Background
Vaughan Nelson is a Houston-based investment counseling firm established in 1970 and is a
wholly-owned affiliate of Natixis Investment Managers, LLC. The Firm, staffed by experienced,
research-oriented investment professionals, has over 53 years of providing comprehensive equity
and fixed income investment advice to taxable and tax-free clients including foundations,
endowments, corporations, pensions, public entities, insurance companies, mutual funds and high
net worth individuals. The Firm expanded its equity capability to include International/Global
investing in October 2019 with a team located at 180 N. Stetson Avenue, Suite 5525, Chicago, IL
60601. The Firm’s sole focus is providing investment management services for equity and fixed
income portfolios totaling ~$16.4 billion as of 12/31/2023.
Ownership
Vaughan Nelson is wholly-owned by Natixis Investment Managers, LLC, which, following a
modification in corporate structure that took place in January 2024, is a subsidiary of Natixis
Investment Managers, an international asset management group based in Paris, France, that, in
turn, is owned by Natixis, a French investment banking and financial services firm. Natixis is
wholly owned by BPCE, France’s second largest banking group. Vaughan Nelson operates
autonomously and provides investment management services independently with its own research,
investment team and trading. The modification in corporate structure mentioned above was the
merger of Natixis Investment Managers, LLC into Natixis Investment Managers U.S. Holdings, LLC
and the subsequent name change of the holding company to "Natixis Investment Managers, LLC."
The internal reorganization did not change the ultimate parent of Vaughan Nelson or the identity
and responsibilities of, or services provided by, either Vaughan Nelson's or Natixis Investment
Managers, LLC's personnel.
Primary Business
The primary business of Vaughan Nelson is the management of client assets in equity and/or fixed
income securities on an ongoing, continuous basis. Normally, Vaughan Nelson is engaged by clients
(both institutional and individual) to provide investment management services for their own
account separate from other clients (a “separate account”) where investment decisions are
implemented on a fully-discretionary basis in accordance with the client’s guidelines and
restrictions. At or before the time that Vaughan Nelson begins managing a separate account,
Vaughan Nelson meets with the prospective client and/or consultant to assess the prospective
client’s investment objectives and risk tolerances. Vaughan Nelson endeavors to tailor its advisory
services to the individual needs of clients within the acceptable limits of the selected investment
strategy, as documented in the client’s advisory agreement. Clients may impose restrictions on
investing in certain securities or types of securities, including securities falling into any of twelve
(12) available Socially Responsible Investing (“SRI”) categories. Vaughan Nelson utilizes and relies
on a third-party firm’s SRI screening and criteria and the application of that criteria in identifying
companies/securities falling into each category. Vaughan Nelson’s SRI screening process is
different from its general Environmental, Social, and Governance (“ESG”) approach (as discussed in
Item 8 below) in that SRI is designed only to eliminate certain investment types based solely on one
or more specific ethical considerations and will be applied only
upon a client’s request. Depending
on client instruction, advisory services are provided either with or without consideration to the
overall financial situation of the client (e.g. tax considerations, liquidity needs, etc.). SRI restrictions
may preclude clients from investing in certain strategy model holdings which may create the
potential for performance dispersion.
Vaughan Nelson also serves as advisor/sub-advisor to sponsored, affiliated and unaffiliated mutual
funds and exchange-traded funds (collectively, “Funds”) where investment decisions are
implemented on a fully discretionary basis, subject to the requirements of the Investment Company
Act of 1940 and restrictions contained within the related Prospectus and Statement of Additional
Information for each fund.
Finally, Vaughan Nelson participates as a non-discretionary sub-adviser to wrap programs where
the investment advice is provided to affiliated and unaffiliated sponsors (the investment advisor)
who then have discretion over the implementation, including trade execution, of the investment
advice. In certain circumstances the investment advisor will communicate trade appetite back to
Vaughan Nelson for execution on a ‘stepped-out’ basis. It is the responsibility of the affiliated and
unaffiliated sponsors of the wrap programs to take into consideration the financial situation and
any needs of the ultimate client. For this service, Vaughan Nelson is paid a portion of the wrap fee
paid by the client to the program sponsor.
Performance differences between all Vaughan Nelson’s clients will occur due to differences in cash
availability, investment restrictions, account sizes, trade sequencing (see Item 12 Brokerage
Practices) and other factors.
Discretionary and Non-Discretionary assets (inclusive of those for which a model is provided but
not included in RAUM of $1,754,317,146) as of 12/31/23 are broken down as follows:
Discretionary Assets $14,696,062,060
Non-Discretionary Assets $1,760,580,272
Total Assets $16,456,642,332
Business Continuity
For purposes of business continuity, Vaughan Nelson’s primary information and data are hosted on
premises in our Houston office and redundantly in a third-party, Boston, MA (~1600 miles from
Houston) based data center facility (Markley Center). Both environments have high levels of both
physical security and redundant power/data providers for maximum availability. Additionally,
there are multiple layers of redundancy within the virtualized server environment both in Houston
and hosted at the Markley Center. All infrastructure managed by Vaughan Nelson is kept in sync on
a near real-time interval for all network drives and files with additional full tape backups kept
offsite. For critical applications, the firm’s trading, compliance, and portfolio accounting systems
are hosted by NIM-os (a non-advisory operating services affiliate) with multiple layers of
redundancy and SLAs in place for system availability. All employees are able to work remotely
within this infrastructure in order to continue operations when the Business Continuity Plan is
activated (e.g. hurricane, pandemic). Vaughan Nelson also maintains an office space “hot-site” at
dedicated company leased office space in Austin, Texas should the need arise. The Austin office
space facility houses the infrastructure necessary to recover (i.e. phone, connectivity to data center,
workstations, redundant internet access, etc.) in the event physical access to the Houston facility is
lost.