AXA IM US is a Delaware corporation registered with the Securities and Exchange Commission
as an investment adviser. AXA IM US’s investment management business originated in 2001
when the high yield bond group of Cardinal Capital Management, based in Greenwich, CT,
joined AXA IM US.
AXA IM US is a wholly owned, indirect subsidiary of AXA SA a Société Anonyme organized under
the laws of France. Our chain of ownership to our ultimate parent holding company, AXA SA, is
as follows:
• AXA SA directly and indirectly owns substantially all of AXA Investment Managers SA’s
equity ownership interests.
• AXA Investment Managers SA directly owns 100% of AXA IM U.S. Group Holding Inc.
• AXA IM U.S. Holding Inc. directly owns 100% of AXA IM US.
For purposes of this brochure, AXA SA and its direct and indirect subsidiaries are collectively
referred to as the “AXA Group”. The AXA Group is a diversified, global financial services company.
We offer discretionary portfolio management services under the following investment strategies:
(i) core, and dynamic high yield, (ii) enhanced and short duration high yield, (iii) U.S. active
corporate investment grade, (iv) leveraged loans and structured products (which are strategies
in respect of which AXA IM relies on the resources and capabilities, including certain personnel,
of AXA Investment Managers Paris to supply services pursuant to a PAA as defined and described
in Item 10 below), (v) U.S. buy & maintain, which includes U.S. corporate bonds, U.S. government
issued securities and select U.S. municipal bonds, (vi) long equity strategies, including a broad
range of global and regional quantitative equity strategies for which AXA IM US relies on the
resources and capabilities, including certain personnel, of AXA Investment Managers UK, AXA
Investment Managers Paris AXA IM Asia (Hong Kong) and AXA IM Asia (Singapore) Ltd. To supply
services pursuant to a PAA, (vii) Structured Credit, including, but not limited to residential
mortgage backed securities (“RMBS”), commercial mortgage backed securities (“CMBS”), agency
credit risk transfers (“CRTs”), enhanced equipment trust certificates (“EETC”) and collateralized
loan obligations (“CLOs”), (ix) equity real estate investments and commercial mortgage loans, for
which AXA IM US relies on the resources and capabilities, including certain personnel, of AXA
Real Estate Investment Managers SGP, and (x) significant risk transfer which includes investing in
balance sheet securitizations (in respect of which AXA IM relies on the resources and capabilities,
including certain personnel, of AXA Investment Managers Paris). In addition to the above
referenced strategies, in the future, AXA IM US may provide portfolio management services
utilizing additional investment strategies provided by certain AXA IM US foreign affiliates
pursuant to PAAs with such AXA IM US foreign affiliates. See Item 10.
We manage and/or sub-advise separate accounts for international and domestic institutional
clients. Our separately managed account clients are permitted to impose restrictions or
limitations on how we manage their accounts within our investment strategies. These restrictions
or limitations generally appear either in the client’s investment management agreement or in
the investment guidelines adopted for the account. Investors in pooled investment vehicles
cannot impose specific restrictions on their accounts and such accounts are managed in
according with the guidelines in the offering documents provided to investors.
In addition, we are the investment manager for the St. Bernard Opportunity Fund I, Ltd. (the “St.
Bernard Fund”), an offshore private investment fund domiciled in the Cayman Islands. The St.
Bernard Fund pursues a long and short credit strategy with a focus on “credit-sensitive”
mortgage-backed securities (“MBS”) and asset- backed securities (“ABS”) (i.e., the analysis of
which involves assessment of credit risk). The St. Bernard Fund may also invest in non-credit-
sensitive MBS and ABS, as well as other instruments, including without limitation, collateralized
debt obligation transactions (“CDOs”) (in particular, through secondary purchases of CDOs of
MBS and ABS), single name and index credit default swaps (“CDS”) referencing MBS/ABS,
corporate issuers, or other reference obligations, long and short equity positions, and distressed
securities. In addition, we are the investment manager for the AXA IM U.S. High Yield Fund, LLC
(the “U.S. High
Yield Fund”), a US private investment fund domiciled in Delaware. The U.S. High
Yield Fund pursues a core high yield strategy. The U.S. High Yield Fund seeks to achieve its
investment objective through investing primarily in a diversified portfolio of U.S. dollar-
denominated high yield corporate debt securities in order to seek high income and total return
and to seek to outperform the BofA Merrill Lynch U.S. High Yield Master II Index over a full market
cycle.
As referenced above, as of the date on this brochure we also serve as a sub-adviser to seven U.S.
investment companies registered under the Investment Company Act of 1940, as amended (the
“U.S. Investment Companies”).
In addition, we serve as a sub-investment adviser to several of our non-U.S. affiliated investment
advisers (the “Affiliated Adviser Clients”) that provide investment advice to various institutional
(i) non-U.S. funds marketed to non-U.S. retail and institutional investors (and which are not
marketed to, nor available for investment by, U.S. investors), (ii) offshore private investment
vehicle accounts, and (iii) other non-U.S. accounts (collectively, the “Underlying Portfolios”). For
more information concerning the Affiliated Adviser Clients, see Item 5 and Item 10 below.
On a non-discretionary basis, we provide investment advice to AXA IM Global Health Fund SCSP
SICAV-RAIF (“Global Health Fund”) and AXA Global Health Impact Opportunities Fund SA SICAV
RAIF, private equity funds focused on investing in portfolio companies seeking to meet the
healthcare needs of high-volume, mass-market populations through offering commercially viable
products and services, through an advisory services agreement with AXA Investment Managers
UK Limited. Under these agreements, an employee of AXA IM US sits on each fund’s investment
committees and has an equal vote with other members of such investment committee.
We also provide non-discretionary model portfolios to affiliates on a monthly basis. We are not
responsible for providing updates to the model on an ongoing basis. However, interim emergency
rebalancing can be initiated by us on exceptional basis such as removal of an issuer due a major
event. Recommendations may differ from the advice provided to discretionary clients in the
same strategy due to differences in investment objectives, size and liquidity profiles. It is the
affiliates sole discretion whether or not and to what extent to implement our recommendations.
At the direction of the affiliate, we are responsible for executing transactions for accounts based
the model portfolios for some accounts as per the governance documents. Model portfolios may
invest in the same securities as other clients and will can be bunched traded when deemed
appropriate to achieve best execution. If AXA IM US is not responsible for execution per the
governance documents, we solely provide the model portfolio, and the affiliate is responsible for
all trade execution.
We also provide a structured credit strategy focused on foreign and domestic private debt, whole
loans, and collateralized loan obligations on behalf of CLO issuers, a non-discretionary CLO fund
and certain Affiliated Adviser Clients that manage certain offshore private investment vehicles.
AXA IM US also provides analytical support services for and/or trades certain swaps, futures, and
derivatives under the jurisdiction of the Commodity Futures Trading Commission. AXA IM US
relies on an annually filed exemptions from commodity pool operator and commodity trading
advisor registration in respect of such trading.
In addition to the foregoing activities, AXA IM US also provides support services to other AXA IM
affiliates. Some of the support services that AXA IM US provides to such AXA IM includes 1)
compliance support; 2) sales and distribution support; 3) finance support including tax,
accounting, and CFO assistance; 4) client services; 5) legal support; and 6) select operational,
audit and organizational support (“Support Services”). AXA IM US may be reimbursed for a
portion of these services either under the Master Fee Services Agreement or the Expense
Allocation Recharges Procedure described in Item 5 below.
As of December 31, 2023, our regulatory assets under management calculated on a gross basis
and managed on a discretionary basis was $74,269,220,465. In addition to the discretionary
regulatory assets under management calculated above, AXA IM US also advised $15,923,800,563
of assets on a non-discretionary basis.