Private company
Invesco Advisers, Inc.
American investment advice company based in Atlanta, incorporated in Delaware. Summary from the record
Last updated Oct 21, 2026.
Overview
- IndustryInvestment Advice2
- HeadquartersAtlanta, United States2
- Legal formCorporation2
- LEIO37NHJVF7S22I1ONOU832
- StatusActive2
- LEI statusIssued and current2
- Registered addressC/O THE CORPORATION TRUST COMPANY, 19801 Wilmington, United States2
- Registered withDivision of Corporations, Department of State, 21066982
Corporate structure
Invesco Advisers, Inc. is part of a group headed by Invesco. 1,042 entities, 18 countries on record. Switch between the flow chart and the network, and select any entity to see its details.
- Invesco Atlanta, Georgia, United States
- Invesco Advisers, Inc. Atlanta, Georgia, United States
- Invesco California Value Municipal Income Trust Atlanta, Georgia, United States
- INVESCO SPPIF (GP) FEEDER FUND LLC Subsidiary · Wilmington, Delaware, United States
- AIM FUNDS GROUP (INVESCO FUNDS GROUP) Fund · Atlanta, Georgia, United States
- CML ACCUMULATION ANNUITY ACCOUNT E Fund · Atlanta, Georgia, United States
- Invesco / SEI Trust Company Investment Trust Fund · Atlanta, Georgia, United States
- INVESCO AMERICAN FRANCHISE FUND Fund · Atlanta, Georgia, United States
- Invesco Balanced-Risk Allocation 10 Fund Fund · Atlanta, Georgia, United States
- Invesco Balanced-Risk Allocation 12 Fund Fund · Atlanta, Georgia, United States
- Invesco California Municipal Fund Fund · Atlanta, Georgia, United States
- INVESCO COMMERCIAL REAL ESTATE FINANCE INVESTMENTS, LP Fund · Atlanta, Georgia, United States
- INVESCO COMSTOCK FUND Fund · Atlanta, Georgia, United States
- Invesco Comstock Large Cap Value CIT Fund · Atlanta, Georgia, United States
- Invesco Comstock Select Fund Fund · Atlanta, Georgia, United States
- INVESCO CONVERTIBLE SECURITIES FUND Fund · Atlanta, Georgia, United States
- INVESCO FIXED MATURITY SELECTIVE EMERGING MARKET DEBTS 2028 Fund · Atlanta, Georgia, United States
- Invesco Global Fixed Maturity Fund SP Fund · Atlanta, Georgia, United States
- Invesco Global Focus Fund Fund · Atlanta, Georgia, United States
- Invesco Global Real Estate Income Fund Fund · Atlanta, Georgia, United States
- INVESCO HIGH YIELD GLOBAL BOND FUND, LTD. Fund · Atlanta, Georgia, United States
- INVESCO INTERMEDIATE TERM MUNICIPAL INCOME FUND Fund · Atlanta, Georgia, United States
- Invesco International Growth Fund, LP Fund · Atlanta, Georgia, United States
- Invesco Mortgage Recovery Master Fund, L.P. Fund · Atlanta, Georgia, United States
- Invesco Multi-Asset Income Fund Fund · Atlanta, Georgia, United States
- Invesco New Jersey Municipal Fund Fund · Atlanta, Georgia, United States
- Invesco Premier Portfolio Fund · Atlanta, Georgia, United States
- and 199 more
- Invesco PowerShares Atlanta, Georgia, United States
- Invesco Galaxy Ethereum ETF Atlanta, Georgia, United States
- Invesco Galaxy Solana ETF Atlanta, Georgia, United States
- Invesco Agency MBS ETF Fund · Atlanta, Georgia, United States
- Invesco BCPL Badger Fund Fund · Atlanta, Georgia, United States
- Invesco Bulletshares 2027 Treasury Bond ETF Fund · Atlanta, Georgia, United States
- Invesco Bulletshares 2028 Treasury Bond ETF Fund · Atlanta, Georgia, United States
- Invesco Bulletshares 2030 Treasury Bond ETF Fund · Atlanta, Georgia, United States
- Invesco BulletShares 2031 High Yield Corporate Bond ETF Fund · Atlanta, Georgia, United States
- Invesco Bulletshares 2031 Treasury Bond ETF Fund · Atlanta, Georgia, United States
- Invesco BulletShares 2032 High Yield Corporate Bond ETF Fund · Atlanta, Georgia, United States
- Invesco BulletShares 2033 Corporate Bond ETF Fund · Atlanta, Georgia, United States
- Invesco BulletShares 2033 High Yield Corporate Bond ETF Fund · Atlanta, Georgia, United States
- Invesco BulletShares 2033 Municipal Bond ETF Fund · Atlanta, Georgia, United States
- Invesco BulletShares 2034 Corporate Bond ETF Fund · Atlanta, Georgia, United States
- Invesco Bulletshares 2034 High Yield Corporate Bond ETF Fund · Atlanta, Georgia, United States
- Invesco BulletShares 2035 Corporate Bond ETF Fund · Atlanta, Georgia, United States
- Invesco Bulletshares 2036 Corporate Bond ETF Fund · Atlanta, Georgia, United States
- Invesco BulletShares 2036 Municipal Bond ETF Fund · Atlanta, Georgia, United States
- Invesco Core Fixed Income ETF Fund · Atlanta, Georgia, United States
- Invesco Diversified Dividend Opportunities ETF Fund · Atlanta, Georgia, United States
- Invesco Emerging Markets Enhanced ETF Fund · Atlanta, Georgia, United States
- Invesco Global Equity Net Zero ETF Fund · Atlanta, Georgia, United States
- Invesco International Developed Enhanced ETF Fund · Atlanta, Georgia, United States
- Invesco Managed Futures Strategy ETF Fund · Atlanta, Georgia, United States
- Invesco MSCI EAFE Income Advantage ETF Fund · Atlanta, Georgia, United States
- and 234 more
- Invesco Private Capital, Inc. Atlanta, Georgia, United States
- WL ROSS & CO. LLC Atlanta, Georgia, United States
- 4 more
- WL ROSS & CO LLC Subsidiary · DE
- INVESCO CREDIT PARTNERS FUND, L.P. Fund · Atlanta, Georgia, United States
- INVESCO INTERNATIONAL PARTNERSHIP FUND VI, L.P. Fund · New York, New York, United States
- INVESCO PARTNERSHIP FUND VI, L.P. Fund · Atlanta, Georgia, United States
- INVESCO U.S. PRIVATE EQUITY PARTNERSHIP FUND VI, L.P. Fund · Atlanta, Georgia, United States
- Invesco U.S. Venture Partnership Fund VI, L.P. Fund · Atlanta, Georgia, United States
- WL ROSS & CO. LLC Atlanta, Georgia, United States
- Compass Group Subsidiary · 4.95% · Chertsey, United Kingdom
- Amica Subsidiary · Finland
- COMPASS GROUP BELGILUX Subsidiary · Bruxelles, Belgium
- COMPASS GROUP FINANCE NETHERLANDS B.V. Subsidiary · Amsterdam, Netherlands
- COMPASS GROUP INTERNATIONAL B.V. Subsidiary · Amsterdam, Netherlands
- THE EXCELSIOR INSURANCE COMPANY LIMITED Subsidiary · Chertsey, United Kingdom
- Pennon Group Subsidiary · 4.32% · Exeter, United Kingdom
- 6 more
- Card Factory Subsidiary · Wakefield, United Kingdom
- CF BIDCO LIMITED Subsidiary · Wakefield, United Kingdom
- SPORTSWIFT LIMITED Subsidiary · Wakefield, United Kingdom
- Strategy Subsidiary · Tysons Corner, Virginia, United States
- 1 more
- Drax Group Stake · 8.23% · Selby, United Kingdom
- Opus Energy Selby, United Kingdom
- DRAX CORPORATE LIMITED Subsidiary · Selby, United Kingdom
- DRAX ENERGY SOLUTIONS LIMITED Subsidiary · Selby, United Kingdom
- DRAX FINCO PLC Subsidiary · Selby, United Kingdom
- DRAX PUMPED STORAGE LIMITED Subsidiary · Selby, United Kingdom
- DRAX RIVER HYDRO LIMITED Subsidiary · Selby, United Kingdom
- HIRWAUN POWER LIMITED Subsidiary · Selby, United Kingdom
- MILLBROOK POWER LIMITED Subsidiary · Selby, United Kingdom
- PROGRESS POWER LIMITED Subsidiary · Selby, United Kingdom
- and 1 more
- Reata Pharmaceuticals Stake · 5.66% · Irving
- Atlantic Wealth Holdings Limited Subsidiary · United Kingdom
- Atlantic Wealth Management Limited Subsidiary · United Kingdom
- Beijing HIW XinHe Investment Co., Ltd. Subsidiary · China
- BVK Global Real Estate Invesco S.à r.l. Subsidiary · Luxembourg
- C M Investment Nominees Limited Subsidiary · United Kingdom
- Elliot Associates Limited Subsidiary · United Kingdom
- Greenspruce GP Limited Subsidiary · United Kingdom
- HIW Private Equity Investment Management Limited Subsidiary · Hong Kong
- Huajing Private Equity Management (Hainan) Co Ltd (“PRC”) Subsidiary · China
- Huaneng Invesco Private Equity Management Company Ltd Subsidiary · China
- Invesco (Cayman Islands) Ltd. Subsidiary · Cayman Islands
- INVESCO (INDIA) PRIVATE LIMITED Subsidiary · Atlanta, Georgia, United States
- Invesco (Nominees) Limited Subsidiary · United Kingdom
- Invesco Administration Services Limited Subsidiary · United Kingdom
- Invesco Asia Pacific Private Equity Investment and Fund Management (Shenzhen) Limited Subsidiary · China
- Invesco Asset Management (Bermuda) Limited Subsidiary · Bermuda
- and 91 more
- Invesco Advisers, Inc. Atlanta, Georgia, United States
Built from parent and subsidiary links from GLEIF, the Global Legal Entity Identifier Foundation (CC0); subsidiaries listed in Exhibit 21 of annual reports filed with the SEC; subsidiaries, stakes and holdings from Wikidata (CC0); 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
Invesco Advisers, Inc. 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$749.5B15 82,498 accounts, $730.5B with discretion
- Employees2,804 713 in investment advice or research
- ClientsInvestment companies: 200 ($459.3B); Pooled investment vehicles (other than investment companies and business: 198 ($129.3B); Corporations or other businesses not listed above: 62 ($47.8B); Pension and profit sharing plans (but not the plan participants or government: 86 ($41.9B); State or municipal government entities (including government pension plans): 30 ($29.6B); Other: THE "OTHER" CATEGORY INCLUDES SMAS, CDOS, NON-IVZ RETAIL: 81,882 ($16.1B); Sovereign wealth funds and foreign official institutions: 13 ($14.2B); Insurance companies: 23 ($11.2B); Charitable organizations: 2 ($125.6M); Banking or thrift institutions: 2 ($19.0M)
- How it is paidA percentage of assets under its management; 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); Other: IA TO CANADIAN REGISTERED MUTUAL FUNDS; PORTFOLIO MANAGEMENT FOR PRIVATE FUNDS
- Holds client assetsYes: cash and securities
- RegistrationSEC 801-33949, CRD 105360 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).
- INVESCO GROUP SERVICES, INC.owns 75% or more, since 06/2018
- INVESCO HOLDING COMPANY (US),owns 75% or more of OPPENHEIMER, since 05/2019
- INVESCO LTD. (public company)owns 75% or more of INVESCO HOLDING, since 01/2002
- OPPENHEIMERFUNDS, INC. (US)owns 75% or more of INVESCO GROUP, since 05/2019
Disciplinary record
The firm answered yes to 6 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.
- Any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority has found the firm or an advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical.
- Any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority has found the firm or an advisory affiliate to have been involved in a violation of investment-related regulations or statutes.
- In the past ten years, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority has entered an order against the firm or an advisory affiliate in connection with an investment-related activity.
Each event as the firm describes it on its Disclosure Reporting Pages:
FEDERAL FINANCIAL SUPERVISORY AUTHORITY ("BAFIN") · Jul 30, 2020 · fine $309,595 · final about INVESCO LTD
Allegations: INVESCO LTD AND AIM INTERNATIONAL MUTUAL FUNDS FAILED TO SUBMIT VOTING RIGHTS NOTIFICATIONS TO BAFIN AND THE ISSUERS BY THE REQUIRED DEADLINE. BAFIN ISSUED A NOTICE OF HEARING ON JULY 30, 2020 TO INVESCO LTD ALLEGING THAT VIOLATIONS OF THE VOTING RIGHTS REQUIREMENTS OCCURED ON 26 OCCASSIONS RELATING TO THE VOTING RIGHTS NOTIFICATIONS OF INVESCO LTD AND ON 28 OCCASIONS RELATING TO VOTING RIGHTS NOTIFICATIONS OF AIM INTERNATIONAL MUTUAL FUNDS.
Sanction: Civil and Administrative Penalt(ies) /Fine(s)
How it ended: Decision
Detail: DECISION TO IMPOSE A FINE OF 260,000 EUROS (APPROXIMATELY $309,595 USD) AGAINST INVESCO LTD WILL BE PAID BY THE JULY 2, 2021 DEADLINE.
Summary: BAFIN IMPOSED A FINE OF 260,000 EUROS (APPROXIMATELY $309,595 US DOLLARS) AGAINST INVESCO LTD FOR 54 INCORRECT THRESHOLD FILINGS BETWEEN 05/2019 AND 10/2019. THE FINE WILL BE PAID BY THE JULY 2, 2021 DEADLINE.
Resolved: May 31, 2021
U.S SECURITIES AND EXCHANGE COMMISSION ("SEC") · Nov 28, 2022 · fine $17,500,000 · final
Allegations: THE SEC ALLEGED THAT INVESCO ADVISERS, INC. ("IAI") LACKED COMPREHENSIVE POLICIES AND PROCEDURES TO DETERMINE THE PERCENTAGE OF COMPANY-WIDE ASSETS UNDER MANAGEMENT ("AUM") THAT WAS ESG INTEGRATED. THE SEC ALSO ALLEGED THAT IAI MADE MISLEADING STATEMENTS CONCERNING THE COMPANY-WIDE PERCENTAGE OF AUM THAT WAS ESG INTEGRATED.
Sanction: Cease and Desist
How it ended: Order
Detail: THE SETTLEMENT REQUIRED INVESCO ADVISERS, INC. ("IAI") TO PAY A CIVIL MONETARY PENALTY OF $17.5 MILLION. IAI PAID THE CIVIL MONETARY PENALTY ON NOVEMBER 14, 2024.
Summary: ON NOVEMBER 8, 2024, INVESCO ADVISERS, INC. ("IAI") ENTERED INTO A SETTLEMENT WITH THE SEC REGARDING IAI'S ENVIRONMENTAL, SOCIAL AND GOVERNANCE ("ESG") POLICIES AND PROCEDURES. THE SEC FOUND THAT IAI LACKED COMPREHENSIVE POLICIES AND PROCEDURES TO DETERMINE THE PERCENTAGE OF COMPANY-WIDE ASSETS UNDER MANAGEMENT ("AUM") THAT WAS ESG INTEGRATED. THE SEC ALSO FOUND THAT IAI MADE MISLEADING STATEMENTS CONCERNING THE COMPANY-WIDE PERCENTAGE OF AUM THAT WAS ESG INTEGRATED. IAI WAS CENSURED AND ORDERED TO CEASE AND DESIST FROM VIOLATING SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULES 206(4)-1, 206(4)-7 AND 206(4)-8 THEREUNDER. IAI AGREED TO PAY A PENALTY OF $17.5 MILLION. No Information Filed
Resolved: Nov 8, 2024
Another 2 records concern WL ROSS & CO. LLC (1), INVESCO DISTRIBUTORS, INC. (1), which report the details on their 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 6/11/2026.16 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.
Item 4: Advisory business Services
________________________________________________________________________________ Firm Description Invesco Advisers, Inc. “Invesco Advisers” “the Firm” “We” is a Delaware corporation and was founded in 1986. The Firm has been registered as an investment adviser with the SEC since 1988, Invesco Group Services, Inc. is the sole owner of Invesco Advisers and Invesco Ltd. is its ultimate parent company. Invesco Ltd. is a publicly traded leading independent global investment management firm dedicated to helping investors worldwide achieve their financial objectives. Shares of Invesco Ltd. are listed on the New York Stock Exchange under the symbol "IVZ," and Invesco Ltd. is a constituent of the S&P 500®. Investment advisory services are provided by investment professionals located in Atlanta, Austin, Boston, Dallas, Denver, Downers Grove, Houston, Los Angeles, Louisville, Newport Beach, New York City, Rochester, San Francisco and Seattle. As of December 31, 2025, Invesco Advisers manages $749,518,786,407 billion in assets for 82,498 clients, consisting of $730,503,852,494 on a discretionary basis and the remaining $19,014,933,913 on a nondiscretionary basis. ________________________________________________________________________________ Advisory Services Invesco Advisers provides discretionary and nondiscretionary investment advisory services across a broad spectrum of investment strategies, sectors and asset classes to individuals, institutional and high net worth clients through separate accounts, wrap programs and U.S. registered investment companies, and other commingled investment vehicles (together with registered investment companies, “Commingled Funds,” as detailed below). Invesco Advisers’ investment advisory services consist of (i) investigating, identifying, and evaluating investment opportunities, (ii) structuring, negotiating and making investments on behalf of its clients, (iii) managing and monitoring the performance of such investments and (iv) disposing of such investments. Invesco Advisers provides advisory services in accordance with the applicable investment guidelines, including applicable restrictions on investing in certain securities, or types of securities or other financial instruments, that are customized by the client, or in accordance with the mandate selected by the client including as disclosed in fund offering materials. Invesco Solutions encompasses the bulk of the firm’s systematic investment strategies. These include systematic equities and multi-asset strategies, including asset allocation and commodities and derivative strategies. The Solutions team also manages firm-wide multi-asset investing training, messaging, and communication, internally and externally, and is the central source for global multiasset investing business strategy, data, metrics, and competitive intelligence. The Solutions team comprises approximately 100+ investment professionals across eight major global locations. Solutions portfolio management teams are led by their respective systematic equities, asset allocation, and global strategies team leads, each of whom reports to Scott Wolle, who serves as CIO, Invesco Solutions. The Invesco Solutions team has the flexibility to tap into a broad set of capabilities. The team utilizes strategic and tactical asset allocation approaches to help design and implement custom solutions
across a wide range of vehicles for its clients. Additionally, the team provides advisory and oversight functions for institutional indexing platform. • • •
Advisory Solutions: institutional and advisor client facing teams that consult investors on asset allocation and portfolio construction while leveraging Invesco’s proprietary analytics engine, Invesco Vision. Development and Implementation: managing portfolios through an outcome-based lens for clients. Research and Portfolio Analytics: providing thought leadership and customized engagements around asset allocation modeling and portfolio construction.
In providing advisory solutions for clients, Invesco Solutions may recommend investment products managed by Invesco Advisers’ affiliates, and in certain circumstances, the Invesco Solutions team may have discretion to execute investments on behalf of its advisory clients in alternative investment products managed by such affiliates. Where client accounts invest in such affiliated products, Invesco Advisers' management fee is typically reduced or, in some circumstances, eliminated, in respect of client funds allocated to such affiliated products. However, it is possible that, even after application of such reduction or elimination, total fee revenue to Invesco Advisers and its affiliates may increase because of the Invesco Solutions team’s decision to invest in affiliated products instead of third-party products. Separate Accounts Invesco Advisers provides discretionary and nondiscretionary investment advice to institutional and high net-worth clients through separately managed accounts pursuant to the terms of individually negotiated investment management agreements. The investment objectives and guidelines applicable to separate accounts may be customized for separate account clients. Wrap Programs Invesco Advisers provides discretionary and nondiscretionary investment advisory services directly and indirectly to individuals or entities participating in separately managed account programs that we do not sponsor, also referred to as Wrap Programs (“Wrap Programs”). In a Wrap Program, Invesco Advisers will provide certain investment management services, and the financial intermediary sponsoring the Wrap Program (“Program Sponsor”) will provide the client with other services such as determining the appropriate investment strategy for its client. The client’s Wrap Program agreement with its Program Sponsor generally sets forth the services to be provided to the client by or on behalf of the Program Sponsor, which can include, among other things: (i) manager selection; (ii) trade execution, often without a transaction-specific commission or charge; (iii) custodial services; (iv) periodic monitoring of investment managers; and (v) performance reporting. Wrap Programs for which Invesco Advisers provides certain advisory services, include the following types:
1. Traditional wrap (“Traditional Wrap”): Invesco Advisers enters into a contract with the Program Sponsor but does not have a contract with the client. Invesco Advisers makes investment decisions and places trades for client accounts. 2. Dual contract (“Dual Contract”): Invesco Advisers enters into a contract with the client and the client also has a separate contract with the Program Sponsor. In some cases, Invesco Advisers
enters into a contract with an investment manager to act as a sub-adviser to its client accounts; the client has a separate contract with the investment manager, and the investment manager has an agreement with the Program Sponsor. In Dual Contract programs, Invesco Advisers provides investment advisory services to the client and places trades for client accounts. 3. Model-only (“Model-Only”): Invesco Advisers enters into a contract with the Program Sponsor but does not have a contract with the client. Invesco Advisers provides investment models to the Program Sponsor, and the Program Sponsor places trades for the client account based on some or all of the model recommendations. Invesco Advisers is not responsible for and does not attempt to determine whether a Wrap Program is suitable or advisable for Wrap Program participants. Invesco Advisers may make available through Wrap Programs the same or similar strategies that are available to institutional clients or through Funds; however, not all of Invesco Advisers’ strategies are available through Wrap Programs and not every Invesco Adviser strategy that is available through a particular Wrap Program will be available through other Wrap Programs. Further, the manner in which Invesco Advisers executes a strategy through Wrap Programs may differ from how that same or a similar strategy is executed through another Wrap Program or for a Fund or institutional Client. For instance, the execution of a particular strategy in a Wrap Program may differ from the execution of the same or a similar strategy for a Fund or institutional Client due to the need to adhere to “reasonable restrictions” imposed by the Wrap Program Client or due to the use of affiliated no-fee registered investment companies or other affiliated commingled vehicles rather than individual securities. Accordingly, the performance of a strategy available through a Wrap Program may differ from the performance of the same or a similar strategy that is executed through another Wrap Program or for a Fund or institutional Client. In most Wrap Programs, the Program Sponsor charges the client a comprehensive fee (the "wrap fee”), inclusive of the advisory fee charged by Invesco Advisers for investment advisory services and fees for other services being provided by the Program Sponsor. Therefore, Invesco Advisers receives a portion of the wrap fee in most Wrap Programs. A client in a Wrap Program may restrict the purchase of certain securities for its account. A client may name either specific securities or a category (e.g., tobacco companies, gambling stocks or other restrictions by ESG mandates) that includes specified securities that may not be purchased for the account. The client or Program Sponsor is responsible for identifying any security or group of securities which may not be held in an account. If a client identifies a category of restricted securities without identifying the underlying companies of which the category is comprised or a source for identifying such underlying companies, Invesco Advisers may utilize outside service providers to identify the universe of companies that will be considered in such a category. Such restrictions may adversely affect the account's performance and the account will likely not have the same performance as other accounts managed without similar restrictions in the same investment strategy. The change of the classification of a company, the grouping of an industry or the credit rating of a security may force Invesco Advisers to sell securities in a client's account at an inopportune time and possibly cause a taxable event to the client. The ability to restrict investments does not apply to the purchase policies of or underlying securities held by any mutual funds, exchange-traded funds (“ETFs”) or other Commingled Funds held in a Wrap Program account.
Wrap Program clients are urged to refer to the appropriate disclosure document and client agreement for more information about the Wrap Program, investment advisory services, fees and contract termination provisions. Commingled Funds Invesco Advisers provides investment management (as both adviser and sub-adviser) and administrative services (if applicable), to the following types of Commingled Funds (collectively, the “Funds”): • open-end, closed-end and exchange-traded funds registered as investment companies under the Investment Company Act of 1940, as amended (the “1940 Act”) (such funds, “Registered Funds”). • open-end and closed-end commingled vehicles excepted from regulation and registration under the 1940 Act pursuant to Sections 3(c)(7) & 3(c)(1) of the 1940 Act (“Private Funds”) and other privately offered structures relying on Section 3(c)(5)(C), 3(a)(1)(A) and/or 3(a)(1)(C) of the 1940 Act and Rule 3a-7 promulgated under the 1940 Act. • publicly registered real estate investment trusts not registered under the 1940 Act (“Public REITs”). • collective trust funds excepted from regulation and registration under the 1940 Act pursuant to Section 3(c)(11) of the 1940 Act (“Collective Trust Funds”). • registered and unregistered commingled vehicles organized outside of the United States; and • closed-end commingled vehicles exclusively offered to employees of the Firm and other investment advisers under Invesco Ltd. (“Affiliates”) pursuant to a 1940 Act exemptive order. Each Commingled Fund for which Invesco Advisers provides advisory services is managed in accordance with its investment guidelines and restrictions and generally is not tailored to the individualized needs of any particular investor. An investment in a Commingled Fund does not, in and of itself, create an advisory relationship between the investors therein and Invesco Advisers or an affiliate. Digital Asset Strategies Invesco Advisers may offer or manage investment strategies that provide exposure to digital assets, including cryptocurrencies and other blockchain-based tokens (“Digital Assets”), through separate accounts, commingled vehicles, or other investment structures. These strategies may invest directly in Digital Assets or in instruments or companies with economic exposure to such assets. The information in this Brochure is qualified in its entirety by the disclosures contained in the investment management agreements (“IMAs”) and/or offering materials for the respective Funds or client accounts.
Item 5: Fees and compensation Fees
________________________________________________________________________________ The fees described in this section are strictly for investment advisory services and do not include other fees, such as certain brokerage, custody fees or fees charged by other service providers retained by
the client. Invesco Advisers does not receive or participate in the sharing of custody fees or otherwise receive any benefit as a result of custodial arrangements entered into by its clients’ accounts. Additional fees are incurred in connection with certain trades placed by Invesco Advisers on behalf of Wrap Program clients. See Item 12 (Brokerage Practices) for further information. Invesco Advisers reserves the right to waive its investment advisory fee and to negotiate such fees as permitted in client governing documents. Fee schedules vary depending on the strategy and size of account, among other factors, and may change. To the extent permitted under applicable law, Invesco Advisers charges performance fees, in addition to asset-based fees. Please refer to Item 6 (Performance-Based Fees and Side-by-Side Management). Advisory Fee Schedules set forth below may not reflect the potential upper limit of fees earned by Invesco Advisers under a performance fee structure. From time to time, Invesco Advisers acts as a sub-adviser to certain portfolios managed by another registered investment adviser and will share management fees with the adviser pursuant to the terms of the applicable sub-advisory agreement. Please refer to Item 10 (Other Financial Industry Activities and Affiliations) for additional information on affiliated services and compensation. ________________________________________________________________________________ Investment Advisory Fee Schedules The following sets forth a basic description of the standard advisory fee ranges for investment strategies offered by Invesco Advisers. Fees and other compensation are negotiated in certain circumstances, and arrangements with particular clients vary. Information on the fee arrangements for Separate Accounts, Commingled Funds, and Wrap Programs are noted further below:
Investment Strategy
Fee Range
Sub-strategies/mandates
EQV International Equity
1-150bps
EQV International Equity
Global Equity
Global Focus Global Equity Global Opportunities Global Core Equity Global Small Cap Equity
International Equity
International Growth International Diversified International Value International Small-Mid Cap International Small Company Developing Markets Emerging Markets Ex China Asia Pacific Equity Global Consumer Trends Large Cap Growth Conservative Multi-Cap Growth Small Cap Core Small Cap Growth
Emerging Markets Equity
1-150bps
US Growth Equities (Houston)
1-125bps
Discovery Large Cap Growth Discovery Mid Cap Growth Discovery Small Cap Growth Sector (Health Care) Sector (Technology)
US Discovery Growth Equities
US Dividend and Core Equities
1-125bps
US Value Equities
1-100 bps
Global Liquidity
1-100bps
Dividend Equity Dividend Growth Large Cap Core Mid Cap Core Small Cap Core All Cap Core Large Cap Value (Comstock) Equity and Income (Relative Value) Small and Mid-Cap Value (Intrinsic Value) Treasury Cash Management Government Cash Management
Investment Strategy
Macro Alpha
Fee Range
1-100bps
Emerging Markets Debt
Stable Value Investment Grade Credit
Tax-Free Cash Management Ultrashort/Conservative Income Multi-Sector Income International Bond Absolute Return Flexible Income ETF Emerging Markets Local Bond Emerging Markets Flexible Bond Emerging Markets Bond Emerging Markets Corporate Bond Developing Initiatives Bond India Bond Asian Flexible Bond
1-100bps 1-100bps
Fixed Income Factors
Municipals
Sub-strategies/mandates
0.01-100bps
Core Bond Core Plus Bond Corporate Credit Equity Enhanced Fixed Income Long Duration Corporate Bond Short Term Bond Convertible Securities US Investment Grade Corporate Bond High Yield Systematic Global Multi-Factor Government Bond Short Term Municipal Limited Term Municipal Intermediate Term Municipal AMT-Free Municipal Income Municipal Income Short Duration High Yield High Yield Municipal Rochester® Municipal Opportunities Limited Term California Municipal California Municipal Rochester® Limited Term New York Municipal Rochester® AMT-Free New York Municipal Rochester® New York Municipals
Investment Strategy
Fee Range
Structured Investments
1-150bps
Multi-Sector Credit High Yield
1-60bps 0.01-100bps
Invesco Solutions
0.01-150bps
Sub-strategies/mandates New Jersey Municipal Pennsylvania Municipal Rochester® High Yield Municipal ETF Intermediate Municipal ETF Advantage Municipal Income Trust II California Value Municipal Income Trust Municipal Income Opportunities Trust Municipal Opportunity Trust Municipal Trust Pennsylvania Value Municipal Income Trust Quality Municipal Income Trust Trust for Investment Grade Municipals Trust for Investment Grade New York Municipals Value Municipal Income Trust US Mortgage-Backed Agency Focused High Quality Variable Rate Bond US Mortgage-Backed Securities Opportunistic Mortgage Diversified Income U.S. High Quality Short-Term Bond Securitized Investment Grade Credit Active Multi-Sector Credit Global High Income High Yield Short Duration High Yield Balanced Income Balanced (Equity, Fixed Income, Alternatives) Global Multi-Asset Multi-alternatives Target Risk Balanced-Risk Allocation Balanced-Risk Allocation 10% Balanced-Risk Allocation 12% Balanced-Risk Allocation 15% Balanced-Risk Allocation 18% Multi-Strategy Small Cap Index Plus Balanced Risk Commodities
Investment Strategy
Fee Range
Global and US Real Assets – Direct Real Estate
1-150bps
Global and US Real Assets-Securities
1-150bps
Sub-strategies/mandates US Market Neutral Enhanced Index Global Low Volatility QQQ Hedged Advantage US Core Equity Investments US Core-Plus Debt Investments US Core-Plus Equity Investments US Value-Add and Opportunistic Investments Non-Listed Diversified Equity REIT Non-Listed Diversified Debt REIT Fund-of-Fund Mandates investing in Private Funds, Public REITs, Registered Investment Companies and/or Direct Real Estate US Real Estate Securities Total Return Global Real Estate Securities Total Return Global Real Estate Securities Income-Oriented Energy Infrastructure-Master Limited Partnerships Real Assets ESG ETF Real Assets Securities Total Return
________________________________________________________________________________ Other Fees and Expenses In addition to the advisory fees paid to Invesco Advisers, clients are responsible for other charges permitted by the clients’ governing documents with Invesco Advisers. The fees and charges could include but not be limited to: (i) custodial and accounting charges; (ii) brokerage fees, commissions and related costs; (iii) interest expenses; (iv) taxes, duties and other governmental charges; (v) transfer and registration fees or similar expenses; (vi) costs associated with foreign exchange transactions; (vii) costs, expenses and fees (including investment advisory and other fees charged by the investment advisers of funds in which a client’s account is invested) associated with products or services that are necessary or incidental to such investments or accounts;(viii) services rendered by affiliates (ix) legal expense and (x) offering expenses. Client accounts that invest in mutual funds, exchange-traded funds (“ETFs”) or other funds, including Invesco Funds, will indirectly bear their proportionate share of the advisory fees and other operating and organizational expenses of such fund (to the extent consistent with applicable law and a client’s contract), unless Invesco Advisers agrees to an arrangement whereby such fees are waived. Third-party administrators (“TPAs”) monitor investments in affiliated Invesco Trust Company products, mutual funds, and ETFs held in client accounts to identify any affiliated product fees that may apply. To mitigate potential conflicts of interest associated with these affiliated fees, TPAs apply any fee waivers approved by Invesco Fund Treasury. Invesco’s Fund Treasury team oversees the TPAs’ activities and reviews their processes to help ensure that affiliated investments and any related waivers are identified, calculated, and implemented accurately and in a timely manner. For an additional discussion of brokerage and other transaction costs, please refer to Item 12 (“Brokerage
Practices”). Additional types of fees and expenses specific to various vehicles are summarized below, subject to what is outlined in the governing document(s) for a particular vehicle. ________________________________________________________________________________ Separate Accounts Generally, fees for separate accounts are calculated as a percentage of assets under management based on the month-end market value. Fees are shown as annual percentages and are generally billed on a quarterly basis. The table above sets forth the investment advisory fees for the first $100 Million in assets under management for separate accounts by investment strategy. In certain cases, fees are negotiable. Please contact Invesco Advisers for details regarding additional breakpoints in the investment advisory fee for assets under management above $100 Million. Each direct real estate separate account arrangement is negotiated on a case-by-case basis. In the case of Invesco Advisers’ direct real estate products, in addition to asset-based fees, fixed fees may also be charged on a transaction-by-transaction basis, based on the terms negotiated with each separate account client. Additionally, from time to time, direct real estate separate account arrangements will provide for the chargeback of certain expenses to the client (such as due diligence, travel, legal and accounting) related to potential investments allocated thereto, even if the transaction is not ultimately consummated (dead deal costs). ________________________________________________________________________________ Registered Funds and REITS Registered Funds, non-listed and listed real estate investment trusts with offerings registered under the Securities Act of 1933, as amended (“Public REITS”) and other non-listed real estate investments trusts with offerings exempt from registration under the Securities Act of 1933, as amended, managed by Invesco Advisers (Public REITs along with non-Public REITS referred to as “REITs”) compensate it for services in accordance with investment advisory agreements approved by the applicable Boards of Directors/Trustees (the “Board”) of each Registered Fund or REIT. Advisory fees are calculated separately for each Registered Fund and REIT on a monthly basis at a specified annual percentage (which percentage may vary by share class) of such Registered Fund's or REIT’s net assets or stockholders’ equity as applicable. In certain instances, transaction-based fees and performance-based compensation can be earned by Invesco Advisers in accordance with the applicable governing documents. In addition to the advisory fees, clients bear other ongoing operating expenses including, but not limited to: (i) shareholder servicing fees; (ii) custodian fees; (iii) administration services fees; (iv) audit fees; (v) legal fees; (vi) registration and filing fees; (vii) costs associated with trustees; (viii) insurance fees and (ix) reports to shareholders and (x) costs incurred related to services provided by the adviser or its affiliates. Please refer to the Prospectuses, offering documents or Statements of Additional Information (“SAI”) of the Registered Funds or REITs for a more detailed description of all applicable fees. Private Funds (Direct Real Estate) and Other Privately Offered Real Estate Vehicles Direct real estate Private Funds and other privately offered real estate vehicles managed by Invesco Advisers charge transaction-based fees and incentive fees, in addition to asset management fees, if permitted by the Private Funds’ governing documents. Management fees are charged in accordance with the applicable fund’s governing documents whereby payment is either made directly by the client via a physical invoice or withheld from a following distribution and the payment is made on behalf of the client. In the case where fees are withheld, the Client is notified. Fees are typically in arrears and are recorded and invoiced as earned. In the event that a refund is warranted, e.g., a termination, a
Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks
_______________________________________________________________________ Investment Strategies Invesco employs several methods of analysis and investment strategies in managing assets, each of which is discharged by discrete investment centers. Each significant investment strategy is described in the table below. Investment Strategy EQV International Equity
Summary of Philosophy and Process The Firm’s EQV International Equities investment strategies employ a rigorous, bottom-up stock selection process that seeks to identify companies with sustainable earnings growth (Earnings), efficient capital allocation (Quality), and attractive prices (Valuation).
Global Equity
The Firm’s Global Equity strategies invest in what they believe to be high quality businesses that are exposed to structural global growth trends. The team takes a generalist approach to research, seeking best ideas regardless of sector or country, and builds high conviction portfolios independent of any benchmark.
International Equity
The Firm’s International Equity strategies seek to identify and invest in secular changes in the world and look for pockets of durable change that it believes will
Substrategies/mandates EQV International Equity
Risks
Market Risk Allocation Risk Investing in Stocks Risk Preferred Depositary Receipts Risk Foreign Investment Risk European Investment Risk Emerging Markets Global Focus Investment Risk Geographic Global Equity Focus Risk Global Opportunities Asia Pacific Global Core Equity Region Risk Global Small Cap Equity (including Japan) Value Investing Convertible Rights and Warrants Risk Growth Investing Risk Small- and MidInternational Growth Capitalization International Companies Risk Diversified Sector Focus International Value
Investment Strategy
Emerging Markets Equity
Summary of Philosophy and Process drive global growth for the next decade. The team takes a generalist approach to research, seeking best ideas regardless of sector or country, and builds high conviction portfolios independent of any benchmark.
SubRisks strategies/mandates International Small-Mid ESG Considerations Cap International Small Derivatives Risk Company Convertible
The Firm’s Emerging Markets Equity strategies seek to provide investors exposure to undervalued companies across emerging markets. Through a highly active approach, the team seeks to invest in companies whose share prices are substantially below their estimate of fair value, looking for new ideas in unloved areas of the market. The team has a clear preference for cash-generative companies with strong balance sheets, as these attributes suggest sustainable business models and conservative management.
Developing Markets Emerging Markets Ex China Asia Pacific Equity
Debt Securities Depositary Receipts Risk Rights and Warrants Risk Management Market Risk Investing in Stocks Risk Foreign Investment Risk Emerging Markets Investment Risk European Investment Risk Geographic Focus Risk Asia Pacific Region Risk (exJapan) Small- and MidCapitalization Companies Risk Sector Focus Preferred Convertible Rights and Warrants Risk Depositary Receipts Risk Debt Securities U.S. Government Obligations Risk Liquidity Risk
Investment Strategy
Summary of Philosophy and Process
US Growth Equities (Houston)
The Firm’s US Growth Equities investment strategies utilize a rigorous, bottom-up stock selection process that seeks to maximize alpha through the selection of stocks, which offer attractive growth opportunities based on valuation and perceived quality. Specific to Conservative Multi-Cap Growth, the strategy excludes investments in companies whose primary business involves alcohol, tobacco or gambling.
US Discovery Growth Equities
The Firm’s US Discovery Growth Equities, run by the NY-based team, seeks to invest in premier growth companies that provide high sustained growth rates.
Substrategies/mandates
Risks
Rule 144A Securities and Other Exempt Derivatives Risk ESG Considerations Management Market Risk Global Consumer Health Care Trends Sector Risk Large Cap Growth Investing in Conservative Multi-Cap Stocks Risk Technology Growth Sector Risk Small Cap Core Growth Small Cap Growth Investing Risk Small- and MidCapitalization Companies Risk Preferred Sector Focus REIT Risk/Real Estate Risk Foreign Investment Risk Emerging Discovery Large Cap Markets Growth Investment Risk Discovery Mid Cap Depositary Receipts Risk Growth Derivatives Risk Discovery Small Cap NonGrowth Diversification Sector (Health Care) Active Trading Sector (Technology) Valuation Risk Management
Investment Strategy US Dividend and Core Equities
Summary of Philosophy and Process The Dividend Equity strategies employ a total return approach – emphasizing appreciation, income and preservation, with strong upside participation and better downside preservation over a full market cycle. The sustainability and growth of a company's dividend is critical to the Dividend Equity research process. The Dividend Growth strategy seeks strong long-term, riskadjusted returns that come from investing in high-quality companies with sustainable growth rates that are attractively priced. Focusing on stocks that not only pay a dividend, but potentially grow their dividend, can provide an attractive opportunity for meaningful upside with the potential for lower volatility. The Firm’s US Core team seeks to build a portfolio designed to outperform in most market environments. The team focuses on companies with sustainable competitive and/or superior execution that are also priced at reasonable valuations.
Substrategies/mandates Dividend Equity Dividend Growth Large Cap Core Mid Cap Core Small Cap Core All Cap Core
Risks Market Risk Investing in Stocks Risk Small- and MidCapitalization Companies Risk Dividend Risk Value Investing Foreign Investment Risk Emerging Markets Investment Risk Sector Focus Preferred Growth Investing Risk Convertible Depositary Receipts Risk REIT Risk/Real Estate Risk NonDiversification Derivatives Risk Valuation Risk Management
Investment Strategy US Value Equities
Summary of Philosophy and Process The Firm’s US Value Equities strategies utilize several different methodologies, each predicated on a rigorous, bottom-up, valueoriented security selection process.
Substrategies/mandates
The Large Cap Value (Comstock) strategy is a contrarian approach to stock selection with a long-term investment time horizon of typically 5-7 years to take advantage of significant discrepancies between the current stock market price and the underlying intrinsic value of a company.
Large Cap Value (Comstock)
The Equity and Income (Relative Value) strategy typically follows a balanced investing approach, focusing on capturing potential market upswings while mitigating risk through broad diversification across stocks, bonds and convertible securities. Within equities and convertible securities, these strategies will invest primarily in large, well-established, undervalued companies that are experiencing a positive change, or catalyst. The fixed income securities in which the Equity & Income strategy may invest include investments in government agencies, US Treasuries and investment grade corporate bonds, which act as a capital buffer during market downturns and provide current income.
Equity and Income (Relative Value)
Risks Market Risk Investing in Stocks Risk Convertible Securities Risk* Debt Securities Risk* Preferred Securities Risk* U.S. Government Obligations Risk* Zero Coupon or Pay-In-Kind Securities Risk* Small- and MidCapitalization Companies Risk Foreign Investment Risk Emerging Markets Investment Risk Depositary Receipts Risk REIT Risk/Real Estate Risk Sector Focus Risk* Value Investing Rights and Warrants Risk* Changing Fixed Income Market Conditions Risk* Derivatives Risk Active Trading Valuation Risk Management *Applicable to Fixed Income portion of Balanced substrategy
Investment Strategy
Summary of Philosophy and Process The Small and Mid-Cap Value (Intrinsic Value) strategy utilizes a traditional approach that seeks to create wealth by maintaining a long-term time horizon and investing primarily in US companies that are significantly undervalued on an absolute basis. The philosophy is based on the idea that companies have a measurable intrinsic value, independent from the stock market, that is based on the future cash flows generated by the business and that market prices are more volatile than business values and investors regularly overreact to negative news.
Substrategies/mandates Small and Mid-Cap Value (Intrinsic Value)
Risks
Global Core Equity
The Firm’s Global Core Equity strategy seeks to invest in high quality companies whose competitive advantages provide opportunities for long-term growth. The investment team look for companies run by strong management teams, strong balance sheets, and that are believed to be attractively priced in relation to their intrinsic value. The strategy is actively managed, concentrated and employs a longterm investment horizon.
Global Core Equity
Market Risk Investing in Stocks Risk Foreign Investment Risk Emerging Markets Investment Risk Geographic Focus Risk Small- and MidCapitalization Companies Risk Sector Focus Depositary Receipts Risk Preferred Derivatives Risk Value Investing ESG Considerations Management
Investment Strategy Global Liquidity
Summary of Philosophy and Process The Firm’s Global Liquidity strategies provide high quality cash management and ultrashort fixed income solutions through a disciplined investment approach designed to maximize current income consistent with the preservation of capital and maintenance of liquidity.
SubRisks strategies/mandates Money Market Treasury Cash Fund Risk Management Debt Securities Government Cash Management Changing Fixed Income Market Tax-Free Cash Conditions Risk Management Market Risk Ultrashort/Conservative U.S. Income Government
Obligations Risk Banking and Financial Services Industry Focus Yield Risk Floating and Variable Rate Obligations Risk Rule 144A Securities and Other Exempt Restricted Repurchase Agreement Risk Municipal Variable-Rate Demand Notes Stablecoin Redemption Risk and Regulatory Risk* Digital Assets Risk* Foreign Securities and Credit Exposure ESG Considerations Mortgage and AssetBacked
Investment Strategy
Summary of Philosophy and Process
Substrategies/mandates
Risks Commercial Paper Risk Foreign Investment Foreign Government Debt Risk Liquidity Risk Derivatives Valuation Fixed Income Agency Debt Collateralized Debt Obligations Collateralized Loan Obligations Emerging Markets Investment Sovereign Debt Risk High Yield Debt Securities (Junk Bond) Management *Applicable to stablecoin products only
Investment Strategy Macro Alpha
Emerging Markets Debt
Summary of Philosophy and Process The Firm’s Macro Alpha strategies are managed with a global macrooriented approach, investing across interest rate, foreign currency, and credit markets over an investment horizon of 6-9 months. Regional economic views are aggregated into a global economic perspective to determine the overall risk environment. The team focuses on identifying economic conditions and market structure favorable for relatively higher Sharpe ratio opportunities. In-depth country analysis enables relative value decisions to identify the best expression of views. While the macroeconomic base case evolves gradually, market pricing changes more rapidly, offering trading opportunities.
The Firm’s Emerging Markets Debt strategies are managed based on systematically capturing emerging market risk premia within a robust macroeconomic framework, designed to optimize returns and minimize drawdown. The team’s investment management style combines top-down macroeconomic and bottom-up analysis. Top-down global macro analysis determines the overall portfolio risk budget and the allocation of that risk budget to the various return levers, the bottomup analysis informs how to most efficiently construct the portfolio across each of return levers. We
SubRisks strategies/mandates Global Strategic Income Market Risk Debt Securities Multi-Sector Income International Bond High Yield Debt Flexible Income ETF Securities (Junk
Bond) Risk Credit Linked Notes Risk Bank Loan Risk Dividend Risk Unrated Changing Fixed Income Market Conditions Risk Preferred Small- and MidCapitalization Companies Risk Mortgage- and Asset-Backed Equity-Linked Notes Risk Derivatives Risk Short Position Emerging Markets Local Risk Bond Foreign Investment Risk Emerging Markets Foreign Flexible Bond Government Emerging Markets Bond Debt Risk Emerging Markets Emerging Markets Corporate Bond Investment Risk Developing Initiatives Geographic Bond Focus Risk ExchangeIndia Bond Traded Funds Asian Flexible Bond ExchangeTraded Notes Investment Companies Risk Financial Sector REIT Risk/Real Estate Risk
Investment Strategy
Stable Value
Summary of Philosophy and Process believe maintaining an appropriate investment horizon is central to our approach. Our investment horizon of 6-9 months allows us to look through short term noise while still adding value through both allocation and selection.
The Firm’s Stable Value strategy uses a unique approach to stable value construction that seeks to consistently achieve the following objectives: preservation of principal; book value liquidity for all participant withdrawals; and competitive returns that move in the general direction of interest rates. Portfolios are typically
Substrategies/mandates
Risks Mortgage- and Asset-Backed Depositary Receipts Risk MLP Risk Limited Partner Equity Securities Liquidity Risk Interest Rate General Partner MLP Tax Risk U.S. Government Obligations Risk Money Market Fund Risk Rule 144A Securities and Other Exempt Senior Loans and Other Loans Active Trading Management
Active Trading Changing Fixed Income Market Conditions Risk Debt Securities Derivatives Risk Dollar Roll Transactions
Investment Strategy
Investment Grade Credit
Item 7: Types of clients
________________________________________________________________________________ As discussed in Item 4 (“Advisory Business”), Invesco Advisers provides discretionary and nondiscretionary investment advisory services to individuals, institutional clients and high net worth individuals, registered investment companies, REITs and other Commingled Funds. ________________________________________________________________________________ Account Minimums Separate Accounts Generally Separate accounts (Institutional and High Net Worth Clients only) generally require a minimum investment of between $50 and $100 million depending on the investment strategy; however, Invesco Advisers may, in its sole discretion, accept smaller levels of investment in certain cases. Direct Real Estate Separate Accounts and Private Funds Direct real estate Private Funds and separate accounts managed with a direct real estate investment strategy generally require an investment of at least $10 million and $500 million, respectively; however, Invesco Advisers may, in its sole discretion, accept smaller levels of investment in certain cases. REITs establish account minimums by share class, as applicable, as set forth in their prospectuses or other relevant offering documents which may be waived by an affiliate of Invesco Advisers as outlined in such prospectuses. Wrap Programs Wrap Program account investment minimums are determined by the applicable Program Sponsor. Invesco Advisers will generally accept accounts with assets under management ranging from $50,000 to $200,000. This minimum investment requirement will vary depending on the selected investment
strategy and the particular Wrap Program. The typical minimum investment for Dual Contract Wrap Programs is $1 million. Invesco Advisers reserves the right to decline business at its discretion.
Item 6: Performance-based fees and side-by-side management Conflicts of interest
________________________________________________________________________________ Side-by-Side Management Invesco Advisers manages client accounts having a variety of investment objectives, policies, strategies, limitations, and restrictions. Invesco Advisers’ affiliates likewise manage a variety of separate accounts, Wrap Programs, and Commingled Funds. “Side-by-side management” refers to our simultaneous management of multiple types of client accounts or investment products and raises certain conflicts of interest described immediately below. For more information about other potential conflicts of interest, see Item 11 (Code of Ethics, Participation or Interest in Client Transactions and Personal Trading) and Item 12 (Brokerage Practices). ________________________________________________________________________________ Conflicts of Interest: Performance and Transaction Based Fees in Side-by-Side Management From time to time, Invesco Advisers will manage client accounts that are charged a performance-based fee and/or transaction-based fee and other client accounts that are charged a different type of fee, such as an asset-based fee, simultaneously. Invesco Advisers has a financial incentive to favor client accounts with performance-based fees and transaction-based fees because it will likely earn greater fees on such client accounts as compared to client accounts without performance-based fees or transaction-based fees. Thus, Invesco Advisers has an incentive to direct the best investment ideas and give better execution and brokerage commissions to client accounts that pay performance-based fees, and to allocate, aggregate or sequence trades in favor of such client accounts. Likewise, Invesco Advisers has an incentive to allocate investments to client accounts that will pay a transaction-based
fee in connection with such investment rather than a client account that will not pay the Adviser a fee for the execution of such investment. In managing client accounts with performance-based or transaction-based fees, Invesco Advisers may also have an incentive to choose investments with more risk and speculation than might otherwise be chosen for client accounts without performance-based or transaction-based fees. It is possible that different account types are not permitted to participate in an investment opportunity at the same time due to certain governing regulations. The decision as to which client accounts may participate in an investment opportunity will factor in the suitability and strategy of the client accounts. A client account may be prevented from participating in an investment opportunity due to that opportunity being more appropriate for the primary strategy of another client account. Side-by-side management gives rise to a variety of potential and actual conflicts of interest for Invesco Advisers, including its employees and supervised persons of the Firm. Invesco Advisers follows policies and procedures that are reasonably designed to treat clients fairly and equitably, help mitigate conflicts, and prevent any client or group of clients from being systematically favored or disadvantaged. For example, Invesco Advisers has investment allocation policies and procedures which are designed and implemented to provide fair and equitable treatment of relevant clients over time and to prevent these conflicts from influencing the allocation of investment opportunities among clients’ accounts.
Item 10: Other financial industry activities and affiliations Conflicts of interest
________________________________________________________________________________ Financial Industry Activities Invesco Advisers is registered as an investment adviser with the SEC and as a commodity pool operator and a commodity trading advisor with the Commodity Futures Trading Commission and is a member of the National Futures Association. Invesco Advisers also has business arrangements with affiliated entities that are registered as: brokerdealers, investment companies, investment advisers, commodity pool operators and commodity trading advisors, and with an affiliated entity that is a trust company and an affiliated entity that sponsors and syndicates limited partnerships. In some cases, these business arrangements create a potential conflict of interest, or the appearance of a conflict of interest, between Invesco Advisers and its client, including because of direct and indirect compensation received by Invesco Advisers and/or the affiliated entities. Many U.S. and non-U.S. laws aim to limit these conflicts of interests. At Invesco Advisers, we have policies and procedures designed to comply with these laws. For more information about other potential conflicts of interest, see Item 11 (Code of Ethics, Participation or Interest in Client Transactions and Personal Trading). ________________________________________________________________________________ Broker – Dealer and Transfer Agency Affiliations Invesco Capital Markets, Inc. (“ICMI”) and Invesco Distributors, Inc. (“IDI”) are wholly owned subsidiaries of Invesco Advisers. ICMI and IDI are registered broker-dealers with the SEC under the
Securities Exchange Act of 1934, as amended (“’34 Act”) and are members of the Financial Industry Regulatory Authority (“FINRA”), the Municipal Securities Rulemaking Board (“MSRB”) and the Securities Investor Protection Corporation (“SIPC”). Invesco Advisers utilizes ICMI to facilitate certain equity trades on behalf of Registered Funds, other client accounts and certain accounts of the Firm’s investment adviser affiliates. These trades are then sent to another firm for clearing and settlement services. For additional information, please refer to Item 12 (Brokerage Practices). ICMI is also the sponsor and principal underwriter for Invesco unit investment trusts (“UITs”). A UIT generally holds a fixed portfolio of securities and is not actively managed. ICMI creates the UITs and other firms sell them to their clients. ICMI has in place a Selected Dealer Agreement with its affiliated broker-dealer, IDI. IDI serves as the selling agent for the UITs, providing other broker-dealers with product information. ICMI does not solicit the sale of UITs to retail investors. IDI’s activities include, but are not limited to: (i) principal underwriter and distributor for certain affiliated Registered Funds and for certain affiliated unregistered money market funds; (ii) distributor of certain municipal fund securities (529 Plans) managed by Invesco Advisers; (iii) distributor of shares or units for certain investment portfolios of the Invesco Capital Management LLC ETF Trusts on an agency basis; (iv) selling agent for Invesco’s UITs; (v) distributing collective trusts; and (vi) placement agent for private placements of certain Invesco unregistered funds, and (vii) dealer manager for certain affiliated REITs. Certain management persons of Invesco Advisers are registered representatives of IDI and ICMI and Associated Persons with the National Futures Association. Invesco Investment Services, Inc. ("IIS") is a registered transfer agent that acts as transfer agent for the Registered Funds advised by the Firm. IIS receives fees for its provision of transfer agency services to certain Invesco Funds. ________________________________________________________________________________ Adviser and Sub-Adviser Arrangements Invesco Advisers has entered into various adviser/sub-adviser arrangements with the following related investment advisers. For more complete information regarding these related persons, please refer to filings made with the SEC by the following related persons at https://adviserinfo.sec.gov/. • • • • • • • • •
Invesco Management S.A. Invesco Asset Management (Japan) Limited Invesco Asset Management Limited Invesco Canada Ltd. Invesco Capital Management LLC Invesco Hong Kong Limited Invesco Managed Accounts, LLC Invesco Senior Secured Management, Inc. OppenheimerFunds, Inc.
File No. 801-67712 File No. 801-52601 File No. 801-50197 File No. 801-62166 File No. 801-61851 File No. 801-47856 File No. 801-61716 File No. 801-38119 File No. 801-8253
The following other registered investment adviser subsidiaries of Invesco Ltd. may from time to time have other arrangements not specified in this filing. For more complete information regarding these related persons, please refer to filings made with the SEC by the following related persons: • • • • •
Invesco Investment Advisers LLC Invesco Loan Manager, LLC Invesco Private Capital, Inc. IRE (Cayman) Limited WL Ross & Co. LLC
File No. 801-1669 File No. 801-118817 File No. 801-45224 File No. 802-74648 File No. 801-67779
Invesco Advisers may, in its discretion, so long as consistent with applicable law: delegate any of our discretionary investment, advisory or other rights, powers, functions and obligations to any affiliate or subsidiary that is also under the control of Invesco Ltd. In these circumstances, Invesco Advisers remains fully responsible for the account from a legal and contractual perspective. No additional fees are charged for the affiliates’ services except as set forth in the IMA.; and • employ any affiliate or subsidiary that is also under the control of Invesco Ltd., its agents or third parties to perform any administrative or ancillary services required to enable us to perform our services, without further notification to or consent of a client, and any such delegation shall be revocable by Invesco Advisers. ________________________________________________________________________________ Invesco Trust Company Invesco Trust Company, a Texas state trust company, is a wholly owned, indirect subsidiary of Invesco Ltd. that serves as trustee and investment manager to the Collective Trust Funds. Invesco Trust Company also serves as custodian for IRA accounts invested in Invesco Funds. Invesco Advisers serves as an investment sub-adviser for certain Collective Trust Funds managed by Invesco Trust Company. In this role, Invesco Trust Company pays Invesco Advisers sub-advisory fees out of its management fees. ________________________________________________________________________________ Partnerships and Other Legal Entities From time to time, Invesco Advisers and its related persons will advise clients to invest in limited partnerships (“LPs”) or investment–related LLCs where another related person of the Firm is an adviser. Invesco Advisers has related persons that are SEC-registered investment advisers and are either general partners in LPs or are managers of investment–related LLCs. These related persons often provide services other than advice (including, but not limited to, administration, organizing and managing business affairs, executing, and reconciling trades, preparing financial statements and providing audit support, preparing tax related schedules or documents, and sales and investor relations support, diligence and valuation services), in some cases for a fee separate and apart from an advisory fee. ________________________________________________________________________________ Affiliated Funds From time to time and subject to applicable law, Invesco Advisers will invest discretionary client accounts, including the Registered Funds, in other funds, including exchange-traded funds, managed by Invesco Advisers or its affiliates with the consent of the client (which in certain instances may be obtained through disclosure in the IMA or a Fund’s offering documents). Such investments may be a •
part of a fund’s portfolio construction or cash management and held on a short-term or long-term basis depending on the fund’s investment strategy and portfolio management considerations. ________________________________________________________________________________ Affiliated Index Provider Invesco Indexing LLC (“Invesco Indexing”), an affiliate of Invesco Advisers, develops indices (each, an “Invesco Index”) that are used by client accounts advised by Invesco Advisers and/or used by Commingled Funds purchased and sold by Invesco Advisers on behalf of its clients. Invesco Indexing determines the composition and relative weightings of the securities in each Invesco Index. In order to manage potential conflicts of interest, Invesco Advisers and Invesco Indexing have policies and procedures designed to prevent the undue influence of Invesco Advisers in the operation of any index developed and administered by Invesco Indexing. Among other matters, these policies and procedures provide for information barriers to restrict the sharing of confidential information (for example, from portfolio management and trading). Where Invesco Indexing is the index provider for client accounts advised by Invesco Advisers, Invesco Advisers will in certain instances pay licensing fees to Invesco Indexing for the use of an Invesco Index when consistent with applicable law. For information concerning index-related risks, please see Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss). ___________________________________________________________________________________ Securities Lending Invesco Advisers may serve as a securities lending agent to the Registered Funds and other client accounts. In this capacity, Invesco Advisers may have an incentive to increase or decrease the amount of securities on loan, lend particular securities, delay or forgo recalling securities on loan, or lend securities to less creditworthy borrowers, to generate additional fees for Invesco Advisers and its affiliates; further, Invesco Advisers may have an incentive to allocate loans to clients that provide more fees to Invesco Advisers. Invesco seeks to mitigate these potential conflicts of interest by utilizing a methodology designed to provide its securities lending clients with equal lending opportunities over time and in accordance with policies, procedures, and contractual obligations.
Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest
Personal Trading
________________________________________________________________________________ Invesco Advisers and its affiliates (collectively “Invesco”) have implemented firm wide policies and procedures, such as the Global Code of Conduct, Global Privacy, Code of Ethics and Personal Trading Policies, Global Insider Trading Policy, Gifts and Entertainment (aka Inducement Policies), Global Outside Business Activity Policy, Global Political Contributions, Global Anti-Bribery and Anti-Corruption, all of which are designed to prevent and address conflicts of interest. These policies and procedures reflect the fiduciary principles that govern the conduct of Invesco Advisers and its employees, some of those policies and procedures are listed below. Code of Conduct Invesco operates in highly regulated and complex global environment. The Global Code of Conduct Policy (the “COC Policy”) provides Invesco Advisers and their employees with a clear statement of our ethical and cultural standards. First and foremost, Invesco serves our clients as fiduciaries. The COC Policy outlines Invesco’s key principles, reporting and compliance with the COC Policy, and is meant to supplement Invesco’s broader global compliance policies.
Employees are required to certify to the COC Policy no less than annually and are expected to adhere to both the letter and the spirit of the Policy. Code of Ethics and Personal Trading Invesco has adopted a written Code of Ethics and Personal Trading Policy (the "Code") pursuant to Rule 204A-1 under the Advisers Act and Rule 17j-1 under the 1940 Act. Consistent with these rules, the Code contains provisions for personal trading and reporting requirements designed to identify, address and prevent potential conflicts of interest. The Code applies to all Invesco employees and their immediate family members and requires preclearance of personal securities transactions, as well as periodic reporting and certification of holdings. Employees are required to maintain personal accounts with an approved broker-dealer. Investment Persons are subject to additional pre-clearance obligations and trading restrictions due to their potential ability to be incentivized in favor of certain products in which they may have a personal interest. The Code includes restrictions on personal securities transactions, such as prohibitions on short-term trading profits, designated blackout periods, and limitations on investment activities including participation in IPOs, limited offerings, and any conduct that could constitute insider trading. Invesco also maintains and monitors a restricted list designed to prevent potential conflicts of interest and avoid the appearance of undue influence in investment selection. Invesco has established a violation and escalation procedure that outlines the remedial actions to be taken in response to Code violations, which may include sanctions, such as suspension, demotion, or disgorgement of profits. The Code is available to clients or prospective clients upon request. ________________________________________________________________________________ Material Non-Public Information/Insider Trading Invesco adopted an Americas Insider Trading Policy, which was designed to detect and prevent insiders who may acquire confidential or material, non-public information pertaining to an issuer that may prevent or prohibit Invesco from providing investment advice to client accounts with respect to such issuer irrespective of a client account’s investment objectives or guidelines. Under the Code, Covered Persons are prohibited from trading, either personally or on behalf of others on material non-public information or communicating material non-public information to others in violation of the law. Invesco also has adopted the Invesco Ltd. Insider Trading Policy applying restrictions to certain transactions in Invesco’s securities (e.g., short-sales or publicly traded options), and there are exemptions specific to certain transactions under Invesco sponsored plans (e.g., stock awards or direct stock purchases, ESPP, 401k and Dividend Reinvestment Plan). In connection with certain activities of Invesco, Covered Persons may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. Per the Americas Insider Trading Policy, Invesco will not be free to act upon any such information. Due to these restrictions, Invesco may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold.
________________________________________________________________________________ Outside Business Activities All Invesco employees are subject to the Global Outside Business Activities Policy, which requires employees to obtain prior approval before engaging in any outside activity. An outside business activity includes any engagement outside an employee’s duties and responsibilities to Invesco that may generate revenue, involve a formal commitment to another organization or entity, or otherwise present a potential conflict of interest, regardless of compensation or other benefits received. Prior review and approval allow Invesco to assess whether the activity creates an actual or potential conflict of interest. Employees are also required to annually certify their previously reported outside business activities and any conditions imposed on those activities. ________________________________________________________________________________ U.S. Political Contribution Invesco’s Global Political Contributions Policy (the “PC Policy”) is designed to ensure compliance with applicable U.S. federal, state, and local regulations, including Rule 206(4)-5 under the Investment Advisers Act, MSRB Rule G‑37, FINRA Rules 2030 and 4580, and other relevant state requirements. The PC Policy prohibits Invesco and its employees from making or soliciting political contributions or engaging in political activities for the purpose of procuring or retaining business with U.S. government entities. The policy further prohibits political contributions made on behalf of Invesco; prohibits non‑U.S. nationals from making political contributions in U.S. federal, state, or local elections; and prohibits employees from directing any other person to make a political contribution on their behalf. The PC Policy applies to all Invesco employees and to their spouse and dependent children under the age of 26 who reside at home and are eligible to vote in U.S. elections. All political contributions must be pre‑cleared prior to being made, and employees are required to annually certify their compliance with the policy. _________________________________________________________________________________________________
Gifts and Entertainment Invesco has adopted the U.S. Gifts and Entertainment Policy that is designed to (i) restrict and limit the giving or receiving of gifts, entertainment, or meals by personnel, and (ii) along with the Code, address or avoid any potential or actual conflicts of interest between personal interests of such personnel and clients. Occasionally, personnel participate in entertainment opportunities that are for legitimate business purposes, subject to the restrictions and limitations set forth in the U.S. Gifts and Entertainment Policy, and the Code. ________________________________________________________________________________ Conflicts of Interest Invesco Advisers and its related entities engage in a broad range of activities, including investment activities for their own account and for the account of other investment funds, and provide transactionrelated, investment advisory, management and other services to funds and operating companies. In the ordinary course of conducting its activities, the interests of a client will, from time to time, conflict with the interests of Invesco Advisers, other clients, or their respective affiliates. Certain of these conflicts of interest, as well a description of how these conflicts are addressed can be found below. The material conflicts of interest encountered by a client include those discussed below, although the discussion below does not necessarily describe all conflicts that may be faced by a client. Other conflicts may be disclosed throughout this brochure and the brochure should be read in its entirety for other conflicts. Our policies and procedures are intended to identify these and other potential conflicts and to assure that in all instances client interests come first.
___________________________________________________________________________________ Portfolio Manager Conflicts of Interest Portfolio managers managing multiple accounts are subject to the following actual or apparent conflicts of interest: • The management of multiple accounts can result in a portfolio manager devoting unequal time and attention to the management of each account. Invesco seeks to manage such competing interests by having portfolio managers focus on a particular investment discipline. Generally, the portfolio manager will use the same investment model for a given investment discipline with respect to Wrap Program accounts managed by Invesco Advisers, non-Invesco Funds and those Funds for which he/she is also responsible. Therefore, Wrap Program and other client accounts following the same investment strategy typically hold the same or similar securities. • A portfolio manager could identify a limited investment opportunity that would be suitable for some but not all advisory accounts they manage. Invesco Advisers, and the Funds, have adopted procedures for allocating portfolio transactions across multiple accounts to mitigate these conflicts. See “Trade Allocation” below for further information. ___________________________________________________________________________________ Inconsistent Investment Positions and Strategies, and Timing of Competing Transactions From time to time, Invesco Advisers and its affiliates will buy, sell, or hold securities in the same investment products as it or related persons have some financial interest, including ownership. In addition, Invesco Advisers and other affiliates may buy, sell, or hold the same securities they may have recommended to clients while also advising the opposite investment decision for one or more other clients. These positions and actions may result in an adverse impact or in some instances may benefit one or more affected clients, including clients that are our affiliates. For example, a long/short position in two client accounts simultaneously can result in a loss to one client based on a decision to take a gain in the other. Taking concurrent conflicting positions in certain derivative instruments can likewise result in a loss to one client and a gain to another. Invesco Advisers will also face conflicts of interest when the Firm holds significant positions in illiquid securities in side-by-side accounts. In a similar manner, transactions, or investments by one or more clients could cause a dilution or otherwise disadvantage the values, prices, or investment strategies of another client. Under certain circumstances, a client will invest in a transaction in which one or more other clients are expected to participate or already have made or will seek to make an investment. Such clients (or groups of clients) will have conflicting interests and objectives in connection with such investments, including with respect to views on the operations or activities of the issuer involved, the targeted returns from the investment and the timeframe for, and method of exiting the investment. Invesco Advisers makes allocation determinations based solely on its expectation at the time such investments are made, however investments and their characteristics may change and there can be no assurance that an investment may prove to have been more suitable for another Client in hindsight. Certain clients of Invesco Advisers and its affiliates invest in bank debt and securities of companies in which other clients hold securities, including equity securities. If such investments are made by a client account, the interests of such client account could be in conflict with the interest of such other client account particularly in circumstances where the underlying company is facing financial distress. The
Item 12: Brokerage practices Conflicts of interest
________________________________________________________________________________ Selection of Brokers Invesco Advisers often receives discretionary investment authority from its clients at the outset of an advisory relationship. Subject to the terms of the applicable IMAs, Invesco Advisers’ authority often includes the ability to select brokers and dealers (“Brokers”) through which to execute transactions on behalf of its clients, and to negotiate the commission rates at which transactions are effected. When we have the authority to select Brokers for client accounts, we select Brokers for the execution of transactions in accordance with our duty to seek “best execution” (i.e., to seek the most favorable overall price and execution under the circumstances prevalent at the time of the transaction). In seeking best execution, we are not obligated to choose the Broker offering the lowest available commission rate if, in our reasonable judgment, (i) we believe that the total costs or proceeds from the transaction might be less favorable than may be obtained elsewhere; (ii) a higher commission is justified by the brokerage and research services provided by the Broker that fall within the safe harbor of Section 28(e) of the 1934 Act (“Section 28(e)”) or otherwise is permitted under applicable law, rules, and regulations of the relevant jurisdictions in which we operate, and under applicable agreements; or (iii) other considerations, such as the order size, the time required for execution, the depth and breadth of the market for the security, minimum credit quality requirements to transact business with a particular broker-dealer, or the quality of the Broker’s back office or other considerations support our decision to use a different Broker. Purchase and sale orders for equity securities (including convertible securities and options and futures contracts on equity securities) are executed by Invesco’s Global Trading Desk under the general supervision of the Global Head of Equity Trading Each of the regional trading desks that comprise the Global Trading Desk operates under the trading policies and procedures of the Invesco entity that manages it. There are no material differences between the trading policies and procedures of the trading desks. Purchase and sale orders for fixed income securities are primarily executed by the Global Trading Desk under the general supervision of the Global Head of Fixed Income Currencies and Commodities Trading. Fixed Income and Cash Management portfolio managers and analysts may also execute purchase and sale orders for certain fixed income securities under the general supervision of the various investment team heads. Invesco Advisers uses an affiliated Broker, ICMI, to facilitate equity trades for certain clients in circumstances where Invesco Advisers has received client consent to use ICMI as an introducing broker and has determined that use of ICMI complies with Invesco Advisers’ best execution obligations. Transactions facilitated by ICMI on behalf of Registered Fund clients are effected in accordance with Rule 17e-1 under the 1940 Act and applicable procedures approved by the Board of the Invesco Funds or Board of other Registered Funds sub-advised by Invesco Advisers. Transactions on behalf of Invesco Capital Management LLC’s clients or certain European and Canadian clients advised by affiliates of Invesco Advisers may also be facilitated by ICMI subject to applicable law. Invesco Advisers will act in good faith and with due diligence in the selection, use and monitoring of its affiliates, subsidiaries, and agents in connection with its brokerage and trading policies and practices. The following policies apply to all client accounts managed by Invesco Advisers, unless otherwise noted. Certain policies, however, either do not apply to or are different for Wrap Program accounts because certain trades for these accounts are executed through the sponsoring broker designated by
the Program Sponsor (the “Sponsoring Broker”). For information regarding trading for Wrap Programs see “Wrap and Model-Based Program Trading” below. Best Execution Invesco Advisers selects Brokers based on their ability to provide the best execution reasonably available under the circumstances (which may or may not result in paying the lowest available brokerage commission or spread). Best execution is the process of executing securities transactions for clients in such a manner that the client’s total cost or proceeds (as applicable) in the relevant transaction is the most favorable under the circumstances, while taking into consideration all factors that Invesco Advisers deems relevant. In seeking best execution and negotiating commission rates, the commission cost is one factor we consider. Other factors include, but are not limited to: price, quality, speed, efficiency, confidentiality, familiarity with potential purchasers or sellers, the ability or willingness of a Broker to clear and settle transactions effected by other Brokers, research or brokerage services provided (if permissible), reliability of brokerage services, execution capability, a Broker’s financial responsibility, the difficulty of effectuating specific transactions, and any other relevant logistical or processing considerations. Invesco Advisers also analyzes which services best assist it in fulfilling its overall investment responsibilities to its clients. Invesco Advisers weighs all such factors in selecting Brokers that will deliver best execution in the long-term and are in the best interests of our clients. Invesco Advisers periodically and systematically evaluates the execution performance of Brokers executing client transactions. Determination of Commission Rates Purchases and sales will be effected by Brokers either on an agency basis or on a principal basis. Negotiated commissions will be paid in connection with purchases and sales effected by Brokers on an agency basis or on a principal basis when the Broker acts as a “riskless principal”. Commissions are typically not paid in connection with purchases of underwritten issues, which include a fee or concession paid by the issuer (not by client accounts) to the underwriter(s). However, in some circumstances commissions may be paid in connection with purchases of underwritten issues. Purchases of money market instruments may be made directly from issuers without the payment of commissions. Invesco Advisers believes that the interests of its client accounts are best served by brokerage policies that provide for the payment of a fair commission to Brokers rather than merely requiring the payment of the lowest possible commission rates. Invesco Advisers considers that the commission charged on a particular transaction is generally a relatively small part of the total cost of the transaction, and, therefore, a larger commission can be offset by a more favorable execution quality or price on any particular transaction. In addition, Invesco Advisers believes that a Broker's willingness to undertake a difficult and possibly unprofitable transaction will depend on the overall profitability of such Broker's transactions for Invesco Advisers’ client accounts. A commission which is higher than usual may also be appropriate if the Broker has brought to Invesco Advisers an unusually favorable trading opportunity. Wrap Programs do not typically incur commissions on transactions in individual securities. See “Wrap and Model-Based Program Trading” below for more information.
These factors, as well as the commission rates generally charged by Brokers and the aggregate amount of commissions generated in the past and likely to be generated in the future, will be considered when determining the reasonableness of a particular commission. Due to these considerations, the commission actually paid by a client account on any particular transaction will not always be the lowest available. Invesco Advisers regularly monitors commission rates in the industry to help determine the reasonableness of commissions to be charged to its client accounts. If Invesco Advisers believes that a commission would be either unreasonably high or unreasonably low based upon relevant factors, including difficulty of executing the transaction or the value of research or brokerage services received, Invesco Advisers may agree to a lower or higher commission rate, as appropriate, with the relevant Broker. Research and Other Soft Dollar Benefits From time to time, Invesco Advisers will acquire research, statistical data or other information or services (“research or brokerage services”) from Brokers, which may include ICMI, in return for executing, on behalf of client accounts, trades with those Brokers that generate commissions. The asset management industry uses the term soft dollars to refer to this industry practice. Invesco Advisers will engage in soft dollar transactions for those client accounts in which we have the discretion to select Brokers (and in the case of ICMI, an affiliated Broker) and when not prohibited by applicable law. Invesco Advisers receives a benefit in these transactions because it does not have to produce or pay for research or brokerage services when it uses the commission dollars generated from these client accounts to pay for them. Additionally, certain research or brokerage services can and will benefit certain clients that do not incur the commission charges used to pay for them. Invesco Advisers’ receipt of research or brokerage services pursuant to these soft dollar arrangements will not reduce the advisory fees payable by clients. The safe harbor provided by Section 28(e) requires that the adviser make a good faith determination that the amount of commissions paid was reasonable in relation to the value of the research or brokerage services provided by the Broker, viewed in terms of either that particular transaction or the adviser's overall responsibility to all of its discretionary accounts. To the extent that the execution services and prices offered by more than one Broker are comparable, Invesco Advisers will effect transactions with Brokers that furnish research or brokerage services we believe will be beneficial to client accounts. Invesco Advisers faces a potential conflict of interest with its duty to seek best execution when it uses client transactions to generate soft dollars that can be used to pay for research or brokerage services (“soft dollar research or brokerage services”). We may have an incentive to select Brokers based on our interest in receiving soft dollar research or brokerage services, rather than on client accounts’ interests in receiving most favorable execution. This conflict exists because Invesco Advisers is able to acquire and use a soft dollar research or brokerage service in managing client accounts without paying cash (“hard dollars”) for it, which in turn reduces our expenses. Invesco Advisers will therefore “pay up” for certain trades (e.g., pay a higher commission to execute a trade than the lowest available negotiated commission) using a portion of a Broker’s brokerage commission (i.e., soft dollars) for brokerage or research services in accordance with Section 28(e).
Item 14: Client referrals and other compensation Conflicts of interest
________________________________________________________________________________ Registered Funds and/or Invesco Advisers pay various fees to broker-dealers and other financial intermediaries that provide distribution and other services related to such funds, including but not limited
to distribution and servicing fees payable in connection with plans adopted pursuant to Rule 12b-1 under the 1940 Act, upfront commissions on sales of certain classes of the Registered Funds, administrative, recordkeeping, sub-accounting and/or networking fees, marketing support payments and payments in support of training and educational seminars sponsored by such financial intermediaries. Certain other registered investment adviser subsidiaries of Invesco Ltd. will from time to time receive additional compensation from non-clients, and Invesco Advisers will also compensate employees or employees of affiliates from time to time in connection with the sale of the Firm’s products. For more complete information, please refer to the filings made with the SEC by those related persons. With respect to Wrap Programs, Invesco Advisers receives fees from the Program Sponsor for all services rendered by Invesco Advisers to Wrap Program clients. The Firm might be considered to receive cash compensation from a non-client in connection with giving advice to Wrap Program clients. Similarly, in certain cases where Invesco Advisers serves as a sub-adviser, the Firm may receive advisory fees from the primary investment manager (the Program Sponsor) rather than directly from the investment advisory client. ________________________________________________________________________________ Payment for Client Referrals Invesco Advisers normally does not pay fees to persons for client referrals; however, if in the event such fees are paid, Invesco Advisers will be responsible for the payment of these fees rather than the client. These fees typically involve the Firm paying a portion of its investment management fee to the referring party (the “Endorser”). Invesco Advisers will not charge the referred client a higher fee in order to compensate for the fee it pays to the Endorser. To the extent required by law, Invesco Advisers requires the Endorser to enter into a written agreement with us. Under this written agreement, the Endorser would be obligated to provide the prospective client with certain disclosures before an endorsement is disseminated.
Item 9: Disciplinary information
________________________________________________________________________________ Affiliate Disciplinary Information: On August 24, 2016, without admitting or denying the findings, WL Ross & Co. LLC (“WL Ross”), an SEC registered affiliate of Invesco Advisers, consented to the entry of an order to cease and desist from committing or causing any violations and any future violations of Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 (“Advisers Act”) and Rule 206(4)-8 thereunder and agreed to pay a civil monetary penalty of $2.3 million to the SEC. According to the order, WL Ross failed to adequately disclose its fee allocation practices to certain private equity funds it advised (the “WLR Funds”) and their investors and that ambiguous language in its private equity funds’ limited partnership agreements resulted in certain WLR Funds paying higher management fees between 2001 and 2011. The order also states that in determining to accept the settlement offer, the SEC considered remedial acts promptly undertaken by WL Ross and cooperation afforded to the SEC staff, including WL Ross’ selfreporting of the transaction fee allocation issue to the SEC staff, WL Ross’ voluntary determination to revise its fee allocation methodology, and WL Ross’ voluntary reimbursement, with interest, of $11,873,571 in management fee credits resulting from its retroactive application of the revised allocation methodology to the inception of the WLR Funds. On May 31, 2021, Invesco Ltd., the ultimate parent company of Invesco Advisers, agreed to a settlement with the Federal Financial Supervisory Authority (“BaFin”) in the amount of 260,000 Euros (approximately $309,595 USD) for a matter related to ownership filings with the German regulator in relation to German listed companies. BaFin alleged Invesco Ltd. and AIM international mutual funds failed to submit voting rights notifications to BaFin and issuers by the required deadline. BaFin issued a Notice of Hearing on July 30, 2020, to Invesco Ltd. alleging that violations of the voting rights
requirements occurred on 26 occasions related to the voting rights notifications of Invesco Ltd. and on 28 occasions relating to the voting rights notifications of AIM international mutual funds between 05/2019 and 10/2019. Invesco Ltd. paid the administrative fine on June 30, 2021. On September 24, 2024, Invesco Advisers, Inc. (“IAI”) and Invesco Distributors, Inc. (“IDI”) (together, with IAI, “Invesco”) entered into a settlement with the U.S. Securities & Exchange Commission (SEC) in connection with the agency’s industry-wide investigation into the maintenance and preservation of electronic communications pursuant to applicable recordkeeping provisions of federal securities law. The settlement censures Invesco and requires that Invesco cease and desist from any existing and future violations, pay a civil monetary penalty of $35,000,000 and retain an independent compliance consultant, following the format for all other recent electronic communications settlements. Invesco cooperated with the government’s inquiry and has already taken significant steps to further strengthen the firm’s compliance environment as it relates to electronic communications, including by enhancing its policies and procedures, implementing increased training regarding the use of electronic communications, and beginning to implement changes to the technology available to employees. On November 8, 2024, Invesco Advisers, Inc. (“IAI”) entered into a settlement with the SEC regarding IAI’s environmental, social and governance (“ESG”) policies and procedures. The SEC found that IAI lacked comprehensive policies and procedures to determine the percentage of company-wide assets under management (“AUM”) that was ESG integrated. The SEC also found that IAI made misleading statements concerning the company-wide percentage of AUM that was ESG integrated. IAI was censured and ordered to cease and desist from violating Sections 206(2) and 206(4) of the Advisers Act and Rules 206(4)-1, 206(4)-7 and 206(4)-8 thereunder. IAI agreed to pay a penalty of $17.5 million.
Item 13: Review of accounts
________________________________________________________________________________ Separate Accounts Clients are provided reporting containing information regarding their account on a periodic basis, generally monthly or quarterly per the governing document(s). Additional information included in the reports, such as performance, sector classifications, yield, income, portfolio composition and value, and purchases and sales, are prepared and reviewed by the appropriate responsible parties, including Performance, Portfolio Management, Fund Operations and Investment Management (as applicable). Portfolio Management is responsible for the final review and approval of the reports to the clients. Additional reports may be provided on a periodic or non-routine basis upon the written request of the client. In addition to periodic and ad-hoc reports, we may conduct client portfolio reviews with Invesco investment professionals and client relationship managers on a case-by-case basis as directed by the client. ________________________________________________________________________________ Commingled Funds Registered Funds Registered Fund accounts are subject to both compliance and investment policy reviews. Registered Funds for which Invesco Advisers provides investment advisory services are monitored through the
Firm’s trading systems. The various systems have rules programmed into them by the Compliance Department and are monitored through daily exception reports and workflow monitoring. The CIOs or Head of Investments and the Portfolio Oversight teams analyze the performance and risk profile, and review portfolio strategies and construction of the various investment portfolios Invesco Advisers manages. These teams focus on investment management issues and are responsible for conducting a proactive review of the strategies and construction of investment portfolios. Portfolio Managers certify on a periodic basis that the Registered Fund’s trades were made in accordance with the Fund’s prospectus and SAI. Additionally, Investment Risk, Lead Portfolio Managers, Portfolio Managers and Analysts monitor these accounts on a regular basis. The Board of each Invesco Fund receives monthly and quarterly reports which include information regarding the Invesco Fund's investment activities, performance, and commission allocations during recent periods. At least semi-annually, the Board and shareholders of each Invesco Fund receive complete financial statements of the Invesco Fund, including a schedule of the Invesco Fund's investments. Private Funds and REITs Direct real estate Private Funds generally distribute annual audited financial statements to all fund investors. In addition, more frequent financial reporting is delivered to investors in accordance with the terms of the Private Funds governing document(s). The financial statements are prepared and reviewed by Accounting. Additional information included in the reports, such as performance, sector classifications, yield, income, portfolio composition and value, and purchases and sales, are prepared and reviewed by the appropriate responsible parties, including Performance, Portfolio Management, Fund Operations, and Investment Management (as applicable). Portfolio Management is responsible for the final review and approval of the reports to all fund investors. REITs are subject to ongoing reporting under the ‘33 Act and/or the ‘34 Act, as applicable. ________________________________________________________________________________ Wrap Programs Wrap program clients receive reports periodically from the Program Sponsor. Accounts of clients that participate in Wrap Programs are generally reviewed at least weekly to compare the weight of the stocks in each account to the target model portfolio. This review is conducted by the separately managed accounts trading team in Operations. Wrap account management can require additional Portfolio Managers and operations personnel to provide daily, monthly, and quarterly reviews regarding specific client account requirements. These team members and Compliance work to assure that individual accounts comply with contractual guidelines and restrictions. They monitor individual account composition and performance in comparison to models and arrange for efficient investment/liquidation when cash deposits and disbursements are made. Frequency of reviews and account review loads vary depending on the type of investment activity. Major changes in market conditions may also trigger ad hoc reviews.
Item 15: Custody
________________________________________________________________________________ Invesco Advisers does not serve in a custodian role for Registered Funds or any other client accounts. However, Invesco Advisers may be deemed to have custody of client funds or securities, requiring it to comply with the requirements of Rule 206(4)-2 under the Advisers Act (“Custody Rule”) for clients other than Registered Funds. For clients that qualify for the audit exemption, Invesco Advisers, Inc. maintains client funds and/or securities with a qualified custodian where possible and distributes audited financial statements outlined by the time period mandated by the Custody Rule, subject to relevant exceptions provided for in the Custody Rule. The qualified custodians send account statements directly to the client or their independent representatives at least quarterly for those clients that do not avail themselves of the audit exemption. Clients should carefully review the statements received from the custodian with those they receive directly from Invesco Advisers. Further with respect to those clients that do not qualify for the audit exemption, Invesco Advisers will notify clients of each custodian’s name and address when a custodial account is opened or when changes occur and an annual surprise cash examination will be performed as required under the Custody Rule.
Item 16: Investment discretion
___________________________________________________________________________________ Pursuant to the applicable discretionary investment management agreement or similar client account documentation, Invesco Advisers has discretionary authority, subject to the restrictions and limitations (if any) that have been imposed by clients or specified in the account or fund governing document(s), to invest client portfolios, including amounts to be bought and sold, brokers to use, bid/ask spreads or commission rates that will be charged. Contract restrictions might include, for example and without limitation, limited concentrations, diversification criteria, liquidity requirements, maximum rates of turnover, specific asset allocations, prohibitions on investing in an issuer, class or sector and direction to use specific Brokers.
Item 17: Voting client securities
___________________________________________________________________________________ Invesco Ltd. and its wholly owned investment adviser subsidiaries (collectively, “Invesco”) have adopted a Policy Statement on Global Corporate Governance and Proxy Voting (the “Invesco Global Proxy Voting Policy” or “Policy”). The Policy, which Invesco believes describes policies and procedures reasonably designed to assure proxy voting matters are conducted in the best interests of its clients. Invesco understands proxy voting is an integral aspect of the investment management services it provides to clients. As an investment adviser, Invesco has a fiduciary duty to act in the best interests of our clients. Where Invesco has been delegated the authority to vote proxies with respect to securities held in client portfolios, we exercise such authority in the manner we believe best serves the interests of our clients and their investment objectives. We recognize that proxy voting is an important tool that enables us to drive shareholder value. A summary of Invesco’s global operational procedures and governance structure is included in Part II of the Policy. Invesco’s good governance principles, which are included in Part III of the Policy, and its internal proxy voting guidelines are both principles and rules and cover topics that typically appear on voting ballots. Invesco’s investment teams (together with the Global Governance and Advisory team) retain ultimate authority to vote proxies. Given the complexity of proxy issues across our clients’ holdings globally, our investment teams consider many factors when determining how to cast votes. We seek to evaluate and make voting decisions that favor proxy proposals and governance practices that, in our view, promote long-term shareholder value. A copy of the Invesco Global Proxy Voting Policy is available on Invesco’s web site: https://www.invesco.com/content/dam/invesco/corporate/en/pdfs/regulatory/global-proxy-votingpolicy.pdf. Invesco makes available its proxy voting records publicly in compliance with regulatory requirements and industry best practices in accordance with the U.S. Securities and Exchange Commission regulations, Invesco will file a record of all proxy voting activity for the prior 12 months ending June 30th for each U.S. registered fund. That filing is made on or before August 31st of each year and available on Invesco’s web site: https://vds.issgovernance.com/vds/#/MTAzOTcw. Clients can obtain the policy by calling Invesco’s Client Services department at 1-800-959-4246.
Applicability of Policy Invesco’s investment teams (together with the Global Governance and Advisory team) vote proxies on behalf of Invesco-sponsored funds and both fund and non-fund advisory clients that have explicitly granted Invesco authority in writing to vote proxies on their behalf. In the case of institutional or subadvised clients, Invesco will vote the proxies in accordance with the Policy unless the client agreement specifies that the client retains the right to vote or has designated a named fiduciary to direct voting. ________________________________________________________________________________ Invesco’s Good Governance Principles Invesco’s good governance principles outline its views on best practice in corporate governance and long-term investment stewardship. These principles have been developed by Invesco’s global investment teams in collaboration with the Global Governance and Advisory team and various departments internally. The broad philosophy and guiding principles in this section inform Invesco’s approach to long-term investment stewardship and proxy voting. The principles and positions reflected in the Policy are designed to guide Invesco’s investment professionals in voting proxies; they are not intended to be exhaustive or prescriptive. Invesco’s investment teams retain full discretion on vote execution in the context of our good governance principles and internal proxy voting guidelines, except where otherwise specified in the Policy. The final voting decisions may consider the unique circumstances affecting companies, regional best practices, and any dialogue we have had with company management. As a result, different investment teams may vote differently on particular proxy votes for the same company. To the extent investment teams choose to vote a proxy in a way that is not aligned with the Invesco Global Proxy Voting Policy, such manager’s rationales are fully documented. When evaluating proxy issues and determining how to cast our votes, Invesco’s investment teams (and/or the Global Governance and Advisory team) may engage with companies in advance of shareholder meetings, and throughout the year. These meetings can be joint efforts between our global investment professionals. The good governance principles apply to proxy voting with respect to operating companies. Invesco applies a separate approach to open-end and closed-end investment companies and unit investment trusts. Where appropriate, these guidelines may be supplemented by additional internal guidance that considers regional variations in best practices, company disclosure and region-specific voting items. Invesco may vote on proposals not specifically addressed by these principles based on an evaluation of a proposal’s likelihood to enhance long-term shareholder value. ________________________________________________________________________________ Class Actions Issuers of securities held in client accounts could be the subject of class action lawsuits, and occasionally Invesco Advisers is asked whether to participate in litigation, including by filing proofs of claim in class actions. Funds Invesco Advisers directly or through its delegates (which may include, without limitation, personnel of an affiliate, a law firm, custodian or other claim filing service), uses good faith efforts to file proofs of claim on behalf of Funds in class action lawsuit settlements or judgments and regulatory recovery funds pending in the U.S. that involve issuers of securities presently or formerly held in the Funds’ portfolios of which Invesco Advisers learns and for which the Funds are eligible during each Fund’s existence
(“Claim Service”). Invesco Advisers has complete discretion to determine, on a case-by-case basis, whether to file proofs of claim and any other required documentation for the Funds in any actions of which Invesco Advisers becomes aware. Separate Accounts and Wrap Programs With respect to separate account clients and Wrap Programs, Invesco Advisers shall not be required, or be liable for, any failure to (i) provide the Claim Service, (ii) file proofs of claim and/or (iii) file any required documentation in any actions. As a general matter, it is the separate account client’s or Wrap Program client’s responsibility to monitor and analyze its portfolio and consult with its own advisers and custodian about whether it may have claims that it should consider pursuing. Invesco Advisers does not act as legal counsel to the client accounts. A client’s decision whether to participate in a securities class action lawsuit may involve facts and legal judgments that are beyond the scope of Invesco Advisers’ management of the account and expertise as an investment adviser. The client is responsible for the costs of any participation. Invesco Advisers is not responsible for a client’s or custodian’s failure to file claim forms or to request exclusion.
Item 18: Financial information
________________________________________________________________________________ Invesco Advisers does not require or solicit prepayment of more than $1,200 in fees per client six months or more in advance, does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients, and has not been the subject of a bankruptcy petition at any time during the past ten years.
Rev. December 1, 2025
WHAT DOES INVESCO DO WITH YOUR PERSONAL INFORMATION? *
Why?
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. 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:
What?
Social Security number and income Transaction history and investment experience Investment experience and assets When you are no longer our customer, we continue to share information about you according to our policies.
How?
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 Invesco chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information
Does Invesco 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
Yes
No
For our marketing purposes— to offer our products and services to you
No
We do not share
For joint marketing with other financial companies
No
We do not share
For our affiliates’ everyday business purposes— information about your transactions and experiences
No
We do not share
For our affiliates’ everyday business purposes— information about your credit worthiness
No
We do not share
For our affiliates to market to you
No
We do not share
For non-affiliates to market to you
No
We do not share
Questions?
Call 1-800-959-4246 (toll free).
* This privacy notice applies to individuals who obtain or have obtained a financial product or service from the Invesco family of companies. For a complete list of Invesco entities, please see the section titled “Who is providing this notice” on page 2.
Who we are Who is providing this notice?
Invesco Advisers, Inc., Invesco Private Capital, Inc., Invesco Senior Secured Management, Inc., WL Ross & Co. LLC, Invesco Distributors, Inc., Invesco Managed Accounts, LLC, and the Invesco family of mutual funds.
What we do How does Invesco 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 Invesco collect my personal information?
We collect your personal information, for example, when you ■ ■ ■
Open an account or give us your contact information Make deposits or withdrawals from your account or give us your income information Make a wire transfer
We also collect your personal information from others, such as credit bureaus, affiliates or other companies. Why can’t I limit all sharing?
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
Definitions Affiliates
Companies related by common ownership or control. They can be financial and nonfinancial companies. Invesco does not share with our affiliates so that they can market to you.
Nonaffiliates
Companies not related by common ownership or control. They can be financial and nonfinancial companies. Invesco does not share with non-affiliates so that they can market to you.
Joint marketing
A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Invesco doesn’t jointly market.
Subsidiaries and ownership
Parent company (GLEIF)
Funds it manages
- Invesco Advantage Municipal Income Trust II3
- Invesco Bond Fund4
- Invesco California Value Municipal Income Trust5
- Invesco High Income Trust II6
- Invesco Municipal Income Opportunities Trust7
- Invesco Municipal Opportunity Trust8
- Invesco Pennsylvania Value Municipal Income Trust9
- Invesco Quality Municipal Income Trust10
- Invesco Senior Income Trust11
- Invesco Trust for Investment Grade Municipals12
- Invesco Trust for Investment Grade New York Municipals13
- Invesco Value Municipal Income Trust14
Ownership links from GLEIF, the Global Legal Entity Identifier Foundation (CC0); each one cites its LEI record.
Timeline
Filings
27 filings to the SEC since October 2021: 27 other. The latest 20:
- Aug 21, 2026N-PX EDGAR
- Aug 14, 202613F-NT EDGAR
- May 12, 202613F-NT EDGAR
- Feb 13, 202613F-NT EDGAR
- Nov 13, 202513F-NT EDGAR
- Oct 8, 202540-APP/A EDGAR
- Aug 28, 2025N-PX EDGAR
- Aug 13, 202513F-NT EDGAR
- Jun 27, 202540-APP/A EDGAR
- May 12, 202513F-NT EDGAR
- Apr 17, 202540-APP/A EDGAR
- Feb 13, 202513F-NT EDGAR
- Dec 16, 202440-APP EDGAR
- Nov 12, 202413F-NT EDGAR
- Aug 29, 2024N-PX EDGAR
- Aug 13, 202413F-NT EDGAR
- May 14, 202413F-NT EDGAR
- Feb 13, 202413F-NT EDGAR
- Nov 13, 202313F-NT EDGAR
- Aug 11, 202313F-NT EDGAR
The 27 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
Invesco Advisers, Inc. has told the SEC it owns more than 5% of 1 company, latest first (Schedules 13D and 13G).
- Invesco Real Estate Income Trust Inc.SCHEDULE 13G/A Nov 14, 2024 to May 12, 202617
Sources
The numbers on this page point here. Each one links to the record it came from.
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