manager tenure.
The qualitative review generally includes an examination of the fund’s organization, resources, investment process, portfolio
construction and risk management, and manager reputation and experience.
Once the process is completed, the investment team regularly monitors the funds that it has reported on to the affiliated
recordkeeper. The investment team typically reviews the funds on the TRS platform on a quarterly basis to discuss any mutual
fund or investment option developments and review performance. This information, along with the other sources, is provided to
the affiliated recordkeeper.
Model Allocation Portfolios
On occasion, TAM may agree to a relationship with a third party involving the provision of model investment portfolios. Fees
for such services will vary based on the relationship, services provided and other factors. In addition, TAM may recommend
portfolios of funds it advises to the sponsor for certain wrap fee or advisory programs, and/or, make portfolios of funds it advises
available to the public by publishing the portfolios on company websites or by other means of dissemination. For portfolios
where TAM is acting as portfolio strategist, TAM is providing advice to the sponsor. The sponsor has ultimate decision-making
responsibility and discretionary authority for the accounts investing in the portfolios and is solely responsible for recommending
such portfolios to investors. In the case of published portfolios available to the public, the information is not intended to serve as
impartial investment or fiduciary advice and is not intended to be used as a primary basis for investment decisions. TAM will
generally create portfolios solely from registered investment companies it advises and does not consider other funds or
investments in the construct of the portfolios. TAM receives compensation from the funds that make up the portfolios for the
investment advisory and other services it provides to those funds, but does not currently charge a separate fee for its portfolio
construction services.
Assets Under Management
TAM currently manages client assets on a discretionary and non-discretionary basis. As of December 31, 2023, TAM managed
approximately $65 billion of client assets on a discretionary basis, and approximately $1 billion of client assets on a
non-discretionary basis.