Kellogg Asset Management, LLC (Kellogg) has been an investment adviser registered with
the Securities and Exchange Commission since 2009. It was organized to focus on the
unique needs of institutional clients. Kellogg is a wholly owned subsidiary of Associated
Trust Company, N.A. (ATC), an affiliated banking institution with trust powers. ATC is a
wholly owned subsidiary of Associated Bank, N.A. (AB). AB is a wholly owned subsidiary of
Associated Banc-Corp (AB-C). AB-C is a diversified bank/financial services holding company
headquartered in Green Bay, Wisconsin. Kellogg provides advisory services to its affiliates
and to third parties.
Fixed Income Management Services
Kellogg provides fixed income investment management solutions to serve the financial
needs of institutional investors and high net worth investors. Kellogg’s goal is to deliver
competitive investment performance in a risk-controlled framework to a variety of clients,
such as, corporations, foundations, insurance companies, municipalities, as well as high net
worth individuals. Kellogg provides investment analysis, security selection and trade
execution for each portfolio it manages.
Safety, liquidity and yield are Kellogg’s primary considerations when making investments in
bonds. Yield curve positioning, duration management and sector rotation are tools Kellogg
utilizes to minimize risk while seeking to maximize return. The relative attractiveness of
various sectors and a bottom-up analysis of specific securities are key factors in portfolio
construction.
Kellogg uses the following types of investments in carrying out its various fixed income
investment strategies: corporate debt securities, United States government securities,
mortgage-backed securities, asset-backed securities, municipal securities and other types of
investment grade securities. Clients are responsible for informing Kellogg, in advance and in
writing, of any restrictions on investing in certain securities or types of securities.
Kellogg may implement strategies and invest in types of investments other than those listed
above for client accounts, depending on a particular client’s investment objectives and
financial needs.
Equity Management Services
Kellogg provides equity investment management solutions to serve the financial needs of
institutional and high net worth investors. Kellogg’s goal is to deliver competitive investment
performance in a risk-controlled framework to a variety of clients, such as corporations,
foundations, insurance companies, as well as high net worth individuals. Kellogg provides
investment analysis, security selection and trade execution for each portfolio it manages.
Regular meetings are held with clients or their advisors to review the investment objectives
and constraints.
Kellogg’s goal in managing equities is to provide growth of capital in a risk-controlled
framework. We assemble a portfolio of companies where our positive fundamental view
differs from consensus, with the belief that subsequent events will validate our investment
thesis and the stock price will move toward our assessed value.
Kellogg uses the following types of investments in carrying out its various equity investment
strategies: common stocks, ADRs, and ETFs, as well as options strategies to enhance income
or provide downside protection. Clients are responsible for informing Kellogg, in advance
and in writing, of any restrictions on investing in certain securities or types of securities.
Kellogg may implement strategies and invest in types of investments other than those listed
above for clients’ accounts, depending on a particular client’s investment objectives and
financial needs.
Actively Managed Outside Manager Investment Services
Kellogg’s actively managed outside manager investment services includes the Associated
Select Advisor Portfolio (ASAP) program, the Associated LifeStage collective funds, and Health
Savings Accounts.
The services offered by Kellogg include the selection, analysis and monitoring of outside
investment managers used in various model portfolios and recommended lists. Selection of
third-party mutual funds is based in part, but not limited to, management style, manager
experience, consistent application of a philosophy, and long-term performance.
Associated Select Advisor Portfolio Program
Kellogg uses third-party mutual funds to build diversified portfolios that can meet a wide
variety of investment objectives and risk tolerances. Kellogg’s ASAP program offers six
investment strategies that range from Aggressive Growth to Conservative Balanced, each of
which is described in more detail herein. Kellogg uses third-party mutual funds when
developing these strategies.
Kellogg has entered into a license agreement with Envestnet Asset Management, Inc. and its
legal affiliates (Envestnet) pursuant to which Kellogg licenses the ASAP models to Envestnet
for inclusion on Envestnet’s Third Party Models Program. In the future, Kellogg may enter
into similar arrangements with other third-party platform providers (Third-Party
Platforms). As a result, advisors and other financial institutions (Third-Party Advisors) may
engage Third-Party Platforms to directly trade their assets pursuant to the ASAP models.
Kellogg will act as a manager of the ASAP program, and will be responsible for providing the
ASAP models, including periodic updates, to the Third-Party Platforms. In return for these
services, Kellogg receives a portion of the wrap fee charged to clients. Clients with ASAP
program accounts will be advisory clients of those Third-Party Advisors who access the
ASAP models through a Third-Party Platform.
Associated Investment Services, Inc. (AIS), an affiliated registered investment adviser and
indirect wholly-owned subsidiary of AB-C, provides its advisory clients access to the ASAP
program through Envestnet’s Third Party Models Program as a Third-Party Advisor.
In addition to providing the ASAP program through Third Party Platforms, the ASAP
program is also available to clients of ATC directly.
Associated LifeStage Collective Funds
Kellogg is the manager of the Associated LifeStage collective funds of Associated Trust
Company, N.A. (ATC), an affiliated banking institution with trust powers. Associated
LifeStage collective funds are available solely to clients of ATC. LifeStage collective funds
sponsored by ATC are only used in ATC products.
Health Savings Accounts
Kellogg provides investment advice to AB in connection with the Health Savings Accounts
(HSAs) for which AB serves as custodian. In this role, Kellogg is responsible for
recommending and monitoring the mutual funds available for investment in an HSA. In return
for these services, Kellogg receives a portion of the fee charged by AB to its clients.
Asset Allocation and Portfolio/Model Management Services
Kellogg also offers custom asset allocation strategies. These strategies use a diversified
portfolio of bond and/or stock mutual funds to create a mix of assets targeted to a specific
risk tolerance. Each strategy varies in its degree of risk and potential return. To maintain a
particular asset allocation strategy, portfolios must be periodically rebalanced.
In addition to providing various asset classes (stocks, bonds, cash) and market capitalization
(large, mid, and small company stock funds), the strategies also provide diversification by
blending growth and value investment styles.
Assets Under Management
As of December 31, 2023, Kellogg had discretionary assets under management of
$2,508,796,355 and non-discretionary assets under management of $6,750,121.