Fund Evaluation Group, LLC, doing business as FEG, (“FEG” or the “Firm”) provides discretionary and
non-discretionary investment advisory services, focusing predominately on institutional clients. Since our
founding in 1988, we have partnered with institutional investors to develop sophisticated, globally diverse
portfolios designed with a goal to enhance investment returns. Our mission is to empower our clients to
achieve their goals by striving for superior investment performance, objective insights, and research. FEG
is headquartered in Cincinnati, OH and has satellite offices Indianapolis, IN and Dallas, TX. As of
December 31, 2023, FEG has approximately 130 employees and approximately $78 billion in assets under
advisement. Regulatory assets under management (RAUM) of $19,848,561,829 are comprised of
$10,727,229,402 in discretionary RAUM and $9,120,604,536 in non-discretionary RAUM.
FEG’s client base includes a wide set of institutions, including nonprofits, retirement plans, insurance
companies and financial advisers. FEG’s parent, Fund Evaluation Group 2017, Inc. is owned by Fund
Evaluation Group Employee Stock Ownership Trust (“FEG Trust”), a voting trust administered by Argent
Trust Company as trustee. The FEG Trust is owned by Fund Evaluation Group Employee Stock Ownership
Plan (“FEG ESOP”), an employee stock ownership plan that is 100% owned by eligible employees of FEG.
The spectrum of services offered by FEG are generally classified into two categories: discretionary and
non-discretionary. In forming the basis for its investment advisory services, FEG carefully reviews each
client’s individual investment needs and objectives to determine which services or products are most
suitable for the client. In some cases, a combination of FEG’s services and products, including affiliated
proprietary funds, will be recommended or utilized to fulfill the client’s needs. Non-discretionary
investment services are based upon the recommendations of each individual FEG Advisor.
Recommendations can vary depending on each FEG Advisor and their specific area of expertise and
individual subjective judgment. Although the goal of all recommendations or investment management by
FEG is to increase investment performance and reduce risk, no guarantees can be made. All investors should
be aware that past performance is no guarantee of future results. FEG Advisor’s compensation is based
upon the fee charged by FEG for services provided. FEG provides ongoing investment services to its clients
through the following service lines:
FEG Consulting
FEG’s investment consulting service provides oversight of investment portfolios on a non-discretionary
basis and generally includes the following:
Investment Policy Statement: FEG will modify or draft a policy that specifies the client’s goals and
objectives, as well as the asset allocation targets and ranges, the performance and risk benchmarks, manager
guidelines and restrictions, how the managers will be evaluated, and concludes with an acknowledgement
section where all fiduciaries attest to these policies. FEG will review the Investment Policy Statement
annually and recommend updates as appropriate.
Asset Allocation Study: Based on the client’s return objectives and risk tolerance, FEG will assist the client
in developing the appropriate asset mix. The study includes but is not limited to FEG’s capital market
assumptions, volatility of the asset categories, as well as correlations. FEG will review the asset allocation
annually.
Performance Reports: FEG will provide quarterly performance reports that track the progress of the
client’s account and the individual managers versus the objectives and benchmarks outlined in the
Investment Policy Statement.
Manager Searches: FEG will assist the client in selecting new managers, when needed, and provide on-
going monitoring and evaluation of existing managers. FEG’s research staff generally conducts quarterly
calls with applicable managers. When a manager is terminated, or the client decides to add a new mandate,
FEG will conduct a manager search. This includes reviewing several managers and their organizational
structure, track record, personnel, and fees (among other things) and summarizing the results to assist the
client in selecting the appropriate manager.
Alternative Investments: Following the processes outlined in the “Manager Searches” section above, FEG
will recommend alternative investment managers that meet the client’s needs, including direct partnerships
and fund of funds. FEG will also provide on-going review (e.g., quarterly conference calls) of applicable
managers and recommendations of new managers.
Educational Material: Each quarter FEG will provide a research narrative on a specific topic that will
assist the client in making well-informed decisions. FEG will also conduct research on topics at the client’s
request. These research studies are designed to open discussion on relevant investment topics, and to
position the portfolio for future success.
Consulting Supplemental Services
Delegated Investing Services: FEG will provide operational support for back office administrative tasks
of clients while maintaining a non-discretionary
relationship on the majority of the portfolio. Under this
service model, clients are able to allocate less than 50% of their portfolio to FEG’s affiliated discretionary
funds. With authorization from the client, FEG will implement client approved investment decisions with
custodians and managers. This service may also include Subscription Agreement services as outlined
below. All arrangements under this service will require written approval from the client.
Consulting Implementation Services: FEG will provide operational support for the back office
administrative tasks of clients while maintaining a non-discretionary relationship. Upon authorization from
the client, FEG will implement client approved investment decisions with custodians and managers. FEG
will not purchase or sell securities for the client’s account unless instructed in writing by the client.
Following approval, FEG will prepare pertinent information and execute the transaction(s).
Subscription Agreements: FEG provides subscription agreement services. FEG will collect and complete
subscription agreements for funding new investments and liquidating existing investments, and forward
documents to the client for their review and signature before processing. FEG also tracks the document
flow and monitors the custodian’s receipt and disbursement of payments.
FEG is able to customize the consulting services described above in order to meet the unique needs of our
clients. Customized services are mutually agreed upon by FEG and the client in the advisory agreement.
FEG Outsourced Chief Investment Officer (OCIO)
FEG OCIO is a discretionary investment program offered by FEG and is managed by FEG’s Portfolio
Management team. For certain OCIO clients, their individual FEG Advisor may have final authority for
managing the investments in accordance with client’s IPS. FEG OCIO is designed mostly for taxable and
tax-exempt institutions on a separate account basis. This service integrates similar components to those
offered through FEG Consulting, but because of its discretionary nature, FEG implements and manages
client portfolios on an ongoing basis within the asset allocation guidelines adopted by the client in the
Investment Policy Statement. Portfolio construction is generally comprised of a diversified portfolio of
index funds, mutual funds, exchange traded funds, commingled fund products and separately managed
accounts. Clients selecting FEG OCIO receive a quarterly investment report incorporating performance
measurement of the investments in accordance with the client’s investment objectives.
FEG Managed Portfolios
FEG Managed Portfolios is a discretionary investment program which offers model portfolios to third
parties who serve as financial intermediaries and/or platform providers to individual clients. FEG’s
Portfolio Management team is responsible for the management of the models. The model portfolios are
geared towards individual investors that seek to add value through dynamic asset allocation and manager
research. Portfolio construction is generally comprised of a diversified mix of index funds, mutual funds
and exchange traded funds.
FEG Research Services
FEG leverages its research provided to institutional clients by providing research services to financial
institutions. FEG Research Services provides capital markets research such as capital market assumptions,
asset allocation recommendations, recommended managers list, client-directed manager due diligence and
other research-oriented solutions customizable to the needs of the client. Clients also have the opportunity
to co-brand or white-label educational publications.
Other Services
FEG has the ability to utilize the technology platforms of third parties to support performance reporting,
fee calculation and billing. A portion of FEG’s own discretionary clients may pay a fee for this service.
FEG participates in separately managed account programs sponsored by third parties. The portion of the
fee payable to FEG is determined by a percentage of the assets under management.
FEG participates in an Endowment Alliance Program to help financial advisers build their endowment and
foundation business. Financial advisers can access FEG Managed Portfolios solutions and leverage FEG’s
institutional client experience. FEG endowment portfolios include allocations to alternative investments
through hedge funds or liquid alternatives based upon client objectives and policies.
In establishing client accounts, FEG will discuss with clients how to tailor services to their particular
investment objectives, financial needs and risk tolerance. Clients may impose restrictions on investing in
certain securities, types of securities and industry sectors. These restrictions are set forth in the client’s
Investment Policy Statement or advisory contract. Based on the particular investment objectives and
certain client needs, FEG may allocate a portion of the client’s portfolio to a sub-adviser. The sub-advisers
will manage that portion of client assets based on the client’s investment strategy and objectives. However,
FEG will be responsible for the assignment, oversight and monitoring of these sub-advisers.