A. Overview
This brochure relates to the investment advisory services offered by Aegon USA Realty Advisors, LLC, a US-based
investment adviser registered with the Securities and Exchange Commission (“SEC”). Aegon USA Realty Advisors,
LLC utilizes the primary business name Aegon Real Assets US to market its asset management products and
services. Aegon Real Assets US is a limited liability company formed in 2009 under the laws of the State of Iowa.
Aegon Real Assets US is a wholly owned subsidiary of Aegon USA Asset Management Holding, LLC (“AUAM
Holding”), an indirect wholly owned subsidiary of Aegon Ltd.
Aegon Real Assets US is part of a broader investment firm using the brand name Aegon Asset Management.
References to Aegon Asset Management include various affiliated investment advisory, operational, and
distribution business units including Aegon USA Investment Management, LLC (“Aegon AM US”), and Aegon
Asset Management UK plc (“Aegon AM UK”) (formerly known as Kames Capital plc), each an SEC-registered
investment adviser, and various unregistered foreign affiliates (and joint ventures), including, Aegon Asset
Management Pan-Europe B.V., Aegon Asset Management Hungary B.V., Aegon España S.A.U. de Seguros y
Reaseguros, Aegon Industrial Fund Management Co. LTD, Aegon Investment Management B.V. (“Aegon AM
NL”), and La Banque Postale Asset Management S.A.
Though legally distinct, the Aegon Asset Management affiliates function as a global business. Through the use
of distinct investment platforms, Aegon Real Assets US collaborates with various Aegon Asset Management
affiliates to deliver products and services globally. Aegon Real Assets US believes that this structure helps it
better serve its clients’ needs.
For additional information regarding Aegon Real Assets US’ legal and governance structures, refer to Item 10,
Other Financial Industry Activities and Affiliations. Aegon Real Assets US’ principal office is in Cedar Rapids, Iowa,
with other offices in San Francisco, California, and Chicago, Illinois.
Certain Aegon Asset Management affiliates jointly participate in investment platforms. Aegon Real Assets US
engages Aegon AM NL through a participating affiliate arrangement; for more information see Item 10.B.7,
Other Financial Industry Activities and Affiliations - Relationships with Related Persons: Participating Affiliate
Arrangement.
B. Advisory Services & Products
Aegon Real Assets US provides investment advisory services to various Clients (defined below), primarily with
respect to investments in equity and/or debt interests in real estate-related assets, real property, and pooled
investment vehicles (e.g., fund-of-funds structures).
Clients are defined as (1) individual institutional investors and (2) investment vehicles or entities, including
private funds, partnerships, limited liability companies, and joint ventures (each referred to herein generically
as a “Fund” and collectively, the “Funds”).
In providing services to the Funds, Aegon Real Assets US formulates each Fund’s investment objectives and
manages the investment of each Fund’s assets, and provides reports to Investors (as defined below). In this
context, investment advice is provided directly to the Funds and not individually to the limited partners,
members, or shareholders of the Funds (the “Investors”).
Aegon Real Assets US manages the assets of the Funds in accordance with the terms of each Fund’s applicable
confidential offering and/or private placement memorandum, individual limited partnership or shareholder
agreements, and other governing documents applicable to each Fund (the “Governing Fund Documents”).
Approval is generally required of the respective Fund’s Investors for any action that is beyond the guidelines
prescribed in the Governing Fund Documents.
Aegon Real Assets US sponsors a “Tax Credit Equity” platform, also known as Community Investments, that
provides institutional investors with the opportunity to invest in real estate assets that qualify for low-income
housing tax credits (LIHTC), or other forms of tax credits, either indirectly through a fund or joint venture
structure, or directly through separately managed account arrangements (typically for affiliated Clients). Return
on investment occurs through an allocation of tax credits and other tax benefits, and in some cases, cash flow,
generated by the underlying real estate assets. Examples of the types of properties that may qualify for tax
credits include apartment complexes and historic rehabilitation properties. While all investment vehicles within
the Tax Credit Equity platform are named “Funds,” only certain of those Funds are considered to be investment
advisory Clients, while other Tax Credit Equity Funds are considered to be “non-investment advisory” Clients.
For purposes of this Brochure, Tax Credit Equity
Funds means only those Funds that are considered to be
investment advisory Clients.
Aegon Real Assets US’ Real Estate Private Equity platform identifies, selects, and allocates capital to private
equity real estate (including real estate investments in opportunity zones), real property, natural resources, and
energy investments. These investments may be made through direct investments, real estate partnerships, joint
ventures, and fund-of-funds strategies. With respect to fund-of-funds strategies, the underlying Funds typically
will make direct investments in debt and/or equity investments in real property (examples may include real
estate, timberland, wind, solar, oil, and gas investments).
Aegon Real Assets US’ Real Estate Private Equity platform also provides investment advisory advice on a
discretionary basis to separately managed account(s) and private funds related to private equity investments in
real estate, oil, and gas-related assets.
Additional information about Aegon Real Assets US’ investment strategies and services can be found in Item 8,
Investment Strategies, Methods of Analysis, and Risk of Loss.
C. Non-Investment Advisory Services & Products
Aegon Real Assets US also maintains other types of real estate platforms and business units dedicated to
providing various real estate-related products and services. Aegon Real Assets US considers those to be “non-
investment advisory” as Aegon Real Assets US is not providing securities-related investment advice with respect
to those activities. As used hereafter, “advisory” and “investment advisory” refers to those investment advisory
matters within the scope of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and Item
4.B, Advisory Business – Advisory Services & Products, unless otherwise noted. Examples of such non-
investment advisory services and products include, but are not limited to, those described below:
Aegon Real Assets US has a debt platform that originates and services (for institutional lender-investors) real
estate loans, including commercial mortgage loans, agricultural loans, and construction loans. Commercial
mortgage loans include, but are not limited to, conventional and participating loans. Aegon Real Assets US
originates commercial real estate loans on several types of assets, including apartment, retail, office buildings,
and industrial properties, among others. Agricultural mortgage loans primarily finance land-based and
agribusiness operations on a nationwide basis, such as row crops, ranches, permanent plantings, timberland,
and processing and storage facilities.
Aegon Real Assets US has a mortgage loan servicing group that provides to institutional lenders a full array of
traditional mortgage loan services for a variety of commercial, agricultural, and construction mortgage loans.
Aegon Real Assets US is a primary servicer that provides tax and insurance analysis, loan surveillance, portfolio
management, and lease analysis. Aegon Real Assets US also provides comprehensive loan-level and portfolio-
level accounting and reporting.
Aegon Real Assets US has a real estate asset management group that manages equity interests in real estate
acquired by direct investment or by foreclosure of mortgage loans (i.e., real estate owned or “REO”). These real
estate assets are held directly by a Client. Aegon Real Assets US provides acquisition, asset management, and
disposition services for these property investments. Examples of these types of assets may include, but are not
limited to, investments in land, apartments, office buildings, retail space, industrial properties, and other asset
types.
With respect to non-investment advisory services and products, Aegon Real Assets US’ Clients do not receive
the benefit of laws and regulations exclusively applicable to our investment advisory business.
D. Assets Under Management
As of December 31, 2023, Aegon Real Assets US had regulatory assets under management with respect to its
advisory (i.e., securities-related) business (including Tax Credit Equity Funds that are advisory in nature) as
follows:
Regulatory Assets Under Management US Dollar Amount
Discretionary regulatory assets under management: $1,856,440,553
Non - discretionary regulatory assets under management: $41,573,623
Total regulatory assets under management: $1,898,014,176
Additionally, Aegon Real Assets US’ non-advisory, non-regulatory (i.e., non-securities related) assets under
advisement as of December 31, 2023, totaled approximately $18.1 billion. Such assets include mortgage loans,
non-advisory Tax Credit Equity assets, and direct and indirect interests in physical real estate assets.
*Includes assets such as commercial mortgages, reverse mortgages, credit tenant mortgage loans, residential
mortgage loans, and real estate owned in partnership with third parties.