This Brochure describes the investment advisory services offered
by Rockefeller Asset Management (“RAM”), a division of
Rockefeller & Co. LLC (“Rockefeller & Co.”). RAM provides a
broad range of investment strategies in varying investment
vehicles to institutional clients, intermediaries, high net-worth
individuals and family offices, and other types of investors.
Rockefeller & Co. and its affiliates offer additional investment
advisory services which are not described in this Brochure.
Specifically, Rockefeller & Co. offers investment advisory and
family office services through a separate division, the Rockefeller
Global Family Office (the “Global Family Office”). Additionally,
Rockefeller & Co.’s affiliate, Rockefeller Financial LLC
(“Rockefeller Financial”), offers investment advisory and wrap
programs to its clients in its capacity as a dually registered
investment adviser and broker-dealer. Separate brochures
describing the advisory services offered by the Global Family
Office and the advisory and wrap fee programs offered by
Rockefeller Financial are available on the SEC’s website at
www.adviserinfo.sec.gov and may also be obtained by
contacting us by email at
[email protected].
Rockefeller Financial also offers brokerage and other services to
its clients.
Firm Overview
RAM is a division of Rockefeller & Co., which is a Delaware
limited liability company that is registered with the U.S.
Securities and Exchange Commission (the “SEC”) as an
investment adviser under the Investment Advisers Act of 1940,
as amended (the “Advisers Act”). Rockefeller & Co. also conducts
business under the trade name Rockefeller Capital
Management.
RAM and a vast majority of its investment personnel are based
in the firm’s principal place of business operations at 510
Madison Avenue, 21st Floor, New York, New York 10022. Certain
RAM professionals work from different locations, including but
not limited to Rockefeller Capital Management’s headquarters
at 45 Rockefeller Plaza, 5th Floor, New York, New York 10111.
Rockefeller & Co.’s history, through its predecessors, dates to
1882 when John D. Rockefeller established a New York office to
manage the Rockefeller family’s investment, personal, and
philanthropic interests. Rockefeller & Co.’s immediate
predecessor, Rockefeller & Co., Inc. was incorporated in 1979
and in 1980 registered with the SEC as an investment adviser
under the Advisers Act.
Rockefeller & Co. is now an indirect, wholly-owned subsidiary of
Rockefeller Capital Management L.P. Rockefeller Capital
Management L.P. was established on March 1, 2018, when
Gregory J. Fleming, together with investment funds affiliated
with Viking Global Investors, L.P. (“Viking”), acquired the
investment advisory and trust company businesses established
by the Rockefeller Family. Today, RCM is majority owned by the
Viking funds, with minority stakes held by a U.S. affiliate of IGM
Financial Inc. (“IGM”), a trust representing the Rockefeller
family, and current and former members of RCM’s management
and individual members of the Rockefeller family. Viking and
IGM are not involved in the day-to-day management of RCM or
the Firm. No employee, officer, director, or other representative
of Viking or IGM, or any of their respective controlled affiliates,
is a member of any committee of RCM or the Firm that
determines which products or services are offered or sold to
Firm clients. Please refer to Schedule A of Rockefeller & Co.’s
Form ADV Part 1A for additional information about the
ownership of the firm.
Rockefeller Capital Management L.P.’s operating subsidiaries
include: Rockefeller & Co., an investment adviser registered with
the SEC providing investment advisory and family office services
through its Global Family Office division and investment
management services through its RAM division; Rockefeller
Asset Management International Ltd. (“RAM International”), a
UK limited company performing non-US distribution and
investor servicing activities for RAM; Rockefeller Financial, a
broker-dealer and investment adviser registered with the SEC
providing private wealth management services, securities
services and strategic advice; Rockefeller Trust Company, N.A., a
national trust bank regulated by the Office of the Comptroller of
the Currency (“RTC NA”) and The Rockefeller Trust Company
(Delaware), a limited purpose trust company regulated by the
State Bank Commissioner of the State of Delaware (“RTC
Delaware”), both of which provide fiduciary services acting
either as a trustee, co-trustee, executor, co-executor, or as a
fiduciary or agent for other fiduciary relationships; Rockefeller
Strategic Services LLC (“Rockefeller Strategic Services”), which
provides strategic advisory services with respect to certain types
of business transactions not requiring registration in the U.S. as
a broker dealer; and Rockefeller Capital Management Insurance
Services, LLC (“RCM Insurance Services”), an insurance company
licensed in all 50 states that provides access to a broad range of
personal insurance expertise and services through multiple
national providers to enable effective estate planning, asset
protection or other key wealth management planning strategies
and priorities.
Unless otherwise specified, references herein to “clients” or
“you” refer to advisory clients of RAM and the descriptions of
investment advisory services refer to those of RAM and not to
the advisory services and business practices of the Global Family
Office or of other affiliates, including Rockefeller Financial, RTC
NA, RTC Delaware, Rockefeller Strategic Services and RCM
Insurance Services.
RAM Investment Advisory Services
RAM provides a broad range of investment strategies on a
discretionary, non-discretionary and model delivery basis for
institutional clients, intermediaries, high net-worth individuals
and family offices, and other types of investors. Clients may
access RAM’s investment strategies through a variety of
investment vehicles and arrangements, such as separately
managed accounts, registered investment companies, exchange
traded funds, privately offered investment funds, and non-U.S.
investment vehicles. In certain cases, RAM offers these services
on a sub-advisory capacity and through separately managed
account programs, including wrap fee, dual contract and model
delivery programs (“SMA Programs”).
RAM’s primary investment strategies are set forth below.
Long-Only Equity Strategies
• Climate Solutions Equity Strategy
• Emerging Markets Equity Strategy
• Global Equity Strategy
• Global Environmental, Social and Governance (“ESG”)
Equity Strategy
• Global Fossil Fuel Free ESG Equity Strategy
• Global Dividend Growth Equity Strategy
• Global ESG Improvers Strategy
• Global Innovation Strategy
• Non-U.S. Equity Strategy
• Non-U.S. ESG Equity Strategy
• Ocean Engagement Equity Strategy
• Thematic Equity Strategies
• U.S. Large Cap Equity Strategy
• U.S. ESG All Cap Equity Strategy
• U.S. ESG Improvers Strategy
• U.S. Concentrated Strategy
• U.S. Small Cap Equity Strategy
• U.S. Small Cap ESG Equity Strategy
• U.S. SMID Cap Equity Strategy
Hedge Fund Strategy
• Long/Short Equity Strategy
Taxable Fixed Income Strategies
• Short-Term Taxable Strategy
• Short-Term Taxable ESG Strategy
• Intermediate Taxable Strategy
• Core Taxable Strategy
• Taxable Laddered Strategy
• Treasury Laddered Strategy
• Core Taxable ESG Strategy
• Preferred Securities Strategy
• Cash Management Strategy
Tax Exempt Fixed Income Strategies
• Short-Term Tax Exempt Strategy
• Intermediate Tax Exempt Strategy
• Intermediate Tax Exempt ESG Strategy
• Long-Term Tax Exempt Strategy
• Municipal Laddered Portfolio
Private Equity
• FinTech Venture Capital
• Growth Equity
Other Investment Strategies
RAM offers additional investment strategies which are not listed
above. These strategies include, but are not limited to:
• Multi-asset class
strategies, including some with
allocations to third party managers and funds and
alternative asset classes
• Quantitative strategies
• Customized investment strategies tailored to a client’s
particular requirements.
SMA Programs
As mentioned above, RAM serves as portfolio manager to certain
sponsors of SMA Programs, including its affiliate Rockefeller
Financial. Under these arrangements, the program sponsor
typically engages RAM to provide investment management
services to the program sponsor. The program sponsor then
makes these investment strategies available to its program
participants. The program sponsor is responsible for the design
of their SMA Program, and for determining suitability of the SMA
Program for each of its program participants. Program
participants are permitted to establish reasonable investment
restrictions on the management of their program accounts.
For equity strategies made available on SMA Programs, we
typically provide portfolio recommendations (i.e., the model
portfolio) to a program sponsor who is responsible for
implementing the portfolio on behalf of its program participants.
For example, the model program sponsor is responsible for,
among other things, executing portfolio transactions for
program participants and ensuring compliance with investment
restrictions established by program participants. For fixed
income strategies, RAM is generally responsible for executing
transactions for these accounts. Fixed income trading is typically
done away from the program sponsor. Please refer to Item 12
for information about RAM’s brokerage practices for additional
information.
In providing a model, RAM generally uses the same sources of
information and investment/research personnel as it uses to
manage its other client accounts that have similar investment
objectives. Models provided to SMA Program sponsors often
may differ from portfolios that RAM manages directly for other
clients that have similar investment objectives. For example,
SMA Program sponsors may place restrictions and limitations on
securities that can be held in a model. In addition, as compared
to RAM’s directly managed strategies, SMA Program strategies
may, for example and without limitation. invest only in US listed
securities, trade at different times and rebalance positions at
different frequencies or dispersion tolerances, Accounts within
the same model, or a similar model, can hold different securities
and/or trade at different times. Program account performance
may be adversely affected depending on when the specific
model account was funded, or the implementation and portfolio
trading taken by the program sponsor on its program accounts.
In general, material portfolio changes will not be communicated
to model program sponsors until completion of aggregated
trading by RAM for its managed account clients, which could
result in model portfolio clients receiving executions which are
less or more favorable than the executions received by RAM
managed account clients. Clients of model delivery programs
benefit from research acquired through soft dollars but do not
contribute to the cost of acquiring such research because
brokerage transactions for model delivery programs are typically
executed by the plan sponsor and not by RAM.
Clients accessing a RAM investment strategy through a SMA
Program should consult the Form ADV Part 2A and/or wrap fee
brochure, if applicable, of the program sponsor for additional
information.
Qualified Custodians
Clients select their own bank or broker-dealer as their qualified
custodian to hold the funds and securities for which RAM will
provide investment advisory services. RAM has certain business
arrangements in place with unaffiliated third party banks and
broker-dealers who can serve as the qualified custodian for
client accounts, including FNZ Trust Company LLC (“FNZ”) and JP
Morgan Private Bank (“JP Morgan”). RAM may suggest that
clients consider utilizing one of these firms for custody services.
RAM may also recommend that clients access its investment
strategies through SMA Programs, including the wrap fee
program sponsored by its affiliate Rockefeller Financial.
Additional information about RAM’s business arrangements
with these qualified custodians and with Rockefeller Financial is
provided below in Items 11, 12, 14 and 17.
Rockefeller & Co. does not custody client funds and/or securities
on behalf of RAM clients. Please refer to Item 15 – Custody for
additional information.
Other Services Available to Accounts
Customized Advisory Services and Client Restrictions
As discussed above, RAM makes available to clients customized
investment strategies. Any such arrangements must be agreed
upon in advance and typically will be documented through
written investment guidelines or in an investment policy
statement.
Clients may impose reasonable investment restrictions on the
management of their accounts which, if accepted by RAM in
writing, will apply until changed or withdrawn by the client. If
RAM determines that a client imposed restriction prevents the
efficient management of the account, it will seek to have it
modified or removed by the client. Client imposed investment
restrictions will not apply to investment strategies accessed
through investments in mutual funds, exchange traded funds
and other comingled investment vehicles, which have their own
stated investment objectives and policies.
We reserve the right to deem any proposed investment
restriction as unreasonable and to not accept the proposed
investment restriction. If one or more investment restrictions is
determined to be unreasonable, we may not be able to accept
management of the account or may elect to terminate the
account. If you elect to restrict investments, you accept any
effect such restrictions may have on the investment
performance and diversification of your portfolio. The
performance of accounts with client imposed investment
restrictions will differ from, and may be lower than, the
performance of accounts without such restrictions.
Affiliated Investment Products and Affiliated Services Providers
Use of investment strategies, investment funds and other
investment products managed by the Global Family Office
division of Rockefeller & Co. (“Affiliated Investment Products”)
and services offered by affiliates of RAM, including but not
limited to the Global Family Office and Rockefeller Financial
(collectively, “Affiliated Service Providers”) raises conflicts of
interest between RAM and its clients. Please see Item 11 –
Conflicts of Interest below for a more comprehensive discussion
of the conflicts associated with Affiliated Investment Products
and Affiliated Service Providers.
Bloomberg Rockefeller ESG Improvers Index
Bloomberg and RAM have jointly established the Bloomberg
Rockefeller U.S. All Cap Multi-Factor ESG Improvers Index (the
“ESG Improvers Index”). The ESG Improvers Index is a multi-
factor index which combines the Rockefeller ESG Improvers
Score™, an uncorrelated and proprietary ESG factor supplied by
RAM, with quality and low volatility factors from Bloomberg.
Unlike other ESG indices that emphasize screening around ESG
leaders or laggards, this index ranks a company’s improvement
in performance on material ESG issues relative to industry peers
because of the potential that companies exhibiting positive ESG
momentum will become more highly valued in the marketplace.
The ESG Improvers Index seeks exposure to ESG Improvers,
Quality, and Low Volatility attributes with minimal tracking error
and sector deviations relative to the Bloomberg US 3000 Index.
Bloomberg is responsible for calculation, governance, and
provision of the ESG Improvers Index.
Regulatory Assets Under Management
As of December 31, 2023, Rockefeller & Co.’s regulatory assets
under management were:
• Regulatory Assets under Management:
$27,371,518,357
o Discretionary Assets: $25,159,860,967
o Non-Discretionary Assets: $2,211,657,390
The firm’s Regulatory Assets Under Management comprise
assets managed by both the RAM and Global Family Office
divisions of Rockefeller & Co.
