General Information
Cornerstone Investment Partners, LLC (“Cornerstone”) was formed in 2001 and provides portfolio
management services to its clients. Cornerstone also provides its research services to some financial
intermediaries as a non-discretionary investment advisor in Unified Managed Account Programs.
Cornerstone is 100% owned by CIM Holdings LLC, which is 100% owned by current employees of
Cornerstone. No single employee has a majority ownership. Please see Cornerstone Investment
Partners, LLC Brochure Supplements, Exhibit A, for more information on the individuals who
formulate investment advice and have direct contact with clients or have discretionary authority over
client accounts.
As of December 31, 2023, Cornerstone managed $1,896,807,143 on a discretionary basis, and no
assets on a non-discretionary basis. Cornerstone also had assets under advisement totaling
approximately $896,807,143 primarily through Unified Managed Account (“UMA”) programs. These are
client assets that Cornerstone oversees as part of its overall core investment advisory services, but
does not manage on a discretionary basis or directly place trades.
SERVICES PROVIDED
Cornerstone serves three primary types of clients: Institutional clients, Clients of Other Investment
Professionals, and Registered Investment Company clients. Institutional clients usually select one or
more of Cornerstone’s Portfolios in which to invest based on the needs of the Institution. Other
registered investment advisers and investment professionals (the “primary advisers”) may recommend
or hire Cornerstone to manage their clients' assets. The primary adviser works with the client to decide
which Portfolio(s) offered by Cornerstone may be appropriate for the client. Cornerstone’s approach to
investing and its management style is explained to the client to be sure it is compatible with the client’s
investment objective.
Portfolio Management
Institutional clients include, but are not limited to, public and private retirement plans, union and
management plans along with endowment and foundation accounts. Accounts in the institutional realm
are mostly tax-exempt but may include taxable portfolios or entities. These institutional clients can
approach Cornerstone directly or through an intermediary. The direct approach would most likely be
the result of a review of peers within a performance database such as PSN or eVestment Alliance.
These databases are a central repository of investment performance and statistical data on managers
both domestic and global. Clients then seek out those managers that meet their investment criteria.
Clients can also find managers using an intermediary, generally an investment consultant. Investment
consultants are used either on a retainer or project basis to assist institutional clients in manager
selection. Once managers are identified, institutional clients will provide them with their specific
investment guidelines and policy requirements, which detail all approved and/or restricted activity as it
relates to their portfolio. Institutional clients are the most sophisticated users of our services.
The Investment Objectives and Guidelines will be updated from time to time when requested by the
client, or when determined to be necessary or advisable by Cornerstone based on updates to the
client’s financial or other circumstances.
To implement the client’s Investment Plan, Cornerstone will manage the client’s investment portfolio on
a discretionary or a non-discretionary basis. As a discretionary investment adviser, Cornerstone will
have the authority to supervise and direct the portfolio without prior consultation with the client. Under
a non-discretionary arrangement, clients must be contacted prior to the execution of any trade in the
account(s) under management. This can result in a delay in executing recommended trades, which
could adversely affect the performance of the portfolio. This delay also normally means the affected
account(s) will not be able to participate in block trades, a practice designed to enhance the execution
quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement,
the client retains the responsibility for the final decision on all actions taken with respect to the
portfolio.
Notwithstanding the foregoing, clients may impose certain written restrictions on Cornerstone in the
management of their investment portfolios, such as prohibiting the inclusion of certain types of
investments in an investment portfolio or prohibiting the sale of certain investments held in the account
at the commencement of the relationship. Each client should note, however, that restrictions imposed
by a client may adversely affect the composition and performance of the client’s investment portfolio.
Each client should also note that his or her investment portfolio is treated individually by giving
consideration to each purchase or sale for the client’s account. For these and other reasons,
performance of client investment portfolios within the same investment objectives, goals and/or risk
tolerance may differ, and clients should not expect that the composition or performance of their
investment portfolios would necessarily be consistent with similar clients of Cornerstone.
Asset Management for Clients of other Investment Professionals
Other registered investment advisers and investment professionals may recommend or hire
Cornerstone to manage their clients' assets. In these arrangements, Cornerstone will implement and
manage an investment strategy in the client’s account; however, Cornerstone does not serve as the
primary adviser to the client. The primary adviser will retain direct contact with the client and will
manage the client relationship. The primary adviser’s client will typically enter into an advisory contract
directly
with Cornerstone or alternatively, depending on the contractual arrangement the client has with
the primary adviser, Cornerstone may contract directly with the primary adviser to provide the client
investment advisory services.
Cornerstone will have exclusive investment discretion as to which securities shall be purchased or sold
in the client’s account in a manner consistent with the client’s selected product, investment objectives,
policies and restrictions (if any) and the capabilities of the broker-dealer. In order to determine whether
the strategy is suitable for a client, the primary adviser and the client are responsible for ascertaining
the goals and objectives of the portfolio in question. In addition, Cornerstone will obtain initial
documentation of the client’s risk parameters and investment objectives. However, it is the
responsibility of the primary adviser and/or the client to promptly notify Cornerstone of any changes in
financial condition of the client that would necessitate a change in the client’s investment objective.
Clients may impose certain written restrictions on Cornerstone in the management of their investment
portfolios, such as prohibiting the inclusion of certain types of investments in an investment portfolio or
prohibiting the sale of certain investments held in the account at the commencement of the
relationship.
Wrap Program Clients
Cornerstone participates in a number of managed account/wrap programs sponsored by
broker/dealers who are also registered investment advisers (“Sponsors”). Clients of these Sponsors
may pay a bundled fee that includes the investment management, custodial services and brokerage
commissions to the extent transactions are executed through the Sponsor. In cases where
Cornerstone’s fee is not bundled with the Sponsor’s fee, Cornerstone’s fee is billed and collected
separately and is in addition to the Sponsor’s fee.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s
Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the
following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule’s provisions, we must:
Meet a professional standard of care when making investment recommendations (give prudent
advice);
Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
Charge no more than is reasonable for our services; and
Give you basic information about conflicts of interest.
Retirement Plan Advisory Services
Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring
that prudent procedural steps are followed in making investment decisions. Cornerstone will provide
Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular
services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary(ies)
designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the decision
to retain our firm; (ii) agree to the scope of the services that we will provide.
The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan
Fiduciaries may retain investment advisers for various types of services with respect to Plan assets.
For certain services, Cornerstone will be considered a fiduciary under ERISA. To the extent that the
Plan Fiduciaries retain Cornerstone to act as an investment manager within the meaning of ERISA §
3(38), Cornerstone will provide discretionary investment management services to the Plan. With
respect to any account for which Cornerstone meets the definition of a fiduciary under Department of
Labor rules, Cornerstone acknowledges that both Cornerstone and its Related Persons are acting as
fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in the written agreement
between Cornerstone and Client. With respect to any account for which Cornerstone meets the
definition of a fiduciary under Department of Labor rules, Cornerstone acknowledges that both
Cornerstone and its Related Persons are acting as fiduciaries. Additional disclosure may be found
elsewhere in this Brochure or in the written agreement between Cornerstone and Client.
Discretionary Management Services
When retained as an investment manager within the meaning of ERISA § 3(38), Cornerstone provides
continuous and ongoing supervision over the designated retirement plan assets. Cornerstone will
actively monitor the designated retirement plan assets and provide ongoing management of the
assets. When applicable, Cornerstone will have discretionary authority to make all decisions to buy,
sell or hold securities, cash or other investments for the designated retirement plan assets in our sole
discretion without first consulting with the Plan Fiduciaries. We also have the power and authority to
carry out these decisions by giving instructions, on your behalf, to brokers and dealers and the
qualified custodian(s) of the Plan for our management of the designated retirement plan assets.