Intech Investment Management LLC

Item 7 – Types of Clients                                   estimating diverse alpha sources, optimizing portfolio
                                                            target weights, and systematically rebalancing to
Intech provides investment advisory services to             capture trading profit. Each portfolio is systematically
institutional investors, including pension and profit-      rebalanced using a methodology that implements the
sharing plans, Taft-Hartley plans, sovereign wealth         target weights, based on current liquidity conditions,
funds, and global funds such as UCITS. Intech serves        client directives, etc.
these clients through separate accounts and pooled
investment vehicles and acts as sub-adviser to              Intech offers institutional investors enhanced equity
registered investment companies and as investment           and active equity strategies that aim to manage active
manager to certain private funds.                           risk, and defensive equity and alternative equity
                                                            strategies that aim to manage absolute risk, each of
The minimum account varies by product and account           which is engineered with risk controls and optimization
vehicle, i.e., separate or commingled account, selected     parameters specific to the strategy’s underlying
by the client. Intech accepts accounts below the            benchmark index and level of aggressiveness.
minimum if special circumstances are warranted. For
example, Intech may allow an existing client with           Risk management is an important component of
multiple accounts above the minimum to open another         Intech’s portfolio construction and monitoring process.
account below the minimum account size. Intech, in its      The enhanced equity strategies seek to control active
sole discretion, reserves the right to decline any          risk tightly and provide a higher excess return after
account or close any account that falls below the           fees than its equity benchmark. The active equity
minimum account size.                                       strategies seek to provide a higher active risk and
                                                            excess return after fees than enhanced equity
                                                            strategies. Defensive equity strategies focus on
Item 8 – Methods of                                         managing absolute risk relative to equity markets,

Analysis, Investment                                        seeking upside return participation and downside
                                                            protection. Alternative equity strategies seek to
Strategies, and Risk of Loss                                manage absolute risk and provide positive absolute
                                                            returns, with low correlation to traditional, long-only,
As explained in Item 4 - Advisory Business, Intech’s
                                                            equity exposure. Risk controls do not promise any level
investment philosophy is focused on providing a
                                                            of performance or guarantee against loss of principal

and there can be no guarantee that Intech’s                    correlation to the benchmark index. Depending on the
mathematical investment process will achieve the               client’s country of domicile, sometimes there are
desired results.                                               government or regulatory limitations on investments in
                                                               certain securities, which affect Intech’s ability to invest
From time to time, Intech makes enhancements to its            in such securities.
mathematical investment process, or develops new
products as a result of ongoing research. New products         Risk of Loss
that are developed or enhancements to existing
products must have a solid theoretical basis and               There are inherent risks associated with investing in
undergo rigorous testing before they are implemented           securities markets. Investing in securities involves a
or offered. Depending on the nature of the                     risk of loss that clients should be prepared to bear. The
enhancement, it may not be applied to, or affect, all          risks will vary based on the nature and attributes of
products or underlying clients.                                the relevant investment strategy and the specific
                                                               securities and other instruments held. There is no
Portfolios are generally fully invested at all times in        performance guarantee associated with investing in
common stocks, with the remainder in cash and cash             any Intech investment strategy. There can be no
equivalents necessary to support client cash flows and         assurance that the investment objectives associated
prevent overdrafts. In limited circumstances, and only         with any Intech strategy will be met.
to the extent necessary, Intech invests in non-affiliated
exchange traded funds for client accounts to gain              Intech’s products are designed for long-term investors
exposure to a specific index or in cases where cash            seeking exposure to portfolios of equity securities. As a
holdings are above the normally held level.                    result, portfolios are subject to the risks of the equity
                                                               markets. The value of investments in equity securities
Expected turnover varies according to the product              may experience sudden, unpredictable declines, as
selected. A higher portfolio turnover rate increases           well as extended periods of underperformance in
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