Eileen Comerford

RiverSource Investments combines macroeconomic, geopolitical analysis with fundamental research to identify the most promising investment opportunities across global regions, markets, sectors and stocks. Stocks are selected based on their ability to outperform in the context of the firm's economic outlook. Stocks are sold when there is a change in their fundamental characteristics and when they are no longer expected to outperform in the existing economic climate. All of RiverSource's strategies incorporate the use of both top-down and bottom-up analysis. The firm's equity strategies include: the RiverSource Contrarian 120/20 Strategy, the RiverSource Dividend Opportunity Strategy, the RiverSource Mid-Cap Growth Strategy, the RiverSource Mid-Cap Value Strategy, the RiverSource Opportunity Value Strategy, the RiverSource Value Strategy and the Seligman Small-Cap Value Strategy. Though not limited by sector, RiverSource tends to invest in the stocks of mid-cap and large-cap companies in the finance, electronic technology, technology services and health technology sectors. The firm maintains a low turnover rate. The RiverSource Contrarian 120/20 strategy's structure allows for focus on opportunities without style confinement. It is a short portfolio that seeks to achieve efficient risk management and increased informational efficiency through investments in ETFs and index/basket securities combined with a long portfolio that seeks to generate total return. The RiverSource Dividend Opportunity strategy employs a disciplined contrarian approach that employs collaborative analysis that incorporates intrinsic value and behavioral insights with disciplined risk management. The strategy seeks to provide competitive performance over the long-term. The RiverSource Mid-Cap Growth strategy seeks to achieve competitive risk-adjusted returns over full market cycles through investments in high-quality growth companies with solid fundamental strengths including proven management teams, sustainable franchises, earnings improvement, sufficient free cash flow and reasonable valuations. The RiverSource Mid-Cap Value strategy employs a disciplined contrarian approach that employs collaborative analysis that incorporates intrinsic value and behavioral insights and disciplined risk management. The strategy seeks to provide competitive performance over the long-term. The RiverSource Opportunity Value strategy employs a disciplined contrarian investment approach that focuses on investments in the stocks of large-cap companies. The strategy is based on a disciplined contrarian approach that employs collaborative analysis which incorporates intrinsic value and behavioral insights and disciplined risk management. The strategy seeks to provide competitive performance over the long-term. The RiverSource Value strategy employs a disciplined large-cap value contrarian investment approach that is based on collaborative analysis which incorporates intrinsic value and behavioral insights and disciplined risk management. The strategy seeks to provide competitive performance over the long-term. The Seligman Small-Cap Value strategy seeks to generate competitive returns over a 3 to 5 year time horizon through investments in undervalued companies with improving fundamentals and market-caps of $3 billion or less. RiverSources' fixed-income strategies include: the RiverSource Bank Loan Strategy, the RiverSource Core Fixed-Income Aggregate Strategy, the RiverSource Core Plus Fixed-Income Aggregate Strategy, the RiverSource Currency Alpha Absolute Return Strategy, the RiverSource Global Aggregate Fixed-Income Strategy, the RiverSource Global Government Fixed-Income Strategy, the RiverSource Global Inflation Protected Securities Strategy, the Institutional High Yield Fixed-Income Strategy, the RiverSource Investment Grade Corporate Fixed-Income Strategy and the RiverSource US Inflation Protected Securities Strategy. The RiverSource Bank Loan strategy invests in a broadly diversified portfolio that seeks to maximize returns and minimize default risk over the long-run. The RiverSource Core Fixed-Income Aggregate strategy seeks to produce consistent excess returns over a client's benchmark within a risk-managed framework that is consistent with the client's objectives. The RiverSource Core Plus Fixed-Income Aggregate strategy seeks to produce excess returns over a client's benchmark within a risk-managed framework that is consistent with the client's objectives through investments that include high yield, non-dollar and emerging markets opportunities. The RiverSource Currency Alpha Absolute Return strategy seeks to achieve positive absolute returns in excess of the return on cash, with a low correlation to traditional asset classes. The RiverSource Global Aggregate Fixed-Income strategy seeks to generate alpha in a risk-controlled framework by focusing on multiple and uncorrelated sources of active risk. The RiverSource Global Government Fixed-Income strategy seeks to generate alpha in a risk-controlled framework by focusing on multiple and uncorrelated sources of active risk, through investments that focus on global government and government-related securities. The RiverSource Global Inflation Protected Securities strategy seeks to provide positive risk-adjusted returns relative to the benchmark by focusing on duration management, yield curve and country selection across global markets. RiverSource's Institutional High Yield Fixed-Income strategy seeks strong and consistent risk-adjusted returns with a focus on generating alpha and actively managing downside risk. The RiverSource Investment Grade Corporate Fixed-Income strategy seeks credit opportunities in the investment grade corporate bond market that can be exploited to achieve attractive risk-adjusted returns. The strategy focuses on investments in securities with solid fundamental credit, a reasonable time horizon and the ability to withstand short-term volatility. The RiverSource US Inflation Protected Securities strategy seeks to provide positive risk-adjusted returns relative to the benchmark by focusing on duration management, yield curve and security selection in domestic markets.

Seligman manages portfolios employing a team approach. Each investment team leader is a Managing Director. Their investment teams conduct primary research on all securities considered for inclusion in their portfolios. Their research on potential stock purchases includes on-site visits and one-on-one meetings with management to assess the quality, prospects and direction of a company. Seligman takes the following steps to address investment risk in the portfolios: minimal-to-no cash positions, fundamental research, close management contact and continuous evaluation of their holdings. Their analysts are organized by industry specializations. The investment decision-making process is overseen by the CIO and implemented by each team leader.

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