Neuberger Berman Investment Advisers LLC (“NBIA”) is registered with the Securities and Exchange Commission (“SEC”) as an investment adviser. NBIA’s affiliate, Neuberger Berman BD LLC (“NBBD”), is registered with the SEC as a broker-dealer and is a member of the Financial Industry Regulatory Authority ("FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Brokerage and investment advisory services and fees differ. It is important for you to understand those differences. Free and simple tools are available to research firms and financial professionals at https://www.investor.gov/CRS, which also provides educational materials about broker-dealers, investment advisers, and investing.
This Form CRS provides information applicable to retail investors. If you are not a retail investor and would like additional information regarding the services we provide to you, please contact your NBIA or NBBD representative.
What investment services and advice can you provide me?
We offer both brokerage and investment advisory services to retail investors.
NBBD’s brokerage services offered to retail customers by its portfolio managers and wealth advisors in their capacities as associated persons of NBBD (“NBBD Brokers”) include buying and selling securities (including for advisory clients of NBIA on a client-directed basis), making recommendations with respect to privately offered pooled investment vehicles managed by affiliates of NBBD (including privately offered pooled investment vehicles registered under the Investment Company Act of 1940, as amended, “NB Private Funds”), and wealth planning services. Certain portfolio managers, as NBBD Brokers, recommend, on a limited and complementary basis, select third-party privately offered pooled investment vehicles (collectively with NB Private Funds, “Private Funds”).
With respect to NBBD’s wealth planning services, NBBD provides one-time analyses that are intended solely for informational and discussion purposes and NBBD does not undertake to provide any ongoing or periodic review, follow-up or monitoring of any topics covered therein.
Certain existing retail customers have invested through an existing framework (“Brokerage Framework”) where NBBD and NBBD Brokers provide asset allocation recommendations as among proprietary strategies managed by affiliates of NBBD (separately managed accounts (“NB SMAs”), mutual funds (“NB MFs”), exchange-traded funds (“NB ETFs”), and NB Private Funds), which may include overlay strategies. In connection with its asset allocation recommendations under the Brokerage Framework, NBBD will confirm the retail customer’s investment profile (e.g., financial situation, needs and investment objectives) on at least an annual basis, but will not provide any ongoing monitoring. The Brokerage Framework is no longer being offered to new customers.
Except as or otherwise agreed with a customer, NBBD does not provide any ongoing or periodic review, follow-up or monitoring of retail customer accounts for purposes of Regulation Best Interest.
When NBBD makes a recommendation, you make the ultimate decision regarding any purchase or sale of investments, or any asset allocation.
On a limited basis, certain NBBD Brokers may provide recommendations to its customers for which NBBD’s trust company affiliate (“NB Trust Co”) provides investment services. Those investment services may allow certain customers to access strategies different from those available through NBBD and its advisory affiliates, and subject those customers to different terms and different fees. Those customers should review carefully their agreement with NB Trust Co.
For most retail advisory clients of NBIA and for employees of NBBD and its affiliates, NBBD generally acts as broker in connection with the purchase and sale of securities, and introduces those customers’ transactions and accounts to its clearing broker for clearance and settlement.
NBIA’s advisory services offered to retail clients by its portfolio managers and wealth advisors in their capacities as supervised persons of NBIA (“NBIA Advisers”) include discretionary investment advisory services through NB SMAs and its Guided Portfolio Solutions Program (“GPS Program”), where NBIA allocates client assets among proprietary strategies (NB SMAs, NB MFs, and NB ETFs), and, on a limited and complementary-only basis, select third-party strategies (separately managed accounts (“Third-Party SMAs”), mutual funds and exchange-traded funds). Where NBIA provides non-discretionary services, you make the ultimate decision regarding any purchase or sale of investments.
Unless specifically agreed with you, Private Funds are not available in advisory accounts, and are offered only through NBBD.
Generally, the PWM Advisory Program is available to clients investing a minimum of $5 million and standalone NB SMAs are available to clients investing a minimum of $1 million. Certain offerings may be available at lower investment minimums; for example, GPS Program accounts require a minimum initial investment of $100,000.
Certain third-party wrap fee program sponsors (“Wrap Sponsors”) make NBIA’s advisory services available to, or utilize NBIA’s model portfolio for, their clients (“Wrap Clients”), including on a “dual contract” basis, where the clients (“Dual Contract Clients”) contract separately with NBIA for advisory services and the Wrap Sponsor or a designated broker for brokerage and other services. The standard minimum account size is determined by the Wrap Sponsor but is typically $250,000 for fixed income accounts and $100,000 for equity accounts. For Dual Contract Clients, the standard minimum account size is $500,000 for equity strategies and $1 million for fixed income strategies.
Generally, NBIA will monitor client assets within each NB SMA (including those offered through a dual contract program) or GPS Program account on an ongoing basis. With respect to the PWM Advisory Program, NBIA will monitor the allocation of assets across strategies on at least a quarterly basis.
In all cases, where strategies are only available to certain customers (e.g., based on the jurisdiction in which client/customer resides, the client/customer’s financial sophistication), NBIA and NBBD will only recommend or allocate clients/customers to strategies in which the client/customer is permitted to invest.
For additional information, please see NBBD’s Regulation Best Interest Disclosure Statement (“NBBD Reg BI Statement”) at https://www.nbprivatewealth.com/reg-bi-disclosure-nbbdhttps://www.nb.com/en/gb/regulatory-disclosures/reg-bi-disclosure-nbbd, NBIA’s Form ADV Part 2A brochure (“NBIA ADV Part 2A”) (Items 4 and 7 of Part 2A) at https://www.nbprivatewealth.com/adv-part-2a-nbiahttps://www.nb.com/en/us/regulatory-disclosures/adv-part-2a-nbia, NBIA’s Form ADV Part 2B brochures (“NBIA ADV Part 2Bs”) and NBIA’s ERISA 408(b)(2) disclosure as provided to you, and the terms of any agreement between you and NBIA or NBBD, as applicable.