Advisory business Voya IM LLC (a registered investment adviser) is a wholly owned subsidiary of VIM Holdings LLC, a Delaware limited liability company. Voya Financial, Inc., a publicly traded company, holds a 76% economic stake in VIM Holdings LLC through its subsidiary Voya Holdings Inc. As of July 25, 2022, Allianz SE, a stock corporation organized and existing under the laws of the European Union and the Federal Republic of Germany, holds an indirect 24% economic stake in VIM Holdings LLC as a result of a transaction combining Voya IM LLC with the assets and teams comprising specified transferred strategies formerly managed by Allianz Global Investors U.S. LLC.
Voya IM LLC began business as an investment adviser on December 12, 1997. Voya IM LLC provides investment advisory and certain related services to its clients. The investment advisory services include management of portfolios of securities and derivatives within limitations set forth in clients’ investment guidelines. The advisory services include, as appropriate, advice with respect to commercial mortgage obligations, mortgage and other asset backed securities, corporate loans, derivatives, dollar roll transactions, repurchase and reverse repurchase agreements, syndicated bank loans, commercial real estate loans, structured products, private placement opportunities and alternative assets, among other investments.
Related services Voya IM LLC and/or its affiliates will provide if mutually agreed upon by Voya IM LLC and the client, include the following: portfolio valuation and performance analysis; mortgage loan servicing and administration (including exercising rights, consents, authorizations, elections and making decisions with respect to commercial mortgage loans and the underlying loan documents on behalf of the lenders); assistance with securities accounting and tax analysis; coordination of securities lending; and assistance with regulatory inquiries and analysis of existing and proposed statutes and regulations governing certain investments. The types of financial instruments that are be used and the specific services to be provided are outlined in an agreement entered into between Voya IM LLC and the client. To the extent particular mortgage loan servicing and administration services constitute investment advisory services, personnel undertaking such services are supervised persons of Voya IM LLC.
For fund clients, Voya IM LLC tailors its advisory services to the needs of the fund as a whole (rather than the individual needs of underlying investors). By contrast, Voya IM LLC will tailor its advisory services and investment guidelines to the individual needs of clients. Clients will sometimes impose their own investment restrictions regarding the types of financial instruments that can be used to manage their overall investment objectives of a particular mandate.
All objectives and guidelines are detailed in the investment advisory agreement entered into between Voya IM LLC and the client.
Assets under management As of December 31, 2023, Voya IM LLC managed $33,827,869,628 in discretionary assets and $0 in non‑discretionary assets.
Other advice Pursuant to written agreements, Voya IM LLC provides recommendations, investment advice and analysis regarding investment strategies and potential investments to affiliated and unaffiliated entities.

The investment advice and analysis can include model portfolio holdings and/or weightings, analysis and evaluation of potential investments (such as commercial mortgage loans) and other information regarding the construction and maintenance of portfolios, which can be used by these entities in the management of their own or their clients’ assets. Voya IM LLC will sometimes (but need not) delay communicating information regarding the composition of model portfolios, the analysis and evaluation of potential investments (or any updates thereto) until after Voya IM LLC advisory accounts have commenced or completed trading in the same or similar securities. As a result, trades ultimately placed using a Voya IM LLC model portfolio or where the client retains investment discretion will be subject to price movements, particularly with large orders or where the securities are thinly traded, that can result in these accounts receiving prices that are less favorable than the prices obtained for other Voya IM LLC advisory accounts. It is also possible that entities who make execution decisions for model portfolio or other accounts will act upon such recommendations before certain Voya IM LLC advisory accounts have commenced trading based on such recommendations. As a result, Voya IM LLC advisory accounts, particularly with respect to large orders or orders involving thinly traded securities, will receive prices that are less favorable than the prices obtained for certain model portfolio or other accounts.
Investment authority Subject to any written guidelines which the client provides or other specialized arrangements, Voya IM LLC normally has complete discretion and authority to manage client accounts. Voya IM LLC, as the client’s agent and attorney‑in‑fact, generally holds a limited power of attorney to act without prior consultation. Accordingly, Voya IM LLC is generally authorized to perform various functions, at the client’s expense, without further approval from a client, except as required by law, including: (a) to make all investment decisions; (b) to buy, sell and otherwise trade in securities; (c) to issue instructions to the custodian for operational matters of the account, including but not limited to such items as tender offers and reorganizations; (d) to select brokers or dealers to execute securities transactions; and (e) vote proxies and make similar decisions. As a general matter, a fund’s or account’s custodian rather than Voya IM LLC is responsible for filing class action claims. With respect to many clients, Voya IM LLC enters into swaps and other derivatives and executes ancillary documents on their behalf. In certain instances, Voya IM LLC enters into non‑discretionary arrangements with its clients where Voya IM LLC obtains client approval prior to execution of a trade or provides the client with investment recommendations which the client, in its sole discretion, can implement.
Trading support and outsourcing Voya IM LLC and/or its affiliates provide administrative, trading, marketing and other support services for affiliated or unaffiliated entities, where the entities are responsible for making portfolio management decisions. Most notably, an affiliate of Voya IM LLC, utilizing the same trading desk, provides trading desk, research or similar support services for a former affiliated investment adviser.