AMUNDI PIONEER ASSET MANAGEMENT, INC.
- Advisory Business
- Fees and Compensation
- Performance-Based Fees
- Types of Clients
- Methods of Analysis
- Disciplinary Information
- Other Activities
- Code of Ethics
- Brokerage Practices
- Review of Accounts
- Client Referrals
- Custody
- Investment Discretion
- Voting Client Securities
- Financial Information
Amundi Pioneer provides investment advisory services encompassing a wide range of investment strategies, as discussed herein. Amundi Pioneer provides investment management services to various entities, including open and closed-end investment companies (“Domestic Funds”) that are registered under the U.S. Investment Company Act of 1940, as amended (the “Investment Company Act”), and other similarly managed accounts such as private funds, foreign registered investment companies (“Off-Shore Funds”), and a controlled foreign corporation (“CFC”) wholly owned by a registered investment company (“RIC”). Amundi Pioneer also provides investment sub-advisory services to RICs. Amundi Pioneer is registered with the Commodity Futures Trading Commission (“CFTC”) as a Commodity Pool Operator (“CPO”) and a commodity trading advisor (“CTA”). Amundi Pioneer’s U.S. history dates back to 1928 with the creation of the Pioneer Fund, one of the first mutual funds.
Amundi Pioneer is a wholly owned subsidiary of Amundi Pioneer Asset Management USA, Inc. (“APAMUSA”), which in turn, is a wholly owned subsidiary of Amundi USA, Inc. (“Amundi USA”). Amundi USA is a wholly owned subsidiary of Amundi. Amundi is controlled by Credit Agricole S.A., a French credit institution. Credit Agricole S.A. currently holds 70% of Amundi’s share capital. The remaining shares of Amundi are held by institutional and retail investors. Amundi Pioneer provides investment services only to Domestic Funds, Off-Shore Funds, and a CFC. Amundi Pioneer does not tailor its services to individual needs of clients.
As of 1/31/2019, Amundi Pioneer managed approximately $65,955,000,000 in assets for approximately 81 clients. Approximately $65,630,000,000 was managed on a discretionary basis, and $325,000,000 was managed on a non-discretionary basis. please register to get more info
The fees for providing investment management services to all clients, including Domestic Funds and other similarly managed accounts such as private funds and Off-Shore Funds, are negotiated on an individual basis and vary significantly among clients. Fees generally are expressed as a percentage of assets under management of the client, and clients are billed monthly or quarterly and in arrears. Fees paid by certain clients also may include performance fees permitted by Section 205(b) of the Investment Advisers Act of 1940, as amended (the “Investment Advisers Act”) and SEC Rules adopted thereunder. With respect to the Domestic Funds, each management contract generally has an initial term of two years and continues thereafter only if approved by the Fund’s Board of Trustees (the “Board”), including a majority of the Board’s independent trustees, annually and may be terminated without penalty by either the Fund, by a vote of the Fund’s Board or by a vote of a majority of its outstanding voting securities, or by Amundi Pioneer upon 60 days’ prior written notice to the Fund. The contracts also terminate if “assigned,” as that term is defined in the Investment Company Act. The fees are described below and in the investment company registration statements and amendments filed with the SEC. Management fees are calculated as a percentage of assets under management. Domestic Funds Management Fee (expressed as a percentage of assets under management) Pioneer AMT-Free Municipal Fund 0.50% up to $250 Million; 0.45% on the next $500 Million; 0.40% on the next $1.25 Billion; and 0.35% on the excess over $2 Billion Pioneer Bond Fund 0.40% up to $500 Million; 0.35% on the next $500 Million, 0.30% on the next $1 Billion; 0.25% on the next $8 Billion; and 0.225% on the excess over $10 Billion. Pioneer Bond VCT Portfolio 0.40% Pioneer U.S Government Money Market Fund 0.35% up to $1 Billion; 0.30% on the excess over $1 Billion Pioneer Classic Balanced Fund 0.50% up to $1 Billion; 0.45% on the excess over $1 Billion. Pioneer Core Equity Fund 0.50% up to $5 Billion; 0.45% on the excess over $5 Billion. Pioneer Corporate High Yield Fund 0.60% up to $1 Billion; 0.55% on the excess of $1 Billion Pioneer Disciplined Growth Fund 0.65% up to $1 Billion; 0.60% on the next $4 Billion; and 0.55% on the excess over $5 Billion Pioneer Disciplined Value Fund 0.65% up to $1 Billion; 0.60% on the next $2 Billion; 0.55% on the next $4.5 Billion; and 0.525% on the excess over $7.5 Billion Pioneer Diversified High Income Trust 0.85%, The fees for closed-end funds are calculated based on managed assets, which Pioneer Dynamic Credit Fund 0.70% up to $1 Billion; 0.65% on the excess over $1 Billion Pioneer Equity Income Fund 0.60% up to $10 Billion; 0.575% on the excess over $10 Billion Pioneer Equity Income VCT Portfolio 0.65% up to $1 Billion; 0.60% on the excess over $1 Billion Pioneer Floating Rate Fund 0.60% up to $500 Million; 0.55% on the next $1.5 Billion; and 0.50% on the excess over $2 Billion Pioneer Floating Rate Trust 0.70%, The fees for closed-end funds are calculated based on managed assets, which Pioneer Fundamental Growth Fund 0.65% up to $1 Billion; 0.60% on the next $6.5 Billion; and 0.55% on the excess over $7.5 Billion Sub-Advised: Great-West Multi Manager Large Cap Growth Fund 0.30% up to $500 Million; 0.24% on the next $500 Million; 0.225% on the excess over $1 Billion Pioneer Global Equity Fund 0.65% up to $1 Billion; and 0.60% on the excess over $1 Billion Pioneer Global High Yield Fund 0.70% up to $500 Million; 0.65% on the next $500 Million; 0.60% on the next $500 Million; 0.55% on the next $500 Million; 0.45% on the excess over $2 Billion Pioneer Global Multisector Income Fund 0.50% up to $1 Billion; 0.45% on the excess over $1 Billion. Pioneer High Income Municipal Fund 0.50% up to $500 Million; 0.475% on the next $500 Million; and 0.450% on the excess over $1 Billion Pioneer High Income Trust 0.60%, The fees for closed-end funds are calculated based on managed assets, which include investment leverage. Pioneer High Yield Fund 0.70% up to $500 Million; 0.65% on the next $500 Million; 0.60% on the next $4 Billion; 0.55% on the next $1 Billion; 0.50% on the next $1 Billion; 0.45% on the next $1 Billion; 0.40% on the next $1 Billion; 0.35% on the next $1 Billion; 0.30% on the excess over $10 Billion Sub-Advised: Voya High Yield Fund Account 0.30% up to $500 Million; 0.25% on the excess over $500 Million Pioneer High Yield VCT Portfolio 0.65% up to $1 Billion; 0.60% on the excess over $1 Billion Pioneer Solutions - Balanced Fund 0.00%1 Pioneer ILS Interval Fund, and Pioneer ILS Bridge Fund 1.75% Pioneer International Equity Fund 0.65% up to $1 Billion; 0.60% on the excess over $1 Billion Pioneer Mid Cap Value Fund 0.70% up to $500 Million; 0.65% on the next $500 Million; 0.625% on the next $3 Billion; 0.600% on the excess over $4 Billion with a maximum performance adjustment of +/- 0.10% Pioneer Mid Cap Value VCT Portfolio 0.65% Pioneer Multi-Asset Income Fund 0.50% up to $1 Billion; 0.45% on the next $4 Billion; and 0.40% on the excess over $5 Billion Pioneer Multi-Asset Ultrashort Income Fund 0.35% up to $1 Billion; 0.30% on the next $4 Billion; 0.25% on the next $2.5 Billion, and 0.20% on the excess over $7.5 Billion Pioneer Flexible Opportunities Fund 0.70% up to $1 Billion; 0.675% on the next $1Billion; 0.65% on the excess over $2 Billion. The fund may gain exposure to commodities through investment in a wholly-owned subsidiary of the fund organized under the laws of the Cayman Islands. The fund pays Amundi Pioneer the fee described above, excluding assets invested in the subsidiary. The subsidiary has entered into a separate management contract with Amundi Pioneer. The subsidiary pays Amundi Pioneer a fee at the annual rate of 0.70% of the subsidiary’s average daily net assets. Pioneer Municipal High Income Advantage Trust 0.60%, The fees for closed-end funds are calculated based on managed assets, which 1 The fund does not pay a direct management fee to Amundi Pioneer. The fund bears a pro rata portion of the fees and expenses, including management fees, of each underlying fund in which the fund invests. The fund invests primarily in funds managed by Amundi Pioneer. Pioneer Municipal High Income Trust 0.60%, The fees for closed-end funds are calculated based on managed assets, which Pioneer Fund 0.60% up to $7.5 Billion; 0.575% on the next $2.5 Billion; 0.55% on the excess over $10 Billion; with a maximum performance adjustment of +/- 0.10% Pioneer Fund VCT Portfolio 0.65% Pioneer Real Estate Shares 0.80% up to $1 Billion; 0.75% on the excess over $1 Billion. Pioneer Real Estate Shares VCT Portfolio 0.80% up to $500 Million; 0.75% on the excess over $500 Million Pioneer Select Mid Cap Growth Fund 0.625% up to $500 Million; 0.60% on the next $500 Million; 0.575% on the next $4 Billion; and 0.55% on the excess over $5 Billion Pioneer Select Mid Cap Growth VCT Portfolio 0.74% Pioneer Short Term Income Fund 0.35% up to $1 Billion; 0.30% on the excess over $1 Billion Pioneer Strategic Income Fund 0.60% up to $1 Billion; 0.55% on the next $9 Billion; 0.50% on the excess over $10 Billion Pioneer Strategic Income VCT Portfolio 0.65%
Amundi Luxembourg S.A., an affiliate of Amundi Pioneer, has engaged Amundi Pioneer to provide investment management services to a number of publicly-offered European funds, including certain Luxembourg domiciled UCITS (Undertakings for Collective Investment in Transferable Securities). For the delegated asset management services, Amundi Pioneer receives a portion of the total fees received by Amundi Luxembourg S.A. The rates at which Amundi Pioneer receives fees for its services are established from time to time pursuant to intercompany fee arrangements that consider the competitive range of fees for similar services. With respect to clients that are Off-Shore Funds, each management contract usually provides that either party has the right to terminate the advisory relationship not less than 90 days’ with prior written notice. In the event of account termination, Amundi Pioneer is entitled to receive all fees accrued up to the date of termination. With respect to private funds, each management agreement provides that either party has the right to terminate the agreement, without penalty, upon the giving of 30 calendar days’ notice to the other party. With respect to the Domestic Funds, Amundi Pioneer provides for office space, equipment and personnel for managing the Funds’ affairs and investments and pays all or a part of the salaries and fees of all officers of each Fund and of all Trustees who are “interested persons,” as that term is defined in the Investment Company Act, of Amundi Pioneer. Amundi Pioneer may waive all or a portion of its management fee otherwise payable to it and/or undertake to pay or reimburse a Fund for all or a portion of its expenses not otherwise required to be borne or reimbursed by Amundi Pioneer. Amundi Pioneer has entered into expense limitation agreements with certain of the Domestic Funds whereby Amundi Pioneer has committed for certain periods of time to limit or maintain the expenses of such Domestic Funds.
With respect to the Off-Shore Funds, Amundi Pioneer provides for office space, equipment and personnel for managing the Funds’ investments. Amundi Pioneer may agree to waive a portion of the fees it receives from Amundi Luxembourg S.A. for the delegated asset management services. Clients of Domestic Funds and Off-Shore Funds generally will incur and pay: (1) charges and expenses for accounting, pricing and appraisal services of any portfolio accounting and / or recordkeeping agent appointed by the client with respect to the portfolio; (2) the charges and expenses of any custodian appointed by the client with respect to the portfolio; (3) all brokerage commissions, dealer spreads, transfer fees and taxes; (4) reasonable legal expenses related to any investment of the portfolio; and (5) all other reasonable expenses properly chargeable to the client. Clients also will incur transaction costs on their account. Any expenses allocated to an account relating to securities may be shared pro rata with any other of Amundi Pioneer’s accounts with the same expenses. The expenses and costs described above are not reflected in the fee schedules listed above, which only reflect management fees.
Clients of private funds generally will not incur and pay: (1) charges and expenses for accounting, pricing and appraisal services of any portfolio accounting and/or recordkeeping agent appointed by the client with respect to the portfolio; (2) the charges and expenses of any custodian appointed by client with respect to the portfolio; (3) all brokerage commissions, dealer spreads, transfer fees and taxes; (4) charges and expenses (including reasonable legal fees) associated with the purchase of securities incurred in good faith in connection with the valuation, negotiation and purchase of securities for the portfolio and the ongoing exercise of the client’s rights under the securities held in the portfolio; and (5) all other expenses properly chargeable to the client. Clients also will incur transaction costs on their account. Any expenses allocated to an account relating to securities may be shared pro rata with any other of Amundi Pioneer’s accounts with the same expenses. Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee. Upon termination of any account, any earned, unpaid fees will be due and payable. Amundi Pioneer may sub-contract with investment management firms having a particular expertise (“sub-advisers”) to manage a portion of or all the assets in an account under its management. In such event, the fees payable to sub-advisers would generally be paid by Amundi Pioneer and are based on a percentage of assets under the sub-advisers management. The Brokerage Practices section of this Brochure further describes the factors that Amundi Pioneer considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation. please register to get more info
Certain clients pay Amundi Pioneer performance-based fees. Amundi Pioneer in general, and certain portfolio managers of Amundi Pioneer, manage accounts that are charged a performance- based fee and accounts that are charged only an asset-based fee. Managing both types of accounts at the same time may create an incentive to favor performance-based fee accounts. In addition, as a result of such performance fees, Amundi Pioneer may have an incentive to make riskier investment decisions on behalf of clients for which it may earn performance-based fees because such decisions could yield higher returns.
Amundi Pioneer recognizes that conflicts may arise under these circumstances, and has adopted an investment allocation policy for Amundi Pioneer that addresses the potential conflict of interest for a portfolio manager to favor performance–based fee accounts. This policy provides that no allocation shall be made to an account based on performance, the amount or structure of Amundi Pioneer’s fee for managing the account, the direct or indirect interests of Amundi Pioneer or its employees in the account, or whether the account is public, private, proprietary or third party. In determining which securities to buy or sell for a client and in what amount, Amundi Pioneer may consider a variety of factors, including the client’s investment objectives and strategies, the client’s diversification and liquidity requirements, the size of the client’s account, tax implications, the marketability of the securities, the characteristics of the client’s account and other relevant factors, such as the size of an available purchase or sale opportunity, the extent to which an available opportunity would represent a meaningful portion of the client’s account, and the availability of comparable opportunities. Other factors considered include the amount of securities of the issuer then outstanding, the value of those securities and the market for them. Amundi Pioneer may make purchase and sale decisions with respect to a particular client account that may be the same as, or differ from, the recommendations made, or the timing or nature of the action taken, with respect to other accounts. Frequently, the same investment decision is made for more than one account and Amundi Pioneer’s portfolio managers may place orders to buy or sell the same security for a number of accounts. Amundi Pioneer may aggregate orders to purchase or sell the same security for multiple accounts. In some cases, Amundi Pioneer may not aggregate orders for accounts managed out of one Amundi Pioneer office with orders for accounts managed out of another Amundi Pioneer office. Whenever Amundi Pioneer aggregates orders, all accounts that participate in the transaction will participate on a pro rata or other objective basis, as described below. To the extent that orders are not aggregated, including orders for accounts that are managed out of different Amundi Pioneer offices, clients may not receive the same transaction price and transaction costs may be higher. Amundi Pioneer will not aggregate investment transactions for accounts unless the transaction is consistent with its duties to the accounts, the terms of the applicable investment management agreement and each account’s investment objectives, restrictions and policies.
Equity Trade Allocation: With the exception of transactions in limited investment opportunities such as Initial Public Offerings (“IPOs”), new issues or secondary offerings, executions of aggregated equity trades generally are allocated pro rata to the participating accounts based on order size (i.e., each client will be allocated that percentage of the executed order that its requested order size bears to the total size of the order). Allocated amounts may be rounded to reflect market practices for lot sizes. All accounts in a single aggregated trade receive the average price obtained and pay a pro rata portion of all transactions costs.
If new orders for the same security with the same terms are submitted at any time to an existing order where partial executions have already occurred with respect to the original order, the prior executions will be allocated pro rata among the original participating accounts at the average price obtained for such executions up to the time new orders are received. New orders will be added to the balance of the original unexecuted order, and each original participating account will receive a pro rata allocation based on the percentage that the balance of the original order plus the new orders relates to the balance of the original order. New orders will receive a pro rata allocation based on the percentage that each new order relates to the balance of the original order plus the new orders. All allocations to original participating and new accounts will be at the average price obtained for executions subsequent to the new orders being added to the original order.
If a trade is only partially completed on a given day, that day’s fill will be allocated on a pro rata basis among each participating account at the close of business that day at the average execution price.
Fixed Income Trade Allocation: Amundi Pioneer allocates fixed-income trades prior to the end of the day the trade is executed (“trade date”). In determining the level of allocation to a particular account, portfolio managers and analysts review client guidelines and consider a variety of factors at the time of allocation. Once a fixed income trade has been executed and participating accounts are identified as described above, all participating accounts receive the same purchase price and transaction costs, if any, are shared pro rata among participating accounts. Limited Public Offerings, New Issues and Limited Opportunity Allocations: Client accounts acquiring securities in IPOs, new issue or limited investment opportunity will receive a pro rata allocation of such transaction based on the total net assets of all participating accounts, provided that variances of + 15% are permitted and that allocations to an account may not exceed the portfolio manager’s indication of interest. The net assets of a closed-end fund shall not include the leverage derived from the issuance of preferred shares. Allocations for IPOs, new issues or limited investment opportunities are determined immediately after confirmation of an allocation for shares/interests in the offering from the broker-dealer. Once an allocation is confirmed, if it is less than Amundi Pioneer requested, Amundi Pioneer may adjust its allocation on a pro rata basis to the original allocation as provided in Amundi Pioneer ’s trade allocation procedures. Allocations of IPOs, new issues and limited investment opportunities are reviewed by the Trade Management Committee. The allocation and reporting procedures relating to IPOs, new issues and limited investment opportunities shall not apply to situations where an offering does not present a limited or unique opportunity based on the issue size or availability of substantially similar securities, such as in the case of government securities, certificates of deposit (CDs) and high quality, short-term investments.
Amundi Pioneer maintains separate trading groups for Amundi Pioneer’s managed funds and accounts (“Amundi Pioneer Trading Group”) and any third-party model programs (“Model Portfolios Group”). The two groups operate independently of one another.
Model changes to similarly managed strategies will be communicated to both the Amundi Pioneer Trading Group and the Model Portfolios Group simultaneously.
In cases where Amundi Pioneer is participating in more than one model program for the same strategy, the Model Portfolios Group will disseminate the respective strategy’s model changes to the applicable Firms using an equitable rotation methodology.
Amundi Pioneer will not allocate trades for the purpose of benefitting Amundi Pioneer or any of its officers or its employees; or for the accounts of business associates, friends or relatives while excluding other accounts from the allocation of any securities.
Under no circumstances will Amundi Pioneer delay allocation so that it can allocate the more favorable prices received during the day to one account and the less favorable prices to another account.
In general, to the extent particular trading activity relates both to Amundi Pioneer accounts and those of its advisory affiliate, APIAM, allocation methodologies will be administered jointly. Post-execution allocations must comply with the same general guidelines set forth above for pre- execution allocations and must be consistent with treating all accounts fairly and equitably. All deviations from modifications to allocations for this reason must be documented. please register to get more info
Amundi Pioneer provides investment advisory services encompassing a wide range of investment strategies, as discussed herein. Amundi Pioneer provides investment management services to various entities, including Domestic Funds that are registered under the Investment Company Act, and other similarly managed accounts such as private funds and Off-Shore Funds, and a CFC wholly owned by a RIC. Amundi Pioneer also serves as a sub-adviser to RICs. Each Domestic Fund prospectus contains information related to opening and maintaining an account and other account policies. please register to get more info
Amundi Pioneer selects investments from a wide range of asset classes and employs a variety of styles in managing client assets. With respect to equity securities, Amundi Pioneer employs both fundamental research and quantitative research to its portfolio management. From both the fundamental research and quantitative research groups, information flows to the portfolio managers, who are responsible for active portfolio management. The investment management teams evaluate the research teams’ recommendations against Amundi Pioneer’s buy or sell disciplines, and act accordingly.
With respect to fixed income securities, Amundi Pioneer’s investment professionals consistently apply well established means of identifying potentially rewarding securities, bolstered by access to information from their associates around the globe and aided by technology. Whether applying top-down analysis that leads to selection of government bonds, or the bottom-up approach that ends with corporate bonds being selected, the investment management teams’ goal is portfolio construction that matches product objectives and supports investors’ goals.
The significant investment strategies that Amundi Pioneer uses in managing assets in the Domestic Funds and other similarly managed accounts such as private funds and Off-Shore Funds, are described below. Any percentage limitations on investment strategies are those of the applicable Domestic Fund. Other similarly managed accounts may have different percentage limitations. In each of its strategies, Amundi Pioneer utilizes macroeconomic research regarding economic forecasts and analysis, as well as industry data relating to profits and trends. Demographic, technological and social trends are also analyzed in the overall analysis of certain securities. The material risks involved with these strategies or methods of analysis are described at the end of this section.
Equity Strategies
The significant investment strategies for Pioneer Fund and certain other similarly managed and sub-advised accounts with investment objectives of reasonable income and capital growth are:
The fund invests in a broad group of carefully selected securities that Amundi Pioneer believes are reasonably priced, rather than in securities whose prices reflect a premium resulting from their current market popularity. The fund invests predominantly in equity securities. For - ESG risk purposes of the fund's investment policies, equity securities include common stocks and other equity instruments, such as funds that invest primarily in equity securities, equity interests in real estate investment trusts (REITs), depositary receipts, warrants, rights and preferred stocks. The fund primarily invests in securities of U.S. issuers. The fund may invest up to 15% of its total assets in securities of non-U.S. issuers. The fund will not invest more than 5% of its total assets in the securities of emerging markets issuers.
The fund may invest up to 15% of its net assets in REITs.
The fund may invest in initial public offerings of equity securities. The fund may also invest in investment grade and below investment grade debt securities (known as “junk bonds”).
The fund may, but is not required to, use derivatives. The fund may use derivatives, such as stock index futures and options, for a variety of purposes, including: in an attempt to hedge against adverse changes in the market price of securities, interest rates or currency exchange rates; as a substitute for purchasing or selling securities; to attempt to increase the fund's return as a non-hedging strategy that may be considered speculative; to manage portfolio characteristics; and as a cash flow management technique. The fund may choose not to make use of derivatives for a variety of reasons, and any use may be limited by applicable law and regulations. The fund may also hold cash or other short-term investments.
Amundi Pioneer uses a value approach to select the fund's investments to buy and sell. Amundi Pioneer seeks securities selling at reasonable prices or substantial discounts to their underlying values and then holds these securities until the market values reflect their intrinsic values. Amundi Pioneer evaluates a security's potential value, including the attractiveness of its market valuation, based on the company's assets and prospects for earnings growth. In making that assessment, Amundi Pioneer employs fundamental research and an evaluation of the issuer based on its financial statements and operations. In selecting securities, Amundi Pioneer considers a security's potential to provide a reasonable amount of income. Amundi Pioneer focuses on the quality and price of individual issuers.
Amundi Pioneer also considers environmental, social and/or corporate governance (ESG) standards in selecting securities to buy and sell. Amundi Pioneer integrates ESG analysis into its investment process by securities - Risks of warrants and rights - Preferred stocks risk - Risks of initial public offerings - Risks of investment in other funds - Debt securities risk - Risks of non-U.S. investments - Market segment risk - Derivatives risk - Leveraging risk - Valuation risk - Liquidity risk - Cybersecurity risk focusing on companies with sustainable business models and evaluating ESG-related risks as part of its research recommendations. In addition, Amundi Pioneer generally excludes corporate issuers that do not meet or exceed minimum ESG standards, based on a system that uses ESG ratings provided by third parties or internal sources. When using ESG ratings to exclude corporate issuers and evaluating ESG issues generally, Amundi Pioneer considers ratings in the context of an issuer’s respective sector or industry. The fund generally will not invest in companies significantly involved in certain business activities, including but not limited to, the production of alcohol, tobacco products and certain controversial military weapons, and the operation of coal mines and gambling casinos and other gaming businesses.
The significant investment strategies for Pioneer Core Equity Fund and certain other similarly managed and sub-advised accounts with investment objectives of long-term capital growth are:
Normally, the fund invests at least 80% of its net assets (plus the amount of borrowings, if any, for investment purposes) in equity securities, primarily of U.S. issuers. For purposes of the fund's investment policies, equity securities include common stocks and other equity instruments, such as funds that invest primarily in equity securities, equity interests in real estate investment trusts (REITs), preferred stocks, depositary receipts, rights and warrants. The fund may invest in initial public offerings of equity securities.
The fund may invest up to 20% of its total assets in securities of non- U.S. issuers, including up to 5% of its total assets in the securities of emerging markets issuers.
The fund may invest in debt securities. Generally, the fund acquires investment grade debt securities, but the fund may invest up to 5% of its net assets in below investment grade debt securities (known as “junk bonds”), including below investment grade convertible debt securities.
The fund may, but is not required to, use derivatives. The fund may use derivatives, such as futures and options, for a variety of purposes, including in an attempt to hedge against adverse changes in the market price of securities, interest rates or currency exchange rates; as a substitute for purchasing or selling securities; to increase the fund’s return as a non-hedging strategy that may be considered speculative; to manage portfolio characteristics; and as a cash flow management
Principal Risks: - Market risk - Mid-size companies risk - Value style risk - Portfolio selection risk - Risks of investments in real estate related securities - Risks of warrants and rights - Preferred stocks risk - Risks of initial public offerings - Risks of investment in other funds - Debt securities risk technique. The fund may choose not to make use of derivatives for a variety of reasons, and any use may be limited by applicable law and regulations. The fund may also hold cash and other short-term investments. Amundi Pioneer uses a quality and valuation-conscious approach to select the fund’s investments based upon the recommendations of the adviser’s research team. The adviser selects securities that are buy- rated by the research team and selling at reasonable prices or substantial discounts to their underlying values. The research team then constructs a portfolio that is reflective of its best ideas across the team. The research team seeks to identify securities that provide a favorable risk/reward outcome relative to the benchmark index based on the research analyst's fundamental research and valuation. A security may be sold if the research team's assessment of company fundamentals deteriorates or the security price reaches its valuation target.
Amundi Pioneer’s research team evaluates a security’s potential value based on the company’s quality, growth, risk, and prospects for future economic profit growth. In making that assessment, it employs due diligence and fundamental research, and an evaluation of the issuer based on its financial statements and operations. The research team focuses on the quality and price of individual issuers, not on market- timing strategies. The fund’s portfolio includes securities from a broad range of market sectors that have received favorable rankings from the research team.
- Expense risk - Redemption risk - Cybersecurity risk
The significant investment strategies for Pioneer Fundamental Growth Fund and certain other similarly managed and sub- advised accounts with investment objectives of long-term capital growth are:
Normally, the fund invests at least 80% of its net assets (plus the amount of borrowings, if any, for investment purposes) in equity securities of large companies, that is, companies similar in size to issuers included in the Russell 1000 Growth Index. The Russell 1000 Growth Index (the “index”) is a large capitalization index that measures the performance of those companies in the Russell 1000 Index with higher price-to-book ratios and higher forecasted growth values. On June 30, 2018, securities in the index had a market capitalization range from approximately $2.4 billion to approximately $910 billion. On June 30, 2018, the index had a median market capitalization of approximately $12.2 billion. The size of the companies in the index changes constantly as a result of market conditions and the composition
Principal Risks: - Market risk - Growth style risk - Portfolio selection risk - Issuer focus risk - Risks of securities - Risks of initial public offerings of the index. The fund's investments will not be confined to securities issued by companies included in the index. For purposes of the fund’s investment policies, equity securities include common stocks and other equity instruments, such as funds that invest primarily in equity securities, depositary receipts, warrants, rights, equity interests in real estate investment trusts (REITs) and preferred stocks.
The fund primarily invests in securities of U.S. issuers. The fund may invest in securities of issuers in any industry or market sector. The fund may invest in fewer than 40 securities. The fund may invest in initial public offerings of equity securities. The fund may invest up to 20% of its total assets in securities of non-U.S. issuers. The fund will not invest more than 10% of its total assets in the securities of emerging markets issuers.
The fund may also invest in investment grade and below investment grade debt securities (known as “junk bonds”), including below investment grade convertible debt securities and securities of issuers that are in default.
The fund may, but is not required to, use derivatives. The fund may use derivatives, such as stock index futures and options, for a variety of purposes, including: in an attempt to hedge against adverse changes in the market price of securities, interest rates or currency exchange rates; as a substitute for purchasing or selling securities; to attempt to increase the fund's return as a non-hedging strategy that may be considered speculative; to manage portfolio characteristics; and as a cash flow management technique. The fund may choose not to make use of derivatives for a variety of reasons, and any use may be limited by applicable law and regulations. The fund may also hold cash or other short-term investments.
Amundi Pioneer uses a “growth” style of management and seeks to invest in securities of issuers with above average potential for earnings and revenue growth. To select growth stocks, Amundi Pioneer employs quantitative analysis, fundamental research, and an evaluation of the issuer based on its financial statements and operations, utilizing a bottom-up analytic style. Among other things, Amundi Pioneer focuses on an issuer’s deployment of capital and return on capital. Amundi Pioneer relies on the knowledge, experience and judgment of its staff and the staff of its affiliates who have access to a wide variety of research. Amundi Pioneer focuses on the quality and price of individual issuers, not on economic sector or market-timing strategies. in other funds - Debt securities risk - Risks of non-U.S. investments - Market segment risk - Derivatives risk - Leveraging risk Amundi Pioneer generally sells a portfolio security when it believes that the issuer no longer offers the potential for above average earnings and revenue growth or when Amundi Pioneer no longer views the issuer’s deployment of capital or return on capital as favorable. Amundi Pioneer makes that determination based upon the same criteria it uses to select portfolio securities.
The significant investment strategies for Pioneer Disciplined Growth Fund and certain other similarly managed and sub- advised accounts with investment objectives of long-term capital growth are:
The fund invests primarily in equity securities of U.S. issuers. For purposes of the fund's investment policies, equity securities include common stocks and other equity instruments, such as funds that invest primarily in equity securities, depositary receipts, warrants, rights, equity interests in real estate investment trusts (REITs) and preferred stocks.
The fund may invest in issuers of any market capitalization. The fund may invest in securities in any industry or market sector. The fund may invest in fewer than 40 securities. The fund may invest in initial public offerings of equity securities. In addition, the fund may invest up to 20% of its total assets in securities of non-U.S. issuers, including up to 5% of its total assets in the securities of emerging market issuers. The fund may invest in debt securities. Generally, the fund may acquire investment grade debt securities, but the fund may invest up to 5% of its net assets in below investment grade debt securities (known as “junk bonds”), including below investment grade convertible debt securities. The fund also may hold cash or other short-term investments.
The fund may, but is not required to, use derivatives, such as stock index futures and options. The fund may use derivatives for a variety of purposes, including: in an attempt to hedge against adverse changes in the market price of securities, interest rates or currency exchange rates; as a substitute for purchasing or selling securities; to attempt to increase the fund's return as a non-hedging strategy that may be considered speculative; to manage portfolio characteristics; and as a cash flow management technique. The fund may choose not to make use of derivatives for a variety of reasons, and any use may be limited by applicable law and regulations.
Amundi Pioneer uses a valuation-conscious approach to select the
Principal Risks: - Market risk - Growth style risk - Portfolio selection risk - Issuer focus risk - Small and mid-size companies risk - Risks of investments in real estate related securities - Risks of warrants and rights - Preferred stocks risk - Risks of initial public offerings - Risks of investment in other funds - Debt securities risk - Risks of non-U.S. investments - Market segment risk - Derivatives risk fund’s investments based upon the recommendations of the Amundi Pioneer’s research teams. The research teams use a two-step process in selecting securities that combines fundamental and quantitative research. First, the teams assess whether a company’s fundamentals - financial condition, management, and position in its industry - indicate strong prospects for growth and attractive valuations. Second, the teams employ a quantitative, growth-oriented approach to construct the portfolio, emphasizing those securities believed to have attractive prospects for earnings and revenue growth. A security may be sold if its ranking by the research team is reduced or the security price reaches a reasonable valuation.
The significant investment strategies for Pioneer Disciplined Value Fund and certain other similarly managed and sub- advised accounts with investment objectives of long-term capital growth are:
The fund invests primarily in equity securities of U.S. issuers. For purposes of the fund's investment policies, equity securities include common stocks and other equity instruments, such as funds that invest primarily in equity securities, depositary receipts, warrants, rights, equity interests in real estate investment trusts (REITs) and preferred stocks.
The fund may invest in issuers of any market capitalization. The fund may invest in securities in any industry or market sector. The fund may invest in fewer than 40 securities. The fund may invest in initial public offerings of equity securities. In addition, the fund may invest up to 20% of its total assets in securities of non-U.S. issuers, including up to 5% of its total assets in the securities of emerging market issuers. The fund may invest in debt securities. Generally, the fund may acquire investment grade debt securities, but the fund may invest up to 5% of its net assets in below investment grade debt securities (known as “junk bonds”), including below investment grade convertible debt securities. The fund also may hold cash or other short-term investments.
The fund may, but is not required to, use derivatives. The fund may use derivatives for a variety of purposes, including: in an attempt to hedge against adverse changes in the market price of securities, interest rates or currency exchange rates; as a substitute for purchasing or selling securities; to attempt to increase the fund's return as a non-hedging strategy that may be considered speculative; to manage portfolio characteristics; and as a cash flow management technique. The fund may choose not to make use of derivatives for a variety of reasons, and
Principal Risks: - Market risk - Value style risk - Portfolio selection risk - Issuer focus risk - Small and mid-size companies risk - Risks of investments in real estate related securities - Risks of warrants and rights - Preferred stocks risk - Risks of initial public offerings - Risks of investment in other funds - Debt securities risk - Risks of non-U.S. any use may be limited by applicable law and regulations. Amundi Pioneer uses a valuation-conscious approach to select the fund’s investments based upon the recommendations of Amundi Pioneer’s research teams. The research teams use a two-step process in selecting securities that combines fundamental and quantitative research. First, the teams assess whether a company’s fundamentals— financial condition, management, and position in its industry—indicate strong prospects for growth and attractive valuations. Second, the teams employ a quantitative, value-oriented approach to construct the fund’s portfolio, emphasizing those securities believed to be selling at reasonable prices versus the underlying values. A security may be sold if its ranking by the research team is reduced or the security price reaches a reasonable valuation.
risk - Expense risk - Redemption risk - Cybersecurity risk
The significant investment strategies for Pioneer Select Mid Cap Growth Fund and certain other similarly managed and sub- advised accounts with investment objectives of long-term capital growth are:
Normally, the fund invests at least 80% of its net assets (plus the amount of borrowings, if any, for investment purposes) in equity securities of mid-size companies. Mid-size companies are those with market values, at the time of investment, that do not exceed the greater of the market capitalization of the largest company within the Russell Midcap Growth Index ($42.93 billion as of February 28, 2019) or the 3-year rolling average of the market capitalization of the largest company within the Russell Midcap Growth Index ($40.90 billion as of February 28, 2019) as measured at the end of the preceding month, and are not less than the smallest company within the index. The Russell Midcap Growth Index measures the performance of U.S. mid-cap growth stocks. The size of the companies in the index changes constantly as a result of market conditions and the composition of the index. The fund’s investments will not be confined to securities issued by companies included in the index. For purposes of the fund’s investment policies, equity securities include common stocks and other equity instruments, such as funds that invest primarily in equity securities, depositary receipts, warrants, rights, equity interests in real estate investment trusts (REITs) and preferred stocks. The fund may invest in initial public offerings of equity securities.
The fund may invest in securities of issuers in any industry or market sector. The fund may invest up to 20% of its total assets in debt securities. The fund may invest up to 5% of its net assets in below
Principal Risks: - Market risk - Mid-size companies risk - Growth style risk - Portfolio selection risk - Risks of investments in real estate related securities - Risks of warrants and rights - Preferred stocks risk - Risks of initial public offerings - Risks of investment in other funds - Debt securities risk - Risks of convertible investment grade debt securities (known as “junk bonds”), including below investment grade convertible debt securities, and securities in default. The fund may invest up to 20% of its net assets in REITs. The fund may invest up to 20% of its total assets in securities of non- U.S. issuers. The fund will not invest more than 5% of its total assets in the securities of emerging markets issuers.
The fund may, but is not required to, use derivatives, such as stock index futures and options. The fund may use derivatives for a variety of purposes, including: in an attempt to hedge against adverse changes in the market prices of securities, interest rates or currency exchange rates; as a substitute for purchasing or selling securities; to attempt to increase the fund’s return as a non-hedging strategy that may be considered speculative; to manage portfolio characteristics; and as cash flow management technique. The fund may choose not to make use of derivatives for a variety of reasons, and any use may be limited by applicable law and regulations. The fund also may hold cash or other short-term instruments.
The fund uses a “growth” style of management and seeks to invest in companies with above average potential for earnings and revenue growth that are also trading at attractive market valuations. To select growth stocks, Amundi Pioneer employs quantitative analysis, fundamental research and an evaluation of the issuer based on its financial statements and operations. Amundi Pioneer relies on the knowledge, experience and judgment of its staff and the staff of its affiliates who have access to a wide variety of research. Amundi Pioneer focuses on the quality and price of individual issuers and economic sector analysis, not on market-timing strategies.
Amundi Pioneer generally sells a portfolio security when it believes that the issuer no longer offers the potential for above average earnings and revenue growth. Amundi Pioneer makes that determination based upon the same criteria it uses to select portfolio securities.
risk - Valuation risk - Liquidity risk - Cash management risk - Expense risk - Redemption risk - Cybersecurity risk
The significant investment strategies for Pioneer Mid Cap Value Fund and certain other similarly managed and sub- advised accounts with investment objectives of capital appreciation by investing in a diversified portfolio of securities consisting primarily of common stocks are: - Mid-size companies Normally, the fund invests at least 80% of its total assets in equity securities of mid-size companies. Mid-size companies are those with market values, at the time of investment, that do not exceed the greater of the market capitalization of the largest company within the Russell Midcap Value Index ($33.58 billion as of December 31, 2018) or the 3- year rolling average of the market capitalization of the largest company within the Russell Midcap Value Index ($35.62 billion as of December 31, 2018), as measured at the end of the preceding month, and are not less than the smallest company within the index. The Russell Midcap Value Index measures the performance of U.S. mid-cap value stocks. The size of the companies in the index changes constantly with market conditions and the composition of the index. The equity securities in which the fund principally invests are common stocks, preferred stocks and depositary receipts, but the fund may invest in other types of equity securities to a lesser extent, such as funds that invest primarily in equity securities, equity interests in real estate investment trusts (REITs), warrants and rights. The fund may invest in initial public offerings of equity securities.
The fund may invest up to 25% of its total assets in securities of non- U.S. issuers. The fund will not invest more than 5% of its total assets in the securities of emerging markets issuers. The fund may invest up to 20% of its net assets in REITs.
The fund may invest up to 20% of its total assets in debt securities. The fund may invest up to 5% of its net assets in below investment grade debt securities (known as “junk bonds”), including below investment grade convertible debt securities.
The fund may, but is not required to, use derivatives, such as stock index futures and options. The fund may use derivatives for a variety of purposes, including; in an attempt to hedge against adverse changes in the market price of securities, interest rates or currency exchange rates; as a substitute for purchasing or selling securities; to attempt to increase the fund's return as a non-hedging strategy that may be considered speculative; to manage portfolio characteristics; and as a cash flow management technique. The fund may choose not to make use of derivatives for a variety of reasons, and any use may be limited by applicable law and regulations. The fund may also hold cash or other short-term investments.
The fund uses a “value” style of management. Amundi Pioneer seeks to identify securities that are selling at reasonable prices or at substantial discounts to their underlying values and then holds these securities until the market values reflect their intrinsic values. Amundi risk - Risks of non-U.S. investments - Risks of initial public offerings - Risks of investment in other funds - Risks of investments in real estate related securities - Risks of convertible securities - Preferred stocks risk - Risks of warrants and rights - Debt securities risk - Market segment risk - Derivatives risk - Leveraging risk - Portfolio turnover Pioneer evaluates a security's potential value, including the attractiveness of its market valuation, based on the company's assets and prospects for earnings growth. In making that assessment, Amundi Pioneer employs fundamental research and an evaluation of the issuer based on its financial statements and operations, employing a bottom- up analytic style, which focuses on specific securities rather than on industries. Amundi Pioneer focuses on the quality and price of individual issuers and securities. Amundi Pioneer generally sells a portfolio security when it believes that the security’s market value reflects its underlying value.
The significant investment strategies for Pioneer Global Equity Fund and certain other similarly managed and sub-advised accounts with investment objectives of long-term capital growth are:
Normally, the fund invests at least 80% of its net assets (plus the amount of borrowings, if any, for investment purposes) in equity securities of issuers located throughout the world. Derivative instruments that provide exposure to such securities or have similar economic characteristics may be used to satisfy the fund’s 80% policy. The fund’s principal focus is on companies that exhibit solid fundamental characteristics and are underappreciated by the market. The fund may invest in securities of any market capitalization, and in securities in any industry or market sector. The fund may invest in both developed and emerging markets without limit. Normally, the fund invests at least 40% of its net assets in issuers located outside of the United States, or derivatives that provide similar exposure or have similar economic characteristics. This 40% minimum investment amount may be reduced to 30% if market conditions for these investments or in specific foreign markets are deemed unfavorable.
For purposes of the fund’s investment policies, equity securities include common stocks and other equity instruments, such as funds that invest primarily in equity securities, depositary receipts, warrants, rights and preferred stocks.
The fund may invest up to 20% of its total assets in debt securities , including up to 5% of its net assets in below investment grade debt securities (known as “junk bonds”), and cash and cash equivalents.
The fund may purchase and sell forward foreign currency exchange contracts in non-U.S. currencies in connection with its investments, including as a means of managing relative currency and country
Principal Risks: - Market risk - Risks of non-U.S. investments - Currency risk - Style risk - Portfolio selection risk - Small and mid-size companies risk - Risks of warrants and rights - Preferred stocks risk - Risks of initial public offerings - Risks of investment in other funds - Debt securities risk - Market segment risk - Derivatives risk - Forward foreign exposure. The fund may also use derivatives, including stock index futures and options, forward foreign currency exchange contracts and futures on equity-based volatility indices for a variety of other purposes, including: in an attempt to hedge against adverse changes in the market price of securities, interest rates or currency exchange rates; as a substitute for purchasing or selling securities; to attempt to increase the fund's return as a non-hedging strategy that may be considered speculative; to manage portfolio characteristics; and as a cash flow management technique. The fund may choose not to make use of derivatives for a variety of reasons, and any use may be limited by applicable law and regulations.
The fund integrates a top-down view of the global macro-economic landscape with fundamental, bottom up, equity analysis. The investment process combines the skill of Amundi Pioneer’s macroeconomic analyst and fundamental equity research teams in a rigorous risk adjusted portfolio construction process. The fund seeks to invest in those issuers that have above average potential for sales and earnings growth that are also trading at attractive market valuations. In selecting stocks, Amundi Pioneer employs fundamental research and an evaluation of the issuer based on its financial statements and operations.
Amundi Pioneer relies on the knowledge, experience and judgment of its staff and the staff of its affiliates who have access to a wide variety of research. Amundi Pioneer focuses on the quality and valuation of issuers and securities. Amundi Pioneer generally sells a portfolio security when it believes that the issuer no longer offers the potential for above average earnings and sales growth. Amundi Pioneer makes that determination based upon the same criteria it uses to select portfolio securities.
- Redemption risk - Cybersecurity risk
The significant investment strategies for Pioneer International Equity Fund and certain other similarly managed and sub- advised accounts with investment objectives of long-term capital growth are:
Normally, the fund invests at least 80% of its total assets in equity securities of non-U.S. issuers. These issuers may be located in both developed and emerging markets. Under normal circumstances, the fund's assets will be invested in securities of companies domiciled in at least three different foreign countries. Generally, the fund's investments in any country are limited to 25% or less of its total assets. However, from time to time, the fund may invest more than 25% of its assets in
Principal Risks: - Market risk - Geographic focus - Currency risk - Small and mid-size companies risk issuers organized in Japan or the United Kingdom or in securities quoted or denominated in the Japanese yen, the British pound and the euro. The fund may invest without limitation in securities of emerging market issuers, but generally will not invest more than 25% of its total assets in securities of issuers located in any one emerging market country. The fund considers emerging market issuers to include issuers organized under the laws of an emerging market country, issuers with a principal office in an emerging market country, issuers that derive at least 50% of their gross revenues or profits from goods or services produced in emerging markets or sales made in emerging markets, and emerging market governmental issuers. Emerging markets generally will include, but not be limited to, countries included in the Morgan Stanley Capital International (MSCI) Emerging + Frontier Markets Index.
For purposes of the fund's investment policies, equity securities include common stocks and other equity instruments, such as funds that invest primarily in equity securities, depositary receipts, equity interests in real estate investment trusts (REITs), warrants, rights and preferred shares. The fund may invest in initial public offerings of equity securities. The fund may also purchase and sell forward foreign currency exchange contracts in non-U.S. currencies in connection with its investments, including as a means of managing relative currency exposure.
The fund may invest up to 20% of its total assets in debt securities of U.S. and non-U.S. issuers. The fund may invest up to 5% of its net assets in below investment grade debt securities (known as “junk bonds”), including below investment grade convertible debt securities and securities of issuers that are in default.
The fund may, but is not required to, use derivatives. The fund may use derivatives, including forward foreign currency exchange contracts, for a variety of purposes, including; in an attempt to hedge against adverse changes in the market prices of securities, interest rates or currency exchange rates; as a substitute for purchasing or selling securities; to attempt to increase the fund’s return as a non-hedging strategy that may be considered speculative; to manage portfolio characteristics; and as a cash flow management technique. The fund may choose not to make use of derivatives for a variety of reasons, and any use may be limited by applicable law and regulations. The fund also may hold cash or other short-term instruments.
- Risks of investments in real estate related securities - Risks of warrants and rights - Preferred stocks risk - Risks of initial public offerings - Risks of investment in other funds - Debt securities risk - Risks of convertible securities - Market segment risk - Derivatives risk - Forward foreign currency transactions risk - Leveraging risk - Portfolio turnover risk Amundi Pioneer uses a value approach to select the fund's investments. Amundi Pioneer seeks to identify securities that are selling at reasonable prices or substantial discounts to their underlying values. Amundi Pioneer evaluates a security's potential value, including the attractiveness of its market valuation, based on the company's assets and prospects for earnings and revenue growth, employing a bottom-up analytical style. In making that assessment, Amundi Pioneer employs fundamental research and an evaluation of the issuer based on its financial statements and operations. Amundi Pioneer focuses on the quality and price of individual issuers and securities.
Amundi Pioneer generally sells a portfolio security when it believes that the security’s market value reflects its intrinsic value. Amundi Pioneer makes that determination based upon the same criteria it uses to select portfolio securities.
The significant investment strategies for Pioneer Real Estate Shares and certain other similarly managed accounts with investment objectives of long-term growth of capital and current income as a secondary objective are:
Normally, the fund invests at least 80% of its total assets in equity securities of real estate investment trusts (REITs) and other real estate industry issuers. The fund may at times emphasize particular sub- sectors of the real estate industry. For purposes of the fund's investment policies, equity securities include common stocks and other equity instruments, such as funds that invest primarily in equity securities, warrants, rights, and preferred stocks.
The fund may invest up to 20% of its total assets in debt securities of real estate industry issuers, mortgage-backed securities and short-term investments. The fund may invest up to 5% of its net assets in below investment grade debt securities (known as “junk bonds”), including below investment grade convertible debt securities.
The fund may invest up to 25% of its total assets in securities of non- U.S. issuers. Up to 10% of the fund's total assets may be invested in the securities of emerging markets issuers.
The fund may, but is not required to, use derivatives. The fund may use derivatives, such as options and futures, for a variety of purposes, including; in an attempt to hedge against adverse changes in the market price of securities, interest rates or currency exchange rates; as a substitute for purchasing or selling securities; to attempt to increase the
Principal Risks: - Market risk - Growth style risk - Portfolio selection risk - Small and mid-size companies risk - Issuer focus risk - Risks of investments in real estate related securities - Risks of warrants and rights - Preferred stocks risk - Risks of initial public offerings in other funds - Debt securities risk - Mortgage-backed fund's return as a non-hedging strategy that may be considered speculative; to manage portfolio characteristics; and as a cash flow management technique. The fund may choose not to make use of derivatives for a variety of reasons, and any use may be limited by applicable law and regulations. The fund also may hold cash or other short-term investments. The fund may invest in fewer than 40 securities. The fund may invest in initial public offerings of equity securities.
The fund uses a “growth at a reasonable price” style of management. Amundi Pioneer seeks to invest in companies with above average potential for earnings and revenue growth that are also trading at attractive market valuations. To select stocks, Amundi Pioneer employs fundamental and qualitative research and an evaluation of the issuer based on its financial statements and operations. Amundi Pioneer focuses on the quality and price of individual issuers and securities. Amundi Pioneer generally sells a portfolio security when it believes that the issuer no longer offers the potential for above average earnings and revenue growth.
- Leveraging risk - Valuation risk - Liquidity risk - Cash management risk - Expense risk - Redemption risk - Cybersecurity risk
The significant investment strategies for Pioneer Equity Income Fund and certain other similarly managed and sub-advised accounts with investment objectives of current income and long-term growth of capital from a portfolio consisting primarily of income producing equity securities of U.S. corporations are:
Normally, the fund invests at least 80% of its total assets in income producing equity securities of U.S. issuers. The income producing equity securities in which the fund may invest include common stocks, preferred stocks, funds that invest primarily in equity securities and equity interests in real estate investment trusts (REITs). The remainder of the fund may be invested in debt securities, most of which are expected to be convertible into common stocks. The fund may invest in initial public offerings of equity securities.
The fund may invest up to 20% of its total assets in securities of non- U.S. issuers, including depositary receipts. The fund will not invest more than 5% of its total assets in the securities of emerging markets issuers.
The fund may invest up to 20% of its net assets in REITs.
Principal Risks: - Market risk - Value style risk - Income producing securities risk - Large capitalization companies risk - Portfolio selection risk - Risks of non-U.S. investments - Risks of initial public offerings in other funds securities - Risks of convertible The fund also may invest in investment grade and below investment grade debt securities (known as “junk bonds”). The fund may invest up to 10% of its net assets in junk bonds, including below investment grade convertible debt securities. The fund may, but is not required to, use derivatives, such as stock index futures and options. The fund may use derivatives for a variety of purposes, including; in an attempt to hedge against adverse changes in the market price of securities, interest rates or currency exchange rates; as a substitute for purchasing or selling securities; to attempt to increase the fund's return as a non-hedging strategy that may be considered speculative; to manage portfolio characteristics; and as a cash flow management technique. The fund may choose not to make use of derivatives for a variety of reasons, and any use may be limited by applicable law and regulations. The fund may also hold cash or other short-term investments.
Amundi Pioneer uses a value approach to select the fund's investments to buy and sell. Amundi Pioneer seeks securities that are selling at substantial discounts to their underlying values and then holds these securities until the market values reflect their intrinsic values. Amundi Pioneer evaluates a security’s potential value, including the attractiveness of its market valuation, based on the company’s assets and prospects for earnings growth. Amundi Pioneer also considers a security’s potential to provide a reasonable amount of income. In making these assessments, Amundi Pioneer employs fundamental research and an evaluation of the issuer based on its financial statements and operations, employing a bottom-up analytic style, which focuses on specific securities rather than on industries. Amundi Pioneer generally sells a portfolio security when it believes that the security’s market value reflects its underlying value.
- Debt securities risk - High yield or “junk” bond risk - Market segment risk - Derivatives risk - Leveraging risk - Valuation risk - Liquidity risk - Cash management risk - Expense risk - Redemption risk - Cybersecurity risk
The significant investment strategies for Pioneer Solutions - Balanced Fund and certain other similarly managed and sub- advised accounts with investment objectives of long-term capital growth and current income are:
The fund is a “fund of funds.” The fund seeks to achieve its investment objectives by primarily investing in other funds (“underlying funds”) and using asset allocation strategies to allocate its assets among the underlying funds.
The fund invests primarily in underlying funds managed by Amundi Pioneer Asset Management, Inc. (Amundi Pioneer) or one of its
Principal Risks: - Market risk in other funds - Equity securities - Debt securities risk affiliates. The fund may also invest in securities of unaffiliated mutual funds or exchange-traded funds (ETFs) when the desired economic exposure to a particular asset category or investment strategy is not available through a Pioneer fund. The fund allocates its assets among underlying funds with exposure to the broad asset classes of equity, fixed income and short-term (money market) investments. The fund also may invest in underlying funds with exposure to non-traditional - so-called “alternative” - asset classes such as real estate investment trusts (REITs) or commodities, or that use alternative strategies, such as market neutral strategies (strategies that seek to achieve positive returns while attempting to limit general market exposure) or relative value strategies (strategies that seek to identify securities that are undervalued relative to each other or historical norms). The fund may invest in underlying funds with exposure to debt and equity securities of issuers located throughout the world, including both developed and emerging markets.
The fund does not have target ranges for the allocation of assets among asset classes or individual underlying funds. The fund invests a minimum of 25% of its assets in each of fixed income and equity securities. The fund’s exposure to different asset classes and allocations among underlying funds will change from time to time in response to broad economic and market factors, as well as strategic and tactical considerations. The equity securities to which the fund may have exposure may be of any market capitalization. The fixed income securities to which the fund may have exposure may be of any maturity and of any credit quality, including high yield or “junk” bonds.
Amundi Pioneer allocates the fund's assets among underlying funds based on strategic positioning and tactical considerations, taking into account both broad economic and market factors and factors specific to particular investments.
Amundi Pioneer allocates the fund's investments in the underlying funds based on an evaluation of three components: strategic asset allocation (generally, the weighting of allocations among broad asset classes to capture market returns), tactical asset allocation (generally, the weighting of allocations to various sub-categories within broad asset classes to add value relative to the general strategic allocations) and fund selection. Amundi Pioneer's analysis in selecting underlying funds includes an assessment of a fund's historical relative and absolute performance, volatility and other risk characteristics, and correlation with other funds and benchmarks. Amundi Pioneer considers the relative return potential of investments in view of their expected investments - Risks of investments in real estate related securities - Commodity investments risk - Derivatives risk - Credit default swap risk - Leveraging risk - Liquidity risk - Valuation risk relative risk, including potential volatility and drawdown risk (the risk of significant loss, measured from peak value) among other risks. Amundi Pioneer also analyzes the fund's investment strategies, investment process and portfolio management team. The goal of this process is to identify a combination of investments with the potential to provide total return consistent with the fund's overall risk/return profile. As part of its asset allocation strategy, the fund may invest in Pioneer Multi-Asset Income Fund, among other Pioneer Funds. Pioneer Multi- Asset Income Fund has the flexibility to invest in a broad range of income-producing investments, including both debt securities and equity securities. Pioneer Multi-Asset Income Fund’s debt securities may include instruments and obligations of U.S. and non-U.S. corporate and other non-governmental entities, those of U.S. and non- U.S. governmental entities, mortgage-related or mortgage-backed securities (including “sub-prime” mortgages), asset-backed securities, floating rate loans, convertible securities, Treasury Inflation Protected Securities (“TIPS”) and other inflation-linked debt securities, subordinated debt securities, event-linked bonds and other insurance- linked securities, and funds that invest primarily in debt securities. Pioneer Multi-Asset Income Fund’s equity securities include common stocks, rights, warrants, depositary receipts, funds that invest primarily in equity securities, preferred stock, equity interests in real estate trusts (REITs), equity-linked notes and master limited partnerships. Pioneer Multi-Asset Income Fund may invest in the securities of issuers located throughout the world, including in emerging markets. As of July 31, 2018 approximately 25% of the fund was allocated to Pioneer Multi- Asset Income Fund. The fund’s allocation among underlying funds, including Multi-Asset Income Fund, will change from time to time.
Annual and semi-annual report for the underlying funds may be obtained on the funds’ website at us.amundipioneer.com.
The fund may also invest directly in securities. In addition, the fund may use derivatives for a variety of purposes, including: in an attempt to hedge against adverse changes in the market price of securities, interest rate or currency exchange rates; as a substitute for purchasing and selling securities; to attempt to increase the fund’s return, as a non- hedging strategy that may be considered speculative; to manage portfolio characteristics; and as a cash flow management technique. In addition, certain underlying funds may use derivatives. Investments typically are sold when Amundi Pioneer's overall assessment of market and economic conditions changes or the assessments of the attributes of specific investments change. The fund’s investment strategies and policies may be changed from time to time without shareholder approval, unless specifically stated otherwise in this prospectus or in the statement of additional information. The significant investment strategies for Pioneer Flexible Opportunities Fund and certain other similarly managed and sub-advised accounts with investment objectives of total return are:
The fund selects investments from a broad spectrum of asset classes, including both traditional investments, such as equity and fixed income securities, and less traditional or alternative investments, such as commodity-oriented investments, real estate related investments, and currencies. The fund seeks “real return” by holding some investments that historically have not moved in step with broad equity and fixed income markets and selecting investments believed to provide total return in consideration of perceived risk and changing market and economic conditions over time. Real return is considered to be a level of total return that exceeds the rate of inflation over the course of different market environments.
Equity securities may include common and preferred stocks, depositary receipts, warrants, rights, equity-linked securities and other equity interests. The fund may invest in securities of issuers of any market capitalization. In addition to direct investment in securities and other instruments, the fund may invest in other funds, including exchange- traded funds (“ETFs”), unit investment trusts, and other pooled investment vehicles that may or may not be registered under the Investment Company Act of 1940 (the “1940 Act”). Some of these funds may be managed by Amundi Pioneer. The fund may invest in real estate investment trusts (“REITs”) and U.S. and non-U.S. real estate companies.
Fixed income securities include those issued by U.S. and non-U.S. governmental, corporate and other issuers, including mortgage-related or mortgage-backed securities (including “sub-prime” mortgages), asset-backed securities, floating rate loans, convertible securities, Treasury Inflation Protected Securities (“TIPS”) and other inflation- linked debt securities, subordinated debt securities, event-linked bonds, and other insurance-linked securities, and municipal securities. The fund may invest in debt securities of any credit quality, including those rated below investment grade (known as “junk bonds”) or, if unrated,
Principal Risks: - Market risk - Derivatives risk - Credit default swap risk - Risks of investing in inverse floating rate obligations - Forward foreign currency transactions risk - Short position risk - Leveraging risk - Commodity investments risk - Tax risk - Risks of investing in the Subsidiary - Risks of non-U.S. investments - Currency risk - Sovereign debt risk - Interest rate risk - Credit risk - Prepayment or call risk - Extension risk - Liquidity risk - Inflation-linked agency obligations of equivalent credit quality as determined by Amundi Pioneer. The fund may invest in securities with a broad range of maturities. The fund’s investments may have fixed or variable principal payments and all types of interest rate payment and reset terms, including fixed rate, floating rate, inverse floating rate, zero coupon, contingent, deferred and payment in kind and auction rate features. The fund may purchase or sell securities on a when-issued, delayed delivery or forward commitment basis.
The fund may gain exposure to commodities (such as oil and precious metals) through investment in commodity-linked derivatives, ETFs and other pooled investment vehicles, exchange-traded notes (ETNs) and leveraged or unleveraged commodity-linked notes (derivative debt instruments with principal and/or coupon payments linked to the performance of commodity indices). The fund also may invest in equity securities of issuers in commodity-related industries. The fund may gain exposure to commodities through investment in a wholly-owned subsidiary of the fund organized under the laws of the Cayman Islands (the “Subsidiary”) that is expected to invest in commodity-oriented investments. The fund may invest up to 25% of its total assets in the Subsidiary. The Subsidiary is advised by Amundi Pioneer.
The fund may, but is not required to, use derivatives. The fund may use derivatives for a variety of other purposes, including: in an attempt to hedge against adverse changes in the market price of securities, interest rates or currency exchange rates; as a substitute for purchasing or selling securities; to attempt to increase the fund’s return as a non- hedging strategy that may be considered speculative; to manage portfolio characteristics. The fund may invest without limit in derivative instruments (other than commodity-related derivative instruments). However, the fund may choose not to make use of derivatives for a variety of reasons, and any use may be limited by applicable law and regulations.
The fund may invest up to 100% of its assets in non-U.S. securities, including securities of emerging market issuers. In addition to investing in securities denominated in non-U.S. currencies, the fund may hold non-U.S. currencies and purchase and sell forward currency exchange contracts in non-U.S. currencies. The fund’s currency and currency- related investments may be used to adjust overall currency exposures, including as a means of seeking incremental return, which may be considered a speculative technique.
The fund may take a short position with respect to a security, index or and asset-backed securities risk - High yield or “junk” bond risk - Risks of investing in floating rate loans - Risks of investing in insurance-linked securities - Risks of subordinated securities - Exchange-traded note risk - Municipal securities risk - Risks of zero coupon bonds, payment in kind, deferred and contingent securities - Risks of investing in “when-issued,” delayed delivery, to be announced and forward commitment transactions - Equity securities risk - Small and mid-size companies risk - Risks of securities - Risks of convertible currency, for which Amundi Pioneer has a negative tactical view, either through the short sale of a security or through a derivative position, such as a futures contract or swap agreement. The fund may invest up to 100% of its assets in cash and short-term investments as a means of pursuing its investment strategies or for defensive purposes.
As part of its investment strategies, the fund may engage in active and frequent trading of portfolio securities.
In selecting investments, Amundi Pioneer initially constructs an overall asset allocation model based on its expectations for economic growth and inflation on a global basis. In selecting among asset classes, Amundi Pioneer considers the relative return potential of particular asset classes in view of their expected relative volatility (the variability of returns from one period to the next). The goal of this process is to identify a combination of asset classes with the potential to provide real return due to a favorable overall risk/return profile. In selecting investments within each asset class, Amundi Pioneer considers the potential to provide incremental return to the portfolio consistent with the expectations for the asset class. When investing in equity and debt securities, Amundi Pioneer generally favors those securities it perceives to be undervalued. Investments typically are sold when Amundi Pioneer’s overall assessment of market and economic conditions changes or the assessments of the attributes of asset classes or individual holdings change.
The fund is not required to allocate its investments among asset classes in any fixed proportion, nor is it limited by the issuer’s geographic location, size or market capitalization. The fund may have none, some or all of its assets invested in each asset class in relative proportions that change over time based upon market and economic conditions.
in other funds - Repurchase agreement risk - Market segment risk - Portfolio turnover risk - Valuation risk - Cash management risk - Expense risk - Redemption risk - Cybersecurity risk
Fixed Income Strategies The significant investment strategies for Pioneer Dynamic Credit Fund and certain other similarly managed and sub- advised accounts with investment objectives of a high level of current income and capital appreciation are:
The fund selects investments from a broad spectrum of debt securities. The fund is managed using a benchmark unconstrained approach, which means that it is not managed relative to an index. Accordingly, the fund does not seek to generate returns consistent with broader financial market movements, instead seeking to generate positive total returns over the course of different market environments. Total return is a combination of current income and capital appreciation. The fund also may use derivatives for a variety of hedging and non-hedging purposes.
Normally, the fund invests at least 80% of its net assets (plus the amount of borrowings, if any, for investment purposes) in debt securities. For purposes of satisfying the 80% requirement, the fund may invest in derivative instruments that provide exposure to such debt securities or have similar economic characteristics. The fund has the flexibility to invest in a broad range of issuers and segments of the debt securities markets. Amundi Pioneer allocates the fund's debt securities among different instruments and segments of the debt markets, based on its outlook for economic, interest rate and political trends. Debt securities may include instruments and obligations of U.S. and non- U.S. corporate and other non-governmental entities, those of U.S. and non-U.S. governmental entities, mortgage-related or mortgage-backed securities (including “sub-prime” mortgages), asset-backed securities, floating rate loans, convertible securities, preferred securities, Treasury Inflation Protected Securities (“TIPS”) and other inflation-linked debt securities, subordinated debt securities, event-linked bonds and other insurance-linked securities, municipal bonds and funds that invest primarily in debt securities. The fund may invest without limit in debt securities of any credit quality, including those rated below investment grade (known as “junk bonds”) or, if unrated, of equivalent credit quality as determined by Amundi Pioneer. The fund’s investments in debt securities rated below investment grade may include securities that are in default. The fund may invest in securities of issuers located in emerging markets.
The fund invests in securities with a broad range of maturities and maintains an average portfolio maturity that varies based upon the
Principal Risks: - Market risk - Derivatives risk - Short position risk - Credit default swap risk - Forward foreign currency transactions risk - Structured securities risk - Risks of investing in inverse floating rate obligations - Leveraging risk - High yield or “junk” bond risk - Interest rate risk - Credit risk - Prepayment or call risk - Extension risk - Liquidity risk - Portfolio selection risk - U.S. Treasury obligations risk - U.S. government agency obligations risk - Mortgage-related and asset-backed judgment of Amundi Pioneer. The fund's investments may have fixed or variable principal payments and all types of interest rate payment and reset terms, including fixed rate, adjustable rate, floating rate, zero coupon, contingent, deferred, payment in kind and auction rate features. The fund’s investments may include instruments that allow for balloon payments or negative amortization payments. The fund may invest in equity securities as a consequence of holding debt of the same issuer or when Amundi Pioneer believes the securities offer the potential for capital gains or other portfolio management purposes, although equity securities may not pay dividends or contribute to achieving the fund's primary investment objective of a high level of c please register to get more info
Neither Amundi Pioneer nor any of its management persons has been subject to any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Amundi Pioneer’s advisory business or the integrity of Amundi Pioneer ’s management. please register to get more info
Amundi Pioneer has a number of relationships with related persons that are material to its advisory business or its clients. Amundi Pioneer is affiliated with APIAM, which, like Amundi Pioneer, is an indirect wholly owned subsidiary of Amundi USA Inc.. APIAM is a registered investment adviser primarily engaged in providing investment management services to unregistered pooled investment vehicles and separate accounts. APIAM is registered with the CFTC as a CPO and a CTA.
Amundi Pioneer may appoint sub-advisers for Domestic Funds, and other similarly managed accounts such as private funds and Off-Shore Funds and pay such sub-advisers a portion of the fee received.
Amundi Pioneer may, from time to time, change or recommend a change in a sub-adviser for a fund. Amundi Pioneer will benefit to the extent that it recommends replacing a sub-adviser with another sub-adviser with a lower sub-advisory fee, or if Amundi Pioneer recommends appointing an affiliated sub-adviser. Amundi Pioneer provides various support services to APIAM, including trade management and related services. Employees of APIAM who provide portfolio management, trade management and related services may also work for Amundi Pioneer. APIAM and Amundi Pioneer use various similar policies and procedures, including trading related policies and procedures. Amundi Pioneer manages registered investment companies (the Pioneer family of funds) and other client accounts with investment strategies similar to those client accounts managed by APIAM. Securities frequently meet the investment objectives of one or more investment strategies of APIAM clients and Amundi Pioneer managed funds and other clients of Amundi Pioneer. In such cases, the decision to recommend a purchase to one client or fund rather than another is based on a number of factors. In determining which securities to buy or sell for a client and in what amount, Amundi Pioneer may consider a variety of factors, including the client’s investment objectives and strategies, the client’s diversification and liquidity requirements, the size of the client’s account, tax implications, the marketability of the securities, the characteristics of the client’s account and other relevant factors, such as the size of an available purchase or sale opportunity, the extent to which an available opportunity would represent a meaningful portion of the client’s account, and the availability of comparable opportunities. Other factors considered include the amount of securities of the issuer then outstanding, the value of those securities and the market for them. Amundi Pioneer may make purchase and sale decisions with respect to a particular client account that may be the same as, or differ from, the recommendations made, or the timing or nature of the action taken, with respect to other accounts. It is possible that at times identical securities will be held by more than one fund and/or account managed by Amundi Pioneer and its affiliate APIAM. However, positions in the same issue may vary and the length of time that any fund or account may choose to hold its investment in the same issue may likewise vary. To the extent that multiple clients and/or funds or other clients of Amundi Pioneer seek to acquire the same security at about the same time, a fund or client account may not be able to acquire as large a position in such security as is desired or it may have to pay a higher price for the security. Similarly, a fund or client account may not be able to obtain as large an execution of an order to sell or as high a price for any particular portfolio security if Amundi Pioneer and/or APIAM decides to sell the same portfolio security at the same time on behalf of other funds or accounts. On the other hand, if the same securities are bought or sold at the same time by more than one fund or client account, the resulting participation in volume transactions could produce better executions for the fund or account. In the event more than one fund or account purchases or sells the same security on a given date, the purchases and sales will normally be made as nearly as practicable on a pro rata basis in proportion to the amounts desired to be purchased or sold by such funds or accounts. Although the other funds and accounts managed by Amundi Pioneer may have the same or similar investment objectives and policies as another fund or account managed by Amundi Pioneer, their portfolios do not generally consist of exactly the same investments and their performance results are likely to differ.
The “Performance-Based Fees and Side-by-Side Management” section of this Brochure provides information on how investment opportunities and trades are allocated in an effort to avoid such conflicts of interest.
Amundi Pioneer may recommend investments in securities that also may be owned by its affiliates, officers or employees (either directly or through pooled investment vehicles in which such persons have invested) or clients of related investment advisers of Amundi Pioneer.
Amundi Pioneer has adopted a Conflicts of Interest Policy that is designed to establish a framework for identifying circumstances and relationships that might constitute a conflict of interest and to address these conflicts in a manner that is fair and equitable to Amundi Pioneer’s clients and to Amundi Pioneer and does not disadvantage a client. This policy requires the full disclosure of actual or potential conflicts of interests with clients. If a potential conflict cannot be resolved or eliminated, internal controls will be designed to oversee the conduct or business practice. The conduct or business practice may be discontinued.
APAMUSA, Amundi Pioneer Distributor, Inc. (“Amundi Pioneer Distributor”), APIAM and Amundi Pioneer are indirect wholly owned subsidiaries of Amundi. Amundi has other subsidiaries that are engaged in the investment management business that are not registered as investment advisers under the Investment Advisers Act. Amundi Pioneer Distributor, a wholly owned subsidiary of Amundi Pioneer, is a broker-dealer registered with the SEC and is a member of the Financial Industry Regulatory Authority. Amundi Pioneer Distributor primarily is engaged in the marketing and sale of mutual funds and receives compensation from the Funds for such services. Amundi Pioneer Distributor is the principal underwriter of the Domestic Funds. Pursuant to a participating affiliate agreement between Amundi Pioneer and its affiliate, Amundi Ireland Limited (“Amundi Ireland”), Amundi Ireland provides certain administrative, investment management and trading services to Amundi Pioneer, including the services of Amundi Ireland’s research, portfolio management, compliance and trading staff. Amundi Ireland is engaged in an investment advisory business outside the United States. Pursuant to a participating affiliate agreement between Amundi Pioneer and its affiliate, Amundi Asset Management acting through its London branch (“Amundi London”), Amundi London provides back-up portfolio management services to Amundi Pioneer with respect to certain separate account portfolios. Amundi Asset Management is engaged in an investment advisory business outside the United States.
In connection with the provision of services to Amundi Pioneer, each affiliate has appointed the SEC as its agent for service of process within the jurisdiction of the United States. Amundi Pioneer and each affiliate is operating under the applicable participating affiliate arrangement in reliance upon the Royal Bank of Canada No-Action Letter, dated June 3, 1998.
Amundi has other subsidiaries that are engaged in the banking and insurance businesses in numerous countries. Amundi’s portfolio management activity is organized at a local level. In addition to the portfolio management activity of Amundi Pioneer in Boston, Amundi conducts portfolio management operations in numerous countries. Amundi and its subsidiaries may own investment securities, and from time to time, Amundi Pioneer will make an investment decision on behalf of its clients to purchase or sell a security in which Amundi or one of its other subsidiaries has positions or interests subject to applicable law. Amundi Pioneer’s portfolio managers operate separately and independently of any portfolio managers that make decisions to purchase and sell securities on behalf of Amundi. It is Amundi Pioneer’s policy not to purchase or sell securities on behalf of clients based on any position or interest that Amundi or other subsidiaries may have in such securities.
Amundi has joint venture investments in other entities, any of which may be considered affiliated companies or related persons of Amundi Pioneer (“Amundi Affiliates”). Certain of these Amundi Affiliates are involved in international venture capital and others provide investment advice and/or make investments in securities for their own or client accounts. Subject to applicable law, Amundi Pioneer may purchase or sell for, or recommend for purchase or sale by, a client account securities that such Amundi Affiliates may own, directly or indirectly. Additionally, affiliated advisers may recommend to their clients, or invest on behalf of their clients in securities that are the subject of recommendations to, or discretionary trading on behalf of, Amundi Pioneer’s U.S.–based clients. While each of these entities may act independently from Amundi Pioneer with respect to making investment decisions for client accounts or, if applicable, for a proprietary account, investment information and data is exchanged between or among Amundi Pioneer and some or all of such Amundi Affiliates. In contrast to the portfolio management activities described above, Amundi has research activities globally. Research is communicated via email to global investment staff, including investment personnel of Amundi Pioneer. All documents are emailed and housed in a proprietary document management system for real-time communication of research to all members of investment management on a global basis. Research is communicated throughout the organization, giving portfolio managers the opportunity to react accordingly. please register to get more info
Amundi Pioneer has adopted a Code of Ethics pursuant to Rule 204A-1 under the Investment Advisers Act. Among other things, Amundi Pioneer’s Code of Ethics requires supervised persons of Amundi Pioneer to comply with federal securities laws, and to adhere to certain standards of business conduct that reflect Amundi Pioneer’s fiduciary obligations to its clients. In addition, supervised persons of Amundi Pioneer who participate in or have access to investment decisions on behalf of Amundi Pioneer’s clients must report his or her personal securities transactions and holdings to Amundi Pioneer, pre-clear certain transactions with Amundi Pioneer’s Compliance Department, and refrain from engaging in certain investment activities. To the extent Amundi Pioneer retains a sub-adviser with respect to any account under its management, Amundi Pioneer requires that such sub-adviser adopt a code of ethics that complies with the requirements of Rule 204A-1 under the Investment Advisers Act.
One of the key objectives of the Amundi Pioneer Code of Ethics is to prevent personal trades by Amundi Pioneer officers and employees based on information about securities transactions made for advisory clients. Each officer or employee with access to advisory client information must obtain pre-clearance for all reportable securities transactions in his or her personal accounts, (“Access Person”).
Each Amundi Pioneer employee must observe the following fiduciary principles with respect to his or her personal investment activities:
At all times, each Amundi Pioneer employee must place the interests of advisory clients first;
Personal securities transactions of employees must be conducted in a manner designed to avoid actual or potential conflicts of interest with the interests of any advisory client or any abuse of the employee’s position of trust and responsibility; and Each Amundi Pioneer employee must avoid actions or activities that would allow him or her to inappropriately profit or benefit from his or her position at Amundi Pioneer, or that otherwise brings into question the employee’s independence or judgment. A copy of the Code of Ethics will be provided to any client or prospective client upon request. please register to get more info
Subject to any directed brokerage arrangements, it is the policy of Amundi Pioneer to select brokers or counterparties to execute client transactions in a manner that is consistent with the fiduciary obligations of Amundi Pioneer to the client for whom the transaction is being executed, and to employ a trading process that attempts to maximize the value of a client’s portfolio within the client’s stated investment objectives and constraints. The policy embodies the obligation of an adviser to seek what is commonly referred to as “best execution.” Best execution means that the total costs or proceeds to a client are the most favorable under the circumstances. Best execution does not mean that Amundi Pioneer must obtain the lowest possible commission cost (or markup or markdown), but rather means that Amundi Pioneer should seek to obtain the best overall qualitative execution for the client.
Amundi Pioneer will place orders pursuant to its investment determinations for each client either directly with the issuer or with any broker or dealer, foreign currency dealer, futures commission merchant or others selected by it. Amundi Pioneer will seek the best overall execution available in the selection of brokers or dealers or counterparties and the placing of orders for each client. In assessing the best execution available for any transaction, Amundi Pioneer may consider factors it deems relevant, including the size and type of the transaction, the nature and character of the markets for the security to be purchased or sold, the execution capabilities and financial condition of the broker or dealer or counterparty, and the reasonableness of the commission or dealer spread, if any (whether for a specific transaction or on a continuing basis).
In connection with the selection of such brokers or dealers and the placing of such orders, subject to applicable law, brokers or dealers may be selected who also provide brokerage and research services (as those terms are defined in Section 28(e) of the Securities Exchange Act of 1934, as amended (the "Exchange Act")) (“soft dollar benefits”) to the client and/or the other accounts over which Amundi Pioneer or its affiliates exercise investment discretion. Consistent with Section 28(e), if Amundi Pioneer determines in good faith that the amount of commissions charged by a broker-dealer is reasonable in relation to the value of the brokerage and research services provided by the broker-dealer, a client may pay commissions (or markups or markdowns) to the broker-dealer in an amount greater than the amount another firm may charge. These services may include advice concerning the value of securities; the advisability of investing in, purchasing or selling securities; the availability of securities or the purchasers or sellers of securities; providing stock quotation services, credit rating service information and comparative fund statistics; furnishing analyses, electronic information services, manuals and reports concerning issuers, industries, securities, economic factors and trends, portfolio strategy, and performance of accounts and particular investment decisions; and effecting securities transactions and performing functions incidental thereto (such as clearance and settlement). Amundi Pioneer benefits when it uses client brokerage commissions (or markups or markdowns) to obtain research or other services that it would otherwise have to produce or purchase. Amundi Pioneer maintains a listing of broker-dealers who provide such services on a regular basis. However, because many transactions on behalf of a client and other investment companies or accounts managed by Amundi Pioneer are placed with broker-dealers (including broker- dealers on the listing) without regard to the furnishing of such services, it is not possible to estimate the proportion of such transactions directed to such broker-dealers solely because such services were provided. Amundi Pioneer believes that no exact dollar value can be calculated for such services. The research received from broker-dealers may be useful to Amundi Pioneer in rendering investment management services to the client whose account generated the soft dollar benefit, as well as other investment companies or other accounts managed by Amundi Pioneer , although not all such research may be useful to a client. Conversely, such information provided by brokers or dealers who have executed transaction orders on behalf of such other accounts may be useful to Amundi Pioneer in carrying out its obligations to a client. The receipt of such research enables Amundi Pioneer to avoid the additional expenses that might otherwise be incurred if it were to attempt to develop comparable information through its own staff. Amundi Pioneer will seek to allocate soft dollar benefits to client accounts proportionately to the soft dollar credits the accounts generate.
Promotional or sales efforts provided or conducted by broker-dealers are not considered in the selection of broker-dealers.
Certain brokerage and research services also may assist Amundi Pioneer beyond the investment decision-making process. In such instances, Amundi Pioneer will determine the portion of such brokerage and research not used in the investment decision-making process and will pay for such portion out of its own funds. Amundi Pioneer maintains a list of broker-dealers that regularly provide these services. However, because many transactions on behalf of accounts managed by Amundi Pioneer are placed with broker-dealers (including broker-dealers on the list) without regard to the furnishing of additional services, it is not possible to estimate the proportion of transactions directed to broker-dealers solely because they provide other services.
Certain accounts may have directed brokerage arrangements or other limitations that restrict Amundi Pioneer’s ability to aggregate orders for such accounts with orders for other accounts and provide best execution. In those cases, Amundi Pioneer will make an effort to obtain prices comparable to those obtained for unrestricted accounts; however, trades for restricted accounts will generally occur after trades for unrestricted accounts. Trades will be prioritized among restricted accounts in a fair and equitable manner. In directed brokerage arrangements, Amundi Pioneer may not be in a position to negotiate freely commission rates or spreads, obtain volume discounts on aggregated orders or select broker/dealer on the basis of best price and execution, and, as a result, the directed brokerage transactions may result in higher commissions, greater spreads or less favorable execution on some transactions than would be the case if Amundi Pioneer were free to choose the broker/dealer. Amundi Pioneer does not engage in activities such as directing brokerage to a broker-dealer who either has made a referral or has been designated by a solicitor. Amundi Pioneer may aggregate orders to purchase or sell the same security for multiple accounts if permitted by a client. In some cases, Amundi Pioneer may not aggregate orders for accounts managed out of one Amundi Pioneer office with orders for accounts managed out of another Amundi Pioneer office. Whenever Amundi Pioneer aggregates orders, all accounts that participate in the transaction will participate on a pro rata or other objective basis. To the extent that orders are not aggregated, including orders for accounts managed out of different Amundi Pioneer offices, clients may not receive the same transaction price and transaction costs may be higher. Please see “Side by Side Management” and “Other Financial Industry Activities and Affiliations” for information on conflicts of interest. Cross trading generally refers to the practice by which Amundi Pioneer causes an account to buy or sell securities from or to another account. Amundi Pioneer will only engage in a cross trade where it has determined that such trade is in the best interests of each account and is otherwise consistent with Amundi Pioneer’s fiduciary duty to each account. Amundi Pioneer may trade securities between accounts for a variety of reasons, including, to manage cash flows; to maintain appropriate compositions and weightings; where securities owned by one account subsequently become less appropriate for that account and more appropriate for a different account; or other instances where portfolio management requirements indicate that accounts will be buying and selling the same securities and the purchase and sale decision is made independently for each account.
However, cross trades can be affected in a manner that may be perceived to favor one account over another. For instance, an investment adviser may be viewed as crossing securities that are expected to increase in value from accounts paying lower fees to accounts paying higher fees (e.g., performance-based fees) or to investment companies of which the investment performance is important to the marketing of shares of such investment companies. Conversely, an investment adviser may be perceived as crossing securities that are expected to decrease in value from accounts paying higher performance-based fees to accounts paying lower performance-based fees.
In effecting cross trades, Amundi Pioneer is subject to the rules and regulations applicable to its activities as a registered investment adviser and the rules and regulations applicable to its accounts, such as the Investment Advisers Act of 1940, Investment Company Act, The Employee Retirement Income Security Act of 1974 (“ERISA”) and the rules and regulations of certain foreign regulatory authorities, such as the Bank of Italy. The portions of this policy required by Rule 17a-7 under the Investment Company Act, constitutes the procedure required under Rule 17a-7 for the Domestic Funds managed by Amundi Pioneer.
Amundi Pioneer may enter into transactions for clients with affiliated funds or other clients (known as “crossing securities” or “cross trades”), subject to applicable law. Amundi Pioneer believes that the potential benefit to client accounts that may result from crossing securities outweighs the potential risks. Cross trades are effected pursuant to procedures established by Amundi Pioneer. Amundi Pioneer will cross securities between client accounts where possible if it is in the best interests of the account. All cross trades are properly categorized as such on Amundi Pioneer’s trade management system. Each cross trade is reported on a quarterly basis to the global compliance department and upon request to a respective client. please register to get more info
The investment management functions of Amundi Pioneer are organized into three main areas: portfolio management, research (which includes fundamental research, quantitative research and investment risk) and trading. Management of the Amundi Pioneer portfolios is grouped into teams according to common elements of market, style and objective (e.g., international equity, domestic equity (comprised of small company investment, large and mid-cap value and growth investments, and core investments) and fixed income). Each team consists of investment professionals who meet regularly to discuss holdings, prospective investments and portfolio composition. Day-to-day management of a portfolio is the responsibility of a designated portfolio manager or team of portfolio managers.
Accounts also are reviewed by Amundi Pioneer’s Investment Committee, which meets monthly to:
Review and evaluate investment performance; Review and approve the development, modification and use of investment strategies, techniques and instruments; Review and evaluate the feasibility of all product-related proposals, including investment capability and allocation of resources; and Review and address investment-related compliance matters.
In addition, Amundi Pioneer’s Risk Department provides an ongoing review of the investment activities with respect to each client account in an effort to ensure that the assets of such account are managed in conformity with investment guidelines applicable to the account.
The Risk Department monitors investments using an automated compliance tool, In general, equity orders are tested before execution of a transaction. For the majority of transactions fixed income trades are tested for compliance with investment guidelines on a pre-trade basis. There are instances, however, where due to the purchased security, or the trade being transacted via a phone call, compliance is monitored immediately after execution of a transaction on a pre- allocation basis. We also conduct nightly fixed income checks on all accounts (“batch monitoring”). Certain fixed income trades are reviewed for immediate post-execution compliance on trade date. Trades are required to be entered into the order management system, which will run the compliance checks within two hours of execution. As most securities are purchased in blocks (including allotments for other commonly managed accounts), any purchase that will cause the portfolio with a limit to be out of compliance is not allowed to proceed further in the trade flow. Investment limitations that cannot be tested by the automated compliance system normally are monitored manually. As noted above, individuals employed by Amundi Ireland may provide administrative and portfolio management services to certain of Amundi Pioneer’s clients using a similar research and portfolio management structure as that employed by Amundi Pioneer. Members of the portfolio management teams for each of the Domestic Funds regularly report to the Boards of Trustees of the Domestic Funds regarding the Funds’ performance. In addition, each of the Domestic Funds provides shareholders with a semi-annual written report containing performance and financial information, as required by applicable law. The Domestic Funds also file with the SEC an annual report regarding the Funds’ proxy voting records and a quarterly report regarding the Funds’ portfolio holdings.
Audited financial statements of private funds will generally be prepared and delivered to shareholders within 120 days or as soon thereafter as is reasonably practicable following the close of each fiscal year. Each shareholder is provided with unaudited performance information and account statements at least monthly. Unless otherwise restricted by law, all reports, financial statements, and other information may be delivered to shareholders electronically. please register to get more info
Amundi Pioneer does not utilize or pay for external marketers in connection with solicitation with respect to the Off-Shore Funds.
Affiliates of Amundi Pioneer (“Amundi Pioneer Affiliates”) make revenue sharing payments as incentives to certain financial intermediaries to promote and sell shares of the Domestic Funds. The benefits Amundi Pioneer Affiliates receive when they make these payments include, among other things, entry into or increased visibility in the financial intermediary’s sales system, participation by the intermediary in the distributor’s marketing efforts (such as helping facilitate or providing financial assistance for conferences, seminars or other programs at which Amundi Pioneer personnel may make presentations on the funds to the intermediary’s sales force), placement on the financial intermediary’s preferred fund list, and access (in some cases, on a preferential basis over other competitors) to individual members of the financial intermediary’s sales force or management. Revenue sharing payments are sometimes referred to as “shelf space” payments because the payments compensate the financial intermediary for including the Domestic Funds in its fund sales system (on its “shelf space”). Amundi Pioneer Affiliates compensate financial intermediaries differently depending typically on the level and/or type of considerations provided by the financial intermediary. The revenue sharing payments Amundi Pioneer Affiliates make may be calculated on sales of shares of the Domestic Funds (“Sales- Based Payments”); although there is no policy limiting the amount of Sales-Based Payments any one financial intermediary may receive, the total amount of such payments normally does not exceed 0.25% per annum of those assets. Such payments also may be calculated on the average daily net assets of the applicable Domestic Funds attributable to that particular financial intermediary (“Asset-Based Payments”); although there is no policy limiting the amount of Asset-Based Payments any one financial intermediary may receive, the total amount of such payments normally does not exceed 0.16% per annum of those assets. Sales- Based Payments primarily create incentives to make new sales of shares of the Domestic Funds and Asset-Based Payments primarily create incentives to retain previously sold shares of the Domestic Funds in investor accounts. Amundi Pioneer Affiliates may pay a financial intermediary either or both Sales-Based Payments and Asset-Based Payments.
Amundi Pioneer Affiliates also may make payments to certain financial intermediaries that sell Domestic Fund shares for certain administrative services, including record keeping and sub- accounting for shareholder accounts, to the extent that the funds do not pay for these costs directly. Amundi Pioneer Affiliates also may make payments to certain financial intermediaries that sell the Domestic Fund shares in connection with client account maintenance support, statement preparation and transaction processing. The types of payments that Amundi Pioneer Affiliates may make under this category include, among others, payment of ticket charges per purchase or exchange order placed by a financial intermediary, payment of networking fees in connection with certain mutual fund trading systems, or one-time payments for ancillary services such as setting up funds on a financial intermediary’s mutual fund trading system.
From time to time, Amundi Pioneer Affiliates, at their expense, may provide additional compensation to financial intermediaries that sell or arrange for the sale of shares of the Domestic Funds. Such compensation provided by Amundi Pioneer Affiliates may include financial assistance to financial intermediaries that enable Amundi Pioneer Affiliates to participate in and/or present at conferences or seminars, sales or training programs for invited registered representatives and other employees, client entertainment, client and investor events, and other financial intermediary-sponsored events, and travel expenses, including lodging incurred by registered representatives and other employees in connection with client prospecting, retention and due diligence trips. Other compensation may be offered to the extent not prohibited by federal or state laws or any self-regulatory agency, such as FINRA. Amundi Pioneer Affiliates make payments for entertainment events they deem appropriate, subject to Amundi Pioneer Affiliates’ guidelines and applicable law. These payments may vary depending upon the nature of the event or the relationship.
As of January 1, 2019, Amundi Pioneer anticipates that the following broker-dealers or their affiliates will receive additional payments as described in the Domestic Funds’ prospectuses and statements of additional information:
ADP Retirement Services AIG Ameriprise Financial Services, Inc. Ascensus Broker Dealer Services, Inc. Brighthouse Securities, LLC Cetera Advisors Networks LLC Charles Schwab & Co., Citigroup Global Markets Inc. Commonwealth Financial Network Conduent Securities, LLC Fidelity Brokerage Services LLC First Clearing, LLC First Command Financial Planning, Inc. FSC Securities Corporation Guardian Investor Services LLC GWFS Equities, Inc. H.D. Vest Investment Services Hartford Securities Distribution Company, Inc. J.P. Morgan Securities LLC Jefferson National Securities Corporation Ladenburg Thalmann & Co. Inc. Legend Equities Corporation Lincoln Financial LPL Financial Corp. Merrill Lynch & Co., Inc. Mid Atlantic Capital Corporation MML Investor Services
Morgan Stanley & Co., Inc.
MSCS Financial Services, LLC
Mutual of Omaha Investor Services, Inc.
N.I.S. Financial Services, Inc.
National Financial Services LLC
Nationwide Securities, Inc. Northwestern Investment Services, LLC NYLife Securities, LLC OneAmerica Securities, Inc. Pershing LLC PFS Investments Inc. PNC Investments Principal Securities, Prudential Financial Raymond James Financial Services, RBC Dain Rauscher Royal Alliance Associates, Inc. SagePoint Financial Sammons Financial Network, LLC Security Distributors Standard Life Investments Securities LLC Symetra Investment Services, Inc. TD Ameritrade, Inc. TIAA-CREF Individual & Institutional Services, LLC T. Rowe Price Investment Services, Inc. Transamerica Financial Advisors, Inc. UBS Financial Services Inc. U.S. Bancorp Investments, Inc. Vanguard Marketing Corporation Voya Financial Partners, LLC Wells Fargo Investments, LLC Woodbury Financial Services please register to get more info
Amundi Pioneer does not maintain custody over client assets. Amundi Pioneer does not have the ability to deduct fees from any account, including those of Domestic Funds, private funds, Offshore Funds or other client accounts. please register to get more info
As an investment adviser primarily to open and closed-end mutual funds, Amundi Pioneer has discretionary authority to purchase securities on behalf of such Domestic Funds. Amundi Pioneer’s investment decisions with respect to the Domestic Funds are limited by Investment Company Act rules as well as other rules and restrictions that are set forth in each Fund’s prospectus and statement of additional information. In order for Amundi Pioneer to remain the investment adviser of each Domestic Fund, the Trustees of the Fund must determine annually whether to renew the investment advisory agreement for the Fund. With respect to accounts other than Domestic Funds, Amundi Pioneer usually receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular account and the investment advisory agreement for such client. Amundi Pioneer requires an executed management agreement before assuming discretionary investment authority.
Investment guidelines and restrictions must be provided to Amundi Pioneer in writing. please register to get more info
Amundi Pioneer has adopted policies and procedures concerning the voting of proxies on behalf of client accounts.
When delegating proxy-voting authority for a client, Amundi Pioneer will vote proxies presented in a timely manner in a manner consistent with the best interest of its clients. Amundi Pioneer’s sole concern in voting proxies is the economic effect of the proposal on the value of portfolio holdings. Amundi Pioneer’s proxy voting policies and procedures are designed to complement Amundi Pioneer’s policies and procedures regarding its general responsibility to monitor the performance and/or corporate events of companies that are issuers of securities held in accounts managed by Amundi Pioneer. Amundi Pioneer’s proxy voting policies summarize Amundi Pioneer’s position on a number of issues solicited by companies held by Amundi Pioneer’s clients. The policies are guidelines that provide a general indication on how Amundi Pioneer would vote but do not include all potential voting scenarios.
The overriding goal is that all proxies for US and non-US companies that are received promptly will be voted in accordance with Amundi Pioneer’s policies or specific client instructions. All shares of an issuer held by accounts managed by Amundi Pioneer will be voted alike, unless a client has given Amundi Pioneer specific voting instructions on an issue or Amundi Pioneer determines that the circumstances justify a different approach. Amundi Pioneer has engaged an independent proxy voting service to assist in the voting of securities. The proxy voting service works with the custodians to ensure all proxy materials are received by the custodians and processed in a timely manner. To the extent applicable, the proxy voting service votes all proxies in accordance with Amundi Pioneer’s proxy voting guidelines. The proxy voting procedures describe circumstances in which the proxy voting service will refer proxy questions to Amundi Pioneer. Amundi Pioneer addresses potential material conflicts of interest by having a predetermined proxy voting policy. A Proxy Voting Oversight Group along with a Proxy Coordinator is responsible for monitoring potential conflicts of interest in connection with the voting of proxies on behalf of Amundi Pioneer clients. Any associate involved in the proxy voting process with knowledge of any apparent or actual conflict of interest must disclose such conflict to the Proxy Coordinator and the Chief Compliance Officer of Amundi Pioneer and Funds. The Proxy Voting Oversight Group will review each item referred to Amundi Pioneer by the proxy voting service to determine whether an actual or potential conflict of interest with Amundi Pioneer exists in connection with the proposal(s) to be voted upon. The review will be conducted by comparing the apparent parties affected by the proxy proposal being voted upon against the Proxy Coordinator’s and Compliance Department’s internal list of interested persons and, for any matches found, evaluating the anticipated magnitude and possible probability of any conflict of interest being present. For each referral item, the determination regarding the presence or absence of any actual or potential conflict of interest will be documented in a Conflicts of Interest Report prepared by the Proxy Coordinator.
Clients may review Amundi Pioneer’s proxy voting policies and procedures online at http:www.pioneerinvestments.com. Clients also may request a copy of applicable voting records by contacting Amundi Pioneer. Information regarding how a Domestic Fund voted proxies relating to portfolio securities during the most recent twelve-month period ended June 30 also is publicly available to shareowners without charge at http://www.pioneerinvestments.com and on the SEC’s website at http://www.sec.gov. please register to get more info
Amundi Pioneer does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. Amundi Pioneer has not been the subject of a bankruptcy proceeding.
Business Continuity
Amundi Pioneer has implemented a Business Continuity policy that describes the firm’s program to respond to a significant business disruption or other failure in its ability to continue to conduct business or meet its obligations to its clients. As a subsidiary of APAMUSA, Amundi Pioneer is included in APAMUSA’s Business Continuity Plan (“BCP Plan”). The BCP Plan, which is maintained by Amundi Pioneer’s Risk Management Department, is updated upon any material change to APAMUSA’s operations, structure, business, or location and distributed to the Management Committee of Amundi Pioneer at least annually. The BCP Plan is based on an assessment of the following: identification of significant business disruptions; description of Amundi Pioneer’s mission-critical operations; and description or assessment of Amundi Pioneer’s operational risk, such as loss of communication systems, loss of access to, or total loss of, paper, books and records, loss of access to electronic records, loss of access to the building, or loss of personnel. The Business Continuity policy summarizes key elements of the BCP Plan. The firm contracts with SunGard to provide a redundant data center and dedicated work area recovery site in Marlborough, MA, that includes recovery of all operations and critical systems, including trading and accounting systems, key network files, and email systems. This facility is augmented with remote access to all mission critical systems capabilities for the firm’s staff. The firm conducts business-wide operational tests of the facility, including with fixed income and equity trading, operations and compliance staff, supported by technology and general service teams twice annually.
Privacy
Amundi Pioneer has adopted policies and procedures relating to the collection of confidential client information in accordance with Regulation S-P. A copy of the privacy notice is available on request and will be offered to clients annually as required by Regulation S-P. please register to get more info
Open Brochure from SEC website
Assets | |
---|---|
Pooled Investment Vehicles | $23,655,211,862 |
Discretionary | $75,146,598,387 |
Non-Discretionary | $70,296,161 |
Registered Web Sites
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