Advisory Services
IndexIQ (or the “Firm”) is an indirect wholly-owned subsidiary of New York Life Insurance
Company (“New York Life”). As of December 31, 2023, IndexIQ managed $10,439,892,070 of
client assets on a discretionary basis, and no client assets are managed on a non-discretionary
basis.
IndexIQ has operated since July 2007 and has been registered as an investment adviser with the
Securities and Exchange Commission (the “SEC”) since August 9, 2007. IndexIQ was acquired
by New York Life Investment Management Holdings LLC (“New York Life Investment
Management”) in April 2015. IndexIQ is wholly-owned by IndexIQ LLC. IndexIQ LLC is a
wholly-owned subsidiary of New York Life Investment Management, a subsidiary of New York
Life.
IndexIQ LLC develops and maintains proprietary financial indices (the “IndexIQ Indices”). For
certain IndexIQ Indices, IndexIQ LLC has engaged affiliated and unaffiliated entities to act as an
index consultant to assist IndexIQ LLC with the development, calculation and maintenance of the
IndexIQ Indices. IndexIQ provides investment advisory services to clients, including by utilizing
the IndexIQ Indices. IndexIQ LLC also assists IndexIQ with certain performance reporting,
analytical and data analysis, and the creation of informational material about IndexIQ products.
Certain personnel within NYLIM are dual hatted to IndexIQ LLC and support IndexIQ LLC’s
development and maintenance of the IndexIQ Indices, which certain of IndexIQ's exchange-traded
funds (“ETFs”) seek to track. These individuals are responsible for rebalancing, validating and
delivering index component securities and weightings of each IndexIQ Index on a periodic basis.
IndexIQ offers discretionary investment advisory services to registered investment advisers,
broker-dealers, and open-end Registered Investment Companies (“RICs”) operating as mutual
funds (“Mutual Funds”) or ETFs, individuals, trusts, retirement accounts (IRAs, pensions and
profit sharing plans), corporations, affiliated insurance companies and other institutions. IndexIQ
also offers services to Unified Managed Accounts (“UMAs”), which are typically non-
discretionary, Wrap, Model Portfolio and other advisory programs of third-party sponsors
(“Sponsored Programs”) (collectively, products receiving discretionary and non-discretionary
investment advisory services from IndexIQ, “IndexIQ Products”). These investment advisory
services will generally be tailored to meet our clients’ needs. Client-imposed restrictions are
detailed in the respective client’s investment advisory agreement or in such other form as agreed
upon by IndexIQ and the client. With respect to UMAs and Model Portfolios, the services are
generally limited to providing model portfolios to the sponsors of the Sponsored Programs, but in
some cases, IndexIQ will also provide trading services, depending on the agreement with the
sponsor of the Sponsored Programs.
Certain personnel within NYLIM are dual hatted to IndexIQ in order to facilitate the general
management, trading execution, administration and communication services for the RICs
operating as Mutual Funds or ETFs and various other accounts (e.g., individual, trust and
retirement accounts, as well as corporate and affiliated insurance company and other institutional
accounts) and separately managed accounts (“SMAs”) and UMAs, which are managed and/or
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offered by IndexIQ. We refer to these individuals in this Brochure as our employees.
IndexIQ has the discretion to retain affiliated and unaffiliated subadvisers (each, a “Subadviser”)
for portfolio management services. If a Subadviser is retained, IndexIQ delegates trading authority
to the Subadviser, subject to IndexIQ’s oversight. IndexIQ also will enter into agreements with
third parties to offer IndexIQ Products or to develop new products. IndexIQ currently has
subadvisory agreements with the following affiliated subadvisers: MacKay Shields LLC
(“MacKay”) (SEC File No. 801-5594); and NYL Investors LLC (“NYL Investors”) (SEC File No.
801-78759). We also engage the following unaffiliated subadvisers: CBRE Investment
Management Listed Real Assets LLC (“CBRE”) (SEC File No. 801-49083) and Winslow Capital
Management, Inc. (“Winslow”) (SEC File No. 801-41316).
MacKay is the Subadviser to certain active IndexIQ ETFs managed by IndexIQ. For additional
information regarding MacKay’s investment strategies, processes and procedures for selecting
securities and other investment products held in an account, and the associated risks, please refer
to MacKay’s Form ADV Part 2A Brochure and the IndexIQ ETFs’ Prospectus and Statement of
Additional Information (“SAI”).
NYL Investors is the Subadviser to an active IndexIQ ETF managed by IndexIQ. For additional
information regarding NYL Investors’ investment strategies, processes and procedures for
selecting securities and other investment products held in an account, and the associated risks,
please refer to NYL Investors’ Form ADV Part 2A Brochure and the IndexIQ ETF’s Prospectus
and SAI.
Winslow is the Subadviser to certain active IndexIQ ETFs managed by IndexIQ. For additional
information regarding Winslow’s investment strategies, processes and procedures for selecting
securities and other investment products held in an account, and the associated risks, please refer
to Winslow’s Form ADV Part 2A Brochure and the IndexIQ ETFs’ Prospectus and SAI.
CBRE is the Subadviser to an active IndexIQ ETF managed by IndexIQ. For additional information
regarding CBRE’s investment strategies, processes and procedures for selecting securities and
other investment products held in an account, and the associated risks, please refer to CBRE’s
Form ADV Part 2A Brochure and the IndexIQ ETF’s Prospectus and SAI.
IndexIQ has entered into an agreement with NYLIM, an affiliated registered investment adviser, to
assist IndexIQ in providing services to Sponsored Programs. IndexIQ has also entered into an
investment subadvisory agreement with NYLIM to subadvise mutual funds managed by NYLIM.
For additional information regarding NYLIM’s investment strategies, processes and procedures
and the associated risks, please refer to NYLIM’s Form ADV Part 2A Brochure and the applicable
mutual fund’s Prospectus and SAI.
From-time-to-time, IndexIQ and NYLIM will enter into support agreements with unaffiliated
entities that provide for, among other things, the use of the unaffiliated entity’s name and
trademarks by IndexIQ, NYLIM and an IndexIQ ETF and contributions by IndexIQ or NYLIM to
the unaffiliated entity. With respect to such relationships, the unaffiliated entity will be allowed to
review and provide feedback on the selection criteria of the applicable underlying index for an
IndexIQ ETF that has a license agreement to use the unaffiliated entity’s name and trademarks.
However, the unaffiliated entity will not (i) select any individual companies for inclusion or
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exclusion from the index or (ii) have any right to approve or modify the index, once constructed.
The unaffiliated entity will not have any influence on the day-to-day operations of an IndexIQ ETF
or IndexIQ’s management of an ETF.
I. Managed Accounts
IndexIQ has entered into Managed Account Agreements (each, an “Account Agreement”) with
non-RIC clients or financial institutions including insurance companies. Account guidelines will
be specified in each client’s Account Agreement. Security positions may be at the direction of the
client.
II. Sponsored Wrap Fee, Unified Managed Account, and Related Programs
IndexIQ participates in various Sponsored Programs through which
clients of broker-dealers and
other financial institutions retain IndexIQ as a discretionary or non-discretionary adviser under
wrap fee or other arrangements offered by the programs’ sponsors, wherein the client selects
IndexIQ from among the investment advisers presented by the broker or financial institution to the
client. The broker or financial institution also will evaluate IndexIQ’s performance, execute the
portfolio transactions, and/or provide custodial services for the client’s assets as applicable.
The program sponsor bears responsibility for determining whether advisory services provided to
participants in the Sponsored Programs are suitable in light of the participants’ particular facts and
circumstances. IndexIQ remains responsible for determining that it is properly carrying out the
services that it has agreed to provide as part of the Sponsored Programs.
A Sponsored Program client may terminate the account arrangement upon a specified period of
notice to the broker or other financial institution. Upon termination, any prepaid fee is refundable
on a pro-rata basis for the period unearned.
Although the foregoing describes how these Sponsored Programs operate and IndexIQ’s role in
these programs, each program’s operations could contain certain features or roles for IndexIQ that
vary from the description herein. NYLIM provides certain trade execution and administrative
services to IndexIQ to support IndexIQ’s management of Sponsored Program accounts.
For additional information about these Sponsored Programs, please consult the disclosure
brochures of the Sponsored Programs.
III. Model Portfolios
IndexIQ has entered into agreements to provide model securities portfolios (“Model Portfolios”)
to other investment advisers in their managed accounts or similar Sponsored Programs. IndexIQ
will generally not have discretion over client accounts with respect to providing Model Portfolios
and its responsibilities are generally limited to providing Model Portfolios to such advisers and
certain activities related thereto. In this regard, IndexIQ’s activities do not include trade execution
or other advisory functions performed by the other adviser or overlay or implementation manager
for Sponsored Program clients. These other advisers or third-party overlay or implementation
managers use the Model Portfolios as recommendations for how to trade and invest the program
clients’ accounts. IndexIQ’s Model Portfolio service is not tailored to the individual clients of the
other advisers or the programs. IndexIQ is generally not provided with specific client information
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such as the identity or specific financial circumstances of such Sponsored Program clients. At the
request of a Model Portfolio sponsor or implementation manager, IndexIQ provides
recommendations to the sponsor or implementation manager regarding securities and investments
that the sponsor or implementation manager may or may not consider purchasing for tax
management purposes or to pursue certain investment strategies.. Such recommendations will in
certain circumstances include ETFs managed by IndexIQ that pay management fees to IndexIQ.
IndexIQ receives a fee for its Model Portfolio services. The fee is generally based on the market
value of the assets in a particular Model Portfolio and is assessed on a monthly basis.
For additional information about a particular Model Portfolio, please consult the disclosure
brochure of the applicable Model Portfolio Sponsor or implementation manager.
IV. Registered Investment Companies
IndexIQ provides investment advisory services to open-end RICs operating as Mutual Funds or
ETFs (collectively, the “Registered Funds” and individually, each a “Registered Fund”) in
accordance with Investment Advisory Agreements or Investment Subadvisory Agreements with
the Registered Fund as approved by the applicable Registered Fund’s Board of Trustees (“Board”).
For the Registered Funds that IndexIQ manages directly, IndexIQ has overall responsibility for the
general management and administration of the Registered Funds, subject to the oversight of the
applicable Board. In accordance with the applicable Investment Advisory Agreement, IndexIQ
provides an investment program for each Registered Fund and manages the investment of each
Registered Fund’s assets in conformity with the stated investment policies of such Registered
Fund. With respect to the Registered Funds that IndexIQ subadvises for NYLIM, subject to the
supervision of NYLIM and the oversight of the applicable Board, IndexIQ provides a continuous
investment program for the Registered Funds’ allocated assets and determines the composition of
the assets of the Registered Funds’ allocated assets, including determination of the purchase,
retention or sale of the securities, cash and other investments contained in the portfolio.
With respect to the Registered Funds that IndexIQ manages directly, IndexIQ will from time to
time retain Subadvisers to manage a Registered Fund’s assets. In this regard, IndexIQ makes
recommendations to the Board of the applicable Registered Fund regarding Subadvisers to be
retained to provide subadvisory services and the Board approves the subadvisory agreements
periodically, as required by the Investment Company Act of 1940, as amended. Subadvisers are
recommended by IndexIQ based on a number of factors, including an evaluation of their skills and
investment results in managing assets for specific asset classes, investment styles and strategies.
Currently, IndexIQ engages MacKay and NYL Investors, both affiliated subadvisers, and Winslow
and CBRE, both unaffiliated subadvisers, to subadvise certain ETFs.
IndexIQ or a Subadviser is responsible for placing purchase and sale orders and providing
continuous supervision of the investment portfolio of each of the Registered Funds. IndexIQ is
also responsible for arranging for third-party administration, transfer agent, custodial, and all other
non-distribution related services for the Registered Funds that IndexIQ manages directly. IndexIQ
does not provide custodial services to the Registered Funds. At no time will IndexIQ accept or
maintain custody with respect to a Registered Fund’s assets.
For additional information regarding the Registered Funds’ fees, investment objectives,
investment strategies and associated risks, please refer to Registered Funds’ Prospectuses and
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SAIs. This ADV brochure does not constitute an offer to sell, or a solicitation of an offer to buy,
shares of the Registered Funds.
Termination of Accounts, Advisory Agreements and Program Agreements
Non-Sponsored Managed Accounts: Account Agreements in non-Sponsored Programs generally
may be terminated by either the client or IndexIQ upon a specified period of prior written notice,
generally 10 to 90 days.
Sponsored Programs: Agreements with sponsors of UMA, Wrap and other similar programs
generally may be terminated by the parties upon a specified period of prior written notice, generally
90 days.
Model Portfolios: Agreements between IndexIQ and other advisers relating to IndexIQ’s provision
of Model Portfolios generally may be terminated upon a specified period of prior written notice set
forth in the relevant program agreement, generally ranging from 30 days to 90 days.
Registered Funds: Investment Advisory Agreements with Registered Funds terminate
immediately upon assignment or IndexIQ may terminate upon 60 days’ prior written notice.
Investment Advisory or Subadvisory Agreements must be renewed by the applicable Registered
Fund’s Board on an annual basis after their initial two-year term.