SUBADVISORY AGREEMENT
Exhibit 28(d)(xxxv)
This SUBADVISORY AGREEMENT is dated as of March 29, 2010 by and between SUNAMERICA ASSET
MANAGEMENT CORP., a Delaware corporation (the “Adviser”), and PINEBRIDGE INVESTMENTS, LLC, a
Delaware limited liability company (the “Subadviser”).
WITNESSETH:
WHEREAS, the Adviser and Seasons Series Trust, a Massachusetts business trust (“SST”), have
entered into an Investment Advisory and Management Agreement dated as of January 1, 1999, as
amended from time to time (the “SST Advisory Agreement”), pursuant to which the Adviser has agreed
to provide investment management, advisory and administrative services to SST; and pursuant to it
which the Adviser may delegate one or more of its duties to a subadviser pursuant to a written
subadvisory agreement; and
WHEREAS, the Adviser and SunAmerica Series Trust, a Massachusetts business trust (“SAST,” and
collectively with SST, the “Trusts”), have entered into an Investment Advisory and Management
Agreement dated as of January 1, 1999, as amended from time to time (the “SAST Advisory Agreement,”
and collectively with the SST Advisory Agreement, the “Advisory Agreements”), pursuant to which the
Adviser has agreed to provide investment management, advisory and administrative services to SAST;
and pursuant to it which the Adviser may delegate one or more of its duties to a subadviser
pursuant to a written subadvisory agreement; and
WHEREAS, the Trusts are registered under the Investment Company Act of 1940, as amended (the
“Act”), as open-end management investment companies and may issue shares of beneficial interest (
par value $.01 per share in the case of SST), in separately designated portfolios representing
separate funds with their own investment objectives, policies and purposes; and
WHEREAS, the Subadviser is engaged in the business of rendering investment advisory services
and is registered as an investment adviser under the Investment Advisers Act of 1940, as amended;
and
WHEREAS, the Adviser desires to retain the Subadviser to furnish investment advisory services
to the investment portfolio or portfolios of the Trusts listed on Schedule A attached hereto (the
“Portfolio(s)”), and the Subadviser is willing to furnish such services;
NOW, THEREFORE, it is hereby agreed between the parties hereto as follows:
1. Duties of the Subadviser. (a) The Adviser hereby engages the services of the
Subadviser in furtherance of its Advisory Agreements with the Trusts. Pursuant to this Subadvisory
Agreement and subject to the oversight and review of the Adviser, the Subadviser will manage the
investment and reinvestment of a portion of the assets of each Portfolio listed on
Schedule A attached hereto. The Subadviser will determine, in its discretion and subject to
the oversight and review of the Adviser, the securities and other investments to be purchased or
sold, will provide the Adviser with records concerning its activities which the Adviser or the
Trusts are required to maintain, and will render regular reports to the Adviser and to officers and
Trustees of the Trusts concerning its discharge of the foregoing responsibilities. The Subadviser
shall discharge the foregoing responsibilities subject to the control of the officers and the
Trustees of the Trusts and in compliance with such policies as the Trustees of the Trusts may from
time to time establish and communicate to the Subadviser, and in compliance with (a) the
objectives, policies, and limitations for the Portfolio(s) set forth in the Trusts’ current
prospectus and statement of additional information as provided to the Subadviser, and (b)
applicable laws and regulations.
The Subadviser represents and warrants to the Adviser that the portion of assets allocated to
it of each of the Portfolios set forth in Schedule A will at all times be operated and managed (1)
in compliance with all applicable federal and state laws governing its operations and investments;
(2) so as not to jeopardize either the treatment of the variable annuity contracts which offer the
Portfolio(s) (the “Contracts”) as annuity contracts for purposes of the Internal Revenue Code of
1986, as amended (the “Code”), or the eligibility of the Contracts to qualify for sale to the
public in any state where they may otherwise be sold; and (3) to minimize any taxes and/or
penalties payable by the Trusts or such Portfolio. Without limiting the foregoing, and subject to
Section 9(c) hereof, the Subadviser represents and warrants to the Adviser that all of, or to the
extent applicable the portion of, the assets which it manages of the Portfolio(s) set forth in
Schedule A will at all times be operated and managed in compliance with (a) all applicable federal
and state laws, including securities, commodities and banking laws, governing its operations and
investments; (b) applicable provisions of Subchapter M, chapter 1 of the Code (“Subchapter M”) for
each Portfolio to be treated as a “regulated investment company” under Subchapter M; (c) the
diversification requirements specified in the Internal Revenue Service’s regulations under Section
817(h) of the Code so as not to jeopardize the treatment of the variable annuity contracts that
offer the Portfolios as annuity contracts for purposes of the Code; (d) the distribution
requirements necessary to avoid payment of any excise tax pursuant to Section 4982 of the Code;
(e) the provisions of the 1940 Act and rules adopted thereunder; (f) the objectives, policies,
restrictions and limitations for the Portfolios as set forth in the Portfolios’ current prospectus
and statement of additional information as most recently provided by the Adviser to the Subadviser;
and (g) the policies and procedures as adopted by the Trusts, as most recently provided by the
Adviser to the Subadviser. The Subadviser shall furnish information to the Adviser, as requested,
for purposes of compliance with the distribution requirements necessary to avoid payment of any
excise tax pursuant to Section 4982 of the Code. The Subadviser also represents and warrants that
in furnishing services hereunder, the the Subadviser will not consult with any other subadviser of
the Portfolios or other series of the Trusts, to the extent any other subadvisers are engaged by
the Adviser, or any other subadvisers to other investments companies that are under common control
with the Trusts, concerning transactions of the Portfolios in securities or other assets, other
than for purposes of complying with the conditions of paragraphs (a) and (b) of rule 12d3-1 under
the Act. The Subadviser further represents and warrants that to the extent that any statements or
omissions made in any Registration Statement for the Contracts or shares of the Trusts, or any
amendment or supplement thereto, are made in reliance upon and in conformity with information
furnished by the Subadviser expressly for use therein, such Registration Statement and any
amendments or supplements thereto will, when they become
- 2 -
effective, conform in all material respects to the requirements of the Securities Act of 1933
and the rules and regulations of the Commission thereunder (the “1933 Act”) and the Act and will
not contain any untrue statement of a material fact or omit to state any material fact required to
be stated therein or necessary to make the statements therein not misleading.
The Subadviser accepts such employment and agrees, at its own expense, to render the services
set forth herein and to provide the office space, furnishings, equipment and personnel required by
it to perform such services on the terms and for the compensation provided in this Agreement.
(b) The Subadviser agrees: (i) to maintain a level of errors and omissions or professional
liability insurance coverage that, at all times during the course of this Agreement, is
satisfactory to the Adviser, and (ii) from time to time and upon reasonable request, to supply
evidence of such coverage to the Adviser.
The Adviser and Subadviser each agree that Subadviser shall manage the portion of the assets
of a Portfolio allocated to it as if it was a separate operating portfolio and shall comply with
subsections (a) and (b) of this Section 1 of this Subadvisory Agreement (including, but not limited
to, the investment objectives, policies and restrictions applicable to a Portfolio and
qualifications of a Portfolio as a regulated investment company under the Code) with respect to the
portion of assets of a Portfolio allocated to Subadviser.
The Subadviser will assist the Portfolio(s) and its agents in determining whether prices
obtained for valuation purposes accurately reflect the prices on the Subadviser’s portfolio records
relating to the assets of the Portfolio(s) for which the Subadviser has responsibility at such
times as the Adviser shall reasonably request; provided, however, that the parties acknowledge that
the Subadviser is not the fund accounting agent for the Portfolio(s) and is not responsible for
pricing determinations or calculations and any information provided pursuant to this position by
the Subadviser will be provided for information purposes only.
2. Portfolio Transactions. (a) The Subadviser is responsible for decisions, and is
hereby authorized, to buy or sell securities and other investments for a portion of the assets of
each Portfolio, broker-dealers and futures commission merchants’ selection, and negotiation of
brokerage commission and futures commission merchants’ rates. As a general matter, in executing
portfolio transactions, the Subadviser may employ or deal with such broker-dealers or futures
commission merchants as may, in the Subadviser’s best judgement, provide prompt and reliable
execution of the transactions at favorable prices and reasonable commission rates. In selecting
such broker-dealers or futures commission merchants, the Subadviser shall consider all relevant
factors including price (including the applicable brokerage commission, dealer spread or futures
commission merchant rate), the size of the order, the nature of the market for the security or
other investment, the timing of the transaction, the reputation, experience and financial stability
of the broker-dealer or futures commission merchant involved, the quality of the service, the
difficulty of execution, the execution capabilities and operational facilities of the firm
involved, and, in the case of securities, the firm’s risk in positioning a block of securities.
Subject to such policies as the Trustees may determine and, consistent with Section 28(e) of the
Securities Exchange Act of 1934, as amended (the “1934 Act”), the Subadviser shall not be deemed to
have acted unlawfully or to have breached any duty created by this Agreement or
- 3 -
otherwise solely by reason of the Subadviser’s having caused a Portfolio to pay a member of an
exchange, broker or dealer an amount of commission for effecting a securities transaction in excess
of the amount of commission another member of an exchange, broker or dealer would have charged for
effecting that transaction, if the Subadviser determines in good faith that such amount of
commission was reasonable in relation to the value of the brokerage and research services provided
by such member of an exchange, broker or dealer viewed in terms of either that particular
transaction or the Subadviser’s overall responsibilities with respect to such Portfolio and to
other clients as to which the Subadviser exercises investment discretion. In accordance with
Section 11(a) of the 1934 Act and Rule 11a2-2(T) thereunder, and subject to any other applicable
laws and regulations including Section 17(e) of the Act and Rule 17e-1 thereunder, the Subadviser
may engage its affiliates, the Adviser and its affiliates or any other subadviser to the Trusts and
their respective affiliates, as broker-dealers or futures commission merchants to effect portfolio
transactions in securities and other investments for a Portfolio. The Subadviser will promptly
communicate to the Adviser and to the officers and the Trustees of the Trusts such information
relating to portfolio transactions as they may reasonably request. To the extent consistent with
applicable law, the Subadviser may aggregate purchase or sell orders for the Portfolio with
contemporaneous purchase or sell orders of other clients of the Subadviser or its affiliated
persons. In such event, allocation of the securities so purchased or sold, as well as the expenses
incurred in the transaction, will be made by the Subadviser in the manner the Subadviser determines
to be equitable and consistent with its and its affiliates’ fiduciary obligations to the Portfolio
and to such other clients. The Adviser hereby acknowledges that such aggregation of orders may not
result in more favorable pricing or lower brokerage commissions in all instances.
(b) Notwithstanding Section 2(a) above, for such purposes as obtaining investment research
products and services, covering fees and expenses, the Adviser may direct the Subadviser to effect
a specific percentage of a Portfolio’s transactions in securities and other investments to certain
broker-dealers and futures commission merchants’. In designating the use of a particular
broker-dealer or futures commission merchant, the Adviser and Subadviser acknowledge:
(1) | All brokerage transactions are subject to best execution. As such, Subadviser will use its best efforts to direct non-risk commission transactions to a particular broker-dealer or futures commission merchant designated by the Adviser provided that the Subadviser seek to obtain best execution; | ||
(2) | Such direction may result in the Portfolio paying a higher commission, depending upon the Subadviser’s arrangements with the particular broker-dealer or futures commission merchant, or such other factors as market conditions, share values, capabilities of the particular broker-dealer or futures commission merchant, etc.; | ||
(3) | If the Subadviser directs payments of an excessive amount of commissions, the executions may not be accomplished as rapidly. In addition, the Subadviser may forfeit the possible advantage derived from the aggregation of multiple orders as a single “bunched” transaction where the Subadviser would, in some instances, be in a better position to negotiate commissions; and |
- 4 -
(4) | The Subadviser does not make commitments to allocate fixed or definite amounts of commissions to brokers. As such the Subadviser may be unable to fulfill the Adviser’s request for direction due to the reasons stated above. |
3. Compensation of the Subadviser. The Subadviser shall not be entitled to receive
any payment from the Trusts and shall look solely and exclusively to the Adviser for payment of all
fees for the services rendered, facilities furnished and expenses paid by it hereunder. As full
compensation for the Subadviser under this Agreement, the Adviser agrees to pay to the Subadviser a
fee at the annual rates set forth in Schedule A hereto with respect to the portion of the assets
managed by the Subadviser for each Portfolio listed thereon. Such fee shall be accrued daily and
paid monthly as soon as practicable after the end of each month (i.e., the applicable annual fee
rate divided by 365 applied to each prior days’ net assets in order to calculate the daily
accrual). For purposes of calculating the Subadviser’s fee, the average daily net asset value of a
Portfolio shall mean the average daily net assets for which the Subadviser actually provides
advisory services, and shall be determined by taking an average of all determinations of such net
asset value during the month. If the Subadviser shall provide its services under this Agreement
for less than the whole of any month, the foregoing compensation shall be prorated. The Adviser
and Subadviser acknowledge that the Portfolio will be ultimately responsible for all brokerage
commissions, taxes, custodian fees and any other transaction-related fees, but that, for the
purposes of this Agreement, as between the Adviser and Subadviser, the Adviser will be responsible
for such expenses, and the Adviser authorizes the Subadviser to incur and pay such expenses for the
Portfolio, as deemed appropriate by the Subadviser.
4. Other Services. At the request of the Trusts or the Adviser, the Subadviser in its
discretion may make available to the Trusts, office facilities, equipment, personnel and other
services in order to facilitate meetings or other similar functions. Such office facilities,
equipment, personnel and services shall be provided for or rendered by the Subadviser and billed to
the Trusts or the Adviser at the Subadviser’s cost.
5. Reports. The Trusts, the Adviser and the Subadviser agree to furnish to each
other, if applicable, current prospectuses, statements of additional information, proxy statements,
reports of shareholders, certified copies of their financial statements, and such other information
with regard to their affairs and that of the Trusts as each may reasonably request.
6. Status of the Subadviser. The services of the Subadviser to the Adviser and the
Trusts are not to be deemed exclusive, and the Subadviser shall be free to render similar services
to others so long as its services to the Trusts are not impaired thereby. The Subadviser shall be
deemed to be an independent contractor and shall, unless otherwise expressly provided or
authorized, have no authority to act for or represent the Trusts in any way or otherwise be deemed
an agent of the Trusts.
7. Certain Records. The Subadviser hereby undertakes and agrees to maintain, in the
form and for the period required by Rule 31a-2 under the Act, all records relating to the
investments of the Portfolio(s) that are required to be maintained by the Trusts pursuant to the
requirements of Rule 31a-1 of that Act. Any records required to be maintained and preserved
pursuant to the provisions of Rule 31a-1 and Rule 31a-2 promulgated under the Act which are
prepared or maintained by the Subadviser on behalf of the Trusts are the property of the
- 5 -
respective Trust and will be surrendered promptly to the respective Trust or the Adviser on
request.
The Subadviser agrees that all accounts, books and other records maintained and preserved by
it as required hereby shall be subject at any time, and from time to time, to such reasonable
periodic, special and other examinations by the Securities and Exchange Commission, each Trust’s
auditors, each Trust or any representative of the Trusts, the Adviser, or any governmental agency
or other instrumentality having regulatory authority over the Trusts.
8. Reference to the Subadviser. Neither the Trusts nor the Adviser or any affiliate
or agent thereof shall make reference to or use the name or logo of the Subadviser or any of its
affiliates in any advertising or promotional materials without the prior approval of the
Subadviser, which approval shall not be unreasonably withheld.
9. Liability of the Subadviser. (a) In the absence of willful misfeasance, bad faith,
gross negligence or reckless disregard of obligations or duties (“disabling conduct”) hereunder on
the part of the Subadviser (and its officers, directors, agents, employees, controlling persons,
shareholders and any other person or entity affiliated with the Subadviser) the Subadviser shall
not be subject to liability to the Trust or to any shareholder of the Trust for any act or omission
in the course of, or connected with, rendering services hereunder, including without limitation,
any error of judgment or mistake of law or for any loss suffered by any of them in connection with
the matters to which this Agreement relates, except to the extent specified in Section 36(b) of the
Act concerning loss resulting from a breach of fiduciary duty with respect to the receipt of
compensation for services. Except for such disabling conduct, the Adviser shall indemnify the
Subadviser (and its officers, directors, partners, agents, employees, controlling persons,
shareholders and any other person or entity affiliated with the Subadviser) (collectively, the
“Indemnified Parties”) from any liability arising from the Subadviser’s conduct under this
Agreement.
(b) The Subadviser agrees to indemnify and hold harmless the Adviser, its officers, directors,
partners, agents, employees, controlling persons, shareholders and any other person or entity
affiliated with the Adviser, if any, who controls the Adviser within the meaning of Section 15 of
the 1933 Act against any and all losses, claims, damages, liabilities or litigation (including
legal and other expenses), to which the Adviser, its officers, directors, partners, agents,
employees, controlling persons, shareholders and any other person or entity affiliated with the
Adviser may become subject under the 1933 Act, under other statutes, at common law or otherwise,
which may be based upon (i) any wrongful act or breach of this Agreement by the Subadviser, or (ii)
any failure by the Subadviser to comply with the representations and warranties set forth in
Section 1 of this Agreement; provided, however, that in no case is the Subadviser’s indemnity in
favor of any person deemed to protect such other persons against any liability to which such person
would otherwise be subject by reasons of willful misfeasance, bad faith, or gross negligence in the
performance of his, her or its duties or by reason of his, her or its reckless disregard of
obligation and duties under this Agreement.
(c) The Subadviser shall not be liable to the Adviser, its officers, directors, agents,
employees, controlling persons, shareholders or to the Trust or to any shareholder of the Trust or
to any third party for (i) any acts of the Adviser or any other subadviser to the Portfolio
- 6 -
with respect to the portion of the assets of a Portfolio not managed by Subadviser and (ii)
acts of the Subadviser which result from or are based upon acts of the Adviser, including, but not
limited to: (A), a failure of the Adviser to provide accurate and current information with respect
to any records maintained by Adviser or any other subadviser to a Portfolio, which records are not
also maintained by or otherwise available to the Subadviser upon reasonable request; and (B) acts
of the Subadviser that were made in reasonable reliance upon information provided to it by the
Adviser. The Adviser shall indemnify the Indemnified Parties from any and all losses, claims,
damages, liabilities or litigation (including reasonable legal and other expenses) arising from the
conduct of the Adviser, the Trust and any other subadviser with respect to the portion of a
Portfolio’s assets not allocated to the Subadviser and with respect to any other portfolio of the
Trust.
10. Permissible Interests. Trustees and agents of the Trusts are or may be interested
in the Subadviser (or any successor thereof) as directors, partners, officers, or shareholders, or
otherwise; directors, partners, officers, agents, and shareholders of the Subadviser are or may be
interested in the Trusts as trustees, or otherwise; and the Subadviser (or any successor) is or may
be interested in the Trusts in some manner.
11. Term of the Agreement. This Agreement shall continue in full force and effect
with respect to each Portfolio until two years from the date hereof, and from year to year
thereafter so long as such continuance is specifically approved at least annually (i) by the vote
of a majority of those Trustees of each Trust who are not parties to this Agreement or interested
persons of any such party, cast in person at a meeting called for the purpose of voting on such
approval, and (ii) by the Trustees of the respective Trust or by vote of a majority of the
outstanding voting securities of the Portfolio voting separately from any other series of the
respective Trust.
With respect to each Portfolio, this Agreement may be terminated at any time, without payment
of a penalty by the Portfolio or a Trust, by vote of a majority of the respective Trustees, or by
vote of a majority of the outstanding voting securities (as defined in the Act) of the Portfolio,
voting separately from any other series of the respective Trust, or by the Adviser, on not less
than 30 nor more than 60 days’ written notice to the Subadviser. With respect to each Portfolio,
this Agreement may be terminated by the Subadviser at any time, without the payment of any penalty,
on 90 days’ written notice to the Adviser and the respective Trust; provided, however, that this
Agreement may not be terminated by the Subadviser unless another subadvisory agreement has been
approved by the respective Trust in accordance with the Act, or after six months’ written notice,
whichever is earlier. The termination of this Agreement with respect to any Portfolio or the
addition of any Portfolio to Schedule A hereto (in the manner required by the Act) shall not affect
the continued effectiveness of this Agreement with respect to each other Portfolio subject hereto.
This Agreement shall automatically terminate in the event of its assignment (as defined by the
Act).
This Agreement will also terminate in the event that the Advisory Agreement by and between a
Trust and the Adviser is terminated.
12. Severability. This Agreement constitutes the entire Agreement between the parties
hereto. If any provision of this Agreement shall be held or made invalid by a court
- 7 -
decision, statute, rule or otherwise, the remainder of this Agreement shall not be affected
thereby.
13. Amendments. This Agreement may be amended by mutual consent in writing, but the
consent of each Trust must be obtained in conformity with the requirements of the Act.
14. Governing Law. This Agreement shall be construed in accordance with the laws of
the State of New York and the applicable provisions of the Act. To the extent the applicable laws
of the State of New York, or any of the provisions herein, conflict with the applicable provisions
of the Act, the latter shall control.
15. Personal Liability. The Declarations of Trust establishing each Trust (each, a
“Declaration” and collectively, the “Declarations”), are on file in the office of the Secretary of
the Commonwealth of Massachusetts, and, in accordance with each Declaration, no Trustee,
shareholder, officer, employee or agent of the respective Trust shall be held to any personal
liability, nor shall resort be had to their private property for satisfaction of any obligation or
claim or otherwise in connection with the affairs of the respective Trust, but the respective
“Trust Property” only shall be liable.
16. Separate Series. Pursuant to the provisions of the Declarations, each Portfolio
is a separate series of each Trust, and all debts, liabilities, obligations and expenses of a
particular Portfolio shall be enforceable only against the assets of that Portfolio and not against
the assets of any other Portfolio or of the respective Trust as a whole.
17. Proxy Voting. The Adviser will vote proxies relating to the Portfolios’
securities. The Adviser will vote all such proxies in accordance with such proxy voting guidelines
and procedures adopted by the Board of Trustees of each Trust. The Adviser may, on certain
non-routine matters, consult with the Subadviser before voting proxies relating to the Portfolios’
securities. The Adviser will instruct the custodian and other parties providing services to the
Trusts promptly to forward to the proxy voting service copies of all proxies and shareholder
communications relating to securities held by each Portfolio (other than materials relating to
legal proceedings).
18. Confidentiality. The Subadviser will not disclose or use any records or
information obtained pursuant to this Agreement in any manner whatsoever except as expressly
authorized in this Agreement or as reasonably required to execute transactions on behalf of the
Portfolios, and will keep confidential any non-public information obtained directly as a result of
this service relationship, and the Subadviser shall disclose such non-public information only if
the Adviser or the Board of Trustees of the respective Trust has authorized such disclosure by
prior written consent, or if such information is or hereafter otherwise is known by the Subadviser
or has been disclosed, directly or indirectly, by the Adviser or the respective Trust to others
becomes ascertainable from public or published information or trade sources, or if such disclosure
is expressly required or requested by applicable federal or state regulatory authorities, or to the
extent such disclosure is reasonably required by auditors or attorneys of the Subadviser in
connection with the performance of their professional services or as may otherwise be contemplated
by this Agreement. Notwithstanding the foregoing, the Subadviser may disclose
- 8 -
the total return earned by the Portfolios and may include such total return in the calculation
of composite performance information.
19. Notices. All notices shall be in writing and deemed properly given when delivered
or mailed by United States certified or registered mail, return receipt requested, postage prepaid,
addressed as follows:
Subadviser: |
PineBridge Investment Corp. | |||
00 Xxxx Xxxxxx | ||||
Xxx Xxxx, XX 00000 | ||||
Attention: | ||||
Adviser: |
SunAmerica Asset Management Corp. | |||
Harborside Financial Center | ||||
0000 Xxxxx 0 | ||||
Xxxxxx Xxxx, XX 00000 | ||||
Attention: | Xxxxxxx X. Xxxxxxxx Senior Vice President and General Counsel |
|||
with a copy to: |
AIG Retirement Services, Inc. | |||
0 XxxXxxxxxx Xxxxxx | ||||
Xxxxxxx Xxxx | ||||
Xxx Xxxxxxx, XX 00000-0000 | ||||
Attention: | Xxxxxxx X. Xxxxxx Senior Vice President and General Counsel |
- 9 -
IN WITNESS WHEREOF, the parties have caused their respective duly authorized officers to
execute this Agreement as of the date first above written.
SUNAMERICA ASSET MANAGEMENT CORP. | ||||||
By: | /s/ XXXXX X. XXXXXXX
|
|||||
Title: President and Chief Executive Officer | ||||||
PINEBRIDGE INVESTMENTS, LLC | ||||||
By: | /s/ XXXX XXXXXXXXXX
|
|||||
Title: Senior Managing Director |
- 10 -
Schedule A
Portfolio(s)
SST
Multi-Managed Growth Portfolio (Balanced Component)
Multi-Managed Moderate Growth Portfolio (Balanced Component)
Multi-Managed Income Portfolio (Balanced Component)
Multi-Managed Income/Equity Portfolio (Balanced Component)
International Equity
Diversified Fixed Income-Index Component
U.S. Government Index Component
Core Bond Component
U.S. Government Index Component
Core Bond Component
SAST
High Yield Bond Portfolio
- 11 -