ROCKEFELLER CAPITAL MANAGEMENT L.P.

The advisory business involves Private Advisors who guide clients in defining their goals, objectives, and risk tolerances. Based on these parameters, an asset allocation framework is developed, and strategic and tactical advice is provided. Private Advisors offer recommendations on various products, including equity securities, fixed income products, investment managers, mutual funds, exchange-traded funds, and alternative investments like structured products and variable annuities. Clients receive account statements from their Custodian to ensure alignment with their investment parameters. The firm also utilizes the Rockefeller Private Wealth Advisory Program, a wrap fee program sponsored by Rockefeller Financial, LLC. Private Advisors' compensation arrangements, including asset-based cash bonuses, create conflicts of interest. The firm addresses these by imposing suitability requirements, maintaining a supervisory system with surveillance reviews, periodic supervisory visits, compliance inspections, and audits, and adhering to fiduciary obligations. Under Investment Consulting Arrangements, clients are responsible for instructing their broker-dealer or bank custodian for securities transactions, though the Global Family Office may assist. The Global Family Office does not guarantee the best price on transactions and considers benefits received by the Global Family Office when recommending broker-dealers, with these conflicts being disclosed to clients.

The investment advisory process begins with Private Advisors helping clients define their goals, objectives, and risk tolerances. Based on these agreed-upon investment parameters, a Private Advisor develops or refines an asset allocation framework, provides strategic and tactical asset allocation advice, and recommends a variety of products. These products can include equity securities, fixed income products, investment managers, mutual funds, exchange-traded funds, and alternative investments such as structured products and variable annuities. Investment strategies are utilized by Private Advisors, investment managers, and investment vehicles to manage client accounts, and these strategies carry specific risks associated with various types of investments. The firm performs due diligence on select investment managers and strategies, reviewing factors like the investment manager’s style, philosophy, personnel, past performance, risk, and style drift. Clients have access to a wide variety of investment managers and strategies, though some may not be available due to reasons such as platform accessibility, client demand, or due diligence and capacity considerations.

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