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Adviser Profile

As of Date 10/01/2024
Adviser Type - Large advisory firm
Number of Employees 1,668 4.51%
of those in investment advisory functions 691 -0.72%
Registration SEC, Approved, 1/23/2003
AUM* 337,283,181,637 6.96%
of that, discretionary 329,960,889,828 6.83%
Private Fund GAV* 12,899,099,589 -44.11%
Avg Account Size 8,155,999 4.25%
% High Net Worth 32.33% 7.67%
SMA’s Yes
Private Funds 82 9
Contact Info 212 xxxxxxx
Websites

Client Types

- Individuals (other than high net worth individuals)
- High net worth individuals
- Banking or thrift institutions
- Investment companies
- Pooled investment vehicles
- Pension and profit sharing plans
- Charitable organizations
- State or municipal government entities
- Other investment advisers
- Insurance companies
- Sovereign wealth funds and foreign official institutions
- Corporations or other businesses not listed above
- Other

Advisory Activities

- Portfolio management for individuals and/or small businesses
- Portfolio management for investment companies
- Portfolio management for pooled investment vehicles
- Portfolio management for businesses
- Selection of other advisers
- Educational seminars/workshops

Compensation Arrangments

- A percentage of assets under your management
- Fixed fees (other than subscription fees)
- Performance-based fees

Reported AUM

Discretionary
Non-discretionary
359B 308B 257B 205B 154B 103B 51B
2015 2016 2017 2018 2019 2020 2021 2022 2023

Private Funds



Employees

Private Funds Structure

Fund Type Count GAV
Fund TypeHedge Fund Count51 GAV$8,698,631,788
Fund TypePrivate Equity Fund Count9 GAV$229,933,679
Fund TypeSecuritized Asset Fund Count17 GAV$3,459,787,494
Fund TypeOther Private Fund Count5 GAV$510,746,628

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Brochure Summary

Overview

A. Description of the Firm Neuberger Berman Investment Advisers LLC (“NBIA”) is a Delaware limited liability company, formed in November 2002 and registered with the U.S. Securities and Exchange Commission (the “SEC”) in January 2003. Previously known as Neuberger Berman Fixed Income LLC, the firm adopted its present name on January 1, 2016, concurrent with the transfer of certain businesses from its affiliates Neuberger Berman BD LLC (formerly Neuberger Berman LLC) (“NBBD”), NB Alternative Investment Management LLC (“NBAIM”) and Neuberger Berman Management LLC. On January 1, 2017, NBBD and NBAIM transferred the remainder of their advisory businesses to NBIA. The combined firms’ antecedents date to the founding of Neuberger & Berman in 1939. NBIA’s principal office is located in New York, New York. NBIA is directly owned by Neuberger Berman Investment Advisers Holdings LLC and Neuberger Berman AA LLC, which are subsidiaries of Neuberger Berman Group LLC (“NBG”). NBIA is registered with the U.S. Commodity Futures Trading Commission as a commodity trading advisor (“CTA”) and a commodity pool operator (“CPO”), and is a member of the U.S. National Futures Association. NBIA provides a wide range of discretionary and non-discretionary investment management services to a variety of clients, including individuals, institutions, registered investment companies, non-U.S. registered funds and private investment funds. The firm also provides discretionary investment management services and non-discretionary securities recommendations through wrap fee and similar programs, and acts as discretionary and non- discretionary sub-adviser to a variety of products, including registered investment companies, separately managed accounts, non-U.S. registered funds, collective investment trusts, common trusts funds and private investment vehicles. Indirect Ownership Background – Neuberger Berman Group NBG is a holding company, the subsidiaries of which (collectively referred to herein as the “Firm” or “Neuberger Berman”) provide a broad range of global investment solutions – equity, fixed income, multi-asset class and alternatives – to institutions and individuals through products including separately managed accounts, registered funds and private investment vehicles. As of December 31, 2023, Neuberger Berman had approximately $463 billion under management.1 NBG’s voting equity is wholly owned by NBSH Acquisition, LLC (“NBSH”). NBSH is owned by current and former employees, directors, consultants and, in certain instances, their permitted transferees. Neuberger Berman is headquartered in New York, New York. As of December 31, 2023, Neuberger Berman had approximately 2,826 employees in 39 cities around the world. 1 Firm assets under management figures reflect the collective assets for the various subsidiaries of NBG. NBIA’s investment management services are further discussed below. B. Types of Advisory Services NBIA currently provides the following types of advisory services: Separately Managed Accounts NBIA provides ongoing discretionary investment management services to individual and institutional clients based on the individual investment goals, objectives, time horizon, and risk tolerance of each client. NBIA provides its advisory services through (i) separately managed accounts for individual and institutional clients that are serviced by the Private Wealth segment of NBIA’s business (“Private Wealth Accounts”) and (ii) separately managed accounts for clients that are serviced by the institutional segment of NBIA’s business (“Institutional Accounts”, and collectively with Private Wealth Accounts, “Separate Accounts”). Private Wealth Accounts include accounts managed under the NB Private Wealth Advisory Program (“PW Advisory Program”), through which NBIA provides, on a discretionary and non-discretionary basis, asset allocations and investment management by allocating assets among various proprietary and non- proprietary investment strategies available through the PW Advisory Program, and accounts managed under the Guided Portfolio Solutions Program (“GPS Program”), through which NBIA provides asset allocations and investment management by discretionarily allocating assets among a portfolio of NB Registered Funds (as defined below). Outsourced Chief Investment Officer (“OCIO”) services are also provided by the Private Wealth segment of NBIA’s business, and may occasionally be provided by NBIA to certain institutional clients. Retail clients that have a Private Wealth Account or invest through the PW Advisory Program or the GPS Program should also review NBIA/NBBD’s Form CRS, which is available at http://www.nb.com/form_CRS_nbia_nbbd/. With respect to each Private Wealth Account client that invests through the PW Advisory Program (including those for whom NBIA provides OCIO services) (each, a “PW Program Client”), based on investment guidelines established by the client, NBIA, on a discretionary basis (“Discretionary PW Program”) or non-discretionary basis (“Non-Discretionary PW Program”), allocates the PW Program Client’s assets to various proprietary and third-party investment strategies and investment vehicles that are available as investment options through the PW Advisory Program, including discretionary separate account strategies managed by NBIA or its affiliate (“Proprietary Separate Accounts”), third-party discretionary separate account strategies (“Third-Party Separate Accounts”), NB Registered Funds (as defined below), unaffiliated open- end investment companies (“Third-Party Mutual Funds”), unaffiliated exchange-traded funds, registered under the U.S. Investment Company Act of 1940, as amended (the “Investment Company Act”) (“Third-Party ETFs”, and together with Third-Party Mutual Funds, “Third-Party Registered Funds”), and affiliated and unaffiliated collective investment trusts (“CITs”). From time to time, where specifically agreed with a PW Program Client, NBIA can allocate a PW Program Client’s assets to (i) affiliated and unaffiliated privately offered investment vehicles (“Private Funds”), (ii) Non-U.S. Registered Funds, including UCITS, managed by NBIA or its affiliates, or (iii) Private Investments (each, as defined below). The strategies that are available through the PW Advisory Program are further described in “The PW Advisory Program” in Item 8.B. NBIA utilizes proprietary strategies as its primary investment options. Non-proprietary strategies are generally considered as a complement to proprietary strategies. Similarly, where the NBIA representative for the PW Program Client is part of a portfolio management team, the representative will generally utilize that team’s own strategies as the primary investment options. See also Items 10.C.1, 10.D and 11.B.4. For certain of NBIA’s large Institutional Account clients, NBIA offers customized multi-asset or multi-strategy investment management services that utilize the services of NBIA and its affiliates (“Multi-Asset Strategy Mandates”). For Multi-Asset Strategy Mandates, where agreed with the client and in accordance with applicable law, NBIA could allocate the client’s assets to NB Registered Funds, NB ETFs (as defined below), NB Private Funds (as defined below), CITs sponsored or maintained by Neuberger Berman Trust Company N.A. or its affiliate (“Affiliated CITs”) and Third-Party Portfolio Funds (as defined below). From time to time, NBIA provides investment management services to Separate Accounts for which it helps to establish investment objectives and monitor the achievement of those objectives through investments in pooled investment vehicles for which a third party acts as general partner, managing member or adviser (“Third-Party Portfolio Funds”) and in Third-Party Separate Accounts. The general partner, managing member or adviser to the Third-Party Portfolio Funds and the Third-Party Separate Accounts are collectively referred to as “Third-Party Portfolio Managers”. From time to time, existing Private Wealth Account clients direct NBIA or its affiliate, NBBD, to purchase or sell securities on their behalf (“Client-Directed Transactions”). Securities purchased as Client-Directed Transactions by NBIA or NBBD will, unless otherwise agreed, generally be held in a segregated portion of the client’s account or in a brokerage account as unsupervised holdings; however, it is possible that securities purchased as Client-Directed Transactions will not be reflected in the custodian’s books and records by a specific mark, designation, or other indication. Neither NBIA nor NBBD will provide portfolio management services to the segregated portion of the account or the brokerage account and will not receive advisory fees with respect to that portion of the account or the brokerage account, as applicable. Any decisions concerning the retention, disposition, or other change with respect to securities purchased as Client-Directed Transactions remain solely with the client. It is possible that Clients will be required to establish a separate brokerage account for unsupervised holdings and Client- Directed Transactions. For Private Wealth Account clients, NBIA utilizes a prime brokerage arrangement with National Financial Services LLC (“NFS”) to facilitate the transfer of shares for initial public offerings (“IPOs”) and secondary offerings. Under SEC guidance, an advisory client is not permitted to participate in a prime brokerage arrangement unless the client maintains at least $100,000 in assets with the prime broker. Therefore, clients that maintain less than $100,000 with NFS or another approved prime broker will be excluded from receiving shares of IPOs or secondary offerings as they are not eligible for utilizing the prime brokerage arrangement needed to deliver the shares to their accounts. In addition, portfolio managers, from time to time, invest client assets in the equity or debt of private companies, private investments in public equity (“PIPEs”), SPACs (as defined below) or other private placements or restricted securities (collectively, “Private Investments”). Private Investments may be subject to minimum investment requirements. In addition, Private Investments are generally limited to investors that meet certain eligibility requirements. Proprietary Registered Investment Companies NBIA serves as investment adviser to certain investment companies that are registered under the Investment Company Act, including open-end investment companies that are distributed by one or more of NBIA’s affiliates (the “NB Mutual Funds” and “NB ETFs”) and closed-end funds (“NB Closed-End Funds”, and together with NB Mutual Funds and NB ETFs, “NB Registered Funds”). The NB Closed-End Funds include funds that issue interests via private placement transactions only to persons or entities that are both “accredited investors” as defined in Section 501(a) of Regulation D under the U.S. Securities Act of 1933, as amended (the “Securities Act”), and “qualified clients” as defined in Rule 205-3 under the Advisers Act (the “NB PE Closed-End Funds”). NBIA typically provides investment services that include, among other things and as applicable, determination as to: (a) which securities to buy or sell; (b) the total amount of securities to buy or sell; (c) the broker or dealer through which securities are bought or sold; (d) the commission rates at which securities transactions are effected; and (e) the prices at which securities are to be bought or sold, which include dealer spreads or mark-ups and transaction costs. NBIA also selects and oversees sub-advisers, both affiliated and unaffiliated, for certain of the NB Registered Funds. The advisory services provided by NBIA to the NB Registered Funds cover a broad range of strategies and investments. NBIA carries out its duties subject to the general oversight of each NB Registered Fund’s Board of Trustees/Directors/Managers. NBIA has entered into sub-advisory agreements with certain of its affiliates, including Neuberger Berman Europe Limited, whereby those affiliates provide investment advisory services to certain of the NB Mutual Funds. NBIA has also entered into sub-advisory agreements with certain of its affiliates, including NB Alternatives Advisers LLC, whereby those affiliates provide investment advisory services to the NB PE Closed- End Funds. NBIA will invest the NB PE Closed-End Funds in a portfolio of Third-Party Portfolio Funds and directly in equity or debt securities of portfolio companies alongside other NB Private Funds, Third-Party Portfolio Funds and other private equity firms (each, a “Co-Investment”). The NB PE Closed-End Funds will also invest opportunistically in Third-Party Portfolio Funds acquired as “secondary investments” in privately negotiated transactions from investors in the Third-Party Portfolio Funds typically after the end of the Third-Party Portfolio Fund’s fundraising period (each, a “Secondary Investment”). The interests in Third-Party Portfolio Funds consist of a variety of private equity fund types and strategies, such as venture capital partnerships, special situations partnerships, buyout private equity partnerships, international private equity partnerships (together with Secondary Investments and Co-Investments, the “Private Equity Securities”). Clients should refer to each NB Registered Fund’s summary prospectus, prospectus, Statement of Additional Information, offering/placement memorandum and constitutional documents, as applicable (with respect to NB Registered Funds, the “Offering Documents”) for additional information. Private Investment Vehicles NBIA acts as the investment manager (or similar capacity), providing discretionary investment management services to Private Funds. The Private Funds advised by NBIA or its affiliates are referred to herein as “NB Private Funds”. The NB Private Funds are generally organized or “sponsored” by NBIA or an affiliate of NBIA, and NBIA or an affiliate of NBIA will typically act as the managing member or general partner or similar entity (collectively, the “GP Entity”) of the NB Private Funds. For certain NB Private Funds, affiliates of NBIA also serve as officers, directors or other persons authorized to facilitate the operation of the NB Private Funds. In some cases, NBIA serves as an adviser or sub-adviser to NB Private Funds that are organized, managed or sponsored by entities that are not affiliated with NBIA. The NB Private Funds are not registered under the Investment Company Act, and their shares or interests, as applicable, are not registered under the Securities Act, and are instead sold to qualified investors who meet certain criteria on a private placement basis. Most of the NB Private Funds require that investors be (1)(a) “accredited investors” as defined under Regulation D under the Securities Act (“Regulation D”) and (b) “qualified purchasers” as defined in Section 2(a)(51)(A) of the Investment Company Act or “knowledgeable employees” under Rule 3c-5 of the Investment Company Act or (2) not “U.S. Persons” as defined under Regulation S of the Securities Act. Accordingly, the NB Private Funds are not publicly offered in the United States. Certain NB Private Funds rely on Section 3(c)(1) of the Investment Company Act. The investors in those NB Private Funds are not required to be “qualified purchasers” or “knowledgeable employees”; rather those NB Private Funds restrict the beneficial ownership of its outstanding securities to not more than one hundred persons. Some NB Private Funds are not continuously offered. Certain of the NB Private Funds invest in affiliated and unaffiliated pooled investment vehicles (“Portfolio Funds”) or Separate Accounts. The general partner, managing member or adviser to the Portfolio Funds and the Separate Accounts (which, for affiliated Portfolio Funds (“Affiliated Portfolio Funds”) and Proprietary Separate Accounts, will be NBIA or its affiliate) are collectively referred to as “Portfolio
Managers”. NBIA (or its affiliate) has the overall responsibility for implementing the investment strategies of each NB Private Fund and has the authority to select Portfolio Funds or Separate Accounts within the stated investment strategies and objectives of each NB Private Fund. Certain NB Private Funds invest in one or more Private Investments, including where those NB Private Funds co-invest alongside other Affiliated Funds (as defined below). Clients should refer to each NB Private Fund’s offering memorandum and constitutional documents (with respect to NB Private Funds, the “Offering Documents”) for additional information. For a list of certain of the NB Private Funds, please refer to Section 7.B(1) of Schedule D of Part 1A of NBIA’s Form ADV, which is publicly available at www.adviserinfo.sec.gov. Sub-Advisory Services NBIA acts as sub-adviser to a variety of products, including the following (collectively, the “Sub- Advised Accounts”):
• Third-Party Mutual Funds;
• affiliated and unaffiliated non-U.S. funds registered under the securities laws of offshore jurisdictions (“Non-U.S. Registered Funds”), including Undertakings for Collective Investments in Transferable Securities (“UCITS”);
• Separate Accounts; and
• Private Funds (for a list of certain of the Private Funds sub-advised by NBIA, please refer to Section 7.B(2) of Schedule D of Part 1A of NBIA’s Form ADV, which is publicly available at www.adviserinfo.sec.gov). Wrap and Related Program Accounts See Item 4.D for a description of wrap and related programs. Non-Discretionary Services NBIA provides non-discretionary investment management services to institutional and individual client accounts (“Non-Discretionary Accounts”), including those where it is required to consult with the client before effecting any transactions for the client’s account. For those accounts, NBIA’s services include (i) one-time, periodic or ongoing responsibility to make recommendations to a client as to investment policy statement design and specific securities, strategies, managers, vehicles or other investments to be purchased, sold or held for a client’s account, and, if NBIA’s recommendations are accepted by the client, to arrange or effect the implementation of any accepted recommendations, including the purchase or sale of the recommended securities or other investments and establishing or closing accounts for separate account strategies; or (ii) non- binding investment advice in the form of written investment analyses on specific securities or a model portfolio. With respect to the provision of those non-discretionary services, clients have sole discretion and final responsibility for deciding whether to buy, sell, hold or otherwise transact in any security. Where applicable, NBIA’s recommendations will include equity, fixed income and alternative products and strategies managed by NBIA or its affiliate. As discussed in “Separately Managed Accounts” in this Item 4.B., clients that invest through the PW Advisory Program can do so on a non-discretionary basis. * * * * * * * The Separate Accounts, NB Registered Funds, NB Private Funds, Sub-Advised Accounts, Wrap Program accounts, Unbundled Program accounts, and Dual Contract Program accounts (each as defined herein) are collectively referred to herein as the “Client Accounts.” With respect to the services provided above, in many cases, NBIA engages in discussions or provides materials that are not individualized or directed to any particular investor or that otherwise would not be deemed to constitute “investment advice” under applicable rules, including the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), or Section 4975 of the Internal Revenue Code of 1986, as amended (the “Code”). C. Client Tailored Services and Client Tailored Restrictions NBIA enters into discretionary or non-discretionary investment management agreements with its Separate Account clients. See Item 16. Clients are permitted to impose restrictions on investing in certain securities or other assets in accordance with their particular needs. However, generally, NBIA can decide not to accommodate investment restrictions deemed unduly burdensome or materially incompatible with NBIA’s investment approach. With respect to asset allocation programs offered by NBIA that allocate assets among various strategies or pooled investment vehicles, clients are generally permitted to impose reasonable restrictions on investing in certain securities or other assets with respect to proprietary and third-party discretionary separate account strategies (to the extent the restriction is accepted by the relevant portfolio manager) and on investing in certain funds or other pooled investment vehicles, but are not permitted to restrict the securities in which the pooled investment vehicle can invest. Further, NBIA can generally decline to permit any account restriction that affects more than a stated percentage of the Client Account. From time to time, NBIA is engaged to provide limited investment management services such as liquidating a client’s account. Some clients also have access to customized educational programs or participate in, or are involved in the selection of, investment management research projects of NBIA and its affiliates. NBIA enters into discretionary investment management agreements with the NB Private Funds. Services are performed in accordance with the terms of each such agreement. Each NB Private Fund imposes investment restrictions, if any, as it deems appropriate. Investment restrictions are typically set forth in the Offering Documents for each NB Private Fund. NBIA enters into discretionary investment advisory or management agreements with the NB Registered Funds. Each NB Registered Fund managed by NBIA is managed in accordance with the investment objectives, policies and strategies of the NB Registered Fund, as described in its Offering Documents. Each NB Registered Fund has a Board of Trustees/Directors/Managers that is responsible for providing oversight of the NB Registered Fund. Each NB Registered Fund and its Board of Trustees/Directors/Managers have the ability to impose restrictions on investing in certain securities or types of securities. In the case of the Sub-Advised Accounts, NBIA enters into a sub-advisory agreement with the relevant investment adviser. The terms and conditions of those arrangements vary, and any contact between NBIA and the ultimate client will typically take place through the relevant investment adviser. Each Sub-Advised Account is managed in accordance with the investment objectives, policies and restrictions set forth in the sub-advisory agreement between NBIA and the investment adviser. The advisory agreement or investment guidelines of some Separate Accounts (including those in the PW Advisory Program), Sub-Advised Accounts, Wrap Program accounts, Unbundled Program accounts, and Dual Contract Program accounts restrict the ability of NBIA to invest in certain products including NB Registered Funds or Private Funds (including NB Private Funds) without authorization from the client. Certain Non-Discretionary PW Program clients impose restrictions that limit the strategies and investment vehicles presented to the client by NBBD or NBIA, respectively. See Item 4.D for a description of client-tailored services and the restrictions on Wrap Programs, Unbundled Programs, and Dual Contract Programs. The performance of Client Accounts that are subject to restrictions imposed by clients will vary from the account performance of unrestricted accounts that NBIA manages with the same or a similar investment strategy. D. Wrap and Related Programs NBIA participates as a sub-adviser in discretionary wrap programs and as a model portfolio provider in non-discretionary and discretionary wrap programs (“Wrap Programs”). A Wrap Program is an investment program where the Wrap Program Clients generally pay to the Wrap Program sponsors (“Wrap Sponsors”) one bundled or “wrapped” fee that covers investment management, trade execution, custodial services and other administrative services. In some cases, financial intermediaries, generally banks (“Unbundled Program Sponsors” and, together with Wrap Sponsors, “Program Sponsors”), offer clients programs that function like Wrap Programs (“Unbundled Programs” and, together with Wrap Programs, “Programs”), except that instead of paying a bundled or “wrapped” fee, clients pay fees on an unbundled basis to separate parties, including a fee for trade execution to a designated broker other than the Program Sponsor. The clients of the Wrap Programs are referred to herein as “Wrap Program Clients” and the clients of the Unbundled Programs are referred to herein as “Unbundled Program Clients,” and together with Wrap Program Clients, “Program Clients”. The Program Sponsors are typically broker-dealers, financial institutions or other investment advisers that establish, operate and administer the Programs. The Program Sponsors are responsible for reviewing the financial circumstances, investment objectives, risk tolerances and investment restrictions of each Program Client. For each Program Client, the Program Sponsors are responsible for determining the suitability of, and eligibility (including any applicable investor qualifications) to participate in, the Programs and the suitability of the investment strategy(ies) selected. In discretionary Programs, the Program Sponsor typically selects or appoints NBIA as its sub- adviser to manage designated assets of its Program Clients in one or more investment strategies. In those discretionary Programs, NBIA has no direct contractual relationship with the Program Clients, but has investment discretion over the designated assets in the accounts of the Program Clients. NBIA manages the accounts in accordance with the selected investment strategy and reasonable client-directed restrictions. NBIA is not, however, responsible for the cash sweep vehicles offered by Program Sponsors. In some cases, a Program Sponsor will make NBIA’s advisory services available to their clients in a “dual contract” capacity, where the clients (“Dual Contract Clients”) contract separately with the Program Sponsor or a designated broker for brokerage and other services and with NBIA for portfolio management services (“Dual Contract Program”). Certain of the Dual Contract Client accounts are managed in the investment strategies that are also available to Program Clients. In other cases, Dual Contract Client accounts are managed in certain investment strategies that are otherwise available to Private Wealth Account clients. Subject to its obligation to seek best execution, NBIA will seek to execute equity transactions for Wrap Program Client accounts, Unbundled Program Client accounts and Dual Contract Client accounts, and anticipates that the majority of equity transactions for the accounts will be executed, through the Program Sponsors or designated brokers. However, depending on their capabilities or the types of securities traded, such as securities with smaller market capitalizations, foreign securities, or thinly traded securities, NBIA will at times trade certain equity strategies away from the Program Sponsors or designated brokers more frequently, which could result in a material percentage of equity transactions being executed with brokers other than the Program Sponsors or designated brokers. NBIA frequently executes transactions with broker-dealers other than the Program Sponsors or designated brokers for fixed income transactions, including for almost all municipal securities. When trades are executed through the Program Sponsors or designated brokers, the bundled fee paid by each Wrap Program Client, or brokerage fee agreed to by the Unbundled Program Client or Dual Contract Client and the Program Sponsor or the designated broker, as applicable, typically covers all brokerage commissions and execution costs on the trades. When NBIA chooses to trade away from the Program Sponsors or designated brokers and execute trades through broker-dealers other than the Program Sponsors or designated brokers, while NBIA does not charge any additional fees or commissions, the Program Clients or Dual Contract Clients will generally incur transaction-related charges, which include mark-ups/concessions built into fixed income transaction prices due to the over-the-counter nature of the market, trade- away fees, which include electronic trading platform fees, and fees associated with foreign securities transactions, which are in addition to the bundled fee or the Program Sponsor’s or designated broker’s brokerage fee paid by each Program Client or Dual Contract Client. Please refer to Item 5.C for a further description of additional execution and other costs that are incurred by Program Clients or Dual Contract Clients. Clients that enroll in Wrap Programs, Unbundled Programs, or Dual Contract Programs should satisfy themselves that the Program Sponsors or designated brokers are able to provide best execution of transactions. NBIA also participates in non-discretionary Wrap Programs or Unbundled Programs as a model portfolio provider; provided, in one Sponsor’s model delivery program, we are deemed to have discretion, but with respect to security selection in the model. In those Programs, NBIA furnishes investment advice and recommendations to the Program Sponsors or their designee through the provision of model portfolios (“Model Portfolio Programs”). Some Program Sponsors use NBIA’s model portfolios and updates, either alone or together with other model portfolios, to manage the accounts of the Program Clients, although the Program Sponsors retain investment discretion over the accounts. NBIA is responsible solely for providing its model portfolios to the Program Sponsors of Model Portfolio Programs or their designees and the Program Sponsor or designated broker is responsible for executing portfolio transactions for the accounts of the Program Clients. The services provided by each of NBIA and the Program Sponsors are described in the Program Sponsors’ disclosure materials and the contracts Program Sponsors have with their Program Clients. Certain Program Sponsors charge NBIA platform-related fees that are associated with technology, including onboarding and maintenance, data or marketing and education resources. The range and applicability of the platform-related fees depend on the particular program utilized, the level of services, and the particular Program Sponsor. The platform-related fees are paid out of NBIA’s own resources. A Program Sponsor may have an incentive to select NBIA for participation in the program for NBIA agreeing to pay those fees to the Program Sponsor. NBIA does not generally communicate directly with Program Clients (including communications with respect to changes in a Program Client’s investment objectives or restrictions), and all communications generally must be directed through the Program Sponsor. Also, NBIA does not provide overall investment supervisory services to Program Clients. NBIA is not in a position to determine and is not responsible for determining the suitability of, or eligibility (including any applicable investor qualifications) to participate in, any Program for a Program Client or the suitability of any investment strategies available under the Program with respect to Program Clients. Please refer to Section 5.I(2) of Schedule D of Part 1A of NBIA’s Form ADV for a full list of the Wrap Programs in which NBIA participates. Retail clients that are Dual Contract Clients should also review NBIA/NBBD’s Form CRS, which is available at http://www.nb.com/form_CRS_nbia_nbbd/. E. Assets under Management Discretionary Amounts: Non-Discretionary Amounts: Date Calculated: $ 329,960,889,828 $ 7,322,291,809 12/31/2023