r77q1e.txt
PIMCO Variable Insurance Trust
Approval of Renewal of the Amended and Restated Investment Advisory Contract,
Asset Allocation Sub-Advisory Agreements, and Supervision and
Administration Agreement
On August 15-16, 2011, the Board of Trustees (the "Board") of PIMCO Variable
Insurance Trust (the "Trust"), including all of the independent Trustees,
approved the Trust's Amended and Restated Investment Advisory Contract with
Pacific Investment Management Company LLC ("PIMCO"), on behalf of each of
the Trust's portfolios (the "Portfolios"), for an additional one-year term
through August 31, 2012. The Board also considered and approved for an
additional one-year term through August 31, 2012, the Supervision and
Administration Agreement (together with the Amended and Restated Investment
Advisory Contract, the "Agreements") with PIMCO, on behalf of the Portfolios.
The Board also considered and approved the renewal of the Asset Allocation
Sub-Advisory Agreements (the "Asset Allocation Agreements") with Research
Affiliates, LLC ("RALLC"), on behalf of the PIMCO All Asset Portfolio and
PIMCO All Asset All Authority Portfolio, each a series of the Trust, for
an additional one-year term through August 31, 2012.
The information, material factors and conclusions that formed the basis
for the Board's approvals of the Agreements and the Asset Allocation
Agreements are described below.
1. Information Received
A. Materials Reviewed
During the course of each year, the Trustees receive a wide variety of
materials relating to the services provided by PIMCO and RALLC. At each
of its quarterly meetings, the Board reviews the Portfolios' investment
performance and a significant amount of information relating to Portfolio
operations, including the Portfolios' compliance program, shareholder
services, valuation, custody, distribution, and other information relating
to the nature, extent and quality of services provided by PIMCO and RALLC
to the Trust. In considering whether to approve the renewal of the
Agreements and Asset Allocation Agreements, the Board also reviewed
supplementary information, including, but not limited to, comparative
industry data with regard to investment performance, advisory and
supervisory and administrative fees and expenses, financial and
profitability information regarding PIMCO and RALLC, information about the
personnel providing investment management services and supervisory and
administrative services to the Portfolios and, if available, information
about the fees charged and services provided by PIMCO to other clients
with similar investment mandates as the Portfolios. The Board also
reviewed material provided by counsel to the Trust and the independent
Trustees, which included, among other things, a memorandum outlining legal
duties of the Board in considering the continuation of the Agreements.
B. Review Process
In connection with the approval of the renewal of the Agreements and the
Asset Allocation Agreements, the Board reviewed written materials prepared
by PIMCO and RALLC in response to requests from counsel to the Trust.
The Board also requested and received assistance and advice regarding
applicable legal standards from Trust counsel, and reviewed comparative
fee and performance data prepared at the Board's request by Xxxxxx, Inc.
("Lipper"), an independent provider of investment company performance and
fee and expense data. The Board also heard oral presentations on matters
related to the Agreements and Asset Allocation Agreements and met both as
a full Board and as the independent Trustees, without management present,
at the August 15-16, 2011 meeting. The independent Trustees also met with
counsel to the Trust on August 4, 2011 to discuss the materials presented.
The approval determinations were made on the basis of each Trustee's
business judgment after consideration of all the information presented.
Individual Trustees may have given different weights to certain factors
and assigned various degrees of materiality to information received in
connection with the approval process. In deciding to approve the renewal
of the Agreements and Asset Allocation Agreements, the Board did not
identify any single factor or particular information that, in isolation,
was controlling. This summary describes the most important, but not all,
of the factors considered by the Board.
2. Nature, Extent and Quality of Services
X. XXXXX, RALLC, their Personnel, and Resources
The Board considered the depth and quality of PIMCO's investment
management process, including: the experience, capability and integrity
of its senior management and other personnel; the low turnover rates of
its key personnel; the overall financial strength and stability of its
organization; and the ability of its organizational structure to address
the recent growth in assets under management. The Board also considered
that PIMCO makes available to its investment professionals a variety of
resources and systems relating to investment management, compliance,
trading, performance and portfolio accounting. The Board considered
PIMCO's commitment to investing in information technology supporting
investment management and compliance, as well as PIMCO's continuing
efforts to attract and retain qualified personnel and to maintain and
enhance its resources and systems. The Board considered PIMCO's policies,
procedures and systems to assure compliance with applicable laws and
regulations and its commitment to these programs; its efforts to keep the
Trustees informed about matters relevant to the Portfolios and their
shareholders; and its attention to matters that may involve conflicts of
interest.
The Trustees considered the steps that PIMCO has taken in recent years
with respect to active management of counterparty risk, such as
implementing procedures requiring daily collateral adjustments and frequent
communication between credit analysts and the counterparty risk committee.
The Trustees considered that, over the last year, PIMCO has continued to
strengthen the process it uses to assess the financial stability of
broker-dealers with which the Portfolios do business, to manage collateral
and to protect portfolios from an unforeseen deterioration in the
creditworthiness of trading counterparties. The Trustees considered that
PIMCO continued to invest in automated documentation management systems to
better track trade documentation with broker-dealers.
The Trustees also considered new services and service enhancements that
PIMCO has implemented since the Agreements were last renewed in 2010,
including, but not limited to, undertaking significant technology
initiatives; broadening the PIMCO Retail Oversight ("PRO") group to
include oversight of institutional classes; implementing a quality
management system for processes/activities; converting to a prospectus
content management system; developing a "Pricing Portal" to streamline and
automate certain pricing functions; continuing to implement fair valuation
level assignments per FAS 157; planning to outsource net asset value
delivery to another service provider to accelerate delivery timing to
intermediaries; improving the review of Boston Financial Data Services'
large trade processing; implementing new cost basis reporting obligations;
and creating the PIMCO Risk Committee, which is the global risk oversight
committee at PIMCO.
Similarly, the Board considered the asset-allocation services provided by
RALLC to the PIMCO All Asset Portfolio. The Board noted that the PIMCO All
Asset All Authority Portfolio had not commenced offering shares as of the
date of the meeting. The Board considered the depth and quality of RALLC's
investment management and research capabilities, the experience and
capabilities of its portfolio management personnel, and in particular the
experience and capabilities of Xxxxxx Xxxxxx, RALLC's principal, and the
overall financial strength of the organization.
Ultimately, the Board concluded that the nature, extent and quality of
services proposed to be provided by PIMCO under the Agreements and by RALLC
under the Asset Allocation Agreements are likely to benefit the Portfolios
and their shareholders.
B. Other Services
The Board considered PIMCO's policies, procedures and systems to assure
compliance with applicable laws and regulations and its commitment to these
programs; its efforts to keep the Trustees informed about matters relevant
to each Portfolio and its shareholders; and its attention to matters that may
involve conflicts of interest. The Board also considered the nature, extent,
quality and cost of supervisory and administrative services provided by
PIMCO to the Portfolios under the Supervision and Administration Agreement.
The Board noted that the Supervision and Administration Agreement was
approved at the August 2008 Board meeting to replace the Trust's previous
Administration Agreement. The purpose of the change was to reflect the
increased scope and complexity of supervisory and administrative services
that PIMCO had been providing to the Trust. The Board considered the terms
of the Trust's Supervision and Administration Agreement, under which the
Trust pays for the supervisory and administrative services it requires under
what is essentially an all-in fee structure (the "unified fee"). In return,
PIMCO provides or procures supervisory and administrative services and bears
the costs of various third party services required by the Portfolios,
including audit, custodial, portfolio accounting, legal, transfer agency and
printing costs. The Board noted that the scope and complexity of the
supervisory and administrative services provided by PIMCO under the
Supervision and Administration Agreement continue to increase. The Board
considered PIMCO's provision of these services and supervision of the Trust's
third party service providers to assure that these service providers continue
to provide a high level of service relative to alternatives in the market.
Ultimately, the Board concluded that the nature, extent and quality of the
services provided by PIMCO has benefited and will likely continue to benefit
the Portfolios and their shareholders.
3. Investment Performance
The Board received and examined information from PIMCO concerning the
Portfolios' one-, three-, five- and ten-year performance, as available,
for the periods ended May 31, 2011 and other performance data, as available,
for the periods ended June 30, 2011 (the "PIMCO Report") and from Lipper
concerning the Portfolios' one-, three-, five-, and ten-year performance,
as available, for the periods ended May 31, 2011 (the "Lipper Report").
The Board considered information regarding both the short-term and long-term
investment performance of each Portfolio relative to its peer group and
relevant benchmark index as provided to the Board in advance of each of its
quarterly meetings throughout the year, including the PIMCO Report and the
Lipper Report, which were provided in advance of the August 15-16, 2011
meeting.
The Board noted that, for periods ending May 31, 2011, the Administrative
Class of 71%, 92% and 92% of the Portfolios outperformed their Lipper
category median in the one-year, three-year and five-year periods. The Board
considered that other classes of each Portfolio would have substantially
similar performance to that of the Administrative Class of the relevant
Portfolio on a relative basis because all of the classes are invested in the
same portfolio of securities and that differences in performance among
classes could principally be attributed to differences in the distribution
and servicing expenses of each class. The Board also considered that the
investment objectives of certain of the Portfolios may not always be
identical to those of the other funds in their respective peer groups and
that the Lipper categories do not separate funds based upon maturity or
duration, do not account for the Portfolios' hedging strategies, do not
distinguish between enhanced index and actively managed equity strategies,
do not include as many subsets as the Portfolios offer (i.e., Portfolios
may be placed in a "catch-all" category to which they do not properly belong)
and do not account for certain fee waivers. The Board noted that, due to
these differences, performance comparisons between certain of the Portfolios
and their so-called peers may be inexact.
The Board noted that 92% or more of the assets of the Trust had outperformed
their respective benchmarks on a net-of-fees basis over the three-year,
five-year and ten-year periods ending May 31, 2011 (based on the performance
of the Administrative Class). The Board also noted that ten of 12 Portfolios,
representing 94% of the total assets of the Trust, had outperformed their
respective benchmark index over the five-year period ending May 31, 2011.
The Board discussed actions that have been taken by PIMCO to improve
performance and took note of PIMCO's plans to monitor performance going
forward. The Board also considered that the Trust has experienced an increase
in net assets, with assets managed within the Trust exceeding $18.5 billion
as of June 30, 2011.
The Board considered the intensive nature of managing bond funds, noting that
it requires a number of factors, including, varying maturities, prepayments,
collateral management, counter-party management, pay-downs, credit events,
workouts, derivatives and net new issuance in the bond market. Despite these
challenges, the Board noted that PIMCO has generated "alpha" (i.e., non-market
correlated excess performance) for its clients, including the Trust.
The Board ultimately determined, within the context of all of its
considerations in connection with the Agreements, that the Trust's overall
investment performance was strong, and concluded that PIMCO's performance
record and process in managing the Portfolios indicates that its continued
management is likely to benefit the Portfolios and their shareholders, and
merits the approval of the continuation of the Agreements.
4. Advisory Fees, Supervisory and Administrative Fees and Total Expenses
The Board considered that PIMCO strives to price funds with total expense
ratios at or below the respective Lipper median, while providing premium
investment offerings. PIMCO reported to the Board that, in proposing fees
for any Portfolio or class of shares, it considers a number of factors,
including the type and complexity of the services provided, the cost of
providing services, the risk assumed by PIMCO in the provision of services,
the impact on potential returns from different levels of fees, the competitive
marketplace for financial products, and the attractiveness of potential
Portfolio returns to current and potential investors. Fees charged to or
proposed for different Portfolios for advisory services and supervisory and
administrative services may vary in light of these various factors.
The Board also noted that PIMCO reviews the Portfolios' fee levels and
carefully considers reductions where appropriate.
The Board reviewed the advisory fees, supervisory and administrative fees
and total expenses of the Portfolios (each as a percentage of average net
assets) and compared such amounts with the average and median fee and
expense levels of other similar funds. With respect to advisory fees, the
Board reviewed data from Lipper that compared the average and median
advisory fees of other funds in an "Expense Group" of comparable funds, as
well as the universe of other similar funds. The Board noted that most
Portfolios have total expense ratios that fall below the median expenses of
their Lipper universe.
The Board also reviewed data comparing the Portfolios' advisory fees to the
standard fee rate PIMCO charges to separate accounts and other investment
companies with a similar investment strategy, and found them to be comparable.
The Trustees noted that the advisory fees for the Portfolios were the same or
lower than PIMCO separate account fees in nine out of 14 strategies.
In cases where the fees for other clients were lower than those charged to
the Portfolios, the Trustees noted that the differences in fees were
attributable to various factors, including differences in the services provided
by PIMCO to the Portfolios, the manner in which similar portfolios may be
managed, different requirements with respect to liquidity management and the
implementation of other regulatory requirements, and the fact that separate
accounts may have other contractual arrangements that justify different levels
of fees.
The Board also considered the Portfolios' supervisory and administrative fees,
comparing them to similar funds in the report supplied by Xxxxxx. The Board
considered that as the Portfolios' business has become increasingly complex,
PIMCO has provided an increasingly broad array of fund supervisory and
administrative functions. The Board considered the Trust's unified fee
structure, under which each Portfolio pays for the supervisory and
administrative services it requires for one set fee, and in return, PIMCO
provides or procures supervisory and administrative services and bears the
costs of various third party services required by the Portfolios, including
audit, custodial, portfolio accounting, legal, transfer agency and printing
costs. The Board noted that many other funds pay for these services
separately, and thus it is difficult to directly compare the Portfolios'
unified supervisory and administrative fees with the fees paid by other funds
for administrative services alone. The Board considered that the unified
supervisory and administrative fee leads to fund fees that are fixed, rather
than variable, and that the fixed fees were viewed by many in the industry
as a positive attribute of the Portfolios. The Board concluded that the
Portfolios' supervisory and administrative fees were reasonable in relation
to the value of the services provided, including the services provided to
different classes of shareholders, and that the expenses assumed
contractually by PIMCO under the Supervision and Administration Agreement
represent, in effect, a cap on overall fund expenses which is beneficial to
the Portfolios and their shareholders.
With respect to overall levels of Portfolio expenses, the Board observed
that bond funds are more fee- and expense-ratio sensitive than equity funds,
given the tangible impact of fees and expenses on yield, and that investors
appear to be satisfied with the Portfolios' performance, as evidenced by
the continued growth in Portfolio assets. The Board noted that the total
expenses for the Administrative Class shares of most of the Portfolios falls
below the median total expense of their respective Lipper Expense Group.
The Board discussed with PIMCO those Portfolios and/or classes of Portfolios
that have above median expenses. The Board noted that several Portfolios
launched in recent years have been unique products that have few, if any
peers, and cannot easily be grouped with comparable funds. Upon comparing
the Portfolios' total expenses to other funds in the Expense Groups provided
by Xxxxxx, the Board found the Portfolios' total expenses to be reasonable.
The Trustees also considered the advisory fees charged to the Portfolios
that operate as funds of funds (the "Funds of Funds") and the advisory
services provided in exchange for such fees. The Trustees determined that
such services were in addition to the advisory services provided to the
underlying series in which the Funds of Funds may invest and, therefore,
such services were not duplicative of the advisory services provided to the
underlying series. The Board also considered the various fee waiver
agreements in place for the Funds of Funds.
The Board noted that, with few exceptions, PIMCO has maintained Portfolio
fees at the same guaranteed level as implemented when the unified fee was
adopted, and has reduced fees on a number of Portfolios in prior years. The
Board further noted that, although the unified fee structure does not have
break points, it implicitly reflects economies of scale by fixing the
absolute level of Portfolio fees at competitive levels even if the Portfolios'
operating costs rise when assets remain flat or decrease over time.
Based on the information presented by PIMCO, RALLC and Lipper, members of
the Board then determined, in the exercise of their business judgment, that
the level of the advisory fees and supervisory and administrative fees
charged by PIMCO under the Agreements, as well as the total expenses of the
Portfolios, are reasonable and renewal of the Agreements and the Asset
Allocation Agreements will likely benefit the Portfolios and their
shareholders.
5. Adviser Costs, Level of Profits and Economies of Scale
The Board reviewed information regarding PIMCO's costs of providing services
to the Portfolios as a whole, as well as the resulting level of profits to
PIMCO, noting that those results were similar to the previous year, and
within the ranges, but above the median of publicly held investment
management companies reported by Xxxxxx and Strategic Insight. The Board
noted that it had also received information regarding the structure and
manner in which PIMCO's investment professionals were compensated, and
PIMCO's view of the relationship of such compensation to the attraction and
retention of quality personnel. The Board considered PIMCO's need to invest
in technology, infrastructure and staff to reinforce and offer new services
and to accommodate changing regulatory requirements.
With respect to potential economies of scale, the Board found that because
the unified fee protects shareholders against unanticipated increases in
expense ratios due to redemptions, declines in asset values, or increases in
the costs of services provided or procured by PIMCO, economies of scale are
implicitly recognized in the level of the unified fee (which, together with
the advisory fee, serves as a proxy for each Portfolio's overall expense
ratio). The Board noted that PIMCO may share the benefits of economies of
scale with the Portfolios and their shareholders in a number of ways,
including through fee reductions or waivers, the pricing of funds to scale
from inception and the enhancement of services provided in return for fees
paid. The Trustees also considered that the unified fee has provided
inherent economies of scale by maintaining fixed fees even if a particular
Portfolio's operating costs rise. The Board reviewed the history of the
Portfolios' fee structure, noting that the unified supervisory and
administrative services fee was an extension of the initial "expense guarantee"
under which PIMCO had agreed to maintain the expense ratio of each Portfolio
at specified levels for a period of time to make the Portfolios attractive to
an institutional shareholder base. The Board noted that additional Portfolios
and share classes have been "built" on that institutional platform, which has
meant that, overall, the Portfolios have traditionally had lower fees than
many competitors. The Board noted that, in general, fee rates for the
Portfolios had been set competitively, had been reduced for some Portfolios
over time, had been held steady for most Portfolios as assets grew and
continued to be competitive compared with peers. Finally, the Board
considered that during the recent market downturn the Portfolios' unified
fee has protected shareholders against an increase in expenses that may
accompany declines in assets.
The Board concluded that the Portfolios' cost structure was reasonable and
that the unified fee structure inherently involves the sharing of economies
of scale between PIMCO and the Portfolios, to the benefit of Portfolio
shareholders.
6. Ancillary Benefits
The Board considered other benefits received by PIMCO and its affiliates as a
result of PIMCO's relationship with the Trust, including possible ancillary
benefits to PIMCO's institutional investment management business due to the
reputation and market penetration of the Portfolios. The Board also considered
that affiliates of PIMCO provide distribution and shareholder services to the
Portfolios and their shareholders, for which they may be compensated under the
unified fee, or through distribution fees paid pursuant to the Portfolios'
Rule 12b-1 plans. The Board reviewed PIMCO's soft dollar policies and
procedures, noting that while PIMCO has the authority to receive the benefit of
research provided by broker-dealers executing portfolio transactions on behalf
of the Portfolios, it has adopted a policy not to enter into contractual soft
dollar arrangements.
7. Conclusions
Based on its review, including its consideration of each of the factors
referred to above, the Board concluded that the nature, extent and quality of
the services rendered to the Portfolios by PIMCO and RALLC continued to be
excellent and favored the renewal of the Agreements and the Asset Allocation
Agreements. The Board concluded that the Agreements and the Asset Allocation
Agreements continued to be fair and reasonable to the Portfolios and their
shareholders, that the Portfolios' shareholders received reasonable value in
return for the fees paid to PIMCO by the Portfolios under the Agreements, and
the fees paid to RALLC by PIMCO under the Asset Allocation Agreements, and
that the renewal of the Agreements and the Asset Allocation Agreements was in
the best interests of the Portfolios and their shareholders.
SUPPLEMENT TO AMENDED AND RESTATED
INVESTMENT ADVISORY CONTRACT
PIMCO Variable Insurance Trust
000 Xxxxxxx Xxxxxx Xxxxx
Xxxxxxx Xxxxx, Xxxxxxxxxx 00000
November 8, 2011
Pacific Investment Management Company LLC
000 Xxxxxxx Xxxxxx Xxxxx
Xxxxxxx Xxxxx, Xxxxxxxxxx 00000
RE: PIMCO Global Multi-Asset Managed Volatility
Portfolio (the "Portfolio")
Dear Sirs:
This will confirm the agreement between the undersigned
(the "Trust") and Pacific Investment Management Company
LLC (the "Adviser") as follows:
1. This Trust is an open-end investment company
organized as a Delaware statutory trust, and
consisting of such investment portfolios as
have been or may be established by the Trustees
of the Trust from time to time. A separate
series of shares of beneficial interest of the
Trust is offered to investors with respect to
each investment portfolio. The Portfolio is a
separate investment portfolio of the Trust.
2. The Trust and the Adviser have entered into an
Amended and Restated Investment Advisory Contract
("Contract") dated February 23, 2009 pursuant to
which the Trust has employed the Adviser to provide
investment advisory and other services specified
in the Contract, and the Adviser has accepted such
employment. As provided in the Contract, the parties
may amend the Contract to add additional series of
the Trust, under the same terms and conditions as
set forth in the Contract, and at fee rates set forth
in Exhibit A to the Contract, as may be amended from
time to time.
3. The Trust and the Adviser hereby agree to amend the
Contract as of the date hereof to add the Portfolio
to Exhibit A and make certain other changes to Exhibit A.
The current Exhibit A is replaced with the new Exhibit A
attached hereto.
4. This Supplement and the Contract shall become effective
with respect to the Portfolio on November 8, 2011 and
shall continue in effect with respect to the Portfolio
for a period of more than two years from that date only
so long as the continuance is specifically approved at
least annually (a) by the vote of a majority of the
outstanding voting securities (as defined in the 1940 Act)
of the Portfolio or by the Trust's Board of Trustees and
(b) by the vote, cast in person at a meeting called for
the purpose, of a majority of the Trust's trustees who
are not parties to this Contract or "interested persons"
(as defined in the 1940 Act) of any such party. This
Contract may be terminated with respect to the Portfolio
at any time, without the payment of any penalty, by a vote
of a majority of the outstanding voting securities (as defined
in the 1940 Act) of the Portfolio or by a vote of a majority
of the Trust's entire Board of Trustees, on 60 days' written
notice to the Adviser or by the Adviser on 60 days' written
notice to the Trust. This Contract shall terminate
automatically in the event of its assignment (as defined
in the 1940 Act).
If the foregoing correctly sets forth the agreement between the Trust
and the Adviser, please so indicate by signing and returning to
the Trust the enclosed copy hereof.
Very truly yours,
PIMCO VARIABLE INSURANCE TRUST
By: /s/ Xxxxx X. Xxxxxxx__________________
Title: Vice President
ACCEPTED:
PACIFIC INVESTMENT MANAGEMENT COMPANY LLC
By: /s/ Xxxxx X. Xxxxxx__________________________
Title: Managing Director
PIMCO FUNDS, on behalf of its series PIMCO Funds: Private
Account Portfolio Series - PIMCO Short-Term Floating NAV Portfolio
By: /s/ Xxxxx X. Xxxxxxx
Title: Vice President
Investment Advisory Contract
EXHIBIT A
(as of November 8, 2011)
PIMCO Variable Insurance Trust
________________________________________
Investment
Portfolio Advisory Fee#
---------------------------------------------- -------------
All Asset Portfolio 0.175%
All Asset All Authority Portfolio 0.20%
CommodityRealReturn Strategy Portfolio 0.49%
Diversified Income Portfolio 0.45%
Emerging Markets Bond Portfolio 0.45%
Foreign Bond Portfolio (Unhedged) 0.25%
Foreign Bond Portfolio (U.S. Dollar-Hedged) 0.25%
Global Advantage Strategy Bond Portfolio 0.40%
Global Bond Portfolio (Unhedged) 0.25%
Global Multi-Asset Managed Volatility Portfolio 1.00%
Global Multi-Asset Portfolio 0.90%
High Yield Portfolio 0.25%
Long-Term U.S. Government Portfolio 0.225%
Low Duration Portfolio 0.25%
Money Market Portfolio 0.12%
Real Return Portfolio 0.25%
Short-Term Portfolio 0.25%
Total Return Portfolio 0.25%
Unconstrained Bond Portfolio 0.60%
# Each Portfolio may invest in shares of PIMCO
Funds: Private Account Portfolio Series - PIMCO
Short-Term Floating NAV Portfolio, a series of
PIMCO Funds ("PAPS Short-Term Floating NAV
Portfolio"). PAPS Short-Term Floating NAV
Portfolio is offered only to series of the
Trust (each an "Investing Fund") or other series
of registered investment companies for which PIMCO
serves as investment adviser. PAPS Short-Term
Floating NAV Portfolio does not pay an investment
advisory fee to PIMCO. By investing in the PAPS
Short-Term Floating NAV Portfolio, each Investing
Fund agrees that 0.01% of the fee that each
Investing Fund is currently obligated to pay PIMCO
as indicated on this Exhibit A, will be designated
as compensation for the investment advisory services
PIMCO provides to PAPS Short-Term Floating NAV
Portfolio under its investment advisory contract
with PIMCO.
