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B-1 STATEMENT OF ADDITIONAL INFORMATION Dated May 1 ...

B-1 STATEMENT OF ADDITIONAL INFORMATION Dated May 1 ...

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Portfolio managers are eligible for grants of deferred compensation. These grants are used in limitedsituations, primarily for retention purposes. Grants are fixed and can appreciate/depreciate in value basedon the performance of the American Century mutual funds in which the portfolio manager chooses toinvest them.Conflicts of InterestConflicts of interest may arise when a portfolio manager is responsible for the management of more thanone account. The principal types of these potential conflicts may include:Time and Attention. The management of multiple Portfolios and/or accounts may give rise to potentialconflicts of interest as the portfolio manager must allocate his or her time and investment ideas acrossmultiple funds and accounts. This could result in a portfolio manager devoting unequal time and attentionto the management of each Portfolio and/or other accounts. The effect of this potential conflict may bemore pronounced where Portfolios and/or accounts overseen by a particular portfolio manager havedifferent objectives, benchmarks, time horizons, and fees.One method by which Mason Street Advisors and the sub-advisors seek to manage such competinginterests is to have portfolio managers focus on a particular investment discipline. In general, most otheraccounts managed by a portfolio manager for a similar mandate are managed using the same investmentstrategies that are used in connection with the Portfolio managed by such portfolio manager.Accordingly, portfolio holdings, position sizes (relative to assets) and industry and sector exposures tendto be similar across similar portfolios, which may minimize the potential for conflicts of interest. Inaddition, Mason Street Advisors and the Fund Board actively monitor for performance dispersion amongaccounts, so that appropriate action can be taken if evidence of a conflict is found.Limited Investment Opportunities. If a portfolio manager identifies a limited investment opportunity thatmay be suitable for multiple Portfolios and/or accounts, the opportunity may be allocated among theseseveral Portfolios or accounts, which may limit a Portfolio’s ability to take full advantage of theinvestment opportunity. Mason Street Advisors and the sub-advisors seek to manage such potentialconflicts by using procedures intended to provide a fair allocation of buy and sell opportunities amongPortfolios and other accounts.Variation in Incentives. A conflict of interest may arise where the financial or other benefits available tothe portfolio manager differ among the portfolios and/or accounts that he or she manages. If the structureof the investment adviser’s management fee and/or the portfolio manager’s compensation differs amongPortfolios and/or accounts (such as where certain Portfolios or accounts pay higher management fees orperformance-based management fees), the portfolio manager might be motivated to help certainPortfolios and/or accounts over others. In addition, the portfolio manager might be motivated to favorPortfolios and/or accounts in which he or she has an interest or in which the investment adviser and/or itsaffiliates have interests. Similarly, the desire to maintain assets under management or to enhance theportfolio manager’s performance record or to derive other rewards, financial or otherwise, could influencethe portfolio manager in affording preferential treatment to those Portfolios and/or accounts that couldmost significantly benefit the portfolio manager.Mason Street Advisors and the sub-advisors seek to mitigate this potential conflict of interest throughtheir respective compensation policies. For information regarding the compensation policies of MasonStreet Advisors and each sub-advisor, please refer to the section of this Appendix D called“Compensation of Portfolio Managers.”Personal Accounts. Portfolio managers may be permitted to purchase and sell securities for their ownpersonal accounts or the personal accounts of family members, which could potentially influence theportfolio manager’s decisions with respect to purchasing or selling the same securities for the Portfolio.To mitigate this potential conflict of interest, Mason Street Advisors and the sub-advisors have adoptedB-90

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