Firm Description
Vest is an SEC-registered investment adviser with its principal place of business in Virginia. The
Firm began conducting business in 2012. Vest is wholly owned by Vest Group, Inc., a Delaware
corporation.
Vest serves as the investment adviser or sub-adviser to open-end and closed-end registered
investment companies, U.S. and non-U.S. Exchange Traded Funds (“ETFs”), funds that are not
registered under the Investment Company Act of 1940 (the “1940 Act”), and whose interests are not
registered under the Securities Act of 1933 (the “1933 Act’) (each, a “private fund”), separately-
managed accounts (“SMAs”) and Collective Investment Trusts (“CITs”), and acts as a portfolio
consultant and may provide sub-supervisory services for Unit Investment Trusts (“UITs”)
(collectively “Funds”). In addition, Vest also provides non-discretionary investment
recommendations (“Model Portfolios”) as a sub-adviser to another investment advisor/platform.
As used in this brochure, the words “we,” “our” and “us” refer to Vest and the words “you”, “your”
and “client” refer to the Funds or the Model Portfolios.
Investment Advisory, Sub-Advisory, and Portfolio Consultant Services
Mutual Funds, Closed-end Funds, Private Funds, Variable Insurance Trusts, and ETFs
Vest provides investment advisory and sub-advisory services to open-end mutual funds, closed-end
funds, private funds, variable insurance trusts and ETFs, including in countries other than the United
States. The Firm acts in the capacity of adviser or sub-adviser to any of the previously mentioned
investment vehicles in accordance with the investment management agreement in place with each
specific fund, variable insurance trust or ETF. As the adviser or sub-adviser, Vest is responsible for
selecting investments, managing the portfolios, and overseeing the investment strategies and policies
for each fund, variable insurance trust or ETF, subject to the general supervision of its board of
trustees, as applicable.
The ETFs that Vest sub-advises include “fund of funds” structures (“First Trust Fund of Funds”),
whereby the ETF invests in other ETFs that are sub-advised by Vest and sponsored by Vest’s affiliate,
First Trust Advisors L.P. (“First Trust ETFs”). For these funds of funds, Vest assists the funds’
adviser in selecting the underlying portfolio of funds that each fund of funds may invest in on a
periodic basis.
Collective Investment Trusts
Vest also manages Employee Retirement Income Security Act of 1974, as amended, (“ERISA”)
assets in CITs. The CITs are bank maintained and not registered
with the Securities and Exchange
Commission. The CITs are not mutual funds registered under the 1940 Act or other applicable law,
and unit holders are not entitled to the protections of the 1940 Act. The regulations applicable to the
CITs are different from those applicable to a mutual fund. The CIT’s units are not securities registered
under the 1933 Act or applicable securities laws of any state or other jurisdiction. Vest may also
provide sub-advisory services to CITs managed by other entities.
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Vest is responsible for selecting investments, managing the portfolios, and overseeing the investment
strategies and policies for the CITs, subject to the investment guidelines and restrictions contained in
the relevant advisory agreement and subject to the general supervision of the CITs’ trustees, as
applicable.
Portfolio Consulting Services and Sub-Supervision for UITs
Vest performs the services of portfolio consulting, security selection, and supervision to UITs. Each
UIT is an investment company registered under the Investment Company Act of 1940. Certain of
these UITs invest primarily in options. Vest serves as non-discretionary sub-portfolio supervisor and
portfolio consultant for these UITs, and in this role, assists the UIT sponsor in the determination of
the composition of options and other securities that a UIT may purchase or sell during its initial
period of formation to meet the overall investment guidelines set forth in the UIT documents. The
asset totals for these UITs are described as “supervised on a non-discretionary basis.”
Model Portfolios
Vest provides Model Portfolios to another advisor/platform. In such cases, Vest will not have
authority to execute any transactions. Vest’s recommendations only include First Trust ETFs. Vest
does not charge a fee for the provision of the Model Portfolios.
Separately Managed Accounts
Vest offers investment sub-advisory services to separately-managed accounts under written
investment advisory agreements. Except as otherwise described herein, investments for SMAs are
managed in accordance with the client’s investment objectives, strategies, restrictions and guidelines
as communicated to Vest by the client (or the client’s primary adviser or program sponsor) in the
applicable agreement, including the investment policies or guidelines.
Assets Under Management
As of February 29, 2024, the Firm’s assets under management and assets under
supervision/advisement totaled $28,447,918,051 of which $24,381,015,458 was managed on a
discretionary basis and $4,066,902,593 was supervised on a non-discretionary basis.