We are a Delaware limited liability company organized on April 20, 2005. We are a
wholly-owned subsidiary of BMO Financial Corp., which is a wholly owned subsidiary of
Bank of Montreal (“BMO").
We operate under our legal name, BMO Family Office, LLC, as well as under the brand
names “BMO Wealth Management” and “BMO Family Office.” These brands are discussed
more fully in Item 10 “Other Financial Industry Activities and Affiliations.”
Our primary services are:
• Discretionary Investment Management and Non-Discretionary Investment Advisory
Services, and
• Family Wealth Strategies.
As of October 31, 2022, we provided discretionary and non-discretionary investment
management services on assets of $5.75 billion and non-discretionary investment advisory
services on assets of $4.79 billion.
Family wealth strategies, investment reporting and other non-investment advisory services,
are not subject to the Investment Advisers Act of 1940. These services are discussed in
greater detail in Item 10 “Other Financial Industry Activities and Affiliations.”
Discretionary Investment Management and Non-Discretionary Investment Advisory
Services
Our advisory services include discretionary investment management and non-discretionary
investment advice. In connection with these services, we design and prepare investment
policy statements and asset allocation strategies, select, or recommend sub-advisers and
investments, and monitor and report on portfolio performance. We also provide investment
implementation and other administrative services.
We employ investment research professionals and use due diligence and evaluation
processes to identify, evaluate, and monitor investments. Our evaluation process employs
quantitative and qualitative techniques, as well as operational reviews.
We manage or advise client accounts in accordance with the client’s investment objectives,
risk tolerance, time horizon, tax circumstances, liquidity and cash flow needs, restrictions
and constraints, and other relevant criteria. As further described in Item 8 “Methods of
Analysis, Investment Strategies and Risk of Loss,” we allocate client assets among different
asset classes with varying levels of risk and return. We diversify client portfolios within and
across asset classes, including cash, fixed income, equities, hedge funds, private markets,
and real assets. We recommend affiliated and non-affiliated investments, including separate
accounts, mutual funds, exchange traded funds, commingled funds, limited partnerships,
alternative investments, structured products, individual securities, and derivative
instruments. We may recommend
and use affiliated or unaffiliated sub-advisers to manage
or advise on a client’s portfolio.
We manage a proprietary hedged fund of funds, Confluence Multi-Strategy Fund, LLC
(“Confluence”). Confluence is a private fund exempt from registration under the Investment
Company Act of 1940. Confluence invests in a portfolio of actively managed hedge funds on
behalf of U.S. taxable investors.
We provide non-discretionary advisory services to National Philanthropic Trust (“NPT”) for
the BMO Donor-Advised Fund Program. The program is administered and sponsored by NPT,
an independently operated public charity. We provide non-discretionary advice to NPT client
accounts, including asset allocation, investment policies and strategies, and investments.
Non-Discretionary Sub-Advisory Services
We provide non-discretionary sub-advisory services for:
• the Sequence Multi Asset IDF Series Interests of the SALI Multi-Series Fund, L.P., and
• the Sequence Multi Asset IDF III Series Interests of the SALI Multi-Series Fund IV, L.P.
For the Sequence Multi Asset IDF Series Interests, SALI Fund Partners, LLC serves as the
general partner of the funds. Separate Account Life Insurance (SALI) Multi-Series Fund, L.P.,
is a Delaware limited partnership (“Partnership”). The Partnership’s general partner, SALI
Fund Partners, LLC (“General Partner”), manages the Partnership and is responsible for its
day-to-day operations. SALI Fund Management, LLC (“SALI Investment Manager”), is
responsible for investing the Partnership’s assets. Our primary role is to determine and
recommend asset allocation and investments held by the funds. Historically, the General
Partner has implemented our investment recommendations.
Limited Mandate and Consulting Services
We may provide limited mandate advisory or consulting services. Examples include one-
time portfolio reviews, research or advice on alternative asset investment managers or
portfolios, and research and due diligence on non-recommended investments.
ERISA
When we provide investment advice to clients regarding retirement plan accounts,
individual retirement accounts, or other plans as defined in Section 4975(e)(1) of the
Internal Revenue Code of 1986, as amended (“Code”), we are fiduciaries within the
meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the
Internal Revenue Code, as applicable, which are laws governing retirement accounts. The
way we make money creates some conflicts with clients’ interests, so we operate under a
special rule that requires us to act in clients’ best interest and not put our interests ahead of
clients’ interests.