408(b)(2) Disclosure
GLENMEDE INVESTMENT MANAGEMENT, LP
Glenmede Investment Management, L.P. (“Glenmede” or “the Firm”) is providing you with this disclosure document to give you an overview of various aspects of our relationship with your employee benefit plan (the “Plan”), including a written statement of our “status,” the services we provide and the compensation we receive for services we perform for your Plan. This document is intended to include the information required by the Department of Labor regulation under Section 408(b)(2) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) which is commonly known as the service provider fee disclosure rules (or the “408(b)(2) Regulation”). For additional details, please review any additional documents referred to in this disclosure, including the Investment Management Agreement you signed. Also, you may want to review the Form ADV, Part 2A, which is available on Glenmede’s website at or at the website of the U.S. Securities and Exchange Commission at If you prefer, contact your Glenmede representative for a hard copy.
Status
We are an investment adviser registered under the Investment Advisers Act of 1940. In addition, we are a fiduciary of the Plan within the meaning of Section 3(21) of ERISA.
Service
We provide investment management services for your account as set forth in detail in the Investment Management Agreement. Depending on your relationship, affiliates of ours may provide additional services to you. For example, our parent company, The Glenmede Trust Company, N.A. (“GTC”), may provide custodian or other services directly to you.
Compensation
In return for our services, we are generally paid fees by the Plan as set forth in the Investment Management Agreement with you. These amounts are generally debited from the Plan’s Account unless other arrangements have been made. Fees to our parent company for Custodian or other services are paid separately toGTC in accordance with whatever Agreement you may have with it.
If the Plan invests with Glenmede through a platform offered by a third party (not a Glenmede affiliate), then you do not pay us directly. Rather, we are paid by those plan sponsors in accordance with our agreements with them and you should consult the relevant sponsor for further information.
In addition to our direct fees, if the Plan invests with us directly or through GTC, we may receive “soft dollars.” Glenmede receives third party and/or proprietary research, brokerage and non-brokerage services and credits from certain broker-dealers which execute trades for Glenmede or GTC clients under “soft dollar” agreements or arrangements. Glenmede may share with its affiliate, GTC, to the benefit of GTC’s clients, the soft dollar research it receives from trading,although not on a transaction basis. It is estimated that during 2017, more than 58% of all commissions generated by the firm involved soft dollar commissions (that is, commissions for more than execution), or an average of 1.3 cents of soft dollar credit per share traded. Approximately 22 percent of all such soft dollar commissions are paid to large broker-dealers in return for proprietary research and other services. The remainder are managed through Commission Sharing Arrangements and are used to purchase third-party independent research. All the services provided, whether proprietary or third-party, are intended to be within the Safe Harbor or Section 28(e) of the Securities and Exchange Act of 1934. Similar levels and use of soft dollar commissions and credits are expected to be achieved in 2018. The following brokers were used most to either generate third-party soft dollar credits and/or to provide proprietary research in 2017. (All these relationships are expected to continue at similar levels in 2018):
- BK OF AMERICA
- BARCLAYS
- CREDIT SUISSE
- DEUTSCHE BANK
- ISI EVERCORE
- JANNEY MONTGOM
- JEFFERIES
- JP MORGAN
- KEEFE BRUYETTE
- PIPER JAFF
- RAYMOND JAMES
- RBT BAIRD
- SIDOTI
- STIFEL NICOLAUS
- UBS
- COWEN (csa)
- VIRTU (csa)
- LIQUIDNET (csa)
- CITIGROUP (csa)
- GOLDMAN SACHS (csa)
- ITG (csa)
- ALLIANCE BERN (csa)
- MORGAN STANLEY (csa)
- RBC
- KEYBANK
- ITG
The major third-party research services provided in 2017which are expected to continue to be used in 2018include the following:
- BMO
- BREEN MURRAY
- CRAIG -HALLUM
- GABELLI
- CL KING
- FELTI
- MACQUARIE
- NOMURA
- OPCO
- SNDLER O'NEIL
- STEPHENS
- CRT
- TUDOR / PICK
- 13 "D" RE
- ATHLOS RE
- BCA RE
- BLOOMBERG
- CAP IQ compustat
- CAP IQ factset
- CAP IQ ratings
- CIRRIUS
- PCS SEC (fi new)
- CONSUMER ED (FI)
- CORNERSTONE MACRO
- CREDIT SIGHTS
- DOW JONES
- EMP RE (fmmi)
- EMP RE
- FACTSET
- FBR
- GARTNER
- HAVER
- IBONDEDGE
- PERFORM CREDITSCOPE
- IRC (fund strat)
- JIM FUERY RE
- KLD
- LEERINK SWAIN
- LINDSEY GROUP
- MKM
- MOODYS
- MSCI equity
- MSTAR eq
- NED DAVIS
- NORTHFIELD
- RENMAC
- S&P (Westminster)
- SHILLING
- TM3 / DIVER
- WELLS FARGO
- YARDENI
- VALUE LINE
- CANACCORD GENUITY
- EVESTMENT
- SUNTRUST
- D A DAVIDSON
More information about Glenmede’s brokerage practices can be found in Form ADV, Part 2A,Item 12.
Please note that if the Plan invests with us through a platform, Glenmede does not execute the transactions at its own trade desk, but rather executes at the platform’s chosen custodian in recognition of the fact that most platform clients are charged a fee which includes trading. In such a case, Glenmede is not generating any soft dollar credit or receiving any other compensation from that brokerage firm in respect of Plan trading.
Gifts and Entertainment
Glenmede does sometimes receive gifts or entertainment from persons with whom it does or seeks to do business, including brokers, investment advisors or others. These gifts may include non-monetary and promotional items (such as mugs, calendars or gifts baskets) or entertainment such as meals, sporting events or access to conferences. Glenmede has implemented policies and procedures, whicharedescribedintheFormADV, Part2A, to comply with current regulations intended to ensure that Glenmede and its employees avoid conflicts of interest and limiting the amount of gifts which is permitted. Glenmede monitors gifts received to assure that they comply with this policy. GlenmedehasnotreceivedgiftsorentertainmentexceedingtheU.S.DepartmentofLaborForm5500ScheduleCreportingthresholdsforanyplaninvestorin2017andisnotanticipatedto exceedsuchamountsinthefuture. Wedonotreasonablyanticipatereceiving giftsandentertainmentassociatedwithanyplaninexcessof$150underanyreasonable method ofallocation. Glenmedewillcontinuetomonitoritsgiftsandentertainment reportsandamendthisdisclosureasnecessary.
Other Compensation
Indirect compensation may be received by GTC on “float” when or if Glenmede has custody of the Plan assets. Glenmede may earn interest on cash items posted to your Plan account in those circumstances when the cash is not immediately swept into a money market fund. We sweep to the last whole $1 on a daily basis. Similarly, checks issued from your Plan account may generate interest earnings to Glenmede from the time when the transaction is posted in the account until presented for payment by the recipient. These earnings received by Glenmede are generally at money market rates.
If the Plan is invested in Glenmede’s affiliated mutual funds (The Glenmede Fund, Inc. or the Glenmede Portfolios) other fees may be charged. For example, The Glenmede Trust Company, N.A. has agreements with the Glenmede Funds to provide certain administrative services and receive compensation for these services. These fees are disclosed in the prospectus at page 3.
Conclusion
If you have any questions about this notice or your account with us, please contact your representative for information. You may also contact our Compliance Department at 215-419-6092.
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