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Adviser Profile

As of Date 09/27/2024
Adviser Type - Large advisory firm
- An investment adviser (or subadviser) to an investment company
Number of Employees 212 -5.36%
of those in investment advisory functions 83 -4.60%
Registration SEC, Approved, 03/10/2009
AUM* 136,711,545,887 14.73%
of that, discretionary 131,909,829,158 18.63%
Private Fund GAV* 0 -100.00%
Avg Account Size 70,761,670 4.87%
% High Net Worth 63.97% -14.76%
SMA’s Yes
Private Funds 0 4
Contact Info 212 xxxxxxx
Websites

Client Types

- 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

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

Compensation Arrangments

- A percentage of assets under your management
- Performance-based fees

Recent News

Reported AUM

Discretionary
Non-discretionary
138B 118B 98B 79B 59B 39B 20B
2015 2016 2017 2018 2019 2020 2021 2022 2023

Private Funds



Employees

Brochure Summary

Overview

The Company Insight North America LLC (“INA” or the “Adviser”), formerly known as Pareto New York LLC until 2016, was established in 2004 as a wholly-owned subsidiary of The Bank of New York Mellon Corporation (“BNY Mellon”). Organized as a Limited Liability Company under the laws of New York, INA registered as an investment adviser with the United States Securities and Exchange Commission (“SEC”) on March 10, 2009. INA is part of the group of affiliated companies that may individually or collectively provide investment advisory services under the brand ‘Insight’ or ‘Insight Investment’ (“Insight”). Insight includes, among others, the following affiliated entities: INA, Insight Investment International Limited (“IIIL”), Insight Investment Management Limited (“IIML”), Insight Investment Funds Management Limited (“IIFM”) and Insight Investment Management Global Limited (“IIMG”) (each an “Insight Affiliate” and collectively, “Insight Affiliates”). INA is also affiliated with other BNY Mellon subsidiaries (“BNY Mellon Affiliates”). INA is controlled by David Leduc (Chief Executive Officer), Alex Veroude (Chief Investent Officer), James Parsons (Chief Operating Officer), John Ariola (Head of Finance), Vivek Nayar (Senior Managing Counsel), and Daniel Haff (Chief Compliance Officer). As Chief Executive Officer of IIML, Abdallah Nauphal oversees the management and operations of the entities comprising Insight Affiliates. Several of the management persons referenced above comprise INA’s United States Management Committee (“USMC”). The USMC convenes on a monthly basis to deliberate on topics such as the Adviser’s adjustments to control and risk parameters, litigation and regulatory matters, operational concerns, client relationships, and the implementation of policies and procedures. From a corporate governance perspective, the purpose of the USMC is to foster a culture of interdepartmental transparency while also establishing a collaborative framework surrounding INA’s approach to handling new business development. The USMC reports its findings directly to INA’s Board of Directors. INA’s Board of Directors is comprised of the control persons serving in a directorial capacity at the INA entity level. The INA Board typically convenes on a quarterly basis to discuss project management updates, operational objectives, and a high- level overview of forthcoming changes to the business. In addition to being registered with the SEC as an investment adviser, INA is a member of the National Futures Association (“NFA”) and is registered with the Commodity Futures Trading Commission (“CFTC”) as a Commodity Trading Advisor (“CTA”) and a Commodity Pool Operator (“CPO”). Investment Advisory Services INA provides discretionary and non-discretionary investment advisory services to institutional investors and high-net worth individuals (the “Client” or “Clients”) in the form of separate accounts and pooled vehicles across a wide variety of fixed
income, risk management strategies including currency risk management and liability driven investing, absolute return and multi-asset capabilities (“Investment Advisory Services”). Additional information regarding INA strategies, including the methods of analysis, fees, and certain material risks, is included under Item 8, ‘Methods of Analysis, Investment Strategies and Risk of Loss’. INA provides tailored Investment Advisory Services to its Clients. Discretionary separate account Clients may impose investment restrictions and other guidelines on the management of the account. However, doing so will limit the Adviser’s ability to act for the account and, therefore, the performance of the account may differ and potentially be lower than the performance of discretionary accounts managed in the same or a similar strategy. Under certain circumstances, INA will decline to accept certain Client-imposed guidelines or restrictions. Please see Item 16 for additional information about investment guidelines and restrictions. INA also offers direct Investment Advisory Services and indirect sub-Investment Advisory Services to pooled vehicles (“Funds”), including collective investment trusts (each a “CIT”), registered investment companies (each a “Mutual Fund”) and exchanged traded funds (“ETFs”). Each Fund has an investment objective and set of investment policies and/or guidelines to which it is subject. Participating Affiliates INA uses investment management related services provided by a Participating Affiliate. INA has entered into a Participating Affiliate Agreement (“PAA”) with IIMG, which is an affiliated asset management company and considered a Participating Affiliate where one or more employees of IIMG are deemed to be Associated Persons of INA. In this capacity, the Participating Affiliate and one or more of its employees (subject to INA’s supervision) provide research, advice, and recommendations in connection with INA’s management of U.S. based Client accounts. In this capacity, IIMG operates in accordance with the series of no-action letters published by the SEC requiring the Participating Affiliate to be subject to the supervision of INA and the SEC. For additional information on Participating Affiliates, please see Item 10. Assets Under Management As of December 31, 2023, INA managed approximately $119 billion in regulatory assets under management (“AUM”), $111 billion of which are managed on a discretionary basis and $8 billion on a non-discretionary basis. INA AUM is generally aggregated with the AUM of its Insight Affiliates in advertisements, marketing, and other promotional materials (“Marketing Materials”). The AUM used in the Marketing Materials is therefore calculated differently than the regulatory AUM listed herein. www.insightinvestment.com 6