| Trust |
|
| Columbia Funds Variable Insurance Trust |
|
| Columbia Funds Variable Series Trust |
|
| Columbia Funds Variable Series Trust II |
|
| |
|
Other
Accounts Managed (Excluding the Fund) |
Potential
Conflicts
of Interest |
Structure
of Compensation | ||
| Fund |
Portfolio
Manager |
Number
and Type
of Account* |
Approximate
Total Net
Assets |
Performance-
Based
Accounts** | ||
| Information is as of December 31, 2025, unless otherwise noted
| ||||||
| VP – Acorn Fund |
Nicolas Janvier(c) |
1 RIC
3 PIVs
2 other
accounts |
$11.66 million
$3.09 billion
$0.44 million |
None |
Columbia
Management |
Columbia Management |
| Pratyasha Rath |
1 RIC
7 other
accounts |
$2.44 billion
$1.18 million |
None | |||
| VP – Partners International Growth Fund |
Walter Scott:
Des Armstrong(c) |
4 RICs
34 PIVs
114 other
accounts |
$4.00 billion
$20.71 billion
$31.93 billion |
2 PIVs
($463.00 M)
16 other
accounts
($2.41 B) |
Walter Scott |
Walter Scott |
| |
Jane Henderson |
5 RICs
36 PIVs
129 other
accounts |
$5.68 billion
$23.81 billion
$36.82 billion |
2 PIVs
($449.00 M)
18 other
accounts
($3.73 B) |
|
|
| |
Roy Leckie |
5 RICs
36 PIVs
129 other
accounts |
$5.68 billion
$23.81 billion
$36.82 billion |
2 PIVs
($449.00 M)
18 other
accounts
($3.73 B) |
|
|
| |
Thomas Miedema(c) |
4 RICs
34 PIVs
114 other
accounts |
$4.00 billion
$20.71 billion
$31.93 billion |
2 PIVs
($463.00 M)
16 other
accounts
($2.41 B) |
|
|
| |
Maxim Skorniakov |
5 RICs
36 PIVs
129 other
accounts |
$5.68 billion
$23.81 billion
$36.82 billion |
2 PIVs
($449.00 M)
18 other
accounts
($3.73 B) |
|
|
| VP – Partners Small Cap Value Fund |
William Blair:
Matthew Fleming |
3 RICs
20 other
accounts |
$925.20 million
$1.51 billion |
1 other
account
($339.00 M) |
William Blair |
William Blair |
| |
Mark Goodman |
3 RICs 20 other accounts |
$925.20 million $1.51 billion |
1 other account ($339.00 M) |
|
|
| Fund Name: |
Transition Date: |
| VP – Balanced Fund |
July 27, 2026 |
| VP – BlackRock Global Inflation-Linked Securities Fund |
July 27, 2026 |
| VP – CenterSquare Real Estate Fund |
July 27, 2026 |
| VP – Commodity Strategy Fund |
July 27, 2026 |
| VP – Contrarian Core Fund |
April 20, 2026 |
| VP – Core Equity Fund |
July 27, 2026 |
| VP – Cornerstone Equity Fund |
July 27, 2026 |
| VP – Cornerstone Growth Fund |
July 27, 2026 |
| VP – Disciplined Core Fund |
July 27, 2026 |
| VP – Dividend Opportunity Fund |
July 27, 2026 |
| VP – Emerging Markets Bond Fund |
July 27, 2026 |
| VP – Emerging Markets Fund |
July 27, 2026 |
| VP – Fidelity Institutional
AM® Total Bond
Fund |
May 1, 2026 |
| VP – Government Money Market Fund |
July 27, 2026 |
| VP – High Yield Bond Fund |
July 27, 2026 |
| VP – Income Opportunities Fund |
July 27, 2026 |
| VP – Intermediate Bond Fund |
July 27, 2026 |
| VP – Long Government/Credit Bond Fund |
April 20, 2026 |
| VP – Overseas Core Fund |
July 27, 2026 |
| VP – Partners Core Bond Fund |
April 20, 2026 |
| VP – Partners Core Equity Fund |
April 20, 2026 |
| VP – Partners International Core Equity Fund |
April 20, 2026 |
| VP – Partners International Growth Fund |
April 20, 2026 |
| VP – Partners International Value Fund |
April 20, 2026 |
| VP – Partners Small Cap Growth Fund |
April 20, 2026 |
| VP – Partners Small Cap Value Fund |
April 20, 2026 |
| VP – Principal Large Cap Growth Fund |
July 27, 2026 |
| VP – Select Corporate Income Fund |
July 27, 2026 |
| VP – Select Large Cap Value Fund |
July 27, 2026 |
| VP – Select Mid Cap Growth Fund |
July 27, 2026 |
| VP – Select Mid Cap Value Fund |
July 27, 2026 |
| VP – Select Short Corporate Income Fund |
July 27, 2026 |
| VP – Select Small Cap Value Fund |
July 27, 2026 |
| VP – Seligman Global Technology Fund |
July 27, 2026 |
| VP – Small Cap Value Discovery Fund |
April 20, 2026 |
| VP – Small Company Growth Fund |
April 20, 2026 |
| Fund Name: |
Transition Date: |
| VP – Strategic Income Fund |
April 20, 2026 |
| VP – T. Rowe Price Large Cap Value Fund |
July 27, 2026 |
| VP – TCW Total Return Bond Fund |
July 27, 2026 |
| VP – U.S. Government Mortgage Fund |
July 27, 2026 |
| VP – Victory Sycamore Established Value Fund |
April 20, 2026 |
| VP – Wellington Large Cap Value Fund |
April 20, 2026 |
| VP – Westfield Mid Cap Growth Fund |
April 20, 2026 |
| VP – Westfield Select Large Cap Growth Fund |
April 20, 2026 |
| Identity of Recipient |
|
Conditions/restrictions on use of information |
|
Frequency of Disclosure |
| Recipients under arrangements with the Funds or Investment Manager: |
|
| ||
| Abel Noser |
|
Used for evaluating and assessing
trading activity, execution and practices. |
|
Quarterly |
| ACA Global |
|
Used to evaluate and assess trading
activity, execution and practices in
respect of market abuse regulatory
requirements. |
|
Daily |
| Axioma Inc. |
|
Used as a hosted risk analytics platform
designed for research, portfolio holdings,
investment oversight and strategy
development. |
|
Daily |
| BlackRock, Inc. |
|
Used for front office trading and
analytics, back office settlements,
portfolio accounting and reconciliations,
collateral management, portfolio risk
oversight, compliance mandate
monitoring and portfolio performance
calculations. Used to provide portfolio
attribution reports for Columbia
Convertible Securities Fund. Used for
portfolio analytics. |
|
Daily |
| Bloomberg Finance L.P. |
|
Used for portfolio analytics, statistical
analysis and independent research. Used
for executing cleared swaps
electronically. Used for executing fixed
income trades. Used for evaluating and
assessing trading activity, execution and
practices in respect of market abuse
regulatory requirements, and best
execution and TCA. Used to provide
portfolio attribution reports for Columbia
Convertible Securities Fund. Used for
portfolio analytics. |
|
Daily |
| Bolger, Inc. |
|
Used for commercial printing. |
|
As Needed |
| Bond Connect Company Limited |
|
Used for executing Chinese fixed income
trades. |
|
As Needed |
| Boston Investors Communications
Group, LLC |
|
Used for writing services that require
disclosing portfolio holdings in advance
of their dissemination to the general
public. |
|
Quarterly |
| Broadridge Financial Solutions Inc. |
|
Used for printing of prospectuses and
tailored shareholder reports. |
|
As Needed |
| Capital Markets Services Group |
|
Used for hedging activities supporting
the Columbia Funds. |
|
Daily |
| Castine LLC |
|
Used for facilitating the evaluation of
commission rates and providing flexible
commission reporting. |
|
Daily |
| Citigroup, Inc. |
|
Used for mortgage decision support. |
|
Daily |
| Identity of Recipient |
|
Conditions/restrictions on use of information |
|
Frequency of Disclosure |
| Compliance Solutions Strategies LLC |
|
Used for reporting returns and analytics
to client facing materials. Used for data
storage and as a transformation solution
to support Client Regulatory Reporting
and Fund Detail reporting. |
|
Monthly |
| Deloitte Haskins & Sells, LLP |
|
Used for calculating foreign capital gains
tax accruals irrespective of the tax lot
relief method. |
|
Weekly |
| Donnelley Financial Solutions |
|
Used for providing EDGAR filing and
typesetting services, and printing of
prospectuses, factsheets, annual and
semi-annual reports. |
|
As Needed |
| DS Graphics/Universal Wilde, Inc. |
|
Used for printing of prospectuses,
factsheets, annual and semi-annual
reports. |
|
As Needed |
| Depository Trust & Clearing Corporation |
|
Used for providing trade allocation and
acceptance services with brokers. |
|
Daily |
| ENPOINTE |
|
Used for commercial print. |
|
As Needed |
| Ernst & Young, LLP |
|
Used for analyzing passive foreign
investment company investments. |
|
Monthly |
| FactSet Research Systems, Inc. |
|
Used for calculating portfolio
performance attribution, portfolio
analytics, data for fundamental research,
and general market news and analysis.
Used for executing equity and
convertible trades. |
|
Daily |
| Fidelity National Information Services,
Inc.
|
|
Used as a portfolio accounting system. |
|
Daily |
| FMR LLC |
|
Used for advertising review. |
|
As Needed |
| FX Connect, LLC |
|
Used to execute foreign exchange
orders. |
|
Daily |
| Harte-Hanks, Inc. |
|
Used for printing of prospectuses,
factsheets, annual and semi-annual
reports and commercial print. |
|
As Needed |
| Institutional Shareholder Services, Inc. |
|
Used for proxy voting administration and
research on proxy matters. |
|
Daily |
| Intex Solutions Inc. |
|
Used for providing mortgage analytics. |
|
As Needed |
| Investment Company Institute |
|
Disclosure of Form N-PORT data. |
|
As Needed |
| Investortools, Inc. |
|
Used for municipal bond analytics,
research, and decision support. |
|
As Needed |
| JDP Marketing Services |
|
Used for writing services that require
disclosing portfolio holdings in advance
of their dissemination to the general
public. |
|
Quarterly |
| John Roberts, Inc. |
|
Used for fund fact sheets and
commercial print. |
|
As Needed |
| KPMG LLC |
|
Used by State Street to provide tax
services as a sub-contractor. |
|
Daily |
| Kurtosys Systems |
|
Used for reporting of fund holdings detail
via our website. |
|
Monthly |
| MarketAxess |
|
Used for executing fixed income trades. |
|
Daily |
| Morningstar Investment Services, LLC |
|
Used for independent research and ranking of funds. Used for statistical analysis. |
|
As Needed |
| Identity of Recipient |
|
Conditions/restrictions on use of information |
|
Frequency of Disclosure |
| Neovest |
|
Used to execute futures. |
|
As Needed |
| PwC |
|
Used to review tax services prepared by
State Street and to prepare tax services
PwC performs for the funds. |
|
Daily |
| R. R. Donnelley & Sons Co. |
|
Used for printing of prospectuses,
factsheets, annual and semi-annual
reports. Used for commercial printing. |
|
As Needed |
| Refinitiv |
|
Used to execute foreign exchange
orders. |
|
Daily |
| RegEd, Inc. |
|
Used for reviewing external and certain
internal communications prior to
dissemination. |
|
As Needed |
| Sky Road |
|
Used for front office trading,
optimization, bank loan analytics, and
compliance. |
|
Daily |
| State Street Bank and Trust |
|
Used to provide certain sub-
administration services to the Funds,
including fund accounting and financial
reporting services. |
|
Daily |
| S.W.I.F.T. Scrl. |
|
Used for sending trade messages via
SWIFT to custodian. |
|
Daily |
| TP ICAP |
|
Used for executing equity and fixed
income trades. |
|
Daily |
| Thomson Reuters Corp. |
|
Used for statistical analysis. |
|
As Needed |
| Toppan Merrill Corporation |
|
Used for printing of prospectuses,
factsheets, annual and semi-annual
reports. |
|
As Needed |
| Tradeweb |
|
Used for executing fixed income trades. |
|
Daily |
| Trepp, Inc. |
|
Used for insights about commercial
mortgage-backed securities mortgage
bonds. |
|
Daily |
| Virtu Financial |
|
Used for executing equity trades. |
|
Daily |
| Visions, Inc. |
|
Used for commercial printing. |
|
As Needed |
| Wilshire Associates, Inc. |
|
Used for providing performance attribution reporting. |
|
Daily |
| Identity of Recipient |
|
Conditions/restrictions on use of information |
|
Frequency of Disclosure |
| Recipients under arrangements with subadvisers: |
|
| ||
| Abel/Noser Corp. |
|
Used by certain subadvisers for trade
execution and cost analysis. |
|
Daily |
| Adviser Compliance Associates, LLC. |
|
Used by certain subadvisers for
compliance services and performance
evaluation. |
|
Daily |
| AcadiaSoft, Inc |
|
Used by certain subadvisers for risk
management services. |
|
Daily |
| Accenture PLC |
|
Used by certain subadvisers for back-
office operations. |
|
Daily |
| Alpha Financial Software LLC |
|
Used by certain subadvisers for trade
monitoring, trade settlement, and for
confirming TBAs. |
|
Daily |
| Axioma, Inc. |
|
Used by certain subadvisers for analytics and attribution analysis. |
|
Daily |
| Identity of Recipient |
|
Conditions/restrictions on use of information |
|
Frequency of Disclosure |
| BlackRock, Inc. |
|
Used by certain subadvisers for order
management and compliance services. |
|
Daily |
| Bloomberg Finance L.P. |
|
Used by certain subadvisers for
analytical, portfolio management,
statistical information, compliance and
personal trade monitoring. |
|
Daily |
| BNY Mellon Corp. |
|
Used by certain subadvisers for
custodian reconciliation. |
|
Daily |
| Brown Brothers Harriman & Co. |
|
Used by certain subadvisers for foreign
exchange (FX) derivatives reconciliation,
electronic trade transmission and
settlement. |
|
Daily |
| Clearwater Analytics, LLC |
|
Used by certain subadvisers for
analytical and statistical information. |
|
As Needed |
| CloudMargin Ltd. |
|
Used by certain subadvisers derivative
operations team to process, reconcile
and report daily collateral margin
transactions with counterparties and
custodian. |
|
Daily |
| Commcise Software Limited |
|
Used by certain subadvisers for
commission tracking. |
|
Daily |
| Eagle Investment Systems, LLC |
|
Used by certain subadvisers for MiFID II
transaction reporting, performance
management, data management, and
portfolio analysis & reporting. |
|
Daily |
| Fidelity National Information Services,
Inc. |
|
Used by certain subadvisers for COE
monitoring. |
|
Daily |
| Equity Data Science Inc. |
|
Used by certain subadvisers for portfolio
management. |
|
Daily |
| Eze Castle Software LLC |
|
Used by certain subadvisers for
compliance and personal trade
monitoring. |
|
Daily |
| FactSet Research Systems, Inc. |
|
Used by certain subadvisers for
analytical, portfolio management,
statistical information, compliance and
personal trade monitoring. |
|
Daily and As Needed |
| FIA Technology Services, LLC |
|
Used by certain subadvisers for
reconciliation services. |
|
Daily |
| FIS Brokerage Securities Services LLC |
|
Used by certain subadvisers for
corporate actions management. |
|
Daily |
| FundApps Ltd. |
|
Used by certain subadvisers for global
regulatory shareholding disclosure,
Custodian-Trade management, and pre-
and post-compliance. |
|
Daily |
| FX Connect, LLC |
|
Used by certain subadvisers for foreign
exchange derivatives reconciliation. |
|
Daily |
| Global Trading Analytics, LLC |
|
Used by certain subadvisers for trade
execution cost analysis. |
|
Daily |
| Gresham Technologies Limited |
|
Used by certain subadvisers for
custodian reconciliation. |
|
Daily or Monthly |
| Global Trading Analytics, LLC |
|
Used by certain subadvisers for trade
execution cost analysis. |
|
Quarterly |
| ICE Data Services Inc. |
|
Used by certain subadvisers for liquidity reporting. |
|
Daily |
| Identity of Recipient |
|
Conditions/restrictions on use of information |
|
Frequency of Disclosure |
| IHS Markit Ltd. |
|
Used by certain subadvisers for
confirmation and settlement of bank
loan trades. |
|
Daily
|
| Institutional Shareholder Services, Inc. |
|
Used by certain subadvisers for proxy
voting administration and research
services. |
|
Daily |
| InvestCloud Inc. |
|
Used by certain subadvisers for client
reporting. |
|
Daily |
| JPMorgan Chase & Co. |
|
Used by certain subadvisers for portfolio
management, and risk analytics. |
|
Daily |
| LightSpeed Data Solutions |
|
Used by certain subadvisers for trade
monitoring, trade settlement, and
confirming TBAs. |
|
Daily |
| LiquidNet, Inc. |
|
Used by certain subadvisers for
commission tracking. |
|
Daily |
| MacDonald Information Services Inc. |
|
Used by certain subadvisers for Anti-
Money Laundering screening services,
and compliance services. |
|
Daily |
| Microsoft Corporation |
|
Used by certain subadvisers to create
marketing material for use in client
meetings. |
|
Daily |
| MSCI Barra Inc. |
|
Used by certain subadvisers for
analytical and statistical information, for
back-office operations, and for Liquidity
Rule 22e-4. |
|
Daily |
| MyComplianceOffice Technologies, Inc. |
|
Used by certain subadvisers for
compliance and personal trade
monitoring. |
|
Daily |
| Nex Group plc |
|
Used by certain subadvisers for daily
reconciliations on collateral
management. |
|
Daily |
| Omgeo, LLC |
|
Used by certain subadvisers for
electronic trade monitoring, trade
transmission, trade settlement, and for
confirming TBAs. |
|
Daily |
| Qontigo |
|
Used by certain subadvisers for
Derivatives Rule (Rule 18f-4) analysis. |
|
Daily |
| REFINITIV US LLC |
|
Used by certain subadvisers for FX
derivatives reconciliation. |
|
Daily |
| S&P Global Market Intelligence |
|
Used by certain subadvisers for
corporate actions management. |
|
Daily |
| Salesforce, Inc. |
|
Used by certain subadvisers for back-
office operations. |
|
Daily |
| SEI Investments Co. |
|
Used by certain subadvisers for
analytical, portfolio management,
statistical information, compliance and
personal trade monitoring. |
|
Daily |
| SEISMIC SOFTWARE, INC |
|
Used by certain subadvisers to create
Marketing material for the use in client
meetings. |
|
Monthly |
| SimCorp |
|
Used by certain subadvisers for portfolio
accounting systems. |
|
Daily |
| Snowflake Inc. |
|
Used by certain subadvisers for analytical, portfolio management and statistical information. |
|
Daily |
| Identity of Recipient |
|
Conditions/restrictions on use of information |
|
Frequency of Disclosure |
| SS&C Technologies Holdings, Inc. |
|
Used by certain subadvisers for: Asset &
Portfolio Management Services; trading,
risk & front-office solutions; middle &
back office financial operations; data,
analytics & reporting services. |
|
Daily |
| STANDARD & POOR’S FINANCIAL SERVICES LLC |
|
Used by certain subadvisers for financial
data, ratings, and analytics services. |
|
Weekly |
| StarCompliance LLC |
|
Used by certain subadvisers for
compliance and personal trade
monitoring. |
|
Daily |
| State Street Bank and Trust Company |
|
Used by certain subadvisers for middle
office functions, SWIFT messages from
custodians to facilitate automated
reconciliation. |
|
Daily |
| State Street Corp. |
|
Used by certain subadvisers for
compliance and trade monitoring. |
|
Daily |
| SteelEye, Limited |
|
Used by certain subadvisers for
compliance analytics. |
|
Daily |
| STP Investment Services, LLC |
|
Used by certain subadvisers for
custodian reconciliation. |
|
Daily |
| Tradeweb Markets LLC |
|
Used by certain subadvisers for
confirming TBAs, treasuries, and
discount notes. |
|
Daily |
| UNAVISTA LIMITED |
|
Used by certain subadvisers for
electronic trade transmission and
settlement. |
|
Daily |
| VERMEG Co. |
|
Used by certain subadvisers for
management of swap counterparty
exposure. |
|
Daily |
| Vermilion Software Ltd |
|
Used by certain subadvisers for client
reporting. |
|
Monthly |
| Virtu Financial, Inc. |
|
Used by certain subadvisers for trade execution cost analysis. |
|
Daily or Monthly |