Columbia Cent CLO Advisers, LLC (“Columbia Cent CLO Advisers”) was incorporated in Delaware in August 2020 and
is a subsidiary of RiverSource Life Insurance Company, which owns 100% of the voting interests of the firm. RiverSource
Life Insurance Company is owned by Ameriprise Financial, Inc. (“Ameriprise Financial”). This Brochure describes the
investment advisory services offered by Columbia Cent CLO Advisers and the words “we,” “our,” “us,” “the firm,” “our
firm,” and similar words mean Columbia Cent CLO Advisers. We are providing this Brochure to persons who receive or
who may receive investment advisory services from us in order to ensure compliance with the Investment Advisers Act of
1940, as amended (the “Advisers Act”).
Our General Services
We offer professional advisory services on a discretionary basis and related services including trading, cash management
and reporting. Nearly all of the advisory services we provide involve continuous investment advice based on the stated
investment objectives and policies of each client.
We provide discretionary investment advisory services to our clients, which are pooled investment vehicles (the “Funds” or
the “Clients”) intended for institutional and other sophisticated investors. In certain cases, the Funds will be organized as
issuers of collateralized loan obligations (“CLOs”).
Each CLO issuer issues rated notes (“Senior Notes”) and non-rated notes (“Equity or Sub Notes” - and, together with the
Senior Notes, the “Notes”) pursuant to the terms and conditions of an indenture (“Indenture”). The Senior Notes issued by
each CLO are secured by a portfolio consisting primarily of leveraged loans selected and managed by us. We will provide
investment advisory services to the Clients based on each Client’s specific investment objectives and strategies and will
generally have broad and flexible investment authority with respect to each Client’s investment portfolio. Our advisory
services are generally not tailored to the individual needs of any particular Note holder or investor in a Fund.
Entities managed by us may serve as warehouse or risk retention vehicles for CLOs to accumulate loans intended to be
transferred to a CLO upon its launch. Such entities will be capitalized by third parties, us and/or our affiliates.
As of December 31, 2023, the amount of client assets managed (reported as Regulatory Assets Under Management) on a
discretionary basis was $2,605,013,192.
Offering Brands
In marketing our services to prospective clients, we use Columbia Threadneedle Investments, the global brand of the
Columbia and Threadneedle group of companies.
We may also use various other offering brands. Columbia Management Investments is the operating division within our
affiliate, Columbia Management Investment Advisers, LLC (“Columbia Management”) that we market to institutional
clients. Columbia Management Investments claims compliance with the Global Investment Performance Standards
(GIPS®). In accordance with GIPS®, all fee-paying discretionary (as defined by GIPS®) accounts within Columbia
Management Investments are included in one or more composites that consist of accounts with similar objectives, strategies
and risk tolerances. GIPS® also sets forth requirements for calculating and presenting investment manager performance in
a fair and consistent manner.
Services Provided to Non-U.S. Clients
We may also act as an investment adviser or subadviser and may conduct marketing activity with respect to clients and
prospective clients domiciled in foreign jurisdictions in some instances without maintaining regulatory licenses or
registrations in those jurisdictions to the extent permitted by applicable law. Clients and prospective clients in these
jurisdictions should consider whether the regulatory framework
of their own jurisdiction as it applies to them imposes
restrictions on hiring an investment adviser that does not hold local regulatory licenses or registrations. Clients and
prospective clients should also consider whether the regulatory framework we are subject to provides sufficient protections
given that we may not be subject to the regulatory framework they are familiar with in their own jurisdiction.
Global Asset Management
As we seek to enhance our investment capabilities and the support services provided to our clients, we utilize services from
our U.S. affiliate, Columbia Management, which is owned by Ameriprise Financial. We may also utilize services from other
U.S. affiliates (together with Columbia Management, “U.S. Advisory Affiliates”) and non-U.S. affiliates (“Non-U.S.
Advisory Affiliates” and together with US Advisory Affiliates, “Advisory Affiliates”).
For example, we engage Columbia Management, which is an SEC-registered investment adviser, to provide (jointly or in
coordination with us) services relating to client relations, marketing, investment monitoring, account administration,
investment research, trading and discretionary investment management (including portfolio management and risk
management) to certain of our clients and accounts we manage. In some circumstances, Columbia Management may
delegate responsibility for providing those services to another Advisory Affiliate. Under personnel-sharing and other
arrangements, our personnel may act on behalf of Columbia Management for purposes of providing some of those services
for Columbia Management to its clients, and some of Columbia Management’s personnel may act on behalf of our clients.
Certain of our employees and officers are also officers of certain U.S. Advisory Affiliates, and employees and officers of
our U.S. Advisory Affiliates are also officers of ours.
In addition, Columbia Management provides certain investment-related support services to us, including, but not limited to,
traditional “middle office” and utility functions, such as trade processing, valuation, proxy voting administration and client
reporting. Columbia Management also provides technology, finance, compliance, legal, accounting, marketing and other
resources and services to us.
Potential Conflicts of Interest
As further detailed below under “Methods of Analysis, Investment Strategies and Risk of Loss”, Columbia Management
maintains an internal centralized research function for both equity and fixed-income strategies. Investment research
Columbia Management generates is shared with us and certain of our Advisory Affiliates at the same time that research is
distributed internally at Columbia Management. In connection with the sharing of relevant investment research among our
Advisory Affiliates and, in providing services described above under “Global Asset Management,” investment personnel
may have access to nonpublic holdings information of our clients and certain of our Advisory Affiliates’ clients. Portfolio
managers of those Advisory Affiliates may decide to act on such research before our own portfolio managers do. The sharing
of this information may also lead us and certain of our Advisory Affiliates to place orders in the same securities at the same
or different times, if we and those Advisory Affiliates do not have a collaborative arrangement in place for the relevant
client accounts.
We have adopted policies and compliance controls that seek to ensure that our clients are treated fairly and equitably with
respect to trading and sharing of information among Advisory Affiliates. More information about how we identify, mitigate
and manage conflicts of interest can be found throughout this Brochure, and in particular, under “Our Approach to Conflicts
of Interest” and “Other Conflicts of Interest”.