A. Description of the Firm

Northern Trust Investments, Inc. (“NTI”) is the primary U.S. investment adviser of Northern Trust Asset Management. Northern Trust Asset Management is the branding name of the asset management business of Northern Trust Corporation, a financial holding company and publicly traded company.

NTI has been registered with the U.S. Securities and Exchange Commission as an investment adviser pursuant to the Investment Advisers Act of 1940 since 1988. NTI is also an Illinois banking corporation subject to the rules and regulations of the Illinois Department of Financial and Professional Regulation. NTI is a wholly owned subsidiary of The Northern Trust Company (“TNTC”), an Illinois banking corporation. NTI is registered with the U.S. Commodities and Futures Trading Commission as a Commodity Pool Operator (“CPO”) and Commodity Trading Advisor (“CTA”). NTI is also a member of the National Futures Association.

B. Types of Advisory Services

NTI is a multi-asset class provider of a wide range of discretionary and non-discretionary investment advisory and sub-advisory services. NTI’s asset class capabilities include equity, fixed income, liquidity and asset allocation. Strategy implementation ranges from passive and factor-based quantitative, to fundamental active and multi-manager. Investment solutions can incorporate sustainable investing principles and customized tax management. The following is a description of the investment vehicles and services NTI offers to clients:

Investment Pools: NTI provides discretionary investment advisory and sub-advisory services to the following types of affiliated and non-affiliated registered and unregistered investment pools:

Mutual Funds Bank Common and Collective Funds Exchange-Traded Funds Other U.S. and Non-U.S. Investment Funds Each investment pool has an investment objective and investment guidelines. Generally, NTI cannot tailor the investment guidelines or impose restrictions on an investment pool to meet individual client needs. Investment objectives and guidelines, and any restrictions or limitations thereto, may be customized for single investor investment pools. Separately Managed Accounts: NTI provides discretionary investment advisory services tailored to meet a client’s individual investment objectives and guidelines, as well as any client investment restrictions or limitations. The investment performance of any client account may be affected by the imposition of investment restrictions or limitations. Clients who impose investment restrictions or limitations might affect the account’s performance and limit NTI’s ability to employ various investment strategies. This may result in investment performance that differs from that of a benchmark or other client accounts utilizing the same or similar investment strategy.

Multi-Manager Strategies: NTI provides discretionary investment advisory services on the selection and termination of affiliated and non-affiliated investment advisers. NTI also offers non-discretionary asset allocation and investment adviser selection. Multi-manager strategies can range from a single to multiple asset classes employing a number of investment advisers.

Wrap Programs: NTI provides investment advisory services to clients of various wrap fee programs through Wrap Program Sponsors (“Sponsor”). In connection with these programs, the Sponsor typically assists in defining the investment objectives and selects one or more investment advisers to implement their respective investment strategies. When selected, NTI manages the account in accordance with the agreed-upon investment objectives, guidelines, risk tolerances and restrictions that a Sponsor establishes within its program.

NTI also provides investment advisory services to Sponsors. In these programs, NTI provides investment advisory services to Sponsors by providing them with NTI’s proprietary model portfolios. The Sponsors may use NTI’s model portfolios, as well as any on-going updates to the model portfolio, either alone or with other model portfolios to manage the accounts of their wrap program clients. Sponsors retain investment discretion under these arrangements and NTI is solely responsible for providing its model portfolio to the Sponsor.

NTI does not act as a Sponsor of any Wrap Fee Programs.

Model Portfolios: NTI provides discretionary and non-discretionary investment advisory services using proprietary and non-affiliated model portfolios. Investment strategies available range from single strategy models to multi-asset class solutions.

Investment Research and Advisory Services: NTI provides investment research and advisory services to clients for their use in evaluating and implementing investment solutions.

Overlay Services: NTI provides clients with overlay services that include currency hedging, cash equitization and beta management. These strategies may employ foreign exchange forwards, futures and exchange-traded funds.
Index Provider: NTI constructs indexes that certain of its advised exchange-traded funds or
clients utilize as benchmarks. Transition Management: NTI provides transition management services to assist clients in restructuring or reallocating their assets. C. Assets Under Management As of December 31, 2018, NTI managed approximately $806,622,000,000 in regulatory assets under management. please register to get more info

Open Brochure from SEC website
Pooled Investment Vehicles $403,582,562,712
Discretionary $873,703,215,881
Non-Discretionary $
Registered Web Sites

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