This submission is being made on behalf of the various business groups within Bank of America that provide discretionary investment management services, solutions, products and platforms to serve its clients’ needs (the “Discretionary Investment Management Business”). The relevant business groups and units are part of Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S”) and the Bank of America, N.A. (“BANA”). Both MLPF&S and BANA are affiliates of Bank of America Corporation.
Set forth below are descriptions of the business groups that comprise the Discretionary Investment Management Business:
- Bank of America Private Bank (previously referred to as “U.S. Trust”), a division of Bank of America provides private client advisors and wealth management clients with discretionary portfolios and strategies, and customized client investments for.
- Investment Products (previously referred to as “Managed Solutions Group”), a business unit of Bank of America, provides Merrill Lynch Wealth Management and Merrill Private Wealth Management clients with discretionary investment management solutions, including financial advisor, firm model and third party discretionary management solutions, fund and separate account strategy selection and monitoring activities, and, through Managed Account Advisors LLC (“MAA”), implementation and screening services in connection with the execution and implementation of investment management strategies.
- MAA, an indirect wholly-owned subsidiary of BANA, provides investment advisory services to clients primarily through managed account programs sponsored by its affiliates, including MLPF&S.
- The Chief Investment Office, provides Private Bank and Merrill advisors and clients investment models and portfolio construction solutions for clients, thought leadership and educational materials on market developments and investment strategy, as well as initial and on-going due diligence of investment manager strategies available to wealth management clients.
The Discretionary Investment Management Business supports both Bank of America Private Bank and Merrill. It provides comprehensive wealth management and advisory services to its retail and private clients, including affluent and high-net-worth clients, trusts and small to medium businesses clients. It also provides philanthropic management and asset management to individuals and institutions. Clients have access to a range of investment and wealth management solutions including wealth structuring, investment management, trust and banking needs, offered through Merrill financial advisors and Private Client Advisors in the Private Bank.