Our Firm
Pacific Investment Management Company LLC (“PIMCO,”
“we,” or “us”) is a leading global investment
management firm founded in Newport Beach, California
in 1971. We are an indirect subsidiary of Allianz SE
(“Allianz”), a global financial services company based in
Germany, although our operations are separate from and
autonomous of Allianz. Please see Appendix A for a list
of PIMCO’s principal owners.
PIMCO’s Global Offices. As a global investment
manager, PIMCO uses the resources of our offices
around the world to provide portfolio management,
research and trading services for client accounts (each, a
“Client” or “Account”). The PIMCO entity with which a
client has contracted supervises any services provided by
one or more of our global offices.
Our People. PIMCO was founded on the philosophy that
hard work, high standards of excellence and the desire to
be the best are critical to our success. Biographical and
other information relating to certain key investment
management personnel is contained in the supplement
to this brochure.
Assets Under Management
As of December 31, 2023, PIMCO managed
approximately $2,615,929,249,500 of regulatory assets
under management and $1,864,964,353,567 of net assets
under management, respectively. For purposes of
calculating our AUM, we included assets that we manage
on behalf of Allianz-affiliated companies as well as the
assets of clients contracted with the non-U.S. investment
advisers affiliated with PIMCO listed in Appendix C (the
“Non-U.S. Advisers”), except PIMCO Prime Real Estate
GmbH, which files reports with the SEC as an Exempt
Reporting Adviser.
Our Services
Our Organization. Since 1971 we have provided
discretionary investment management services to clients
throughout the world. PIMCO began as a manager of
fixed income portfolios and has evolved to include active
management of equities, open-end funds, closed-end
funds (exchange listed funds and interval funds),
exchange traded funds (“ETFs”), collective investment
trusts (“CITs”), private investment funds (such as private
equity-style funds and hedge funds) and structured
products. PIMCO is a provider of solutions services,
offering a menu of sophisticated strategies, analysis and
advice for clients in all types of market conditions. While
these services have greatly evolved over time, one thing
that has not changed is our mission to provide the
highest quality investment management services.
As a leading provider of discretionary investment
management services, PIMCO employs a broad range of
portfolio management tools that seek to appropriately
manage risk, hedge exposures, and seek returns
consistent with Client guidelines. We have considerable
experience in an array of global investment strategies,
which include both fixed income and equity strategies. As
markets evolve we will seek to employ new strategies
and manage new products. Additional information
regarding our strategies, methods of analysis, and the
material risks associated with our significant strategies is
included under Item 8, “Methods of Analysis, Investment
Strategies and Risk of Loss.”
Portfolio Management. PIMCO provides investment
management services to Clients through a global team of
investment professionals.
The investment professionals employed by PIMCO are
devoted primarily to the management of Accounts. Client
portfolio management teams include portfolio managers,
risk managers, research analysts, economists, and others
who assist in the development of investment ideas,
implementation of portfolio strategies and risk analysis.
PIMCO has an Investment Committee comprised of
senior portfolio managers and headed by PIMCO's Group
Chief Investment Officer and Chief Investment Officers.
The Investment Committee determines key portfolio
management strategies. Guided by these key strategies,
individual portfolio management teams then make
investment decisions for their respective Accounts.
Separate Account Management. The client
management team, which acts as the bridge between
PIMCO ADV Part 2A Brochure | 2024 5
separate account Clients (each, a “Separate Account”)
and their PIMCO portfolio managers, is devoted to client
service. One of the advantages of this approach is that it
permits our portfolio managers to concentrate the vast
majority of their time to investment activities. Client
management professionals work closely with the
portfolio management team to implement each Separate
Account’s investment guidelines. Client management
professionals also are responsible for day-to-day
servicing of Separate Accounts and play an integral role
in helping to develop investment ideas and strategies in
conjunction with the portfolio management team.
Business Management. Our business management team
provides the infrastructure for the operation of the firm
and includes the Legal and Compliance, Human
Resources, Operations, Finance, and Technology
Departments. One key function of the business
management team is to manage back-office operations.
We have outsourced certain back-office operations to
State Street Investment Manager Solutions LLC and its
affiliates (together, “SSIMS”), a firm specializing in back-
office trade processing, settlement and accounting
operations. This enables us to focus the majority of our
people and resources on what we do best: managing
investments and servicing clients. SSIMS administers the
following functions, among others, on our behalf,
including, but not limited to: (i) coordinating asset
transitions; (ii) assisting with the maintenance and update
of our security master database; (iii) processing trades;
(iv) communicating trade and settlement directives to the
relevant account’s custodian banks; and (v) facilitating
failed trade and overdraft compensation claims. While
SSIMS provides our back-office services, we actively
supervise all work performed on behalf of our Clients in
connection with these services. PIMCO may in-source or
outsource certain processes or functions in connection
with a variety of services that it provides in its
administrative or other capacities without notice to
Clients. Depending upon the nature of the services and
subject to applicable law and agreements, fees
associated with in-sourced or outsourced services will be
borne by PIMCO or, subject to applicable offering
documents or investment management agreements, a
Client. In addition, PIMCO, and not Clients, could benefit
from certain fee reduction arrangements under certain
such agreements. Please refer to “Payments Made to
Service Providers and Other Third Parties” for additional
information.
Asset Management. PIMCO provides asset management
services related to the post-acquisition and ongoing
management and monitoring of certain investments
through a dedicated team of asset managers. Such
activities include, among others: assisting with asset and
liability servicing, such as seeking to ensure that all
principal and interest is received for loan agreements and
that debt obligations are satisfied; monitoring assets
pledged as collateral for financing; and supporting asset
servicing functions as appropriate. In certain instances,
senior members of the asset management division may
function both as asset managers and portfolio managers.
Non-Discretionary Services. In addition to our
discretionary investment management services, we also
provide non-discretionary investment management and
non-discretionary advisory services certain clients.
Some clients grant PIMCO limited discretion with respect
to the assets in their Account (“Non-Discretionary
Accounts”). For example, a Client may require that
PIMCO seek the Client’s approval prior to any buy or sell
transactions in the Client’s Account. In these instances
our ability to transact on behalf of the Client will be
limited. Therefore, a Non-Discretionary Account may not
be able to obtain comparable discounts that we may
negotiate on aggregated transactions, it may pay higher
transaction costs or brokerage commissions, and we may
be unable to achieve the most favorable execution
depending on the circumstances of the transaction and
the limitations of the Account. Similarly, a Non-
Discretionary Account may not be able to participate in
certain investment opportunities. For these reasons, a
Non-Discretionary Account may achieve lower returns
compared to a comparable Account that grants PIMCO
full discretion. For more information on non-
discretionary Accounts, please see “Potential Conflicts
Relating to Non-Discretionary Advisory Services” in
Item 11.
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Other Services. PIMCO engages in related business
activities, including licensing of intellectual property with
respect to, for example, the development of
methodologies for compiling and calculating a
benchmark index. We license or sell our intellectual
property rights in such methodologies to third parties
who use such methodologies to create and issue
investment products that are based on such indices
and/or correlated to the underlying components of such
indices. We also license or sell our intellectual property
rights in such methodologies to third parties who use
such methodologies to hedge or reinsure such
investment products or develop a benchmark index or
use such methodologies to calculate performance on a
financial product. In certain cases, such third parties pay
us a portion of the subscription or licensing fees they
receive in connection with such indices or a percentage
of the total assets allocated to investment products that
are based on or reference such indices. In connection
with the licensing of our indices, we will in certain cases
receive a fee for entering into certain hedging
transactions on behalf of the licensee of the index (or
another third party) or for permitting third parties to
engage in such hedging transactions.
Other examples of related business activities include,
among other things, entities owned by or otherwise
affiliated with us or owned by certain Clients that we
manage or sponsor, including Clients that are pooled
investment vehicles (“PIMCO Funds” or “Funds”), providing
loan servicing, consulting, legal, accounting, tax, due
diligence, asset management or other services to certain
Clients or portfolio companies or other investments
directly or indirectly owned by such Clients. PIMCO
Aurora LLC (“PIMCO Aurora”), formerly PIMCO Services
LLC, is a wholly-owned subsidiary of PIMCO, and service
provider for certain Clients. For additional information
relating to PIMCO Aurora please see “Payments Made to
Service Providers and Other Third Parties” under Item 5.
Securities Lending. While PIMCO primarily offers
investment management services, we generally do not
enter into securities lending arrangements for our Clients
(other than for the PIMCO Funds). Under typical
securities lending arrangements, a manager loans a
security held in a client’s portfolio to a broker-dealer in
exchange for collateral. This collateral can consist of
either cash collateral or non-cash collateral (i.e., other
securities). The client may earn potentially enhanced
returns from these arrangements by collecting finance
charges on the loan or by reinvesting cash collateral to
earn a positive net return. Such returns are generally
shared between the client and the securities lending
agent, and the risk associated with the investment of
collateral is generally borne by the client.
Some Clients have established separate securities lending
arrangements through their custodian. If a Client has
entered into these arrangements, the Client and its
custodian are responsible for adhering to the
requirements of such arrangements, including ensuring
that the securities or other assets in the Account are
available for any securities lending transactions. We shall
neither have nor accept any liability, authority or power
to determine, or influence the determination, whether to
loan any security in an Account or recall any security that
has been lent from an Account by a Client or a Client’s
custodian. For Accounts that we actively manage, we
execute transactions based on a number of factors,
including market conditions and best execution, and
generally do not consider factors relating to a Client’s
securities lending arrangements, such as whether the
Client’s custodian may need to recall securities on loan to
settle the sales transactions. We have established policies
and procedures in the event there is a loss or overdraft in
connection with a transaction. Please refer to “Claims
Process” in Item 12, which would include any loss relating
to PIMCO’s sale of a security that is not available in an
Account due to such Client’s securities lending activities.
Certain PIMCO Funds engage in securities lending, as
described in their respective offering documents. Please
see “Government and Regulatory Risk” below.
Litigation, Class Actions and Bankruptcies. As an
investment manager, we are asked from time to time to
decide whether to participate in litigation, including by
filing proofs of claim in class actions for assets held in an
Account. As a general matter, it is the Client’s
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responsibility to monitor and analyze its portfolio and
consult with its own advisers and custodian about
whether it may have litigation claims that it should
consider pursuing. Generally, PIMCO cannot, without
express Client written authorization, exercise any rights a
Client may have in participating in, commencing or
defending suits or legal proceedings such as class actions
for assets held or previously held in an Account, although
we do undertake such activities for the PIMCO Funds. In
the case of Separate Account Clients, upon mutual
agreement of PIMCO and the Client and receipt of a
letter of authorization and Power of Attorney, we will
assist Clients or their custodian in assembling transaction
information to file a proof of claim (such as a class action
or bankruptcy claim) on behalf of their Account. When
submitting proofs of claim on behalf of Clients, PIMCO
will not include securities purchased on behalf of a Client
by another investment manager. Further, Clients may be
precluded from filing a direct claim against an issuer
where PIMCO files a proof of claim on behalf of a Client.
Generally, a Separate Account’s custodian should receive
all documents for these matters because the securities
are held in the Client’s name at the custodian and the
Separate Account Client should direct its custodian as to
the manner in which such matters should be handled.
Notwithstanding the above, in connection with
bankruptcies, reorganizations, debt workouts, or other
types of corporate events, PIMCO may, and in some cases
does, enter into documents and take any and all such
actions as may be necessary to facilitate such transactions,
including entering into restructuring support agreements,
transaction support agreements, releases of claims,
providing indemnities, filing proofs of claim, engaging in
or defending litigation including as part of an ad hoc
group or other group, and or otherwise participating in
such transactions, or taking similar actions at our
discretion, where permitted, on behalf of PIMCO Funds
and Separate Accounts in order for those Funds and
Clients to participate (or participate to the extent PIMCO
believes desirable) in the bankruptcy, reorganization or
other corporate event, although we are under no
obligation to do so. Any such action will bind the Client
with respect to the securities or other investments with
respect to which the action was taken. In connection with
such corporate events, PIMCO may (i) accept, receive,
purchase or subscribe for securities or other instruments
(including but not limited to, common stock and/or
private equity) into an Account, and (ii) hold such
securities or instruments for a reasonable time in an
Account, in each case, that may or may not be referenced
or otherwise permitted in an Account’s investment
guidelines, provided such actions are in the best interests
of the Account. In addition, to the extent that a Client
holds assets such as bankruptcy claims, we may, but will
not be obligated to, take such actions as we believe
desirable in order to realize the value of such asset.
Clients that are currently or were formerly investors in,
or otherwise involved with, investments that are the
subject of a legal action may or may not (depending on
the circumstances) be parties to the particular legal
action, with the result that a Client may participate in an
action in which not all Clients with similar investments
may participate. In these instances, non-participating
Clients may benefit from the results of such actions
without bearing or otherwise being subject to the
associated fees, costs, expenses and liabilities. In
connection with these actions, PIMCO Funds and
Separate Account Clients may be sued or otherwise be
named as defendants.
Tailoring Services to Client Needs
Upon selecting an investment strategy, Clients typically
provide PIMCO with specific investment parameters in
the form of investment guidelines. The investment
guidelines may include, for example, restrictions on
investing in certain assets, such as product types, issuers
or securities or transaction types with certain attributes.
The investment guidelines form a part of our investment
management agreement with a Client and we manage
the Account within these confines. Clients should be
aware, however, that certain restrictions can limit our
ability to act and as a result, the Account’s performance
may differ from and may be lower than that of other
Accounts that have not limited our discretion.
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Important Information About Procedures For
Establishing a New Client Relationship
To help the government fight the funding of terrorism
and money laundering activities, federal law requires
certain financial institutions to obtain, verify, and record
information that identifies each Client (and, in the case of
legal entity customers, their beneficial owners) who opens
an Account or establishes a relationship. Accordingly, when
we establish a relationship with a Client, when appropriate,
we ask for the Client’s name, address, and other
information or documentation (e.g., a formation document
or tax document), as well as information about the Client’s
beneficial owners (if applicable), that will allow us to identify
and verify the Client and the source of Client funds that are
being invested. Failure to provide requested information,
either at account opening or during the lifetime of the
account, may result in us declining to open the account, or
freezing or blocking the account.
Wrap and Similar Program Services
PIMCO also offers investment management services
through wrap fee programs (“Wrap Programs”) that are
sponsored by banks, broker-dealers or other investment
advisers (each a “Sponsor”). As a provider of investment
advice under a Wrap Program, PIMCO is responsible for
managing the Account in accordance with the selected
investment strategy and any “reasonable restrictions”
imposed by the Wrap Program Client, and for this service
PIMCO typically receives a portion of the Wrap Program
fee from the Sponsor. PIMCO is generally not responsible
for determining whether a particular Wrap Program,
PIMCO’s investment style or a specific PIMCO strategy is
suitable, appropriate, or advisable for any particular Wrap
Program participant. For these reasons and others, while
a same or similar PIMCO strategy might be available
through a Wrap Program, the management, execution,
performance, and fees for a strategy can and will differ
from other Clients, as discussed in greater detail below.
PIMCO provides investment advice to both discretionary
wrap programs, where PIMCO makes decisions with
respect to the investments and trading in the selected
strategy for the portion of the portfolio PIMCO manages
(“Discretionary Wrap Programs”), and non-discretionary
wrap Programs, where PIMCO provides an investment
allocation to a Sponsor who determines whether and
when to invest and trade (“Non-Discretionary Wrap
Programs”), in each case as discussed in greater detail
below.
Generally, in a typical Wrap Program, each Wrap
Program Client enters into an agreement with a Sponsor,
who provides or arranges for the provision of an array of
services, including some or all of the following: assistance
with establishing client goals and objectives, asset
allocation analysis, security selection and other portfolio
management services, selection of investment advisers,
sub-advisers, custodians and/or broker-dealers, trade
execution and ongoing monitoring, reporting and client
support, which is generally covered by a single “wrap”
fee. Clients access certain Wrap Programs through an
intermediary such as a bank, broker-dealer or other
investment adviser rather than the Sponsor, in which case
the intermediary may provide some, or all, of the
functions otherwise provided by a Sponsor. The services
to be performed by the Sponsor, PIMCO or others in
these Wrap Programs, and related fees, are generally
detailed in the relevant agreements between or among
the Client, the Sponsor, PIMCO and/or any other parties.
With respect to a Sponsor that is a registered investment
adviser, the services provided, and other terms,
conditions and information related to the Wrap Program
are also described in the Wrap Program disclosure
documents and the agreement between the Client and
the Sponsor. Sponsors that are not registered investment
advisers may, but are not required to, provide a similar
Wrap Program disclosure document (each Wrap Program
disclosure document, whether for a registered investment
adviser or another Sponsor, a “Wrap Program Brochure”).
All Wrap Program Clients and prospective Wrap Program
Clients should carefully review the terms of the agreement
with the Sponsor and the relevant Wrap Program Brochure
to understand the terms, services, minimum account size
and any additional fees or expenses that are associated
with a Wrap Program account.
PIMCO makes available through Wrap Programs certain
of the same or similar strategies that are available to
PIMCO ADV Part 2A Brochure | 2024 9
institutional clients or through Funds; however, not all of
PIMCO’s strategies are available through Wrap Programs
and not every PIMCO strategy that is available through a
particular Wrap Program will be available through other
Wrap Programs. Further, the manner in which PIMCO
executes a strategy through Wrap Programs may differ
from how that same or a similar strategy is executed
through another Wrap Program or for a Fund or
institutional Client. For instance, the execution of a
particular strategy in a Wrap Program may differ from
the execution of the same or a similar strategy for a Fund
or institutional Client due to the need to adhere to
“reasonable restrictions,” as discussed below, imposed by
the Wrap Program Client or due to the use of affiliated
no-fee registered investment companies or other
affiliated commingled vehicles rather than individual
securities. Accordingly, the performance of a strategy
available through a Wrap Program may differ from the
performance of the same or a similar strategy that is
executed through another Wrap Program or for a Fund
or institutional Client.
As a provider of investment advice under a Wrap
Program, PIMCO is generally not responsible for
determining whether a particular Wrap Program,
PIMCO’s investment style or a specific PIMCO strategy is
suitable, appropriate or advisable for any particular
Wrap
Program Client. Rather, such determinations are
generally the responsibility of the Sponsor and the Client
(or the Client’s financial advisor and the Client) and
PIMCO is responsible only for managing the Account in
accordance with the selected investment strategy and
any “reasonable restrictions” imposed by the Wrap
Program Client. In the course of providing services to
Wrap Program accounts advised by a financial advisor,
PIMCO generally relies on information or directions
communicated by the financial advisor acting with
apparent authority on behalf of its client. PIMCO reserves
the right, in its sole discretion, to reject for any reason
any Wrap Program Client referred to it.
PIMCO may from time to time engage one or more
third-party investment advisers to provide sub-advisory
services to PIMCO for certain strategies that are offered
to Wrap Program Clients. PIMCO (and not the Client) will
be responsible for compensating any such sub-adviser.
In particular, PIMCO has entered into agreements with
Research Affiliates, LLC (“RA”) to develop and offer
multiple PIMCO products, including strategies available
in Wrap Programs (“RA Strategies”) for which PIMCO
serves as investment adviser and RA as sub-adviser.
PIMCO expects that such RA Strategies will be
implemented through a third-party sub-adviser engaged
by PIMCO. The terms of PIMCO’s agreements with such
sub-advisers and/or RA create economic disincentives for
PIMCO to terminate or recommend the termination of
such sub-advisers or RA.
“Reasonable restrictions” imposed by a Wrap Program
Client serve to limit PIMCO’s freedom of action with
respect to an Account and, as a result, the performance
of Accounts for which such investment restrictions are
imposed will differ from, and may be worse than, the
performance of Accounts within the same strategy that
do not have such restrictions.
For its services, PIMCO typically receives a portion of the
wrap or other fee paid to the Sponsor, or is paid a fee by
the Wrap Program Client. For a further discussion of the
nature of Wrap Program arrangements, including the
fees charged by the Sponsor and paid to PIMCO, see
Item 5, Fees and Compensation, Wrap Programs.
Typically, the investment management services we
provide in connection with these Wrap Programs are
discretionary. In Discretionary Wrap Programs, PIMCO is
generally responsible for causing the portion of each
Discretionary Wrap Program Client’s Account that is
managed by PIMCO to engage in transactions that are
appropriate for the selected strategy. Wrap Program
Accounts within a particular strategy are generally
managed similarly, subject to a Wrap Program Client’s
ability to impose reasonable restrictions (such as a
prohibition on holding the securities of a particular issuer
within the Wrap Program Client’s Account). Because
PIMCO’s advisory services to these Accounts are
strategy-dependent, PIMCO will not accept a restriction
that PIMCO believes would be inconsistent with the
applicable investment strategy.
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PIMCO participates in Wrap Programs, which may be
sponsored by affiliates or unaffiliated third parties.
PIMCO generally does not compensate Sponsors for
PIMCO’s inclusion in a Wrap Program or for
introductions of Clients through a Wrap Program,
although PIMCO makes payments to some Sponsors
related to set-up, support, maintenance, servicing,
account services and other costs. Such Sponsors may
have an incentive to recommend PIMCO’s services over
the services of another manager. The portion of the total
wrap fee paid to PIMCO by certain Sponsors includes
breakpoints reducing the effective fee rate payable to
PIMCO and thus increasing the amount retained by the
Sponsor at higher asset levels. These fees paid to PIMCO
by such Sponsors may be negotiable, with the
relationship size being a factor in negotiation. Affiliated
Sponsors, if any, will have an incentive to recommend
PIMCO’s services over the services of unaffiliated
managers. Sponsors may apply different methods of
analysis, use different types of information or apply
different thresholds in determining whether to
recommend an affiliated manager than are applied when
recommending an unaffiliated manager.
Depending upon the particular Wrap Program, accounts
may be funded with cash and/or securities. Restrictions
as to funding with securities in-kind are described in the
relevant Wrap Program brochure and may include certain
securities or types of securities that will be liquidated by
PIMCO or the Sponsor. Under normal circumstances,
Accounts will generally be fully invested in accordance
with the relevant investment strategy within 90 days of
PIMCO commencing management of the Account. To the
extent that an account is funded with portfolio securities
rather than solely cash, implementation may be further
delayed because any in-kind contributions that are not
consistent with the intended investment strategy for the
Account will be liquidated at the Wrap Program Client’s
risk and expense and without taking into account any
adverse tax consequences to the Wrap Program Client.
While the Sponsor is responsible for most aspects of the
relationship with a Wrap Program Client, our personnel
who are knowledgeable about the Wrap Program Account
and its management will be reasonably available to Wrap
Program Clients for consultation (either individually or in
conjunction with Sponsor personnel), upon a Wrap
Program Client’s request, as required by applicable law or
as agreed between PIMCO and the Sponsor. Because the
Sponsor is generally responsible for reports to Wrap
Program Clients, typically we will supply the Sponsor with
information necessary for the Sponsor to provide such
reports directly to Wrap Program Clients. Upon request or
as agreed with a Sponsor, we may provide investment
holdings, transactions, and performance reports directly to
Discretionary Wrap Program Clients on a periodic basis.
Moreover, with respect to each Discretionary Wrap
Program Client, PIMCO reviews each managed portfolio
periodically to ensure it is managed in accordance with the
applicable investment objectives, guidelines and
restrictions.
In addition, PIMCO may be engaged as a sub-adviser by
other investment advisers to manage client accounts
outside of a Discretionary Wrap Program (“Direct
Managed Account”).
For certain cash management purposes (including but
not limited to the investment of cash balances, to
maintain exposure pending available investment
opportunities, or to maintain exposure during Sponsor-
or Client-directed tax selling) or as otherwise directed by
Sponsor or the Client, PIMCO may utilize a variety of
security types, including U.S. Government bonds, money
market funds, and, upon the Client’s authorization, the
PIMCO Ultra Short Government Active ETF (the “PIMCO
ETF”). To the extent a Sponsor or Client has provided
such authorization and the Client’s Account invests in the
PIMCO ETF, the Client will bear the fees and expenses of
the PIMCO ETF in addition to the fees and expenses the
Client pays to PIMCO for the management of the Client’s
Account. The PIMCO ETF’s fees include fees that are paid
to PIMCO for services PIMCO provides to the PIMCO ETF.
PIMCO does not expect to consider any ETFs managed
by other managers for cash management purposes
where the Client or Sponsor has authorized PIMCO to
invest in the PIMCO ETF for such purposes. The Client
and/or the Sponsor may select another investment
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vehicle or account for cash management purposes at any
time and neither the Client nor the Sponsor is required to
select the PIMCO ETF.
With respect to Discretionary Wrap Programs and Direct
Managed Accounts, PIMCO has entered into an
arrangement with SEI Global Services, Inc. (“SEI”) under
which SEI performs certain administrative and
operational functions, such as accounting, reconciliation,
trade settlement, recordkeeping, billing and reporting.
Typically, these services are paid for by PIMCO and not
the Discretionary Wrap Program Clients.
In addition to the advisory services we provide in the
Discretionary Wrap Programs, we also provide non-
discretionary investment management services to
Sponsors who exercise investment discretion. In Non-
Discretionary Wrap Programs, we typically provide a
model portfolio (which includes allocations to direct
investments or to PIMCO Funds, and may include third-
party funds, or a combination thereof in PIMCO’s
discretion) to be analyzed and implemented by the
Sponsor or another manager at the Sponsor’s discretion.
Further, in Non-Discretionary Wrap Programs, the
Sponsor or other manager is typically responsible for
applying any client-imposed restrictions to the model
portfolio. In certain Non-Discretionary Wrap Programs,
the Sponsor who exercises investment discretion may
direct PIMCO to place orders for the execution of
purchase and sale transactions for Wrap Program Client
portfolios. In such case, trades for the Wrap Program
Client will typically occur after trades placed for non-
wrap Accounts, potentially resulting in inferior execution
for Wrap Program Clients. Similarly, for Non-
Discretionary Wrap Program Clients, to the extent PIMCO
does not have trading authority, it is likely that a Sponsor
will execute trades after PIMCO has made similar trades
for its non-wrap Clients and such execution may be
impacted by PIMCO’s execution.
Stable Value Investment Management Services
PIMCO offers a wide variety of stable value services,
including 1) full-service stable value management, in
which PIMCO handles all aspects of the stable value
investment strategy; 2) investment-only fixed income
management where PIMCO is hired directly by plan
sponsors to manage their stable value portfolio; or 3)
fixed income sub-advisory services whereby PIMCO is
hired by other stable value managers and insurance
companies to manage all or a portion of the assets of a
fixed income portfolio. PIMCO manages Separate
Account portfolios for large institutional defined
contribution plans as well as a stable value commingled
vehicle for the small-and mid-sized defined contribution
marketplace.
Model Portfolios
PIMCO develops and maintains model portfolios (“Model
Portfolios”) that are typically comprised of PIMCO Funds,
including ETFs, but may be comprised of separately
managed accounts managed by PIMCO or a third party,
or pooled investment vehicles managed by a third party,
or indices administered by a third party, or a portfolio of
securities (collectively, “underlying investments”). These
Model Portfolios are licensed or otherwise made
available (including through Non-Discretionary Wrap
Programs) to third party managers and intermediaries.
Such firms may use Model Portfolios as investment
strategies for managing their underlying clients’
accounts. The Model Portfolios seek to provide exposure
to investment strategies that collectively reflect PIMCO’s
investment outlook. Model Portfolio allocations are
based on what PIMCO believes to be generally accepted
investment theory. As further described below, a variety
of factors influence the inclusion or exclusion of an
underlying investment in a Model Portfolio. In adjusting
Model Portfolios, PIMCO considers, among other things,
the results of quantitative modeling. Such quantitative
modeling is designed to optimize each Model Portfolio’s
allocation and align with the Model Portfolio’s
investment objective and internal PIMCO guidelines, and
takes into account various factors or “inputs”, determined
by PIMCO, including third party data, to generate a
suggested allocation for the Model Portfolios. PIMCO’s
investment team then reviews the quantitative output
and adjusts the output to reflect variables, which may
include, among other things, the anticipated trade size,
and qualitative investment insights. PIMCO Model
PIMCO ADV Part 2A Brochure | 2024 12
Portfolio allocations are ultimately subject to the
discretion of PIMCO’s investment team. Model Portfolio
allocations are not based on any particular investor’s
financial situation, or need, although, in some instances a
Model Portfolio may be designed or modified to meet
certain investment guideline parameters of third party
platforms on which the Model Portfolio(s) may be made
available and, unless specifically stated otherwise, are not
intended to be, and should not be construed as, a
forecast, research, investment advice or a
recommendation for any specific PIMCO or other
strategy, product or service.
The risks of a Model Portfolio allocation depend on the
risks of the underlying investments represented in the
Model Portfolio allocation. Please refer to Item 8 for a
broader discussion of material risks. The Model Portfolio
allocation is also subject to the risk that the selection of
the underlying investments and the allocation and
reallocation of the Model Portfolio allocation’s assets
among the various underlying investments might not
produce the desired result. Model Portfolios are
constructed in reliance on forward-looking assumptions,
forecasts, and estimates, and, as a result, Model
Portfolios do not fully reflect the impact that material
economic and market factors might have had on
PIMCO’s decision making if PIMCO had actually
managed a portfolio with assets pursuant to the Model
Portfolio since its inception; Model Portfolios also do not
reflect the impact of future material economic and
market factors not available at the time of allocation. The
allocations to underlying investments in a Model
Portfolio have changed over time and may change in the
future. As described above, the selection and weighting
process across underlying investments is partially
informed based on return estimates driven by PIMCO’s
Systems, as discussed further in Item 8, Quantitative
Investing Risk. These Systems rely heavily on the use of
proprietary and nonproprietary data, software, hardware,
and intellectual property, including data, software and
hardware that may be licensed or otherwise obtained
from third parties. The use of such Systems has inherent
limitations and risks. Although PIMCO takes reasonable
steps to develop and use Systems appropriately and
effectively, there can be no assurance that PIMCO will
successfully do so. Errors may occur in the design,
writing, testing, validation, maintenance, monitoring,
and/or implementation of Systems, including in the
manner in which Systems function together. The
effectiveness of Systems may diminish over time,
including as a result of market changes and changes in
the behavior of market participants or based on how
such Systems are applied. The quality of the resulting
analysis, including the Model Portfolio allocations,
depends on a number of factors including the accuracy
and quality of data inputs into the Systems, the
mathematical and analytical assumptions and
underpinnings of the Systems’ coding, the accuracy in
translating those assumptions into program code or
interpreting the output of a System by another System in
order to facilitate a change in market conditions, the
successful integration of the various Systems into the
portfolio selection and trading process and whether
actual market events correspond to one or more
assumptions underlying the Systems. Please refer to
“Quantitative Investing Risk” in Item 8, which discusses
the reliance on Systems and that Systems are subject to
errors and/or mistakes (“System Incidents”) that may
adversely impact Accounts.
PIMCO does not recommend or select money market or
other cash-equivalent sweep vehicles for purposes of
implementation of such cash allocations, which shall be
the responsibility of the implementing investment
professional. Information about Model Portfolios is made
available on certain financial intermediary and other
platforms and is updated periodically in accordance with
the Model Portfolio’s defined production schedule and
with the overriding objective of achieving fair and
equitable treatment of investor accounts over time. With
respect to Model Portfolios, under normal circumstances,
platforms will receive notice of updated model
allocations within a 24-hour period and are expected to
execute trades on the same business day of receipt or
prior to market open on the advised trade date. For
Model Portfolios that hold ETFs, under normal
circumstances, platforms will receive updated model
allocations after market close on the business day
PIMCO ADV Part 2A Brochure | 2024 13
preceding the anticipated trade date or prior to market
open on the anticipated trade date. In the event that a
particular platform’s business needs require updated
allocations to be delivered during a pre-specified window
that falls outside of the delivery window described in the
preceding sentence, PIMCO will make reasonable efforts
to work with those platforms to deliver updated
allocations within such timeframe. In connection with
the Model Portfolios, Market Street Advisor, Inc., (d/b/a
Archer) performs certain administrative and operational
functions, including the dissemination of updates to the
Model Portfolios to platforms. Any investment in an
investment company will be subject to the terms and
conditions of the investment company’s prospectus.
The investment results achieved by a Model Portfolio at
any given time, including for the same or similar
investments, could and will differ from the investment
results achieved by other PIMCO Funds or Accounts for
which PIMCO acts as investment adviser, including Funds
or Accounts with names, investment objectives,
benchmarks, policies and/or portfolio management
teams similar to the Model Portfolio. There is no
guarantee that the use of a Model Portfolio will result in
effective investment outcomes. In addition, PIMCO
cannot guarantee the availability for purchase of any
Fund or investment product, as applicable, at any
particular time or, to the extent a Model Portfolio
includes an allocation to ETFs, that an active trading
market for ETF shares will develop or be maintained or
that their listing will continue or remain unchanged.
Model Portfolios are developed in part on the basis of
historical data regarding particular economic factors and
securities prices that may be ineffective as a result of
changes in the market and/or changes in the behavior of
other market participants.
For certain financial intermediaries who receive or whose
clients receive Model Portfolios, PIMCO may make
payments to such intermediaries related to set-up,
maintenance, servicing, marketing, support, or other
costs. Financial intermediaries who receive such
payments have an incentive to recommend PIMCO’s
Model Portfolios over other managers’ model portfolios,
which creates conflicts for the recipients(s) of such
payments.
Model Portfolios are provided “as-is,” and PIMCO makes
no express or implied warranties of merchantability,
suitability or fitness for a particular purpose or use.
Although PIMCO takes reasonable steps to develop
Model Portfolios, there can be no assurance that PIMCO
will successfully do so. Errors may occur in the design,
testing, validation, monitoring, maintenance,
transmission or implementation of Model Portfolios.
PIMCO generally does not classify errors and/or mistakes
that it may make in connection with a Model Portfolio to
be Trade Errors (as defined below) and PIMCO is not
responsible for losses associated with errors and/or
mistakes related to a Model Portfolio.
Certain Model Portfolios are expected to consist of a
portfolio of securities. Such Model Portfolios may be
used by PIMCO to manage Funds and Accounts at the
same time such Model Portfolios are provided to
intermediaries. It is expected that intermediary firms
could be provided updates to such Model Portfolios
and/or implement updates to such Model Portfolios
subsequent to PIMCO implementing updates to such
Model Portfolios for Funds or Accounts. Accordingly,
PIMCO Funds or Accounts that follow a Model Portfolio
may be competing for applicable investment or
disposition opportunities with accounts managed by
financial intermediaries who receive Model Portfolio
information. Transactions ultimately placed by such
intermediaries for their investors or by the Funds or
Accounts may be subject to price movements,
particularly with large orders relative to the given
security’s trading volume, that may result in execution
prices that are less favorable. Further, while PIMCO takes
reasonable steps in an effort to mitigate the market
impact caused by transactions for accounts over which
PIMCO has investment or trading authority, because
PIMCO does not control the intermediary’s execution of
transactions for its clients, PIMCO cannot control the
market impact of such transactions to the same extent
that it may be able for accounts over which PIMCO has
trading authority. Such intermediaries are expected to
PIMCO ADV Part 2A Brochure | 2024 14
have sole authority and responsibility for the selection of
broker-dealers and the execution of transactions for their
client accounts. PIMCO is not responsible for placing
orders for the execution of Model Portfolio transactions
involving assets of such intermediary client accounts or
for giving instructions to the intermediary with respect
thereto.
Customized Target Date Strategy
PIMCO provides a customized target date service,
myTDFTM, to participating retirement plans. The myTDF
service incorporates certain demographic factors, which
may include an individual’s age, salary, assets, savings
rate, and/or company retirement plan match rate, to seek
to assign more personalized investment allocations for
plan participants of retirement plans that use the myTDF
service. Under the myTDF service, PIMCO uses its
proprietary methodology (referred to as the “engine”) to
construct various portfolios that include PIMCO-advised
CITs (each a “myTDF Portfolio” and collectively, “myTDF
Portfolios”) and to assign a plan participant to a myTDF
Portfolio based on his or her demographic factors. The
engine constructs myTDF Portfolios based on
quantitative and qualitative data relating to various risk
metrics, long-term market trends, correlation of asset
types and actuarial assumptions of life expectancy and
retirement, and then seeks to assign a plan participant to
one of those myTDF Portfolios based on the plan
participant’s individual demographic factors noted
above. The engine is hosted by a technology provider,
who is responsible for the operation of the engine and
hosting the engine on the technology provider’s
platform. Participating retirement plan recordkeepers
(“Plan Providers”) have access to the myTDF service
through the technology provider’s platform. Pursuant to
an automated process, the technology provider’s
platform provides Plan Providers an interface so that the
Plan Provider may provide participant data to be
inputted into the engine, and place trade transactions to
implement the myTDF service for plan participants. Plan
participants should review the documentation provided
by their plan sponsor for more information about the
myTDF service. In addition to the foregoing, PIMCO
offers non-discretionary target date services for
retirement plans. Under these arrangements, PIMCO
licenses to an investment manager PIMCO’s proprietary
methodology for assigning a portfolio that includes
PIMCO-advised CITs to a plan participant. This
investment manager is responsible for implementing the
methodology for plan participants, and PIMCO has no
discretion related to the management of such plan
participant accounts. Use of these non-discretionary
services are subject to the risks described under “Model
Portfolios” above.