RREEF America L.L.C. (“RREEF”), a Delaware limited liability company, is an investment
adviser registered with the U.S. Securities and Exchange Commission (“SEC”) since 1998.
RREEF is part of the global investment management business of DWS Group GmbH & Co.
KGaA (“DWS Group”), a German partnership limited by shares. DWS Group is a separate
publicly listed financial services firm and an indirect majority-owned subsidiary of Deutsche
Bank AG, a multi-national financial services company (together with its affiliates, directors,
officers, and employees, the “Deutsche Bank Group”). RREEF is an indirect subsidiary of DWS
Group.
RREEF provides investment and advisory services to funds and institutional clients on a
discretionary and non-discretionary basis. RREEF has offered its products and services to
clients across a range of asset classes and investing styles, since its formation in 1975.
This brochure, including any brochure supplement, is intended for RREEF’s direct advisory
clients. Investors in any RREEF-advised fund should rely on the fund’s prospectus and offering
materials.
Client-Imposed Investment Restrictions
RREEF primarily manages direct real estate, as well as real estate, real asset, and
infrastructure securities portfolios on behalf of separately managed account clients. RREEF
works closely with its clients to understand their individual investment goals and objectives and
recommends targeted investment strategies and vehicles. Subject to RREEF’s review, these
clients may impose investment restrictions on RREEF’s investment strategies for their
accounts. For direct real estate separately managed accounts, RREEF produces an Annual
Strategic Investment Plan for each account.
With respect to commingled funds (including registered investment companies) managed by
RREEF, investors generally do not have an ability to individually impose restrictions on the
management of such vehicles. Further, such fund offerings are not tailored to address the
specific investment objectives or circumstances of any specific investor.
Assets under Management
As of December 31, 2023, RREEF had discretionary assets under management of
$57,660,909,913 and non-discretionary assets under management of $10,813,631,568.
RREEF’s assets under management noted above differ from those reported in Item 5.F. of
RREEF’s ADV Part 1 given the inclusion of the value of direct real estate investments within
the Part 2A totals. While real estate investments generally are not considered securities under
the instructions to ADV Part 1, and therefore are not included within the Item 5.F. assets under
management totals, they are considered to be “assets” for which RREEF provides investment
advisory services and hence their value is included within the investment advisory fee
calculations.
Investment Capabilities
Products listed below may be managed by RREEF either directly or through sub-advisory
relationships with affiliated and non-affiliated entities. See Item 10 for information regarding
certain affiliated arrangements related to RREEF’s advisory business.
RREEF’s policies and practices can vary by strategy and/or product type. RREEF’s advisory
services can vary by strategy and/or product type and geographic location.
Investment Strategies
Principal investment strategies currently offered by RREEF include:
Liquid Real Assets—Real Estate
Equity investments in publicly and privately traded real estate securities, including Real
Estate Investment Trusts (“REITs”) and Real Estate Operating Companies (“REOCs”);
Liquid Real Assets—Infrastructure
Publicly and privately traded infrastructure related securities, including equity
investments in publicly and privately traded securities of infrastructure related
companies and Master Limited Partnerships (“MLPs”);
Liquid Real Assets—Other Real Assets
Commodities, commodity related equities, natural resources equities, as well as
treasury inflation protection securities, floating rate notes and bank loans;
Direct Real Estate—Core / Core Plus
Predominantly high-quality equity investments in stabilized, income-producing
properties, employing low to moderate leverage;
Direct Real Estate—Value Added
Equity investments in value-add properties requiring redevelopment, repositioning for
alternative use or upgrade, employing moderate leverage;
Direct Real Estate—Opportunistic
Investments in equity and equity-like investments in real estate and real estate-related
assets, including distressed properties and loans, mezzanine facilities, corporate and
government dispositions, and private growth companies. This strategy seeks to
capitalize on economic, financial and property market dislocation and may employ
significant leverage;
Direct Real Estate—Debt
Debt and hybrid investments in real estate assets, real estate companies, and
commercial and residential agency and non-agency mortgage-backed securities;
mezzanine and structured real estate debt investments, transitional senior mortgages,
B-notes, mezzanine loans, preferred equity and other real-estate backed structured
investments; investments in Federal Home Loan Mortgage Corporation (“Freddie Mac”)
subordinate tranche of the K Series (known as the “Class D” or “B-Piece”); Transitional
finance for lease-up, redevelopment, or new construction;
Infrastructure Debt
Investments in private infrastructure debt in the primary and secondary markets; Focus
on loans and bonds in both the sub-investment grade and investment grade markets,
subject to meeting required returns on a portfolio basis; This strategy may employ
substantial leverage;
Sustainable Investments
Strategies for managing certain private funds that focus on private investments of
companies that are building, operating, and selling green projects or environmentally
sustainable green systems and infrastructures. RREEF provides this strategy on a sub-
advisory basis; and
Private Equity – Senior and Junior Capital
Investments in private equity and senior and junior debt of private equity sponsor-
backed portfolio companies.
Products and Services
RREEF primarily offers the following products and services:
Separately Managed Accounts
RREEF manages investment advisory accounts on a discretionary and non-discretionary basis
and pursues strategies falling into one or more of the following general categories:
_ Liquid Real Assets - Real Estate
_ Liquid Real Assets - Infrastructure
_ Liquid Real Assets - Other Real Assets
_ Direct Real Estate - Core/Core Plus
_ Direct Real Estate - Value-Added
_ Direct Real Estate - Debt
_ Infrastructure Debt Investments
Sub-advisory Services
RREEF serves as sub-adviser to certain registered investment advisers and to certain foreign
fund managers who act as the primary investment manager to clients (including registered
investment companies, unregistered commingled funds, and separate account clients).
Pursuant to written sub-advisory agreements, RREEF may manage all or a portion of the
fund’s or separate account client’s portfolio or provide personnel that serve on the portfolio
management team or investment committee. For any investment strategies for which RREEF
only provides sub-advisory services, clients should also review the disclosure documentation
provided by the primary advisor that engaged RREEF to provide sub-advisory services.
RREEF’s sub-advisory services generally involve strategies falling into one or more of the
following general categories:
_ Liquid Real Assets - Real Estate
_ Liquid Real Assets - Infrastructure
_ Liquid Real Assets - Other Real Assets
_ Direct Real Estate - Core/Core Plus
_ Direct Real Estate - Value-Added
_ Direct Real Estate - Debt
_ Direct Real Estate - Opportunistic
_ Infrastructure Debt Investments
_ Sustainable Investments
RREEF has sought and obtained a permanent order from the Securities and Exchange
Commission providing exemptive relief under Section 9 of the Investment Company Act of
1940, as amended (the “Investment Company Act”), on which it relies in connection with the
continued provision of investment advisory services to registered investment companies.
Pooled Vehicles
Non-Registered Funds
RREEF serves as investment manager or sub-adviser to certain privately offered
investment funds not registered under the Investment Company Act and sold only to certain
investors meeting specific eligibility requirements. Some of these funds are, or have
subsidiaries (each, a “REIT Subsidiary”) which are, organized to qualify as real estate
investment trusts under relevant provisions of the Internal Revenue Code of 1986, as
amended (the “Code”). These funds pursue strategies falling into one or more of the
following general categories:
_ Liquid Real Assets - Real Estate
_ Liquid Real Assets - Infrastructure
_ Liquid Real Assets - Other Real Assets
_ Direct Real Estate - Core/Core Plus
_ Direct Real Estate - Value-Added
_ Direct Real Estate - Opportunistic
_ Infrastructure Debt Investments
_ Private Equity – Senior and Junior Capital
_ Sustainable investments
SEC-Registered Non-Traded REIT
RREEF provides discretionary investment advisory services to a non-exchange-traded,
perpetual-life REIT not registered as an investment company under the Investment
Company Act (the “Registered Non-Traded REIT”). Shares of common stock of the
Registered Non-Traded REIT are offered to the public pursuant to a registration statement
Form S-11 filed with the SEC, but not listed for trading on an exchange or other trading
market. The Registered Non-Traded REIT may invest in a diversified portfolio of
commercial real estate properties, real estate securities, and debt backed principally by real
estate, using elements of strategies falling into one or more of the following general
categories:
_ Liquid Real Assets - Real Estate
_ Direct Real Estate - Core/Core Plus
_ Direct Real Estate - Value Added
_ Direct Real Estate - Debt
Model Portfolios
RREEF may provide model portfolio recommendations for a variety of investment styles to
clients of RREEF and RREEF affiliates. Model portfolios may relate to the same investment
strategies that are also offered or utilized through discretionary accounts. RREEF typically
provides model portfolio recommendations on a non-discretionary basis, i.e., model portfolio
recipients are responsible for interposing their own judgment in deciding that the model
portfolio recommendations are appropriate for their client accounts and for determining
whether and which recommended securities transactions
are to be executed on behalf of their
clients.
Strategic Partnerships
RREEF offers its Private Equity – Senior and Junior Capital strategy through a strategic
partnership with Northwestern Mutual Capital (“NMC”), a division of Northwestern Mutual
Investment Management Company, LLC (“NMIMC”), pursuant to which NMC provides portfolio
management services to certain pooled investment vehicles under RREEF’s management.
Non-U.S. Strategies/Other Arrangements
RREEF offers a variety of non-U.S. strategies through its sub-advisory relationships with
advisory affiliates located outside the United States. Apart from furnishing investment advice to
clients, RREEF also provides various investment advisory, consulting, administrative and
research support services to its affiliates, pursuant to intercompany agreements.
RREEF may offer, and may negotiate fees with respect to, its investment advisory and research
support services to other third-party fiduciaries and may also render investment advice to
specific accounts of such fiduciaries that contract with RREEF.
To provide financial services in Australia, RREEF relies on an exemption from the requirement
to hold an Australian financial services license under the Corporations Act 2001 (Cth). RREEF
is regulated by the SEC under applicable U.S. laws, which differ from Australian laws.
Environmental, Social and Governance Considerations
RREEF seeks to incorporate in its investment process environmental, social and governance
(“ESG”) risks and opportunities that could have a material impact on the financial performance
of the issuer, in accordance with the goals of a particular investment strategy and client
investment guidelines, and further subject to its fiduciary obligations and applicable law, rule
and regulation.
For most asset classes and market segments, RREEF portfolio managers have access to ESG
research and grades, including research provided by internal DWS analysts which consider
ESG risks and opportunities, as well as access to ESG quality assessment scores and
additional information from DWS’s proprietary ESG tool (also referred to as the “ESG Engine”).
For those strategies that do not seek to implement a specific ESG strategy, the level of
consideration of ESG factors in a strategy’s process will differ from strategy to strategy, from
sector to sector, and from portfolio manager to portfolio manager.
Because investors can differ in their views of what constitutes positive or negative ESG
characteristics, RREEF may invest in issuers that do not reflect the ESG beliefs and values of
other investors. RREEF’s considerations of ESG risks and opportunities may affect a fund’s
exposure to certain companies or industries, and an ESG-dedicated strategy may forego
certain investment opportunities. While RREEF views considerations of ESG risks and
considerations as having the potential to contribute to a client’s account long-term
performance, there is no guarantee that such results will be achieved.
Because of the inherent differences between Liquid Real Assets and RREEF’s illiquid
strategies encompassing Infrastructure Debt, Private Equity, Direct Real Estate and Real
Estate Debt (the “Illiquid Strategies”), the approach to incorporating ESG is tailored specifically
to the strategy and in accordance with a client’s investment objectives and requires different
tools to be utilized to consider ESG factors when assessing risk and return of a particular
investment.
1. Liquid Real Assets - Available ESG Tools
RREEF portfolio managers in the U.S. Liquid Real Assets (“LRA”) business may use the DWS
proprietary ESG tool and/or the LRA proprietary ESG models, each as outlined below, to
analyze the ESG attributes of a potential investment.
DWS Proprietary ESG Tool
RREEF’s portfolio managers may use output from a proprietary DWS ESG tool that evaluates
an issuer’s performance across a variety of ESG indicators, primarily on the basis of data
obtained from multiple third-party ESG data vendors and public sources and assigns a DWS
ESG Quality Grade to each issuer covered by the ESG tool. An additional DWS internal review
process allows for changes to the DWS ESG Quality Grade. An internal review may occur, for
example, if it is deemed that information is not reflected in the existing ESG grade because
new information or insights have emerged that the ESG data vendors have not yet processed.
Examples of information that may be considered in this review process include, but are not
limited to, the announcement of new (or withdrawal from previously announced) climate-
related commitments, or the resolution of legacy (or involvement in new) controversies.
RREEF’s portfolio management may consider application of internal reviews on a given DWS
ESG Quality Grade and use their discretion whether and how to apply.
The DWS ESG Quality Grade seeks to identify ESG leaders and laggards within an industry-
and region-specific peer groups in terms of overall ESG performance (best-in-class approach).
Issuers within the same industry and region-specific peer group are graded on a scale of A
(true leader) to F (true laggard). Issuers with a grade of C or above are deemed to meet
RREEF’s sustainability criteria. In calculating the DWS ESG Quality Grade, the DWS
proprietary ESG tool utilizes a proprietary methodology to evaluate ESG scores from multiple
third-party data vendors across a broad range of ESG indicators to arrive at a consensus
overall quality grade intended to reflect which companies may be positioned better to address,
and which companies may be more exposed to future ESG risks, relative to their peers. The
broad range of ESG indicators measured include, among others, assessments of an issuer’s
carbon emissions including its own emissions and those of its products and services, land use
and biodiversity, climate change strategy and vulnerability, product safety and quality,
employee management issues including equal opportunities and non-discrimination, freedom
of association and right to collective bargaining and occupational health and safety, community
relations, human rights issues related to supply chain, business ethics and anti-corruption, and
corporate governance matters including executive pay, board diversity and board
independence.
The proprietary DWS ESG tool covers most listed asset classes but there is limited information
on high yield, municipal bonds, emerging markets, IPOs and certain other types of securities
due to incomplete vendor coverage. Through the DWS ESG tool, RREEF’s portfolio
management may also access issuer-specific contextual analysis that provides additional
information about an issuer’s ESG risks and opportunities, risk mitigation actions or plans and
other characteristics.
LRA Proprietary ESG Models
The LRA team has a separate and proprietary process (the “LRA ESG Models”) for using
selected ESG data sources relevant to their strategies. Currently, LRA has two dedicated ESG
strategies, which utilize the ratings and screens of the LRA ESG Models, as documented in the
investment guidelines for those strategies.
2. RREEF Illiquid Strategies - Strategy-Specific ESG Considerations
For Illiquid Strategies, the incorporation of ESG into the investment process takes place during
investment due diligence and portfolio management.
Infrastructure Debt
The U.S. Infrastructure Debt business developed an ESG scoring methodology applicable to
private infrastructure debt investments, which the business began to utilize in 2021 to support
the overall investment process and ongoing monitoring of the ESG attributes of such
investments. These ESG scores are updated quarterly.
Direct Real Estate
RREEF operates a management system approach, called Sustainability Program which, like
other best-practice management systems, follows a Plan-Do-Check-Act (PDCA) methodology
to ensure implementation and improvement on a continuous basis. The Sustainability Program
encompasses the following five separate stages i) Data Collection, ii) Risk Review, including
transitional, physical/disaster (including climate-related) and social norms risks, iii) Goal
Setting, iv) Implementation; and v) Measurement and Reporting (using industry standards and
benchmarks such as green building certification systems and portfolio sustainability
benchmarking).
Real Estate Debt
For Real Estate Debt, RREEF recognizes the importance of identifying, assessing, and
managing material sustainability issues, but, given the nature of the investments which are
loans and not equity investments in real property, RREEF is limited in its influence of the
management of a property, which serves as collateral for a loan. Thus, during the origination
stage, RREEF may exclude certain sectors or property types such as heavy industrial
properties, casinos, and nightclubs, as well as conduct environmental, property level and
borrower/sponsor due diligence, which helps evaluate certain sustainability-relatedrisk.
Sustainable Investments
The Sustainable Investments business’s ESG assessment process aims to integrate ESG
considerations in the investment process and is guided by general accepted frameworks
including, for example, the Sustainability Accounting Standards Board (SASB) standards.
During the due diligence process, the manager engages professional third-party advisors to
examine the financial, technical, and legal aspects of the projects, especially those that would
translate into ESG risks. Potential risks and mitigation measures are presented to the
Investment Committee and mediation work is carried out to reduce such risks. The Sustainable
Investments team monitors the operation of the portfolio companies and seeks to ensure that
they operate in compliance with the environmental standards and regulations. Some of
Sustainable Investment’s funds engage a third-party consultancy to conduct a quarterly ESG
For Direct Real Estate, RREEF recognizes the importance of identifying, assessing, and
managing material sustainability issues as an integral part of conducting the direct real estate
business. Sustainability-related issues can present risks and opportunities for the financial
performance, and investments may have positive and negative environmental and social
effects.
reporting for the Fund and the quarterly reports include risk analyses and record the waste
generation and air pollutant emissions in detail. For some funds we use a proprietary tool to
measure and monitor impact.