Cohen & Steers is a global investment manager specializing in real assets and alternative income, including real
estate, preferred securities, infrastructure, resource equities, commodities, as well as multi-strategy solutions.
Headquartered in New York City, with affiliate offices in London, Dublin, Hong Kong, Tokyo, and Singapore. Cohen
& Steers serves institutional and individual investors through a wide range of investment products and services,
including separately managed accounts, registered funds in the U.S. and Europe, private funds, and the Non-
Traded REIT, which is a “perpetual life” real estate investment trust, which is not listed or traded on a public stock
exchange or other securities market. References herein to the Non-Traded REIT are inclusive of affiliated entities
within its overall structure.
The parent company of Cohen & Steers is Cohen & Steers, Inc., a public company in which founders Martin Cohen
and Robert Steers and their respective family members together have a substantial interest. Cohen & Steers
Capital Management, Inc. registered with the SEC as an investment advisor in July 1986. As of December 31, 2023,
Cohen & Steers, together with its affiliates, managed $83,136,000,000 (rounded to the nearest million) in client
assets.1
Cohen & Steers provides discretionary investment advisory and portfolio consulting services to clients pursuant to
written agreements. The terms of such services, including any restrictions on investments, are established by
Cohen & Steers after negotiations with clients and are set forth in the agreement and/or any offering documents,
organizational documents, and/or other documentation applicable to certain investment vehicles. Cohen & Steers
has standard guidelines that can be customized in certain situations. Examples of customization include the use of
a benchmark different from that of the strategy’s standard benchmark or the exclusion of specified securities from
a client’s portfolio.
Cohen & Steers also provides its discretionary investment advisory services to separately managed account
programs, which include programs sometimes referred to as “wrap fee programs,” sponsored by unaffiliated
banks, broker-dealers and other investment advisors (“SMA Program Sponsors”) either through the SMA Program
Sponsor (this agreement referred to herein as a “Single Contract SMA”) or with both the SMA Program Sponsor
and SMA Program Participants (this agreement referred to herein as a “Dual Contract SMA”) depending on the
program (collectively the “SMA Program”). In addition, Cohen & Steers provides investment advice to overlay
managers (“UMA Program Sponsors”) through model investment portfolios or unified managed account programs
(“UMA Portfolio Programs”). Cohen & Steers’ participation in SMA Programs and UMA Portfolio Programs is
collectively referred to herein as the “Managed Account Programs”. Participants in Managed Account Programs
are referred to herein as “Participants”.
Cohen & Steers may make available through the Managed Account Programs the same or similar strategies that
are available to institutional clients or applicable fund products. The manner in which Cohen & Steers executes a
strategy through each Managed Account Program may differ from how that same or a similar strategy is executed
through another Managed Account Program, for applicable fund products or
for an institutional client. Not all of
Cohen & Steers’ strategies are available through Managed Account Programs, and not every Cohen & Steers
strategy that is available through a particular Managed Account Program will be available through other Managed
Account Programs.
When Cohen & Steers provides investment advisory services to SMA Programs, Cohen & Steers typically receives
a portion of the fee charged to SMA Program Participants by the SMA Program Sponsor, though Cohen & Steers
1 Discretionary assets under management (rounded to the nearest million) were $78,354,000,000. Non- discretionary assets under management (rounded to the nearest
million) were $4,782,000,000. Non- discretionary assets under management are not included in the calculation of our regulatory assets under management in Part 1A, Item
5.F of Form ADV. Regulatory assets under management are reported in Part 1A, Item 5.F of Form ADV.
may receive a fee directly from the Participant. Similarly, when Cohen & Steers provides investment advisory
services to a UMA Portfolio Program, Cohen & Steers receives a portion of the fee charged by the UMA Program
Sponsor to UMA Portfolio Program Participants.
There are several notable differences between a UMA Portfolio Program and a SMA Program. In a UMA Portfolio
Program, the UMA Program Sponsor generally determines which security suggestions provided by Cohen &
Steers will be executed for the Participant. However, in a SMA Program, Cohen & Steers (not the SMA Program
Sponsor) directs what securities transactions will be executed on behalf of the SMA Program Participant.
Additionally, Cohen & Steers may allow SMA Program Participants to restrict investments in certain types of
securities. Cohen & Steers is not aware of, nor does it control, any restrictions permitted or implemented by a
UMA Program Sponsor.
The services to be performed by the SMA Program Sponsor or UMA Program Sponsor, Cohen & Steers or others
in these Managed Account Programs, and related fees, are generally detailed in the relevant agreements between
or among the Participant, the SMA Program Sponsor or UMA Program Sponsor, as applicable, Cohen & Steers,
and/or any other parties. With respect to a SMA Program Sponsor or UMA Program Sponsor that is a registered
investment advisor, the services provided and other terms, conditions and information related to the Managed
Account Program are also described in the Managed Account Program disclosure documents. SMA Program
Sponsors or UMA Program Sponsors that are not registered investment advisors may, but are not required to,
provide a similar Managed Account Program disclosure document. All Participants and prospective Participants
should carefully review the terms of the agreement with the UMA Program Sponsor or SMA Program Sponsor, as
applicable, and the relevant Managed Account Program disclosure document (the “Managed Account Program
Brochure”) to understand the terms, services, minimum account size and any additional fees or expenses that may
be associated with a Managed Account Program account.
In addition, with respect to the SMA Programs, Cohen & Steers has entered into an arrangement with a third-
party service provider, under which such provider performs certain administrative and operational functions.
Typically, these services are paid for by Cohen & Steers, not the SMA Program Participant.