HFMC is registered with the SEC as an investment adviser and with the CFTC as a commodity pool
operator. HFMC is an indirect subsidiary of The Hartford Financial Services Group, Inc. (“The
Hartford”), a publicly traded financial services company based in Connecticut.
HFMC provides discretionary investment advisory services to SEC- registered open-end investment
companies, including mutual funds and exchange traded funds and a closed end, tender offer fund
(collectively, “Hartford Funds” and each series of which is a “Hartford Fund”)
1 and three Cayman
Islands private funds for which HFMC serves as general partner.2
HFMC is also the program manager (the “Program Manager”) to The Hartford Smart529 College
Savings Plan, the SMART529 Select College Savings Plan and SMART529 WV Direct College
Savings Plan (together, the “529 Plans”). As Program Manager, HFMC and/or its affiliates provides
provide certain services to the 529 Plans. In addition, HFMC provides non-discretionary investment
advisory services to the 529 Plans. The 529 Plans offer portfolios that are investment options for the
529 Plans (each a “529 Portfolio”); the 529 Portfolios invest in one or more mutual funds, including
certain Hartford Funds. Certain 529 Portfolios also invest in Hartford exchange traded funds and one
unaffiliated separate account pooled investment vehicle.
HFMC is the parent of Lattice Strategies LLC (“Lattice”), a registered SEC investment adviser. Lattice
is the investment adviser to multi-factor exchange traded funds. Employees perform services on behalf
of both HFMC and Lattice.
HFMC generally provides investment advisory services to its mutual funds and exchange traded funds
through use of a manager of managers or sub-advisory structure. HFMC is responsible for the
management of the Hartford Funds and supervises the activities of the investment sub-advisers as well as
provides administrative services including, among other services, compliance, legal, governance and
other activities required by Hartford Funds. HFMC makes day to day investment allocation decisions for
the Hartford Growth Allocation Fund, Hartford Conservative Allocation Fund, Hartford Moderate
1 The Hartford Mutual Funds, Inc., The Hartford Mutual Funds II, Inc., Hartford Series Fund, Inc., and HLS Series
Fund II, Inc. are combined to form Hartford M u t u a l Funds. Hartford Funds Exchange-Traded Trust are
combined to form “Hartford Exchange Traded Funds” or “Hartford ETFs”. Collectively, Hartford Mutual Funds,
Hartford Schroders Private Opportunities Fund and Hartford ETFs are referred to as “Hartford Funds”.
The Cayman Funds are wholly-owned subsidiaries of the Hartford Real Asset fundthe Hartford Schroders
Diversified Growth Fund, and the Hartford Schroders Commodity Strategy ETF and are not offered to the public.
The sole purpose o f th e Cay m an Fu n d s is to gain exposure to commodity-linked instruments.
Allocation Fund and Hartford Checks and Balances Fund (collectively, “Hartford Funds of Funds”)
which invest in shares of other Hartford Funds.
Investment advisory and administrative services are tailored to each Hartford Fund based on the
investment objectives and strategies disclosed in its prospectus or, to each 529 Plan, in accordance
with the requirements of a 529 Plan’s offering statement.
HFMC also offers non-discretionary security recommendations in the form of model portfolios through
its participation in separately managed account programs or unified managed accounts (“Programs”)
that are sponsored by non-affiliated investment
advisers (“Program Sponsors”). HMFC does not
sponsor a wrap fee program and does not actively manage accounts in wrap fee programs sponsored by
others. The Program Sponsors provide brokerage execution, custody and account administrative
services for a single fee. HFMC’s model portfolios provided to these Program Sponsors are referred to
as “Model Portfolio Strategies”.
For these Model Portfolio Strategies, HFMC may rely solely upon security recommendations from non-
affiliated registered investment advisers (“Non-Affiliated Model Providers”). Non-Affiliated Model
Providers also serve as sub-advisers to registered investment companies sponsored by HFMC for which
HFMC serves as investment manager.
In connection with HFMC’s Model Portfolio Strategy offerings, HFMC provides to a Program Sponsor
a model securities portfolio for a particular investment strategy. Based on the model portfolio, the
Program Sponsor exercises investment discretion and executes transactions on behalf of the Program
Sponsor’s clients based on the Program Sponsor’s discretionary authority.
HFMC provides investment management services in connection with its Model Portfolio Strategies that
differ from the investment advisory services it furnishes to the Funds and the 529 Plan. For example, the
Funds employ investment strategies and techniques and invest in securities that may not be used in
connection with the Model Portfolio Strategies.
In particular, the Model Portfolio Strategies generally:
Limit eligible investments to publicly traded securities and do not invest in private placements,
other illiquid securities, restricted securities or other securities that are not freely or frequently
traded;
Do not use derivatives or other complex investments for hedging or other portfolio management
purposes;
Do not participate in initial public offerings or secondary offerings;
Have lower trade frequency as compared to the Funds, which typically have daily subscription
and redemption activity; and
Have fewer security holdings, than the Funds even though the Model Portfolio Strategy may
utilize security recommendations from the same investment team using similar investment
strategies and /or techniques.
In addition, and separate from the above Model Portfolio Strategies, HFMC constructs model portfolios
(“Hartford Funds Model Portfolios”) based upon the discussions and feedback from its Asset Allocation
Committee (“Committee”). Unlike the Model Portfolio Strategies that invest directly in equity
securities, Hartford Funds Model Portfolios include only mutual funds and exchange traded funds. The
Committee is comprised of members of HFMC’s Multi-Asset Solutions Team and members of HFMC’s
Investment Advisory Group’s Manager Research Team, along with members from two non-affiliated
investment advisers, Wellington Management Company LLP (“Wellington Management”) and
Schroders Investment North America, Inc. (“Schroders”). The Hartford Funds Multi-Asset Solutions
Team leverages the in-depth research of Wellington and Schroders, and the collaborative Committee
process, to construct the Hartford Funds Model Portfolios that include Hartford mutual funds and
exchange traded funds as well as unaffiliated mutual funds and exchange traded funds. The Hartford
Funds Model Portfolios are not publicly available and are intended and available for Program Sponsors
as described above.
As of December 31, 2023, HFMC managed $127.1 billion on a discretionary basis and $1.6 billion on a
non-discretionary basis. HFMC had approximately $297 million in assets under advisement.