Background
Vaughan Nelson is a Houston-based investment counseling firm established in 1970 and is a
wholly-owned affiliate of Natixis Investment Managers, LLC. The Firm, staffed by experienced,
research-oriented investment professionals, has over 52 years of providing comprehensive equity
and fixed income investment advice to taxable and tax-free clients including foundations,
endowments, corporations, pensions, public entities, insurance companies, mutual funds and high
net worth individuals. The Firm expanded its equity capability to include International/Global
investing in October 2019 with a team located at 180 N. Stetson Avenue, Suite 5525, Chicago, IL
60601. The Firm’s sole focus is providing investment management services for equity and fixed
income portfolios totaling ~$13.6 billion as of 12/31/2022.
Ownership
Vaughan Nelson is wholly-owned by Natixis Investment Managers, LLC, which, through
intermediate subsidiaries, is part of Natixis Investment Managers, an international asset
management group based in Paris, France, that, in turn, is owned by Natixis, a French investment
banking and financial services firm. Natixis is wholly owned by BPCE, France’s second largest
banking group. Vaughan Nelson operates autonomously and provides investment management
services independently with its own research, investment team and trading.
Primary Business
The primary business of Vaughan Nelson is the management of client assets in equity and/or fixed
income securities on an ongoing, continuous basis. Normally, Vaughan Nelson is engaged by clients
(both institutional and individual) to provide investment management services for their own
account separate from other clients (a “separate account”) where investment decisions are
implemented on a fully-discretionary basis in accordance with the client’s guidelines and
restrictions. Depending on client instruction, these services are provided either with or without
consideration to the overall financial situation of the client (e.g. tax considerations, liquidity needs,
etc.).
Vaughan Nelson also serves as advisor/sub-advisor to sponsored, affiliated and unaffiliated mutual
funds where investment decisions are implemented on a fully discretionary basis, subject to the
requirements of the Investment Company Act of 1940 and restrictions contained within the related
Prospectus and Statement of Additional Information for each fund.
Finally, Vaughan Nelson participates as a non-discretionary subadviser to wrap programs where
the investment advice is provided to affiliated and
unaffiliated sponsors (the investment advisor)
who then have discretion over the implementation, including trade execution, of the investment
advice. In certain circumstances the investment advisor will communicate trade appetite back to
Vaughan Nelson for execution on a ‘stepped-out’ basis. It is the responsibility of the affiliated and
unaffiliated sponsors of the wrap programs to take into consideration the financial situation and
any needs of the ultimate client. For this service, Vaughan Nelson is paid a portion of the wrap fee
paid by the client to the program sponsor.
Performance differences between all Vaughan Nelson’s clients will occur due to differences in cash
availability, investment restrictions, account sizes, trade sequencing (see Item 12 Brokerage
Practices) and other factors.
Discretionary and Non-Discretionary assets (inclusive of those for which a model is provided but
not included in RAUM of $1,258,476,144) as of 12/31/22 are broken down as follows:
Discretionary Assets $ 12,336,938,462
Non-Discretionary Assets $ 1,265,159,435
Total Assets $ 13,602,097,897
Business Continuity
For purposes of business continuity, Vaughan Nelson’s primary information and data are hosted on
premises in our Houston office and redundantly in a third-party, Boston, MA (~1600 miles from
Houston) based data center facility (Markley Center). Both environments have high levels of both
physical security and redundant power/data providers for maximum availability. Additionally,
there are multiple layers of redundancy within the virtualized server environment both in Houston
and hosted at the Markley Center. All infrastructure managed by Vaughan Nelson is kept in sync on
a near real-time interval for all network drives and files with additional full tape backups kept
offsite. For critical applications, the firm’s trading, compliance and portfolio accounting systems are
hosted by NIM-os (a non-advisory operating services affiliate) with multiple layers of redundancy
and SLAs in place for system availability. All employees are able to work remotely within this
infrastructure in order to continue operations when the Business Continuity Plan is activated (e.g.
hurricane, pandemic). Vaughan Nelson also maintains an office space “hot-site” at dedicated
company leased office space in Austin, Texas should the need arise. The Austin office space facility
houses the infrastructure necessary to recover (i.e. phone, connectivity to data center,
workstations, redundant internet access, etc.) in the event physical access to the Houston facility is
lost.