The Company
Insight North America LLC (“INA” or the “Adviser”), formerly known as Pareto New York LLC until 2016, was established in
2004 as a wholly-owned subsidiary of The Bank of New York Mellon Corporation (“BNY Mellon”). Organized as a Limited
Liability Company under the laws of New York, INA registered as an investment adviser with the United States Securities
and Exchange Commission (“SEC”) on March 10, 2009. INA is part of the group of affiliated companies that may individually
or collectively provide investment advisory services under the brand ‘Insight’ or ‘Insight Investment’ (“Insight”). Insight
includes, among others, the following affiliated entities: INA, Insight Investment International Limited (“IIIL”), Insight
Investment Management Limited (“IIML”), Insight Investment Funds Management Limited (“IIFM”) and Insight Investment
Management Global Limited (“IIMG”) (each an “Insight Affiliate” and collectively, “Insight Affiliates”). INA is also affiliated
with other BNY Mellon subsidiaries (“BNY Mellon Affiliates”).
INA is controlled by David Leduc (Chief Executive Officer), Alex Veroude (Chief Investent Officer), James Parsons (Chief
Operating Officer), John Ariola (Head of Finance), Vivek Nayar (Senior Managing Counsel), and Daniel Haff (Chief
Compliance Officer). As Chief Executive Officer of IIML, Abdallah Nauphal oversees the management and operations of the
entities comprising Insight Affiliates.
Several of the management persons referenced above comprise INA’s United States Management Committee (“USMC”).
The USMC convenes on a monthly basis to deliberate on topics such as the Adviser’s adjustments to control and risk
parameters, litigation and regulatory matters, operational concerns, client relationships, and the implementation of policies
and procedures. From a corporate governance perspective, the purpose of the USMC is to foster a culture of
interdepartmental transparency while also establishing a collaborative framework surrounding INA’s approach to handling
new business development. The USMC reports its findings directly to INA’s Board of Directors.
INA’s Board of Directors is comprised of the control persons serving in a directorial capacity at the INA entity level. The INA
Board typically convenes on a quarterly basis to discuss project management updates, operational objectives, and a high-
level overview of forthcoming changes to the business.
In addition to being registered with the SEC as an investment adviser, INA is a member of the National Futures Association
(“NFA”) and is registered with the Commodity Futures Trading Commission (“CFTC”) as a Commodity Trading Advisor
(“CTA”) and a Commodity Pool Operator (“CPO”).
Investment Advisory Services
INA provides discretionary and non-discretionary investment advisory services to institutional investors and high-net worth
individuals (the “Client” or “Clients”) in the form of separate accounts and pooled vehicles across a wide variety of fixed
income, risk management strategies including currency risk management and liability driven investing, absolute return and
multi-asset capabilities (“Investment Advisory Services”).
Additional information regarding INA strategies, including the methods of analysis, fees, and certain material risks, is
included under Item 8, ‘Methods of Analysis, Investment Strategies and Risk of Loss’.
INA provides tailored Investment Advisory Services to its Clients. Discretionary separate account Clients may impose
investment restrictions and other guidelines on the management of the account. However, doing so will limit the Adviser’s
ability to act for the account and, therefore, the performance of the account may differ and potentially be lower than the
performance of discretionary accounts managed in the same or a similar strategy. Under certain circumstances, INA will
decline to accept certain Client-imposed guidelines or restrictions. Please see Item 16 for additional information about
investment guidelines and restrictions.
INA also offers direct Investment Advisory Services and indirect sub-Investment Advisory Services to pooled vehicles
(“Funds”), including collective investment trusts (each a “CIT”), registered investment companies (each a “Mutual Fund”)
and exchanged traded funds (“ETFs”). Each Fund has an investment objective and set of investment policies and/or
guidelines to which it is subject.
Participating Affiliates
INA uses investment management related services provided by a Participating Affiliate. INA has entered into a Participating
Affiliate Agreement (“PAA”) with IIMG, which is an affiliated asset management company and considered a Participating
Affiliate where one or more employees of IIMG are deemed to be Associated Persons of INA. In this capacity, the
Participating Affiliate and one or more of its employees (subject to INA’s supervision) provide research, advice, and
recommendations in connection with INA’s management of U.S. based Client accounts. In this capacity, IIMG operates in
accordance with the series of no-action letters published by the SEC requiring the Participating Affiliate to be subject to the
supervision of INA and the SEC. For additional information on Participating Affiliates, please see Item 10.
Assets Under Management
As of December 31, 2023, INA managed approximately $119 billion in regulatory assets under management (“AUM”), $111
billion of which are managed on a discretionary basis and $8 billion on a non-discretionary basis.
INA AUM is generally aggregated with the AUM of its Insight Affiliates in advertisements, marketing, and other promotional
materials (“Marketing Materials”). The AUM used in the Marketing Materials is therefore calculated differently than the
regulatory AUM listed herein.
www.insightinvestment.com
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