Private company
Brookfield Public Securities Group LLC
Last updated Oct 21, 2026.
Overview
Corporate structure
Brookfield Public Securities Group LLC is part of a group headed by Brookfield Public Securities. 3 entities, 1 country on record. Switch between the flow chart and the network, and select any entity to see its details.
Major holders of Brookfield Public Securities Group LLC
- Brookfield Asset Management Owns 25% to 50% of Brookfield Asset, since 12/2022 (Form ADV)
- Brookfield US Inc Owns 75% or more of Brookfield Public Securities Group Holdings LLC, since 11/2010 (Form ADV)
- Brookfield US Holdings Inc Owns 75% or more of Brookfield US Inc, since 12/2005 (Form ADV)
- Brookfield Corporation Owns 50% to 75% of Brookfield Asset Management Ulc, since 12/2022 (Form ADV)
- Brookfield Public Securities
- Brookfield Public Securities Group LLC
- Anadarko Petroleum Stake · Houston, Texas, United States
- Brookfield Public Securities Group LLC
Built from major holders from Schedules 13D and 13G; stakes of 5% or more it reported on Schedules 13D and 13G (1 companies); owners and owned firms from Form ADV, the registration investment advisers file with the SEC. Each entity in the chart links to its source.
Investment adviser
Brookfield Public Securities Group LLC is registered with the SEC as an investment adviser. This is what it reports on Form ADV, the registration every adviser files and keeps current.
- Assets it manages$66.5B2 92 accounts, $66.4B with discretion
- Employees90 41 in investment advice or research
- ClientsInsurance companies: 28 ($45.5B); Pooled investment vehicles (other than investment companies and: 23 ($14.3B); Investment companies: 8 ($3.1B); Corporations or other businesses not listed above: 8 ($841.8M); Pension and profit sharing plans (but not the plan participants or: 5 ($601.2M); High net worth individuals: 7 ($430.9M); Individuals (other than high net worth individuals): 344 ($179.6M); Other: CDO/REIT: 5 ($177.8M)
- How it is paidA percentage of assets under its management; Fixed fees (other than subscription fees); Performance-based fees
- What it doesPortfolio management for individuals and/or small businesses; Portfolio management for investment companies; Portfolio management for pooled investment vehicles (other than investment companies); Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles); Selection of other advisers (including private fund managers)
- Holds client assetsYes: cash and securities
- RegistrationSEC 801-34605, CRD 110497 IAPD record
Who owns it
Owners of 5% or more as the firm lists them (Schedule A), and the owners of those owners up the chain (Schedule B).
- BROOKFIELD PUBLIC SECURITIESowns 75% or more, since 01/2019
- BROOKFIELD US HOLDINGS INCowns 75% or more of BROOKFIELD US INC, since 12/2005
- BROOKFIELD US INCowns 75% or more of BROOKFIELD PUBLIC SECURITIES GROUP HOLDINGS LLC, since 11/2010
- BROOKFIELD CORPORATION (public company)owns 50% to 75% of BROOKFIELD ASSET MANAGEMENT ULC, since 12/2022
- BROOKFIELD ASSET MANAGEMENT (public company)owns 25% to 50% of BROOKFIELD ASSET, since 12/2022
Disciplinary record
The firm answered yes to 3 of the disciplinary questions on Form ADV (Item 11). A yes can concern the firm itself or an affiliate.
- The SEC or the CFTC has found the firm or an advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes.
- The SEC or the CFTC has entered an order against the firm or an advisory affiliate in connection with investment-related activity.
- The SEC or the CFTC has imposed a civil money penalty on the firm or an advisory affiliate, or ordered the firm or an advisory affiliate to cease and desist from any activity.
The 1 record concern OAKTREE CAPITAL (1), which reports the details on its own Form ADV.
In its own words: the client brochure
Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 9/2/2026.3 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.
Item 4: Advisory business Services
PSG is an investment adviser that has been registered under the Investment Advisers Act of 1940, as amended (“Advisers Act”) since 1989. PSG is a Delaware limited liability company and an indirect wholly owned subsidiary of Brookfield Asset Management ULC, an unlimited liability company formed under the laws of British Columbia, Canada (“BAM ULC”). BAM ULC is a direct wholly owned subsidiary of Brookfield Asset Management Ltd., a publicly traded company (NYSE: BAM; TSX: BAMA) (the “Manager”). Brookfield Corporation (the “Corporation”), a publicly traded company (NYSE: BN; TSX: BN), holds a 69% interest in the Manager. The Manager is a leading global alternative asset manager focused on real estate, renewable power, infrastructure and private equity, with assets under management over $1 trillion as of December 31, 2025. The Manager draws on Brookfield’s heritage as an owner and operator to invest for value and generate strong returns for its clients across economic cycles. The Corporation, the Manager and their affiliates, other than PSG and the Oaktree Entities (as defined below), are collectively referred to herein as “Brookfield.” Headquartered in New York, NY, PSG maintains offices and investment teams in Chicago, IL, and Houston, TX. PSG provides investment advisory services on a discretionary and non‐discretionary basis to: financial institutions; public and private pension plans; insurance companies; endowments and foundations; sovereign wealth funds; retail, high net worth and institutional investors; separate accounts; separately managed accounts (“SMAs”); and uniform model accounts (“UMAs,” also known as “wrap fee programs”) sponsored by several major broker‐dealer firms; investment companies with variable capital authorized as an undertakings for collective investment in transferable securities (“UCITS”); open‐end and closed‐end investment companies registered with the SEC under the Investment Company Act of 1940, as amended (“1940 Act”); and investment companies exempted from the definition of investment company by Sections 3(c)(1) and 3(c)(7) of the 1940 Act, as amended (“Private Funds”). In this Brochure, the separate accounts, SMAs, UCITS, 1940 Act registered investment companies (“RICs”) and Private Funds that are managed or advised by PSG are collectively referred to as “Client Accounts.” (Herein, the term “Clients” includes individuals as well as the “Client Accounts” that PSG manages). PSG currently provides global alternative investment management strategies focused on specialized equity and fixed income real assets securities investments. Clients can invest in Brookfield strategies via three main channels: public securities, Private Funds and listed partnerships. PSG leverages Brookfield’s core real asset expertise via global listed strategies, including energy infrastructure, infrastructure, real asset debt, real asset solutions and opportunistic strategies through a variety of flexible and scalable mandates including separate accounts, SMAs (which may be part of a wrap program), collective investment trusts (“CITs”), open‐end and closed‐end registered funds and Private Funds.
PSG manages each Client’s portfolio in accordance with the specified guidelines and objectives of the Client. PSG’s discretionary authority to make investments for a portfolio is generally limited by written investment restrictions and guidelines provided by the Client. PSG’s Energy Infrastructure Securities Group (“Energy Infrastructure Team”), located in Houston, TX, primarily allocates Clients’ investment management assets among the marketable securities of issuers of energy‐related master limited partnerships (“MLPs”), MLP affiliates, C‐ Corps, and other midstream or infrastructure energy companies, particularly those participating in the business of operating oil and gas pipelines, terminals and storage facilities and other infrastructure assets. The Energy Infrastructure Team may also invest Clients’ assets in exchange traded funds (“ETFs”) and options and derivatives including total return swaps. The Energy Infrastructure Team manages SMAs under wrap fee programs sponsored by several major broker‐dealer firms. PSG is not a sponsor of any wrap fee programs. In exchange for providing portfolio management services to wrap programs, PSG receives a portion of the wrap fees paid by the wrap fee program participants to the wrap fee program sponsors. The Energy Infrastructure Team manages the SMAs under the wrap fee programs and “non wrap” accounts which are similar in size in a substantially similar manner. As of December 31, 2025, PSG had over $66 billion of discretionary assets under management. Brookfield Corporation and Brookfield Asset Management Ltd. own 100% of the Oaktree business following Brookfield’s acquisition in July 2026 (together with its “advisory affiliates” and “related persons” (as defined in Form ADV), the “Oaktree Entities”). PSG, Brookfield, and the Oaktree Entities currently operate their respective investment businesses largely independently, partnering to leverage their strengths, with each remaining under its own brand and managing their investment operations subject to an information barrier between the firms (the “OAK‐BAM‐PSG Information Barrier”). It is likely that PSG, Brookfield, and the Oaktree Entities will continue to coordinate in many areas more closely than they have in the past. Brookfield and Oaktree formed Brookfield Private Wealth LLC (“BPW”), a registered brokerdealer and a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). More about BPW can be found under Item 10, “Other Financial Industry Activities and Affiliations.” PSG has entered into a sub‐advisory agreement with Crystal River Capital Advisors, LLC (“Crystal River Advisors”), a Delaware Limited Liability Company formed to provide investment management advice to a real estate investment trust.
Item 5: Fees and compensation Fees
PSG generally receives management fees, carried interest allocation and/or performance fees in connection with the investment management services it provides to its Clients. PSG offers its services on a fee basis, including fees based upon assets under management and/or the performance of the Client’s portfolio. The specific manner in which fees are charged by PSG is established in a Client’s written agreement with PSG. PSG will generally bill its fees on a monthly or quarterly basis and Clients may elect to be billed in advance or arrears each calendar month or quarter. Accounts initiated or terminated during a calendar quarter will be charged a prorated fee. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. The Client has the right to terminate an agreement without penalty within five business days after entering into the agreement. PSG’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by a Client. Clients may also incur certain charges imposed by custodians, brokers, third party investment consultants and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd‐lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Such charges, fees and commissions are exclusive of and in addition to PSG’s management fee(s) and PSG shall not receive any portion of these commissions, fees, and costs. Item 12 further describes the factors that PSG considers in selecting or recommending broker‐ dealers for Client transactions and determining the reasonableness of their compensation (e.g., commissions). Annual and other fees may be negotiated on a Client‐by‐Client basis. Fee schedules are subject to negotiation and will vary from time to time based upon numerous factors such as mandate size, types of securities held and portfolio customization. PSG has various minimum mandate sizes depending on the strategy, although PSG may waive the minimum size requirement at its discretion. Clients may be subject to a minimum quarterly or annual fee based on asset size. Affiliates and employees of PSG will receive a discount on the advisory fees charged by PSG for investment strategies managed by PSG.
INVESTMENT ADVISORY SERVICES AND FEES REGISTERED INVESTMENT COMPANY FEES PSG provides investment advisory and administrative services to several RICs and UCITS. The prospectuses and statements of additional information, and related disclosure documents for these funds contain additional information about each fund. For providing advisory services to these funds, PSG receives investment advisory fees monthly, in arrears, at the following annual rates: Brookfield Investment Funds (Closed‐end Fund)1 Brookfield Real Assets Income Fund Inc. (NYSE: RA)
1.00%
Brookfield Investment Funds (Mutual Funds) Brookfield Next Generation Infrastructure Fund2
0.85%
Brookfield Global Listed Real Estate Fund
0.75%
Brookfield Global Listed Infrastructure Fund
0.85%
Center Coast Brookfield Midstream Focus Fund
1.00%
Brookfield Investment Funds (UCITS) plc 3 Brookfield Global Listed Real Estate UCITS Fund 4
0.85%
Brookfield Real Assets Securities UCITS Fund5
0.85%
Brookfield Next Generation Infrastructure UCITS Fund
0.95%
Brookfield Global Listed Core Infrastructure UCITS Fund
0.80%
Brookfield Canadian Funds Brookfield Global Infrastructure Securities Income Fund
1.25%
PSG has a separate investment advisory agreement with each of the above funds. 1 Fees for the closed-end fund are based on the fund’s “managed assets” (the fund’s total assets (including any assets attributable to the use of
leverage for investment purposes) minus the sum of the fund’s accrued liabilities (excluding leverage used for investment purposes)). On March 5, 2026, the Board of Trustees of Brookfield Investment Funds, on behalf of the Brookfield Next Generation Infrastructure Fund, approved a proposal to close the fund to new and subsequent investments and thereafter to liquidate the fund. 3 Fees may vary among the share classes for the UCITS Funds. Please refer to each UCITS Fund’s prospectus for additional information. On March 5, 2026, the Board of Directors of Brookfield Investment Funds (UCITS) p.l.c., approved a proposal to close the Brookfield Global Listed Real Estate UCITS Fund to new and subsequent subscriptions and thereafter to liquidate the fund. On March 5, 2026, the Board of Directors of Brookfield Investment Funds (UCITS) p.l.c., approved a proposal to close the Brookfield Real Assets Securities UCITS Fund to new and subsequent subscriptions and thereafter to liquidate the fund.
For the U.S. RICs, PSG’s investment advisory agreements require annual approval by each RIC’s Board of Directors/Trustees. It may also be necessary to obtain shareholder approval periodically for certain changes to an investment advisory agreement. Each such investment advisory agreement: (i) may be terminated at any time without the payment of any penalty either by vote of the Board of Directors/Trustees, or by “vote of a majority of the outstanding voting securities” (as defined in the 1940 Act) of the respective fund, or by PSG, in each case on not more than sixty (60) days’ and no less than thirty (30) days’ prior written notice to the other party; and (ii) shall automatically and immediately terminate in the event of an “assignment” (within the meaning of the 1940 Act). In connection with each annual approval, the Directors/Trustees consider a number of factors in evaluating the terms of each agreement, including, among other things, PSG’s cost of providing services to the fund, the nature and quality of the services, and the reasonableness of the adviser’s fees in relation to the services rendered. PSG also has entered into administration agreements with the U.S. RICs to perform administrative services necessary for the operation of the funds. PSG serves as an investment sub‐adviser to several non‐affiliated RICs. Complete information concerning the funds that PSG sub‐advises, including fees charged, is disclosed in the prospectuses and statements of additional information of those funds. PSG negotiates a fee which it deems appropriate for the services rendered. Typically, an investment sub‐advisory agreement may be terminated at any time, without the payment of any penalty, by: (i) the Board of Directors/Trustees of each sub‐advised RIC; (ii) the investment adviser, PSG, in its capacity as an investment sub‐ adviser; or (iii) by vote of a majority of the outstanding voting securities of such RIC, on sixty (60) days’ prior written notice. SEPARATE ACCOUNT FEES PSG receives management fees with respect to each separate account based on negotiated fee rates with each separate account or SMA Client, as appropriate. Management or SMA fees are generally payable quarterly, and depending on the particular account, may be payable in arrears or in advance. Management fees will be pro‐rated when PSG provides services for less than the full period for which such fees are due and, if paid in advance, will be refunded. The separate account standard fee schedule is as follows: EQUITY STRATEGIES Infrastructure Equities Strategies The fee schedule below applies to the following Infrastructure Equities strategies: Global Infrastructure Securities Strategy, Global Infrastructure Securities Core Strategy, Global Infrastructure Securities and MLPs Strategy and Global Listed Infrastructure Securities Select Strategy:
75 bps on first $25M 70 bps on next $25M 65 bps on next $50M 60 bps thereafter
The fee schedule below applies to the following Infrastructure Equities strategy: Global Next Generation Infrastructure Strategy:
80bps on first $50m 70bps on next $50m 60bps on next $100m 55bps thereafter
Energy Infrastructure Strategies The fee schedule below applies to the following Infrastructure Equities strategies: Energy Infrastructure Equities and Concentrated Energy Infrastructure Equities:
75 bps on first $25M 70 bps on next $25M 65 bps on next $50M 60 bps thereafter
Real Estate Equities Strategies The fee schedule below applies to the following Real Estate Equities strategies which, as of the date of this Brochure, are no longer accepting new Clients: U.S. Real Estate Securities Value Income Strategy, Global Real Estate Securities Alpha Strategy, Asia‐Pacific Real Estate Securities Strategy, Global Real Estate Securities Select Strategy and Global Real Estate Technology Strategy:
75 bps on first $25M 70 bps on next $25M 65 bps on next $50M 55 bps on next $100M 50 bps thereafter
Please note, different fee break points may have been applied based on the size of the account. REAL ASSET DEBT STRATEGIES The fee schedule below applies to the following Real Asset Debt Strategy: High Yield Strategy:
50 bps on first $50M 45 bps on next $50M 40 bps on next $150M 35 bps thereafter
The fee schedule below applies to the following Real Asset Debt Strategy: Investment Grade Strategy:
35 bps on first $50M 30 bps on next $100M 25 bps on next $200M
20 bps thereafter
DIVERSIFIED REAL ASSET STRATEGY The fee schedule below applies to the Diversified Real Assets Strategy:
80 bps on first $100M 70 bps on next $250M 60 bps thereafter
The Private Real Assets Strategy is available in Private Funds only and the fee information is available within the fund’s subscription documents. SMA WRAP PROGRAM FEES PSG is retained by certain Clients under SMA wrap programs (also known as wrap fee programs) offered by a third-party sponsor (“Wrap Sponsor”), where the Wrap Sponsor may: (i) recommend retention of PSG as investment adviser; (ii) pay PSG’s investment advisory fee on behalf of the Client; (iii) monitor and evaluate PSG’s performance; (iv) execute the Client's portfolio transactions without commission charge (in the case of transactions with such broker/dealer sponsors); and (v) provide custodial services for the Client's assets, or provide any combination of these or other services, all for a single fee paid by the Client to the thirdparty sponsor. PSG is compensated in one of two ways. In most programs, the Client pays a single fee payable to the Wrap Sponsor, of which a percentage is payable to PSG for its asset management services. The Wrap Sponsor’s fee covers various charges, which can include investment management, brokerage and custodial services, recordkeeping, and reporting. Fees, investment minimums, and other features of these programs vary, and are described in each Wrap Sponsor’s disclosure brochure. In other programs, PSG enters into separate agreements with a Client. The Client pays compensation separately to PSG as well as to the Wrap Sponsor for its services, which may include preparing an investment policy statement, considering an appropriate asset allocation, and providing account statements, among others. PRIVATE FUND FEES The fees and expenses of any Private Funds will be described in the offering and constituent documentation of such products. PSG may, in its discretion, manage certain Client Accounts with higher or lower fees, different fee structures, and different expense payment arrangements, than those of other Client Accounts and Affiliated Client Accounts (defined below). The specific manner in which fees and expenses may be charged by PSG will be established in each Client Account’s offering documents or other definitive documentation entered into with a Client (“Offering Documents”).
WITHDRAWAL FEES Certain Private Funds are subject to withdrawal fees unless the general partner and/or managing member of such funds elects to waive such withdrawal fee in whole or in part in its sole discretion. Please refer to the Private Funds’ private placement memoranda and operative documents for more information.
Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks
of Loss
PSG is a leading global alternative investment manager that manages investment strategies focused on equity and fixed income real assets securities, including securities and other investments related to infrastructure, energy infrastructure and energy‐related MLPs, multiasset solutions (e.g., asset allocation across real asset investment classes and sub‐ classes), and real asset debt. Please refer to Item 2 – Material Changes for information related to expected changes to these strategies. PSG’s investment strategies are generally guided by: (i) the investment objectives, policies, strategies, and restrictions as set forth in the applicable advisory agreements with its Clients; (ii) the limits or restrictions set forth in any offering, disclosure or trust document applicable to a Client for which PSG serves as investment adviser or otherwise provides advisory services; and (iii) the applicable legal and regulatory requirements.
EQUITY STRATEGIES Infrastructure Equities The following Infrastructure Equities strategies utilize proprietary valuation tools, as well as fundamental, bottom-up research, to identify mispriced securities within our investment universe of global listed infrastructure companies, including emerging markets, and renewable and/or sustainable infrastructure. Global Infrastructure Securities Core The Global Infrastructure Securities Core Strategy offers a concentrated portfolio of publicly traded infrastructure securities, targeted to outperform the FTSE Global Core Infrastructure 50/50 Index 6 over a market cycle. Global Listed Infrastructure Securities Select The Global Listed Infrastructure Securities Select strategy offers a concentrated portfolio of infrastructure securities. The strategy employs strict selection criteria to seek to significantly outperform the FTSE Global Core Infrastructure 50/50 Index over a market cycle. Global Infrastructure Securities The Global Infrastructure Securities Strategy offers a concentrated portfolio of publicly traded infrastructure securities, targeted to outperform the Dow Jones Brookfield Global Infrastructure Index 7 over a market cycle. Global Infrastructure Securities and MLPs The Global Infrastructure Securities Strategy and MLPs offers a concentrated portfolio of publicly traded infrastructure securities, targeted to outperform the Dow Jones Brookfield Global Infrastructure Composite Index 8 over a market cycle. Global Next Generation Infrastructure The Global Next Generation Infrastructure Strategy offers a diversified portfolio that seeks to invest in companies that may capitalize on or benefit from the world transitioning toward cleaner, cheaper and more efficient energy consumption. The principal investment objective is to achieve total return through growth of capital and current income. The Strategy seeks to achieve its investment objective by investing primarily in publicly traded equity securities in an identified universe of investable companies that have renewable and/or sustainable 6 The FTSE Global Core Infrastructure 50/50 Index gives participants an industry-defined interpretation of infrastructure and adjusts the exposure
to certain infrastructure sub-sectors. The constituent weights are adjusted as part of the semi-annual review according to three broad industry sectors - 50% Utilities, 30% Transportation including capping of 7.5% for railroads/railways and a 20% mix of other sectors including pipelines, satellites and telecommunication towers. Company weights within each group are adjusted in proportion to their investable market capitalization. 7 The Dow Jones Brookfield Global Infrastructure Index is calculated and maintained by S&P Dow Jones Indices and comprises infrastructure companies with at least 70% of their annual cash flows derived from owning and operating infrastructure assets. Brookfield has no direct role in the day-to-day management of the Index. 8 The Dow Jones Brookfield Global Infrastructure Composite Index is calculated and maintained by S&P Dow Jones Indexes and comprises infrastructure companies with at least 70% of their annual cash flows derived from owning and operating infrastructure assets, including MLPs. Brookfield Public Securities Group LLC has no direct role in the day-to-day management of the Index.
infrastructure characteristics, particularly related to power generation with infrastructure-like attributes. Energy Infrastructure Equities The following Energy Infrastructure Equities strategies utilize proprietary valuation tools, as well as fundamental, bottom-up research, focused on asset and management quality and making investments at the intersection of top-tier fundamentals and attractive long-term valuations. The investment universe includes midstream C-corps and MLPs and MLP affiliates, with a focus on those participating in the business of operating oil and gas pipelines, processing plants, terminals, and storage facilities (i.e., midstream). Energy Infrastructure Equities The Energy Infrastructure Equities Strategy offers a portfolio of publicly traded infrastructure securities, targeted to outperform the Alerian Midstream Energy Index 9 over a market cycle. The strategy’s objective is to generate attractive, non-correlated returns in the form of capital appreciation and income through the application of a disciplined investment process focused on the energy infrastructure sector. Concentrated Energy Infrastructure Equities The Concentrated Energy Infrastructure Strategy offers a concentrated portfolio of equally weighted publicly traded energy infrastructure securities, targeted to outperform the Alerian Midstream Energy Index over a market cycle. The strategy’s objective is to generate attractive, non-correlated returns in the form of capital appreciation and income through the application of a disciplined investment process focused on the energy infrastructure sector. Real Estate Equities As of the date of this Brochure, the following Real Estate Equities strategies are being wound down and no longer accepting new Clients. These strategies utilize proprietary valuation tools, as well as fundamental, bottom-up research, to identify mispriced securities within our investment universe of core real estate companies, as well as non-traditional property companies and asset-rich real estate operating companies. U.S. Real Estate Securities Value Income The U.S. Real Estate Securities Value Income Strategy offers a concentrated portfolio of U.S. real estate securities, targeted to outperform the MSCI U.S. REIT Index (RMS) 10 over a market cycle. Global Real Estate Securities Alpha The Global Real Estate Securities Alpha Strategy offers a concentrated portfolio of global real 9 The Alerian Midstream Energy Index is a broad-based composite of North American energy infrastructure companies. The capped, float-adjusted,
capitalization-weighted index, whose constituents earn the majority of their cash flow from midstream activities involving energy commodities, is disseminated real-time on a price- return basis (AMNA) and on a total-return basis (AMNAX). 10 The MSCI U.S. REIT Index is a free float market capitalization weighted index that is comprised of equity REITs securities that belong to the MSCI U.S. Investible Market 2500 Index.
estate securities, targeted to outperform the FTSE EPRA Nareit Developed Index 11 over a market cycle. Asia-Pacific Real Estate Securities The Asia-Pacific Real Estate Securities Strategy offers a concentrated portfolio of real estate securities in the Asia-Pacific region, targeted to outperform the FTSE EPRA Nareit Developed Asia Index 12 over a market cycle. Global Real Estate Securities Select The Global Real Estate Securities Select Strategy seeks to offer a concentrated portfolio of our highest-conviction selections in global real estate equities. The Strategy targets high-quality global real estate investment trusts (“REITs”) and real estate operating companies that PSG believe are attractively valued and well positioned for long-term growth. The strategy seeks to achieve meaningful outperformance over the broader real estate securities market, driven by income and capital appreciation. Brookfield Global Real Estate Technology Strategy This strategy invests in new economy real estate sectors – including industrial, communications infrastructure and data centers. The Brookfield Global Real Estate Technology Strategy seeks to maximize total return from a combination of long-term capital appreciation and moderate current income. FIXED INCOME STRATEGIES Real Asset High Yield The Real Asset High Yield Strategy focuses on high yield publicly listed debt in Brookfield’s core sectors of expertise. The strategy seeks to add value in three primary ways: security selection, credit allocation, and sector allocation. We seek to achieve these objectives in part by focusing on sectors with attractive characteristics for debt; specifically real asset sectors including infrastructure, real estate, and natural resources. Our approach prioritizes capital preservation and income over capital appreciation. We believe this allows us to deliver more stable returns with below-market risk over the different credit cycles. The strategy’s objective is to outperform its benchmark over a full credit cycle with below-market risk (volatility). MULTI- ASSET SOLUTIONS STRATEGIES Diversified Real Assets The Diversified Real Assets Strategy is a broadly diversified, multi-strategy portfolio of real assets that seeks compelling risk-adjusted returns. We believe the strategy provides stability, growth and diversification while offering the benefits of real asset investments, including attractive current income, long-term capital appreciation, a hedge against inflation and 11 The FTSE EPRA Nareit Developed Index is an unmanaged market-capitalization-weighted total- return index, which consists of publicly traded
equity REITs and listed property companies from developed markets.
12 The FTSE EPRA Nareit Developed Asia Index is a subset of the FTSE EPRA Nareit Developed Index designed to track the performance of listed
real estate companies and REITS in the developed Asian markets.
compelling risk-adjusted returns. Brookfield Private Real Assets The Brookfield Private Real Assets Strategy invests across Brookfield’s core operating platforms: private investments and public securities. The result is a portfolio with various risk, return and liquidity characteristics. The strategy seeks to deliver long-term direct exposure via Brookfield’s full product line, dynamic and strategic allocations to real asset sectors and vehicles, and attractive liquidity, volatility and correlation through a combination of private and public investments. The strategy’s primary focus is to achieve an attractive total return through capital appreciation, while benefiting from the lower volatility profile of private investments and seeking inflation protection via exposure to real assets. The Multi-Asset Solutions Team, which manages and oversees the PSG Multi-Asset Solutions Strategies, also provides asset allocation advisory services to other investment products that are advised by other Brookfield affiliated advisors. Employees of the Multi-Asset Solutions Team do not make individual security investment decisions. Certain of those employees are “dual hatted” and deemed employees for regulatory purposes of the other applicable Brookfield affiliated advisors.
MATERIAL RISKS
Clients should understand that all investment strategies and the investments made pursuant to such strategies involve risk of loss, including the potential loss of the entire investment. The investment performance and the success of any investment strategy or particular investment can never be predicted or guaranteed, and the value of a Client’s investments will fluctuate due to market conditions and other factors. The following is a summary of the material risks for PSG, its investment strategies, security types and investment techniques. The information contained in this Brochure cannot disclose every potential risk associated with an investment strategy. Rather, it is a general description of the nature and risks of the strategies and securities that Clients may include in their investment guidelines. Investors in RICs, UCITS, or Private Funds should review the prospectuses, offering memorandums and statements of additional information about risks associated with those products. Artificial Intelligence/Machine Learning Risk
From time to time, PSG may utilize artificial intelligence, machine learning, data analytics and similar tools that collect, aggregate and analyze data (collectively, “Data Tools”) in connection with the management of Client Accounts and/or their investments. There are significant risks involved in utilizing Data Tools and no assurance can be provided that the usage of such Data Tools will enhance the Client Accounts’ portfolios or assist the Client Accounts or their investments in being more efficient or profitable. For example, certain Data Tools may utilize historical market or sector data in their analytics. To the extent that such historical data is not indicative of the current or future conditions in the applicable market or sector, or the Data
Item 7: Types of clients
PSG provides investment advisory services on a discretionary and non‐discretionary basis to financial institutions, public and private pension plans, insurance companies, endowments and foundations, sovereign wealth funds, retail investors (through wrap programs), high net worth investors and institutional separate accounts, SMAs, UMAs, UCITS, open‐end and closed‐ end investment companies registered with the SEC under the 1940 Act, and Private Funds (including alternative investment funds).
Minimum Account Size Brookfield Open-end Funds. The investment minimums for the Brookfield open‐end funds are disclosed in their prospectuses and statements of additional information. Brookfield UCITS Funds. The institutional share classes of the Brookfield UCITS Funds generally
require a minimum investment of $250,000. The retail share classes of the Brookfield UCITS Funds generally require a minimum investment of $1,000. Brookfield ICAV Funds. The investment minimums are generally €100,000. Brookfield Private Funds. For investments in Private Funds, Brookfield generally requires a minimum investment of $1,000,000. Certain international feeder funds may have lower investment minimums. Brookfield Closed-end Fund. Brookfield Real Assets Income Fund Inc. (NYSE: RA), is traded publicly on the NYSE and thus there are no stated minimums. Separate Accounts. For non‐institutional separate accounts, PSG generally requires a minimum investment of $100,000. For institutional separate accounts, depending on the strategy, PSG has various minimum investment levels within the range of $10,000,000 through $50,000,000. SMA Wrap Programs (Wrap Fee Accounts). The Wrap Sponsor typically sets the minimum required investment amount. Therefore, investment minimums are dependent upon the Wrap Sponsor and may be higher or lower than investment minimums established for Client Accounts by PSG. PSG may, in its sole discretion, accept Clients with smaller portfolios based upon certain criteria including anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre‐existing Client relationship, recommendation of the Client’s financial advisor, account retention, and pro bono activities. PSG only accepts Clients with less than the minimum portfolio size if, in the sole opinion of PSG, the smaller portfolio size will not cause a substantial increase of investment risk beyond the Client’s identified risk tolerance. PSG may aggregate the portfolios of family members and affiliates to meet a minimum account size.
Item 6: Performance-based fees and side-by-side management Conflicts of interest
In some cases, PSG has entered into performance fee arrangements with qualified Clients. Such fees are subject to individualized negotiation with each such Client. PSG will structure any performance or incentive fee arrangement subject to Section 205(a)(1) of the Advisers Act, as amended, in accordance with the available exemptions thereunder, including the exemption set forth in Rule 205‐3 under the Advisers Act. In measuring Clients’ assets for the calculation of performance‐based fees, PSG shall include realized and unrealized capital gains and losses. Performance-based fee arrangements may create an incentive for PSG to recommend investments which may be riskier or more speculative than those which would be recommended under a different fee arrangement. Such fee arrangements may also create an incentive to favor higher fee‐paying accounts over other accounts in the allocation of investment opportunities. In addition, during the initial start‐up phase of a Private Fund, or at other times when non‐affiliated investors have redeemed their interests, Brookfield, PSG, or personnel of Brookfield and/or PSG may have an interest, controlling or otherwise in the Private Fund, that may create an incentive for PSG to: (i) recommend investments which may be risker or more speculative than those which PSG would recommend to other PSG advised funds and/or accounts; or (ii) allocate securities to the Private Fund contrary to PSG’s standard allocation policies. To address these conflicts, PSG has adopted policies and procedures under which allocation decisions may not be influenced by certain fee arrangements, and trades are allocated in a manner that PSG believes is consistent with its obligations as an investment adviser.
Item 10: Other financial industry activities and affiliations Conflicts of interest
PSG shares office space and other resources of Brookfield.
BPW is a registered broker-dealer and member of FINRA and SIPC and serves as a limited purpose broker-dealer and placement agent and/or provides wholesaling services (for example, educational and marketing support services) for Brookfield and its affiliates and related entities such as PSG and Oaktree related to products and/or funds advised and/or managed by PSG, Oaktree, and other Brookfield affiliates.
PSG is affiliated with the following entities: • Brookfield Private Wealth LLC, a U.S.-registered broker dealer • Brookfield Private Advisors LLC, a U.S.-registered broker dealer • Brookfield Investment Management (Canada) ULC, an exempt market dealer registered in each of the provinces and territories of Canada • Sera Global Securities US LLC, a U.S.-registered broker dealer • Sera Global Securities Canada LP, an investment dealer registered in certain of the provinces and territories of Canada • Sera Global Securities UK LP, registered with the UK’s Financial Conduct Authority • Crystal River Capital Advisors, LLC • Brookfield Asset Management Ltd. • Brookfield Corporation PSG is affiliated with the following SEC-registered investment advisory firms: • Brookfield Asset Management Private Institutional Capital Adviser (BMG), LLC • Brookfield Asset Management Private Institutional Capital Adviser (Private Equity), L.P. • Brookfield Asset Management Private Institutional Capital Adviser (Canada), LP • Brookfield Asset Management Private Institutional Capital Adviser (Credit), LLC • Brookfield Asset Management Private Institutional Capital Adviser US, LLC • BAM Credit and Insurance Solutions Advisor LLC • Brookfield Renewable Energy Group LLC • Oaktree Capital Management, LP • Oaktree Fund Advisors, LLC PSG’s arrangements with its affiliates may or may not be material to its advisory business at any particular time. PSG and its affiliates may refer clients and offer investment opportunities to each other. As noted above, certain PSG employees in the Multi-Asset Solutions Team and certain BPW employees are “dual hatted” and deemed employees for regulatory purposes of other Brookfield affiliated advisors for which such employees provide asset allocation advisory services to certain investment products advised by those Brookfield affiliated advisors. Brookfield Technology Service Group is another affiliate which provides technology support for PSG and its affiliates. PSG serves as investment adviser and administrator to several RICs and has entered into administration agreements with these RICs to perform administrative services necessary for their operation. These services include maintaining certain books and records, preparing
reports and other documents required by federal, state, and other applicable laws and regulations, and providing the investment companies with administrative office facilities. In addition, several officers and directors of PSG also serve as officers and directors/trustees of these RICs. PSG has entered into a sub‐advisory agreement with Crystal River Capital Advisors, LLC, a Delaware limited liability company formed to provide investment management advice to a real estate investment trust. Brookfield Investment Management (Canada) ULC (“BIM Canada”) is not registered with the SEC as an investment adviser. BIM Canada is registered as an exempt market dealer in each of the provinces and territories of Canada. Entities affiliated with the Manager may from time to time serve as a general partner of limited partnerships and/or managing members of limited liability companies (“LLCs”) in which advisory clients may invest. In addition, entities under common control with PSG may serve as general partner or managing member of certain sub‐advisory funds managed by PSG. PSG has established a Conflicts Committee in addition to having established a variety of policies and procedures, restrictions and disclosures designed to address potential conflicts of interest that may arise between PSG, its employees and affiliates. These policies and procedures include information barriers designed to prevent the flow of information between PSG, its employees and certain other affiliates and policies and procedures relating to trading, allocation, and employee personal transactions. Additional information about these potential conflicts of interest and the policies and procedures to address them are available in Items 11 and 12 in this Brochure.
Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest
All PSG employees are subject to policies and procedures regarding confidential or proprietary information and personal trading. In addition, PSG has adopted both a Code of Business Conduct and Ethics Policy and a Personal Trading Policy (collectively the “Code”) that applies to all of its officers and employees as required by the Advisers Act and the 1940 Act, and monitoring procedures relating to activities by PSG employees that PSG believes may involve potential conflicts between PSG employees and Client Accounts. The Code specifies and prohibits certain types of personal securities transactions deemed to create a conflict of interest and establishes reporting requirements and preventive procedures pursuant to the provisions of Rule 204A‐1 of the Advisers Act and Rule 17j‐1 under the 1940 Act. All employees are subject to PSG insider trading policies and procedures which prohibit employees from trading securities, either personally or on behalf of others, while in possession of material, nonpublic information regarding such securities. Employees are also prohibited from communicating material, nonpublic information to others in violation of the law.
The Code includes certain personal trading restrictions and reporting requirements that apply to all PSG employees which are deemed to be “Access Persons.” Access Persons generally include any employee, trustee, director, officer or “advisory person” of PSG or of any company in a control relationship to PSG; an “advisory person” means any employee of PSG or of any company in a control relationship to PSG, who, in connection with his or her regular functions or duties, makes, participates in or obtains information regarding the purchase or sale of securities by PSG Clients or obtains information regarding the portfolio holdings of any reportable fund, or whose functions relate to any recommendations with respect to such purchases or sales and any natural person in a control relationship with PSG who obtains information regarding the purchase or sale of securities or information regarding the portfolio holdings of any reportable fund. A summary of the restrictions and reporting requirements on the personal investing activities of Access Persons is set forth below. Generally, Access Persons are prohibited from purchasing marketable securities at any time. Marketable securities include stocks, warrants, rights, options, and corporate bonds and debentures. Employees are permitted to transact in securities that are not marketable securities including: government and municipal securities, foreign or domestic; short‐term instruments, such as certificates of deposit, banker’s acceptances, or bank CDs; purchases under DRIPS; open‐end mutual funds (or the equivalent), closed-end funds, or ETFs (other than single stock ETFs) not managed or sub‐advised by Brookfield or any Brookfield affiliate, including PSG and/or Oaktree; non‐equity options; foreign exchange securities; commodity futures; insurance products; and 529 college savings plans in which the underlying investment options are open‐end mutual funds, ETFs or a permissible security enumerated above. An Access Person may not, directly or indirectly, dispose of beneficial ownership of a marketable security except when such sale has been pre‐cleared and approved by the Chief Compliance Officer or his or her designee. Notwithstanding the above, Access Persons are permitted to enter into securities trades and are exempt from the pre‐clearance obligations of the Code if they are: (i) done in a blind trust; or (ii) done in accounts managed by a third‐party financial advisor who has full discretion over investment decisions. Transactions by Access Persons in Brookfield registered and Private Funds (“Brookfield Funds”) and the securities of Brookfield affiliated companies (“Affiliated Companies”) are permitted provided that all such trades in the securities of Brookfield Funds and Affiliated Companies do not occur during any applicable blackout period and are “pre‐cleared” through the PSG Compliance Department. Access Persons are not permitted to, directly or indirectly through any person acting on his or her behalf, buy or sell Brookfield Funds or the securities of Affiliated Companies during a trading blackout period. The Code also includes certain procedures relating to reporting and recordkeeping of personal securities transactions by Access Persons, including disclosure of personal holdings, quarterly reporting of transactions and annual certification of compliance with the Code. All employees also must submit an initial acknowledgment of receipt, compliance and understanding of the
Code.
Potential Conflicts of Interest
In the course of our normal business, PSG and its affiliates and subsidiaries may encounter situations where PSG faces a conflict of interest or could be perceived to be in a conflict-ofinterest situation. A conflict of interest occurs whenever the interests of PSG or its personnel diverge from those of a Client, or when PSG or its personnel have obligations to more than one party whose interests are different. PSG believes managing perceived conflicts is as important as managing actual conflicts. In order to enhance PSG’s ability to monitor both perceived and actual conflicts, PSG has established a Conflicts Committee to identify, consider, disclose and/or address, as appropriate, any perceived and/or actual conflicts. Allocation of Investment Opportunities PSG may have potential conflicts in connection with the allocation of investments or transaction decisions for Client Accounts, including situations in which PSG and/or PSG employees may have interests in the investment being allocated and situations in which a PSG account and/or account in which PSG, its affiliates and/or employees invest (“Affiliated Client Account”) may receive a certain percentage of the investments being allocated. PSG seeks to manage all Client Accounts and Affiliated Client Accounts in accordance with each account’s investment objectives and guidelines, and pursuant to the applicable legal and regulatory requirements. The advice provided by PSG to a Client Account or an Affiliated Client may compete or conflict with the advice provided to another Client Account or Affiliated Client Account or may involve a different timing or course of action taken than with respect to a Client Account or Affiliated Client Account. For example, a Client Account may be competing for investment opportunities with PSG, its Affiliated Client Accounts, and other Client Accounts for certain limited investment opportunities. Fees PSG may receive greater fees or other compensation, including performance‐based fees, from certain Client Accounts and its Affiliated Clients, which may create an incentive for PSG to favor such accounts. Additionally, Affiliated Clients may receive discounted or zero fees on accounts managed by PSG. To address these conflicts, PSG has adopted policies and procedures under which allocation decisions may not be influenced by certain fee arrangements and trades are allocated in a manner that PSG believes is consistent with its obligations as an investment adviser. Performance-based fees are described in detail in Item 6 of this Brochure. Confidential and Material, Non‐Public Information Restrictions PSG may acquire confidential or material, non‐public information (“MNPI”) pertaining to an issuer or the issuer’s securities which may prevent or prohibit PSG from providing investment advice to Client Accounts and/or Affiliated Client Accounts with respect to such issuer or the issuer’s securities, irrespective of a Client Account’s and/or Affiliated Client Account’s
investment objectives or guidelines. Moreover, PSG may have ownership interests in issuers that may prevent PSG from purchasing securities or other instruments from such issuers in its Client Accounts or Affiliated Client Accounts. PSG has adopted policies and procedures to address potential issues related to MNPI, including the PSG Code of Business Conduct and Ethics Policy, PSG Personal Trading Policy, and PSG Insider Trading Policy. Short vs. Long Positions in the Same Security PSG may buy or sell positions in certain Client Accounts or Affiliated Client Accounts. At the same time other Client Accounts and/or Affiliated Client Accounts may be undertaking the same or different strategy, which could disadvantage certain Client Accounts and/or Affiliated Client Accounts. For example, a Client Account may buy a security while PSG may establish a short position in that same security in other Client Accounts or Affiliated Client Accounts. Subsequent short sales may result in impairment of the price of the security which is owned or held by the Client Account. Conversely, a Client Account may establish a short position in a security and PSG may buy that same security in other Client Accounts or for Affiliated Client Accounts. Subsequent purchase(s) may result in an increase in the price of the underlying position in the short sale exposure of the Client Account. Conflicts may also arise because investment decisions regarding a Client Account may benefit PSG, other Client Accounts or Affiliated Client Accounts. For example, the sale of a long position or establishment of a short position by a Client Account may impair the price of the same security sold short by (and therefore benefit) PSG for other Client Accounts or Affiliated Client Accounts, and the purchase of a security or covering of a short position in a security by a Client Account may increase the price of the same security held by (and therefore benefit) PSG, other Client Accounts or Affiliated Client Accounts. Additionally, please refer to the section “Conflicts Relating to Ownership of the Oaktree Entities by Brookfield” regarding conflicts that may arise regarding short vs. long positions held by affiliates of PSG. Principal Transactions PSG may, from time to time, engage in principal securities transactions where it purchases or sells securities between a Client Account and an Affiliated Client Account. Execution of principal securities transactions are subject to the applicable Client and regulatory requirements. Cross Transactions PSG may, from time to time, engage in a cross transaction between two Client Accounts, subject to any regulatory requirements and/or interpretations and/or client restrictions. A cross trade is generally defined as a pre‐arranged transaction between two or more different funds or accounts, each of which is managed by the same adviser. For example, one Client Account managed by PSG has cash and needs to be invested in a particular security, while another Client Account managed by PSG has redemptions to meet and/or other need(s) for cash which requires the selling of a security. In certain circumstances and subject to applicable Client and regulatory requirements, PSG may cross the purchase and transaction between the two Client Accounts internally and not through a market transaction. PSG has policies and
Item 12: Brokerage practices Conflicts of interest
As noted above, PSG provides advisory services to various types of Client Accounts which are invested in publicly offered equity and fixed‐income securities in several real asset-related investment strategies, including energy infrastructure related investment strategies. PSG has investment and trading professionals (and related trading desks) in each of its Chicago, IL and Houston, TX offices.
Chicago Trading Desk: Traders in the Chicago office trade securities for Client Accounts focused on Infrastructure, Real Estate, Real Asset Debt, and Diversified Real Asset Strategies and related public equity and fixed income securities. o All proposed securities trades are entered into and occur through the PSG Order Management System and worked, as necessary, by the traders. o Executions and respective execution prices for a block of a particular security will be averaged out to obtain a single Execution Price for the day. o Certain of the Client Accounts managed by the Diversified Real Asset Investment Team that invest in equity securities in the Energy Infrastructure asset class are traded by the Houston Trading Desk.
Houston Trading Desk: Traders in the Houston office trade securities for the Client Accounts focused on the Energy Infrastructure strategies and related public equity securities. The Energy Infrastructure Team, which manages those Client Accounts, employs investment portfolio models in the management of those Client Accounts which are reviewed daily and updated as deemed appropriate. Accounts advised by the Energy Infrastructure Team and traded on the Houston Trading Desk are typically categorized and traded depending on whether they: (i) may be traded through the PSG Order Management system (“Large Energy Infrastructure Accounts”); or (ii) are traded through or on a particular investment platform’s trading system and/or software (“Rotational Energy Infrastructure Accounts”). The Houston Trading Desk employs a “Trade Order Rotation” for each of the Large Energy Infrastructure Accounts and the Rotational Energy Infrastructure Accounts. o For Large Energy Infrastructure Accounts, which generally consist of RICs and large institutional SMAs:
All proposed securities trades are entered into and occur through the PSG Order Management System and worked, as necessary, by the trader. Executions and respective execution prices for a particular block will be averaged out to obtain a single Execution Price for the day.
o For the Rotational Energy Infrastructure Accounts, the Houston traders provide trade orders, other trading services, and in certain instances proposed allocations for those accounts to Clients and investment platforms for their consideration and execution, as appropriate.
Proposed trade orders for Rotational Energy Infrastructure Accounts are
not entered into the PSG Order Management System and are generated on a third‐ party order production platform and provided to the custodian for the particular account or similar portfolio accounting software programs. Certain trade orders are worked and executed by the Houston Trading Desk, and other trade orders are sent to the account’s custodian for the particular Rotational Energy Infrastructure. Generally, trades for the Rotational Energy Infrastructure Accounts will be executed according to an order rotation plan that is logged each time there is a portfolio event (for example, a model update, dividend reinvestment, or a rebalance due to market movement). The platform that is first in the rotation for a given event will roll to the bottom of the trade order rotation queue for the next event.
INVESTMENT, BROKERAGE, AND TRADE ALLOCATION GUIDELINES PSG has adopted investment, brokerage, and trading allocation guidelines that set out standards that portfolio managers, traders and other personnel involved in the purchase and sale of securities on behalf of Clients must follow when:
Determining which Client Account(s) will participate in an investment opportunity; Seeking best execution for Client transactions; Using Client commissions to acquire brokerage and research services that are provided by broker‐dealers (i.e., entering into “soft dollar arrangements”); and Aggregating Client orders and allocating securities and other instruments among Clients that participate in aggregated orders.
A working group composed of personnel with responsibilities in the operation of investment or trading (“Trade Management Oversight Working Group”) oversees the implementation and monitoring of these investment, brokerage, and trading allocation guidelines. BEST EXECUTION PSG’s investment advisory agreements typically authorize PSG to employ broker‐dealers to effect portfolio transactions. Unless a Client specifically requests otherwise, and in accordance with a Client’s investment guidelines, PSG intends to retain authority without obtaining specific Client consent to determine: (i) which securities are to be bought or sold; (ii) the amount of securities to be bought or sold; (iii) the broker or dealer to be used; and (iv) the commission to be paid. PSG will seek best execution for Client transactions. In evaluating the best execution of Client transactions, PSG will consider the full range and quality of a broker’s services, taking into account all relevant factors. Although it is not possible to create a definitive list of factors to guide this determination, PSG may consider some or all of the following:
Price of security;
Commission rate; Execution capability, including execution speed and reliability;
Trading expertise and knowledge of the other side of the trade; Financial responsibility; Responsiveness; Reputation and integrity; Capital commitment; Value of research or brokerage services or products provided; Access to underwritten and secondary market offerings; Confidentiality; Reliability in keeping records; Fairness in resolving disputes; Market depth and available liquidity; Recent order flow; Timing and size of an order; and Current market conditions.
In selecting broker‐dealers to execute Client transactions, PSG will bear in mind that no factor is necessarily determinative and that seeking to obtain best execution for all Client trades must take precedence over all other considerations. In seeking to ensure best execution of each trade for each Client Account and to avoid undue downward pressure on the price of a particular security, both the Chicago and Houston Trading Desks seek, as appropriate, to limit trading activity in a particular security to a reasonable range of the Average Daily Trading Volume for that security, except to the extent that excess or other liquidity is available in the market. DIRECTED BROKERAGE ARRANGEMENTS In some circumstances, a Client may designate a particular broker or dealer or type of broker or dealer (e.g. women, minority and disabled person-owned broker or dealer) through which trades are to be effected or through which transactions may be introduced, typically under such terms as the Client negotiates with the particular broker or dealer or may receive some other type of benefit. Where a Client has directed the use of a particular broker or dealer, PSG generally will not be in a position to negotiate commission rates or spreads freely or, depending on the circumstances, to select brokers or dealers based on the most favorable price execution for a transaction. Additionally, transactions for a Client that has directed brokerage may lose the possible advantage that Clients who do not direct brokerage may derive by PSG commingling or “bunching” multiple orders into a single order for the purchase or sale of a particular security, and that any such “non‐bunch” orders for Clients may be executed after or follow any “non‐bunched” orders for non‐directed brokerage Client accounts. Moreover, there may be times when the trading activity in a security for a Client that has directed brokerage occurs at a time after PSG has completed the execution of all other transactions in that security for all other accounts managed or traded by PSG and its subsidiaries. Accordingly, directed transactions may be subject to price movements, particularly in volatile markets, that may result in the Client receiving a price that is less favorable than the price obtained for comparable bunched orders. Under these circumstances, the direction by a Client to use a particular broker or dealer to execute
transactions may result in higher commissions, greater spreads, or less favorable net prices than might be the case if PSG were empowered to negotiate commission rates or spreads freely, or to freely select brokers or dealers. ALLOCATION AND AGGREGATION The overriding principle governing PSG’s allocation process with respect to securities is the fair and equitable treatment of all Clients that receive an allocation of securities or transaction proceeds. Where a portfolio manager is managing accounts with similar investment objectives and strategies, the portfolio manager will endeavor to allocate investment opportunities to all such accounts pro rata based on either, depending on the investment strategy: (i) the current equity of each Client Account; or (ii) the current demand after giving effect to any cumulative over/under allocation in previous deals and provided that such shares results in a marketable parcel or round‐lot. Some Client orders may not be filled due to the specific Client’s risk tolerance, available cash, investment objectives, restrictions or strategy. When orders are not entirely filled, allocations are made either, depending on the investment strategy: (i) pari passu based on orders received from the portfolio managers; (ii) on tradeable lot size; or (iii) on a rotating basis factoring in past allocations. For certain SMA accounts which are managed via a wrap sponsor’s platform, securities traded for those Client Accounts may not be aggregated because trades for such Client Accounts are effected by the Client Accounts’ investment platform sponsor or PSG on an account-by-account basis in accordance with the PSG Houston Trading Desk’s Trade Order Rotation, as detailed above. PSG performs investment management services for various Clients. PSG may, in its sole discretion, aggregate purchases or sales of any security, instrument or obligation effected for Client Accounts with purchases or sales, as the case may be, of the same security, instrument or obligation effected on the same day for the accounts of one or more of PSG’s other Clients, including Affiliated Client Accounts. Although such concurrent aggregations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they will be effected only when PSG believes that to do so will be in the best interest of the affected accounts. When transactions are so aggregated, (i) the actual prices applicable to the aggregated transaction will be averaged, and each Client Account participating in the aggregated transaction will be deemed to have purchased or sold its share of the security, instrument or obligation involved at that average price; and (ii) all transaction costs incurred in effecting the aggregated transaction shall be shared on a pro rata basis among all accounts participating in such aggregated transaction, except to the extent that certain broker‐dealers that also furnish custody services may impose minimum transaction charges applicable to some of the participating accounts. When such concurrent aggregations occur, the objective will be to allocate the executions in a manner that is deemed equitable to the accounts involved. Aggregated orders may include transactions for accounts for RICs and Private Funds, in which PSG’s principals or employees may be among the investors. INITIAL PUBLIC AND SECONDARY OFFERING ALLOCATIONS Certain Client Accounts may participate in IPOs and secondary offerings. When allocating shares in an IPO or secondary offering, PSG may allocate a different percentage or amount of shares for Client Accounts, depending on each Client Account’s strategy, investment
Item 14: Client referrals and other compensation Conflicts of interest
PSG may participate in request for proposals (“RFPs”) issued by certain third party, unaffiliated consultants to conduct the search for an investment manager. If PSG responds to an RFP and is awarded the mandate from the prospect, PSG may, in certain limited circumstances, pay a portion of its management fee to the third‐party consultant hired by the prospect. The portion of the fee paid to the third‐party consultant is disclosed to the prospect.
In the ordinary course of business, PSG may send reasonable corporate gifts or pay for meals and entertainment for individuals at firms that do business with PSG or its affiliates, where permitted. PSG’s employees also may be the recipients of reasonable corporate gifts, meals and entertainment. The giving and receipt of gifts and other benefits are subject to limitations under PSG’s Code and PSG’s Gift and Entertainment Policy. To comply with the Rule 206(4)-1 under the Advisers Act, as amended (the “Marketing Rule”), PSG has implemented policies and procedures to the extent necessary to ensure that PSG’s marketing and related activities, including those involving any promoter, conform to the requirements of the Marketing Rule. If a client is introduced to PSG by either an unaffiliated or an affiliated promoter, PSG may pay that promoter a referral fee in accordance with the requirements of the Marketing Rule and any corresponding state securities law requirements. PSG may also pay fees to consultants for their advice and services, prospective investor introductions and industry information and data. If a particular payment constitutes, in PSG’s judgment, an arrangement subject to the Marketing Rule, PSG will comply with the Marketing Rule. Employees of PSG and certain of its Affiliates (typically those in sales and related positions) may be compensated at the discretion of senior management of PSG or the applicable Affiliate for successful efforts in bringing in new accounts. Senior management of PSG or the applicable Affiliate determines the amount of compensation, considering the particular efforts of the employee involved in bringing in the particular account. Any such compensation paid to employees of PSG or its Affiliate, as applicable, does not result in higher fees to Clients.
Item 9: Disciplinary information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of PSG or the integrity of PSG’s management. PSG has no disciplinary information applicable to this Item 9. Please see Oaktree’s Form ADV for relevant disclosures with respect to Oaktree.
Item 13: Review of accounts
PSG will periodically review its Client Accounts: (i) daily through the actions of portfolio managers and their associates; and (ii) periodically in preparation for meetings with Clients. The portfolio managers or analysts will review each of their accounts on a continuous basis and will be responsible for selecting investments in accordance with each Client’s investment objectives, strategies, guidelines and restrictions. Each investment team will meet with a supervisory group periodically. Account trading is monitored periodically by compliance personnel. The review may relate to the entire portfolio, specific portions of the portfolio, or specific transactions or investments. Triggering factors will include changes in market conditions or investment objectives or other arrangements with the Client. The primary reviewer of an account relationship is the portfolio manager responsible for the relationship but may also include research personnel or management personnel from PSG.
Instructions relating to performance of reviews with respect to timing, level and scope of reviews will be determined by the portfolio managers in light of the particular needs and arrangements made with each Client. Reviews will encompass comprehensive evaluations of performance to date, including past transactions, policies and strategies, and future policies, strategies and tactics. From time to time, PSG engages in a firm‐wide review of portfolios or accounts with similar investment objectives or investment strategies. In all cases, the portfolio managers directly responsible for the accounts involved participate in the review along with other professionals within PSG. PSG’s Investment Committee is responsible for conducting these firm‐wide reviews. PSG’s Investment Committee is comprised of members of the portfolio management team(s), as appropriate, and senior management. The nature and frequency of reports to Clients are predicated on the requirements of each Client and will be determined in accordance with the specific needs of, and arrangements made with, each Client. PSG typically produces reports quarterly; monthly or weekly reports are produced for some Clients. PSG also may furnish special reports to the Board of Directors of RICs for which PSG provides investment advisory services. Annual and semi‐ annual reports are issued to investors in closed‐end funds in accordance with the 1940 Act. PSG urges all Clients to carefully review their account statements and compare them to the custodial records provided to them by the broker dealer, bank or other qualified custodian. Client Account statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities.
Item 15: Custody
PSG and its Affiliates may be deemed to have custody of certain Client funds or securities due to its role as general partner of a partnership or managing member of a limited liability company. Clients should receive at least quarterly statements from the broker‐dealer, bank or other qualified custodian that holds and maintains the Client’s investment assets. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. PSG’s investment advisory agreement and/or other separate agreement with a financial institution may authorize PSG through such financial institution to debit the Client’s account for the amount of PSG’s fee and to directly remit that management fee to PSG in accordance with applicable custody rules.
Generally, PSG does not recommend financial institutions to Clients to utilize for custody. However, should PSG recommend a financial institution, they have agreed to send a statement to the Client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to PSG where Clients receive supplemental reports from PSG. Clients should carefully review the statements sent directly by the financial institutions and compare them to those received from PSG.
Item 16: Investment discretion
PSG typically receives discretionary authority from the Client at the outset of an advisory relationship over the following activities:
The securities to be purchased or sold; The amount of securities to be purchased or sold; When transactions are made; and The brokers and other financial institutions through whom we execute securities and other investment related transactions to be utilized.
In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives and/or guidelines for the particular Client Account. When selecting securities and determining amounts, PSG observes the investment policies, limitations and restrictions of the Clients for which it advises. For RICs, PSG’s authority to trade securities may also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. PSG may maintain and provide advisory services to certain non‐discretionary portfolios. Investment guidelines and restrictions must be provided to PSG in writing.
Item 17: Voting client securities
It is the policy and practice of PSG and its Affiliates to vote proxies consistent with its fiduciary duty, the PSG Proxy Voting Policy and Procedures, and the best interests of its Clients, in compliance with Rule 206(4)‐6 under the Advisers Act. In most, if not all cases, the best interest of Clients will mean that the proposals which maximize the value of portfolio securities will be approved. PSG has engaged Institutional Shareholder Services Inc. (“ISS”) to act as agent for PSG to vote proxies in accordance with PSG’s Proxy Voting Guidelines. PSG generally adopts ISS’ Proxy Voting Guidelines as PSG’s Proxy Voting Guidelines after review and consideration by the PSG Proxy Voting Working Group. There may be instances in which PSG may vote against ISS and/or company management recommendation(s) if PSG believes that doing so would be in the best interest of its clients. PSG believes that having an independent third party’s framework and analysis helps to ensure that all proxy voting decisions are made in the best interests of PSG’s Clients after consideration internally by PSG. Unless otherwise specifically provided in the agreement between the Client and PSG, ISS will generally be responsible for evaluating and voting on proposals subject to the oversight of PSG’s Proxy Voting Working Group. PSG’s Proxy Voting Working Group meets periodically to address any exceptions and reviews the services of ISS’s actions, including ISS’s Proxy Voting Guidelines, and consider updates to PSG’s Proxy Voting Policy and Procedures. PSG conducts vendor due diligence on ISS (as well as other vendors), including consideration and review of any conflicts of interest related to ISS, and/or ISS’s activities or services. To the extent a conflict is identified, PSG will
establish and implement measures reasonably designed to address such conflict, such as by requiring ISS to update PSG regarding changes to ISS’s conflict policies and procedures or any business changes PSG considers relevant. For certain PSG clients, PSG has agreed to vote proxies for the accounts of those PSG clients in accordance with the PSG client’s proxy voting guidelines and/or other instructions, and not PSG’s Proxy Voting Guidelines. Authority for PSG to vote proxies for a PSG client account in accordance with the PSG client’s proxy voting guidelines and/or other instructions will typically be found in the investment management agreement or other comparable document(s) between PSG and the PSG client. As a fiduciary to its Clients, PSG’s general policy is to request that ISS cast proxy votes in favor of management proposals and shareholder proposals that we anticipate will enhance the long‐ term value of the securities being voted, in a manner that is consistent with the client’s investment objectives. ISS may also take into account certain proxy voting research and recommendations related to environmental, social, and governance characteristics. However, ISS considers such research and recommendations among many factors it deems relevant to making proxy voting decisions to enhance the long‐term value of the securities being voted. Sometimes securities held in Client Accounts will be the subject of class action lawsuits. PSG and its affiliates actively seek out any open and eligible class action lawsuits for Client Accounts. To this end, PSG has retained a third-party service provider to review class action lawsuits, determine a Client Account’s eligibility, file claim forms and other required documentation, monitor progress and ultimate resolution of class actions, and ensure receipt of class action proceeds and payment to applicable Client Accounts. PSG’s Proxy Voting Policy and Procedures and PSG’s Proxy Voting Guidelines are subject to change as necessary to remain current with applicable rules and regulations and PSG’s internal procedures. PSG’s Proxy Voting Policy and Procedures and PSG’s Proxy Voting Guidelines are available upon request by contacting PSG Investor Relations at 1-855-777-8001 or publicsecurities.enquiries@brookfield.com.
Item 18: Financial information
Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about PSG’s financial condition. PSG has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has not been the subject of a bankruptcy proceeding.
APPENDIX A PRIVACY NOTICE FACTS
WHY?
WHAT?
WHAT DOES BROOKFIELD PUBLIC SECURITIES GROUP LLC (“PSG”) DO WITH YOUR PERSONAL INFORMATION? Financial companies choose how they share your personal information. U.S. federal law gives consumers the right to limit some but not all sharing. U.S. federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. The types of personal information we collect and share depend on the product or service you have with us. This information can include:
HOW?
Social Security number and Income Account balances and wire transfer instructions Account numbers, transactions and assets When you are no longer our customer, we continue to share your information as described in this notice.
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons PSG chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information
Does PSG share?
Can you limit this sharing?
For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus For our marketing purposes—
Yes
No
Yes
No
No
We don’t share
No
We don’t share
to offer our products and services to you For joint marketing with other financial companies For our affiliates’ everyday business purposes— information about your transactions and experiences For our affiliates’ everyday business purposes— information about your creditworthiness For our affiliates to market to you
No
We don’t share
Yes
Yes
For nonaffiliates to market to you
No
We don’t share
Who we are Who is providing this notice?
The PSG affiliated entities set forth below
What we do How does PSG protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does PSG collect my personal information?
We collect your personal information, for example, when you
Why can’t I limit all sharing?
open an account or provide account information give us your contact information or enter into an investment advisory contract make a wire transfer
U.S. federal law gives you the right to limit only sharing for affiliates’ everyday business purposes— information about your creditworthiness affiliates from using your information to market to you sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing.
Definitions Affiliates
Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include the following entities: Brookfield Private Advisors LLC Brookfield Private Wealth LLC Sera Global Securities US LLC Sera Global Securities Canada LP Sera Global Securities UK LP Brookfield Investment Management (Canada) ULC Brookfield Corporation Brookfield Asset Management Ltd. Brookfield Asset Management Private Institutional Capital Adviser (BMG), LLC Brookfield Asset Management Private Institutional Capital Adviser (Private Equity), L.P. Brookfield Asset Management Private Institutional Capital Adviser (Canada), LP Brookfield Asset Management Private Institutional Capital Adviser (Credit), LLC Brookfield Asset Management Private Institutional Capital Adviser US, LLC BAM Credit and Insurance Solutions Advisor LLC Brookfield Renewable Energy Group LLC Crystal River Capital Advisors, LLC
Nonaffiliates
Companies not related by common ownership or control. They can be financial and nonfinancial companies. Non-affiliates we share with can include fund administrators, custodians, brokers, dealers, counterparties, auditors, and legal advisors.
Joint marketing
A formal agreement between nonaffiliated financial companies that together market financial products or services to you. PSG does not jointly market.
Who is providing this service?
BROOKFIELD PUBLIC SECURITIES GROUP LLC
QUESTIONS?
Contact PSG Compliance at (312) 377-8300 or via email at PSGCompliance@brookfield.com
Filings
23 filings to the SEC since October 2021: 23 other. The latest 20:
- Aug 28, 2026N-PX EDGAR
- Aug 14, 202613F-NT EDGAR
- May 15, 202613F-NT EDGAR
- Feb 13, 202613F-NT EDGAR
- Nov 14, 202513F-NT EDGAR
- Sep 2, 2025N-PX EDGAR
- Aug 15, 202513F-NT EDGAR
- May 15, 202513F-NT EDGAR
- Feb 14, 202513F-NT EDGAR
- Nov 15, 202413F-NT EDGAR
- Sep 3, 2024N-PX EDGAR
- Aug 15, 202413F-NT EDGAR
- May 15, 202413F-NT EDGAR
- Feb 14, 202413F-NT EDGAR
- Nov 14, 202313F-NT EDGAR
- Aug 14, 202313F-NT EDGAR
- May 15, 202313F-NT EDGAR
- Mar 9, 202313F-NT EDGAR
- Nov 14, 202213F-NT EDGAR
- Aug 15, 202213F-NT EDGAR
The 23 filings since October 2021 can be filtered by form type and year here when JavaScript is on.
Every filing from the last five years, summarized. The full record is on SEC EDGAR.
Stakes it holds
Brookfield Public Securities Group LLC has told the SEC it owns more than 5% of 1 company, latest first (Schedules 13D and 13G).
- Anadarko PetroleumSCHEDULE 13G/A May 8, 2026 to Jul 24, 20264
Sources
The numbers on this page point here. Each one links to the record it came from.
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