Atlanta Capital Management Company, LLC (“Atlanta Capital”) is an Atlanta, Georgia based
Registered Investment Advisor offering professional investment advisory services to a broad
range of institutional and retail clients since 1969. Atlanta Capital and its advisory affiliates
represent the investment management division of Morgan Stanley, a publicly held company
(“Morgan Stanley”). Atlanta Capital is a wholly owned subsidiary of Morgan Stanley, a publicly
held company that is traded on the New York Stock Exchange (NYSE) under the ticker symbol
“MS”. Morgan Stanley is a leading global financial services firm providing investment banking,
securities, wealth management and investment management services. With offices in more
than 41 countries, the Firm’s employees serve clients worldwide including corporations,
governments, institutions, and individuals.
Atlanta Capital offers investment advisory services in a variety of equity, fixed income and
mixed‐asset strategies. In‐depth fundamental analysis is the primary basis for Atlanta Capital’s
investment decision making process.
We provide investment advisory services through separately managed accounts to a variety of
institutional clients (“Institutional Accounts”), including business organizations, public and
private pensions, trusts, foundations, charitable organizations, high net worth individuals and
other entities. Atlanta Capital’s advisory services are tailored based on the investment
objectives and guidelines provided by our clients. Before establishing an Institutional Account,
Atlanta Capital and the client discuss the available investment strategies and the client’s
investment objectives. Investment in certain securities or types of securities can be restricted
at the request of the client.
Our investment advisory services are available through various bundled “wrap fee” programs
(“Wrap Fee Programs”) sponsored by certain broker‐dealers and/or investment advisers
(“Sponsor(s)”), including an affiliate of Atlanta Capital, to individual investors, including high net
worth and other retail investors. As used herein, the term Sponsor includes overlay managers
to the extent a Wrap Fee Program utilizes an overlay manager.
Clients that participate in these Wrap Fee Programs enter into a single agreement with the
applicable Sponsor for our advisory services, as well as other bundled services. For a single
“wrap” fee (which is paid to the Sponsor and the Sponsor then pays a portion to us) the
Sponsors offer our investment advisory services to their separately managed account clients
and are generally, depending on the program, primarily responsible for:
i. Monitoring and evaluating our performance;
ii. Executing client portfolio transactions typically without additional commission charge
(except that the client can be charged an added commission charge if we use a broker
other than the Sponsor to execute trades, unless a step‐out arrangement is used by
Atlanta Capital as discussed in more detail in Item 12 – Brokerage Practices);
Providing custodial services for clients’ assets;
iii. Ensuring adherence to client guidelines, restrictions and/or client instructions; and/or
iv. Providing tax management services.
We participate in certain Wrap Fee Programs pursuant to which we provide the Sponsors with a
model portfolio that represents the securities we recommend in accordance
with a particular
investment strategy (the “Model Portfolio”). In most instances, we will communicate our
recommendations comprising the Model Portfolio, and any changes thereto, to the Sponsors,
who serve as investment advisers to the Wrap Fee Program clients and are responsible for
implementation of any client‐specific investment restrictions and for determining the suitability
of our investment strategy for the client. In most instances, unless otherwise agreed, the
Sponsor will exercise investment discretion with respect to securities that are purchased or sold
for clients of such Model Portfolio Wrap Fee Programs and will be responsible for executing
trades and seeking best execution for such Wrap Fee Program accounts.
In addition to offering our advisory services through Wrap Fee Programs in the manner
described above, certain separately managed accounts are offered to retail investors through
what’s known as “dual contract arrangements” (a client will pay the Sponsor a fee and will also
pay Atlanta Capital an advisory fee) in which a Sponsor and its client enter into an agreement
with regard to the Sponsor’s overall management of the client’s assets pursuant to which the
Sponsor identifies managers that offer particular strategies or products that the Sponsor
believes are suitable for each client. Either the Sponsor or the client then selects the particular
strategy or product and the applicable manager to manage portions of the client’s portfolio.
In a “dual contract” arrangement, Atlanta Capital generally has separate agreements with the
Sponsor and each applicable client, the latter of which outlines the scope and limitations of the
advisory relationship between Atlanta Capital and the client. In such arrangements, the
Sponsor, who itself has a client relationship with the client, and/or the client are generally
responsible for determining whether a strategy offered by Atlanta Capital is suitable and
appropriate for the client based on its investment objectives, risk tolerance and financial
situation. Under these arrangements, the client can impose restrictions on investing in certain
securities through the Sponsor or Atlanta Capital, if applicable.
For further discussion on the impacts of restrictions on trading, see Item 12 – Brokerage
Practices, “Directed, Restricted or Constrained Brokerage Arrangements; Wrap Fee Programs”.
Atlanta Capital also serves as investment sub‐advisor to a number of registered investment
companies or mutual funds sponsored by Eaton Vance Management and other affiliates
including Calvert Research and Management and by unaffiliated parties who serve as the
primary investment adviser (each a “Fund” and collectively the “Funds”). Each Fund is
managed in accordance with its respective investment objectives, strategies and restrictions as
approved by the Fund’s Board of Trustees or other governing body, as applicable. Retail
investors primarily access Atlanta Capital’s advisory services indirectly by investing in Funds
sub‐advised by Atlanta Capital.
Further Information
For additional information regarding the specific investment strategies we employ please refer
to Item 8 ‐ Methods of Analysis, Investment Strategies and Risk of Loss.
Assets Under Management
As of December 31, 2023, we had approximately $33,178,196,876 in assets under
management, all on a discretionary basis.