What changed in this filing

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Item 1. Business

2022-02-25 compared with 2021-02-24 · 162 added, 156 removed, 361 unchanged (47% of the section changed)

Ameriprise Financial is a diversified financial services company with a 125-year history of providing solutions to help clients confidently achieve their financial objectives.

Ameriprise Financial is a diversified financial services company with a more than 125-year history of providing solutions to help clients confidently achieve their financial objectives.

Ameriprise Financial, Inc.

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We are an industry-leading wealth manager with a differentiated advice value proposition.

Our network of approximately 10,000 financial advisors (our “advisors”) is the primary channel through which we carry out our wealth management activities.

Our network of over 10,000 financial advisors (our “advisors”) is the primary channel through which we carry out our wealth management activities.

Our capabilities are centered on establishing long-term personal relationships between our clients and our advisors.

Through our affiliated advisors, we offer financial planning and advice, as well as banking and full-service brokerage services, primarily to retail clients.

We design products and services as solutions for our clients’ cash and liquidity, asset accumulation, income, protection, and estate and wealth transfer needs.

We design products and services as solutions for our clients’ cash and liquidity, asset accumulation, income, retirement, protection, and estate and wealth transfer needs.

The financial solutions we offer through our advisors also include other providers’ products as well as our own products and services.

We distribute our own life and disability income insurance, as well as variable and structured variable annuity products through our advisor channel.

We distribute our own life and disability income insurance, as well as variable and structured annuity products through our advisor channel.

Our advisor force is among the largest in the industry and is central to how we serve our clients.

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Asset Management

Our global asset management capabilities, represented by the Columbia Threadneedle Investments ® brand, offer a broad spectrum of investment advice and products to individual, institutional and high net worth investors.

These investment products are primarily offered through third parties, though we also provide our asset management products through our advisor network.

Our global asset management capabilities, represented by the Columbia Threadneedle Investments ® brand (which now also includes the BMO Global Asset Management (EMEA) business we purchased in November 2021), offer a broad spectrum of investment advice and products to individual, institutional and high net worth investors.

We refer to the entities purchased in this transaction (BMO Global Asset Management (Europe) Limited and its subsidiaries, BMO Global Asset Management (Asia) Limited, Pyrford International Limited and LGM Investments Limited) broadly as the BMO Global Asset Management (EMEA) business.

Columbia Threadneedle’s investment products are primarily offered through third parties, though we also provide our asset management products through our advisor network and through our institutional sales force.

Our underlying asset management philosophy is rooted in delivering consistently strong, competitive investment performance.

The quality and breadth of our asset management capabilities are demonstrated by 108 of our mutual funds globally are rated as four- and five-star funds by Morningstar.

The quality and breadth of our asset management capabilities are demonstrated by 133 of our mutual funds globally being rated as four- and five-star funds by Morningstar.

We are positioned to continue to grow our assets under management and strengthen our asset management offerings to existing and new clients.

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and Europe as well as expanding into new global and emerging markets.

In the past few years, we have expanded beyond our traditional strengths in the U.S.

and the United Kingdom (“U.K.”).

to serve more clients and gather assets in Continental Europe, Asia, Australia and New Zealand, the Middle East, South America and Africa.

In the past few years and continuing with our recent acquisition of the BMO Global Asset Management (EMEA) business, we have expanded beyond our traditional strengths in the U.S.

and the United Kingdom (“U.K.”) to serve more clients and gather assets in Continental Europe, Asia, Australia and New Zealand, the Middle East, South America and Africa.

We continue to pursue opportunities to leverage the collective capabilities of our global asset management business in order to enhance our investment solutions and to develop new solutions that are responsive to client demand in an increasingly complex and competitive marketplace.

History and Development

Our company has a more than 125-year history of providing solutions to help clients confidently achieve their financial objectives.

Our company has provided solutions to help clients confidently achieve their financial objectives for more than 125 years.

Our earliest predecessor company, Investors Syndicate, was founded in 1894 to provide face-amount certificates to consumers.

In 1983, our company was formed as a Delaware corporation in connection with American Express’ acquisition of IDS Financial

Services from Alleghany Corporation.

In 1983, our company was formed as a Delaware corporation in connection with American Express’ acquisition of IDS Financial Services from Alleghany Corporation.

We changed our name to “American Express Financial Corporation” (“AEFC”) and began marketing our products and services under the American Express brand in 1994.

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Incorporated, Columbia Management, Emerging Global Advisors, LLC, Investment Professionals, Inc., and Lionstone Partners, Inc.

In order to focus our resources and advance our corporate strategy, we have divested or reinsured some of our businesses, including most recently on October 1, 2019, when we completed the sale of our Ameriprise Auto and Home Insurance business to American Family Insurance Mutual Holding Company (American Family Insurance) and in March 2019 when we reinsured approximately $1.7 billion of fixed annuity policies.

Most recently, we acquired BMO Financial Group’s European-based asset management business on November 8, 2021, to extend our reach in EMEA and add important capabilities to Columbia Threadneedle.

In order to focus our resources and advance our corporate strategy, we have divested or reinsured some of our businesses, including the 2019 sale of our Ameriprise Auto and Home Insurance business to American Family Insurance Mutual Holding Company and our 2019 and 2021 fixed annuity reinsurance transactions of approximately $1.7 billion and $7.0 billion of fixed annuity policies, respectively.

Over the years, we have also sought to optimize the structure in which we offer certain banking products.

In May 2019, we received regulatory approvals and converted Ameriprise National Trust Bank to Ameriprise Bank, FSB to expand the products and services we can provide directly to our customers.

At that time, Ameriprise Financial became a savings and loan holding company that is subject to regulation, supervision and examination by the Board of Governors for the Federal Reserve System (“FRB”), and Ameriprise Financial elected to be classified as a financial holding company subject to applicable regulation under the Bank Holding Company Act of 1956, as amended.

Our Integrated Model and Shift in Business Mix

In June 2021, we filed an application to convert Ameriprise Bank, FSB to a state-chartered industrial bank regulated by the Utah Department of Financial Institutions and the Federal Deposit Insurance Corporation, as well as a separate application to transition the FSB’s personal trust services business to a new limited purpose national trust bank regulated by the Office of the Comptroller of the Currency.

Our applications are currently pending.

Our Shifting Business Mix and Integrated Model

The financial results from the businesses underlying our go-to-market approaches are reflected in our operating segments:

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As a diversified financial services firm, we believe our ability to gather assets is best measured by our aggregate assets under management and administration metric.

At December 31, 2020, we had $1.1 trillion in assets under management and administration compared to $973 billion as of December 31, 2019.

As of December 31, 2021, we had $1.4 trillion in assets under management and administration compared to $1.1 trillion as of December 31, 2020.

For a more detailed discussion of assets under management and administration, see “Management’s Discussion and Analysis of Financial Condition and Results of Operations” included in Part II, Item 7 of this Annual Report on Form 10-K.

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We use the Ameriprise Financial ® brand as our enterprise brand, as well as the name of our advisor network and certain of our retail products and services.

Our global Columbia Threadneedle Investments ® brand represents the combined capabilities, resources and reach of Columbia Management Investment Advisers, LLC (“Columbia Management”) and Threadneedle.

Our global Columbia Threadneedle Investments ® brand represents the combined capabilities, resources and reach of Columbia Management Investment Advisers, LLC (including its subsidiaries, “Columbia Management”) and Threadneedle.

The foreign operations of Ameriprise Financial, Inc.

are conducted primarily through Threadneedle Asset Management Holdings Sàrl and Ameriprise Asset Management Holdings Singapore (Pte.) and their respective subsidiaries (collectively, “Threadneedle”).

are conducted primarily through Columbia Threadneedle Investments UK International Limited, TAM UK International Holdings Limited and Ameriprise Asset Management Holdings Singapore (Pte.) and their respective subsidiaries (collectively, “Threadneedle”).

We plan to rebrand the BMO Global Asset Management (EMEA) business over the course of 2022 under the Columbia Threadneedle Investments brand, and we are currently using the BMO mark under a license during a transition period.

We use our RiverSource ® brand for our annuity and protection products issued by RiverSource Life Insurance Company (“RiverSource Life”) and RiverSource Life Insurance Co.

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Our Financial Advisor Platform

With approximately 10,000 advisors, we are a top five branded advisor platform in the U.S.

With over 10,000 advisors, we are one of the top branded advisor platforms in the U.S.

market where we provide our services.

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Our Segments - Asset Management

Through Columbia Threadneedle Investments , we provide investment management, advice and products to retail, high net worth and institutional clients on a global scale.

Columbia Management primarily provides products and services in the U.S.

and Threadneedle primarily provides products and services internationally.

Additional subsidiaries are also included in our Asset Management segment such as Lionstone Partners, LLC, the U.S.

investment adviser for certain private funds and investment products focused on real estate.

Through Columbia Threadneedle Investments (including our newly acquired BMO Global Asset Management (EMEA) business), we provide investment management, advice and products to retail, high net worth and institutional clients on a global scale.

Columbia Management primarily provides products and services in the United States.

Threadneedle, which is integrating our newly acquired BMO Global Asset Management (EMEA) business, primarily provides products and services internationally.

Additional subsidiaries beyond Columbia Management and Threadneedle are also included in our Asset Management segment.

Revenues in the Asset Management segment are primarily earned based on managed asset balances, which are impacted by market movements, net asset flows, asset allocation and product mix.

We may also earn performance fees from certain accounts where investment performance meets or exceeds certain pre-identified targets.

At December 31, 2020, our Asset Management segment had $547 billion in worldwide managed assets.

As of December 31, 2021, our Asset Management segment had $754 billion in worldwide managed assets.

Our Asset Management segment also provides intercompany asset management services for Ameriprise Financial subsidiaries.

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Managed assets include external client assets and owned assets.

Managed external client assets include client assets for which we provide investment management services, such as the assets of the Columbia Threadneedle Investments fund families and the assets of

institutional clients.

Managed external client assets also include assets managed by sub-advisers we select.

Managed external client assets include client assets for which we provide investment management services, such as the assets of the Columbia Threadneedle Investments fund families and the assets of institutional clients.

Managed external client assets also include assets managed by sub-advisers we select but do not include client assets that we advise on a non-discretionary basis such as those assets where we provide voting recommendations and engagement services but do not manage the underlying assets.

Our external client assets are not reported on our Consolidated Balance Sheets, although certain investment funds marketed to investors may be consolidated at certain times.

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Investment Management Capabilities and Products

The investment management activities of Columbia Threadneedle Investments are conducted through specialized investment management teams located around the globe, including Boston, Chicago, Houston, London, Los Angeles, Menlo Park, Minneapolis, New York, Portland and Singapore.

The investment management activities of Columbia Threadneedle Investments are conducted through specialized investment management teams located around the globe, including Amsterdam, Boston, Chicago, Hong Kong, Houston, London, Los Angeles, Menlo Park, Minneapolis, New York, Portland and Singapore.

Our investment management capabilities and products span a broad range of asset classes and investment styles to meet a variety of client needs.

Looking at the type of the $547 billion in assets we manage, we have approximately 55% in equity, 36% in fixed income, 8% in alternatives, hybrids and other and 1% in money market.

We offer or make available the following products and services through our Asset Management segment:

Looking at the type of the $754 billion in assets we manage, we have approximately 54% in equity, 37% in fixed income, 5% in alternatives (which includes real estate, CLOs, private equity, hedge funds, infrastructure and commodities), 3% in hybrids and other and 1% in money market.

We offer or make available the following products and services through our Asset Management segment with a range of investment strategies across these different vehicles and accounts:

Registered Funds to the Columbia Management family of funds including retail mutual funds, exchange-listed exchange-traded funds and U.S.

closed-end funds and variable insurance trust funds (“VIT Funds”) on which we earn management fees for managing the assets of the Columbia Management family of mutual funds based on the underlying value of the assets and service fees.

funds through Threadneedle include different risk-return options across regions, markets, asset classes and product structures, which include retail funds that are similar to U.S.

mutual funds (such as Undertakings for the Collective Investment in Transferable Securities (“UCITS”) funds organized as Luxembourg-based investment companies with variable capital (“SICAVs”).

retail focused funds through Threadneedle, and now expanded with the BMO Global Asset Management (EMEA) business, include different risk-return options across regions, markets, asset classes and product structures, which include retail funds that are similar to U.S.

In addition, as a result of acquisition of the BMO Global Asset Management (EMEA) business, this now also includes a range of listed Investment Trusts, including F&C Investment Trust PLC established in 1868.

• European-based pooled investment funds designed for pensions, insurance companies and other institutional investors seeking solutions for liability or balance sheet asset management (“Liability Driven Investment” or “LDI”).

• Institutional and retail separately managed accounts for a range of clients, including pension, profit-sharing, employee savings, sovereign wealth funds and endowment funds, accounts of large- and medium-sized businesses and governmental clients, as well as the accounts of high net worth individuals and smaller institutional clients, including tax-exempt and not-for-profit organizations for which we receive management and performance-related fees.

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• Management of CLOs, which includes providing collateral management services to special purpose vehicles which primarily invest in syndicated bank loans and issue multiple tranches of securities collateralized by the assets to provide investors with various maturity and credit risk characteristics for which we earn fees based on the value of assets and performance-based fees.

• Private funds where we provide investment management and related services to private, pooled investment vehicles organized as limited partnerships, limited liability companies, or non-U.S.

• Private funds of various types where we provide investment management and related services to private, pooled investment vehicles organized as limited partnerships, limited liability companies, or non-U.S.

entities for which we may receive fees based on the value of the assets or performance-based fees.

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funds, private banking individually managed accounts, common trust funds, and other portfolios sponsored or advised by other firms for which we earn management fees and possibly performance-based fees.

We maintain distribution teams and capabilities that support the sales, marketing, and support of the products and services of our global asset management business.

We maintain distribution teams and capabilities that aid the sales, marketing, and support of the products and services of our global asset management business.

These distribution activities are generally organized into two major categories:

retail distribution and institutional/high net worth distribution.

However, alternatives and certain other areas have a level of specialized distribution.

Retail Distribution

Columbia Management funds are sold through both our Advice & Wealth Management segment and through unaffiliated third-party financial intermediaries.

Columbia Management funds are sold through both unaffiliated third-party financial intermediaries and our Advice & Wealth Management segment.

Fees and reimbursements paid to such intermediaries may vary based on sales, redemptions, asset values, asset allocation, product mix, and marketing and support activities provided by the intermediary.

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Pursuant to distribution agreements with the funds, we offer and sell fund shares on a continuous basis and pay certain costs associated with the marketing and selling of shares.

We earn commissions for distributing the Columbia Management funds through

sales charges on certain classes of shares and distribution (12b-1) and servicing-related fees based on a percentage of fund assets and receive intersegment allocation payments.

We earn commissions for distributing the Columbia Management funds through sales charges on certain classes of shares and distribution (12b-1) and servicing-related fees based on a percentage of fund assets and receive intersegment allocation payments.

This revenue is impacted by overall asset levels and mix of the funds.

Threadneedle funds are sold primarily through financial intermediaries and institutions, including banks, life insurance companies, independent financial advisers, wealth managers and platforms offering a variety of investment products.

Threadneedle also distributes directly to certain clients.

Various Threadneedle affiliates serve as the distributors of these fund offerings and are authorized to engage in such activities in numerous countries across Europe, the Middle East, the Asia-Pacific region and Africa.

Certain Threadneedle fund offerings, such as its EU UCITS products, may be distributed on a cross-border basis while others are distributed exclusively in local markets.

Threadneedle and BMO Global Asset Management (EMEA) funds are sold primarily through financial intermediaries and institutions, including banks, life insurance companies, independent financial advisers, wealth managers and platforms offering a variety of investment products.

Threadneedle and BMO Global Asset Management (EMEA) also distribute directly to certain clients.

In particular, the BMO Global Asset Management (EMEA) business operates direct to consumer savings plans that allow retail investors to purchase at their discretion shares in the investment trusts managed by this business.

Various affiliates serve as the distributors of these fund offerings and are authorized to engage in such activities in numerous countries across Europe, the Middle East, the Asia-Pacific region, Latin America and Africa.

Certain Threadneedle and BMO Global Asset Management (EMEA) fund offerings, such as its EU UCITS products, may be distributed on a cross-border basis while others are distributed exclusively in local markets.

Institutional and High Net Worth Distribution

We offer separately managed account services and certain funds to high net worth clients and to a variety of institutional clients, including pension plans, employee savings plans, foundations, sovereign wealth funds, endowments, corporations, banks, trusts, governmental entities, high net worth individuals and not-for-profit organizations.

We offer separately managed account services and certain funds to high net worth clients and to a wide variety of institutional clients, including pension plans, employee savings plans, foundations, sovereign wealth funds, endowments, corporations, banks, trusts, governmental entities, high net worth individuals and not-for-profit organizations.

We provide investment management services for insurance companies, including our insurance subsidiaries.

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RiverSource solutions help deliver on the Ameriprise client experience and Confident Retirement approach.

We offer clients various annuities, life insurance, and disability insurance options to meet their needs or current stage in life—whether that is covering essentials, ensuring lifestyle, preparing for the unexpected or leaving a legacy.

We offer clients annuities, life insurance, and disability insurance options to meet their needs or current stage in life—whether that is covering essentials, ensuring lifestyle, preparing for the unexpected or leaving a legacy.

RiverSource seeks to partner with our advisors to address clients’ goals and long-term needs at a differentiated level and provide a strong risk profile given the clients our advisors serve.

We provide RiverSource variable annuity products to individual clients to help individuals address their asset accumulation and income goals through our advisors.

Retirement Solutions

We provide RiverSource variable annuity products to clients to help individuals address their asset accumulation and income goals through our advisors.

Our advisor network is the only distributor of RiverSource annuity products, although advisors can offer fixed and variable annuities from selected unaffiliated insurers as well.

As part of the continued evolution of our business model, we are continuing to shift our focus away from annuities with living benefit guarantees and toward the accumulation solutions clients want (such as the structured solutions annuity we introduced in 2020).

We discontinued new sales of substantially all of our living benefit annuity solutions at the end of 2021.

Further, in 2020, we discontinued new sales of fixed annuities and moved the Fixed Annuities and Fixed Indexed Annuities blocks to the Corporate & Other segment as a closed block in addition to reinsuring over 90% of the fixed annuities in this closed block (as discussed below in more detail).

Revenues for our variable annuity products are primarily earned as fees based on a contractholder’s benefit base, contract value or separate account values, which is impacted by both market movements and net asset flows.

We also earn net investment income on general account assets supporting reserves for immediate annuities with a non-life contingent feature, structured variable annuities, for certain guaranteed benefits offered with variable annuities, and on capital supporting the business.

We also earn investment income on any fixed investment option within our variable annuity products.

We also earn net investment income on general account assets supporting reserves for immediate annuities with a non-life contingent feature, structured variable annuities, for certain guaranteed benefits and fixed investment options offered with variable annuities, and on capital supporting the business.

In addition, we receive fees charged on assets allocated to our separate accounts to cover administrative costs and a portion of the management fees from the underlying investment accounts in which assets are invested.

Revenues for our immediate annuities with a life contingent feature are earned as premium revenue.

Revenues for our immediate annuities with a

life contingent feature are earned as premium revenue.

Intersegment revenues for this segment reflect fees paid by our Asset Management segment for marketing support and other services provided in connection with the availability of VIT Funds previously discussed.

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All intersegment activity is eliminated in our consolidated results.

We provide a variety of products to address the protection and risk management needs of our retail clients, including life and disability income insurance.

We provide life and disability income insurance products to address the protection and risk management needs of our retail clients.

Though our advisors may also offer insurance products of unaffiliated carriers, we offer RiverSource insurance products exclusively through our advisors.

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RiverSource Insurance Products

Through the RiverSource Life companies and our Retirement & Protection Solutions segment we offer the following products:

Through the RiverSource Life companies and our Retirement & Protection Solutions segment we currently offer the following products:

• Structured Variable Annuities use the performance of an underlying equity market index to determine earnings, up to either a cap or floor.

• Variable Annuities provides returns linked to underlying investments of the contractholder’s choice of certain funds, as well as additional benefits, such as guaranteed minimum death benefits and guaranteed living benefits.

• Variable Annuities provide returns linked to underlying investments of the contractholder’s choice of certain funds, as well as additional benefits, such as guaranteed minimum death benefits (but without living benefits after the discontinuance of substantially all of those products in 2021).

• Variable Universal Life insurance provides life insurance coverage along with investment returns linked to underlying investment accounts of the policyholder’s choice.

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Universal Life Insurance may also contain product features that credit interest at a rate linked to an underlying equity market index.

In the fourth quarter of 2021, we discontinued new sales of the Universal Life Insurance with secondary guarantees and single-pay fixed Universal Life with a long term care rider products.

• Term Life Insurance provides a death benefit, but it does not accumulate cash value.

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We also offer our clients various riders and alternatives.

Our sales of RiverSource individual life insurance in 2020, as measured by scheduled annual premiums, lump sum and excess premiums and single premiums, consisted of approximately 40% universal life, 56% variable universal life and 4% term life.

We reinsure a portion of the insurance risks associated with our currently offered life and disability income products (as well as previously sold fixed annuity and long-term care products included in our Corporate & Other segment) through reinsurance agreements with unaffiliated reinsurance companies.

We use reinsurance to limit losses, reduce exposure to large and catastrophic risks, and provide additional capacity for future growth.

Our sales of RiverSource individual life insurance in 2021, as measured by scheduled annual premiums, lump sum and excess premiums and single premiums, consisted of approximately 85% variable universal life, 12% universal life and 3% term life.

We reinsure a portion of the insurance risks associated with our currently offered life, disability income and life contingent immediate annuity products (as well as previously sold fixed annuity, fixed indexed annuity and long-term care products included in our Corporate & Other segment) through reinsurance agreements with unaffiliated reinsurance companies.

We use reinsurance to limit losses, reduce exposure to large risks, and provide additional capacity for future growth.

To manage exposure to losses from reinsurer insolvencies, we evaluate the financial condition of reinsurers prior to entering into new reinsurance treaties and on a periodic basis during the terms of the treaties.

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Product Reinsurance Type

Term Life Coinsurance

UL & VUL Yearly Renewable Term

Term Life and Disability Income Coinsurance

Universal Life & Variable Universal Life Yearly Renewable Term

Life Contingent Immediate Annuity Coinsurance

Fixed Annuity (closed block in Corporate & Other) Coinsurance

Long Term Care (closed block in Corporate & Other) Coinsurance

Disability Income Coinsurance

Our Segments - Corporate & Other

Our Corporate & Other segment consists of closed block of business and net investment income or loss on corporate level assets, including excess capital held in our subsidiaries and other unallocated equity and other revenues as well as unallocated corporate expenses.

Our Corporate & Other segment consists of closed blocks of business and net investment income or loss on corporate level assets, including excess capital held in our subsidiaries and other unallocated equity and other revenues as well as unallocated corporate expenses.

Closed Block Long Term Care Insurance

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Closed Block Fixed Annuities

In 2020, we stopped new sales of fixed annuities and moved the Fixed Annuities and Fixed Indexed Annuities business to the Corporate & Other segment as a closed block.

These segment reporting changes align with the way our CEO, who is our chief operating decision maker, began assessing the performance of our reportable segments and other business activities effective in the third quarter of 2020.

Certain prior period amounts have been revised to conform to the current presentation.

In 2020, we discontinued new sales of fixed annuities and moved the Fixed Annuities and Fixed Indexed Annuities blocks to the Corporate & Other segment as a closed block.

In this closed block, we have $7.6 billion of account value associated with our fixed annuities of which 91% has been ceded by RiverSource Life on a coinsurance basis to Global Atlantic Financial Group’s subsidiary Commonwealth Annuity and Life Insurance Company (“Commonwealth”) under customary reinsurance arrangements with a comfort trust.

For the ceded policies, RiverSource Life ceded 100% of the risk on a coinsurance basis.

We operate in a highly competitive global industry.

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Our Asset Management segment competes on a global basis to acquire and retain managed and administered assets against a substantial number of firms, including those in the categories listed above.

Competitive factors influencing our performance in this industry include investment performance, product offerings and innovation, product ratings, fee structures, advertising, service quality, brand recognition, reputation and the ability to attract and retain investment personnel.

Competitive factors influencing our performance in this industry include investment performance, product offerings and innovation, product ratings, fee structures, advertising, service quality,

brand recognition, reputation and the ability to attract and retain investment personnel.

Furthermore, changes in investment preferences or investment management strategy (for example, “active” or “passive” investing styles), client interest in funds with particular environmental, social, or governance practices, client or regulatory requirements on use of client commissions for research, and downward pressure on fees present various challenges to our business and may favor different competitors that focus more on “passive” investing styles.

The impact of these factors on our business may vary from country to country and certain competitors may have certain competitive advantage in certain jurisdictions.

As an example, the implementation of the terms of the British exit from the European Union (“EU”) (commonly known as “Brexit”) and other regulatory or political impacts may ultimately favor certain types of asset managers in the EU over non-EU firms.

As an example, the implementation of the terms of the United Kingdom’s exit from the European Union (“EU”) (commonly known as “Brexit”) and other regulatory or political impacts may ultimately favor certain types of asset managers in the EU over non-EU firms.

Competitors of our Retirement & Protection Solutions segment consist of both stock and mutual insurance companies.

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Ameriprise Financial has a strong values-driven and inclusive culture that is the foundation of all that we do.

While our individual business lines serve different client needs, we share a common vision and core set of values that drives our business and how we work with clients and each other.

While our individual business lines serve different client needs, we have a common vision and values that drive our business and how we work with clients and each other.

Our values are the following:

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• Respect for the individuals and for the communities in which we live and work.

We aspire to provide an excellent employee and advisor experience for our approximately 12,300 employees (which includes over 2,000 employee advisors and over 10,300 corporate employees) and 7,800 franchise advisors.

We are committed to investing in our human capital programs and services to ensure a highly competitive employee value proposition.

We aim to attract, retain, engage, and develop a diverse, high performing workforce with a best-in-class development curriculum, strong leadership and comprehensive employee benefits and wellness programs.

• We continued to generate strong employee engagement, including in our annual engagement survey where our results exceeded external benchmarks.

93% of employees participated in our survey and we received 89% favorable scores in both employee engagement and leadership effectiveness.

• 87% of our employees participated in development training, with an average of 11.4 training hours per employee.

We aspire to provide an excellent employee and advisor experience for all of our people.

This includes approximately 12,000 global employees (1) made up of more than 2,000 employee advisors and more than 10,000 corporate employees, and additionally approximately 8,000 franchise advisors.

Our long-term success requires us to attract, retain, engage and develop a diverse, high-performing workforce with a best-in-class development curriculum, strong leadership and comprehensive employee benefits and wellness programs, including diversifying our benefit offerings to increase mental health and resiliency resources during the pandemic.

We continually invest in our human capital programs and capabilities to ensure a highly competitive employee value proposition.

In 2021, a year when the persistency of the coronavirus disease 2019 (“COVID-19”) pandemic continued to impact the global marketplace:

• We continued to have strong employee engagement, including our industry-leading engagement results (84%) and high leadership effectiveness scores (90%) in our annual engagement survey where our results exceeded external benchmarks.

93% of employees participated in our survey.

• 91% of our employees participated in development training.

We continue to invest in our employees’ development, and, in addition to annual training requirements, we encourage all employees to participate in our professional development programs, including core curriculum for new hires and a Transformational Leader Program for officers for officers.

Leaders are further supported by a broad selection of online courses, workshops, mentoring opportunities, networking events, and peer-to-peer programs.

• We retained 92% of our high-performing employees.

• The retention rate among affiliated advisors who have been with us for more than 10 years is 95%.

• We have also continued to attract experienced, productive advisors, with 336 experienced advisors moving their practices to Ameriprise in 2020 and approximately 1,700 in the last 5 years.

Our diversity and inclusion vision is to foster a diverse and inclusive workforce so that everyone at Ameriprise feels like they can belong, grow, and contribute in a culture that unleashes their potential.

This includes ensuring meaningful dialogue between leaders and employees on current diversity and inclusion topics, leveraging programs to attract, retain and advance diverse talent, and continuing to evolve our leadership development curriculum and training for employees and advisors.

Our focus on fostering a diverse and inclusive culture is also reflected in our clear policies and practices to promote a safe, inclusive and respectful workplace.

Our 13 business resource networks engage over 9,000 participants globally each year to promote cultural awareness and community involvement while providing employees and advisors with wellness and career development resources.

Importantly, our compensation programs are designed to drive a high-performing workforce with deliberate alignment of rewards with client and shareholder success.

Weighing both individual goal achievement (the “what”) and leadership performance (the “how”) is critical to driving strong business results and engaging, motivating and retaining our employees.

Ameriprise was well prepared to manage through the unexpected pandemic and its associated impacts because of the strategic investments and actions we have taken over many years.

From the start, our priority was serving our clients, as well as the health and safety of the Ameriprise employees.

As we navigated through this challenging environment, our balance sheet strength and risk management foundation were keys to our success.

We remain focused on protecting the health and safety of our employees and advisors through a variety of strategic actions, including:

• Effective business continuity planning and strong technology infrastructure enabled a rapid transition to work-from-home for approximately 95% of our workforce

• Implemented comprehensive safety protocols across all locations for those who needed access to our offices

• Provided proactive and frequent updates to employees, advisors, and clients regarding support available during remote environment

• Significantly increased engagement through successfully transitioning to virtual recruiting, onboarding and development for employees and advisors

• Quickly developed and implemented leader resources to effectively lead engaged and productive virtual teams in a remote work environment

• Emphasized existing and new virtual benefit resources to support all aspects of employee well-being (i.e.

physical, emotional, social and financial)

• Expanded our employee assistance program resources to non-employee advisors.

• We are committed to ensuring safe return to the workplace through a phased approach informed by local requirements with focus on employee safety while supporting business needs

In addition, our CEO and Executive Leadership Team, in alignment with the Board of Directors, have worked diligently to position the company to “emerge stronger” from the COVID-19 pandemic.

Through the challenges over this past year, we have grown as a company, from how we support and engage our clients and our workforce, and we are continuing to find ways to innovate, change, adapt and modernize in all aspects of our business.

• We have also continued to attract experienced, productive advisors, with 325 experienced advisors moving their practices to Ameriprise in 2021 and approximately 1,618 over the last 5 years.

• Of our global employees, 40% self-identify as women, and among our U.S.-based employees 18% identify as ethnically diverse.

More detail on our workforce composition with a summary of our EEO metrics can be found in our 2022 Ameriprise Responsible Business report, which is available on our website.

Information contained on or accessible through our websites is not incorporated into and does not form a part of this Form 10-K or any other report or document we file with the SEC, and any references to our websites are intended to be inactive textual references only.

Our diversity, equity and inclusion vision is to foster an inclusive culture and diverse workforce so that everyone at Ameriprise feels like they belong, grow and contribute in a culture that helps them realize their potential.

This includes ensuring meaningful conversations between leaders and employees on current diversity topics, leveraging programs to attract, retain and advance diverse talent, and continuing to evolve our leadership development curriculum and training for employees and advisors.

In 2021, we added resources to support our strategy, including adding new positions on the diversity, equity and inclusion team, developing business unit specific programs, and enhancing our measurement and diagnostic capabilities.

Our focus on fostering a diverse and inclusive culture is also reflected in the policies and practices that promote a safe, inclusive and respectful workplace.

Our 13 business resource networks engage more than 9,000 participants globally each year to promote cultural awareness and community involvement while providing employees and advisors with wellness and career development resources.

Importantly, our compensation programs are designed to attract, retain, and motivate employees with deliberate alignment of rewards with performance.

Weighing both individual goal achievement (the “what”) and leadership performance (the “how”) is critical to driving strong business results.

Employees receive base pay, and all are eligible for annual incentive awards and many are eligible for additional long-term incentives.

Additionally, employees receive a competitive benefits package that addresses employees’ physical, social, emotional, and financial wellness.

Ameriprise was well prepared to manage through the unexpected COVID-19 pandemic and its associated impacts because of the strategic investments and actions we have taken over many years.

From the start and throughout this extended period of multiple variants, our priority has remained on serving our clients, as well as the health and safety of our employees.

As we continue to navigate this challenging environment, our balance sheet strength, technology infrastructure and risk management foundation remain key to our success.

Importantly, throughout the ongoing pandemic, we have remained focused on protecting the health and safety of our employees and advisors through a variety of strategic actions, including having the vast majority of our workforce work-from-home during 2020, using safety protocols in our offices, and increased communications and resources for our employees during the pandemic.

During 2021, we began the transition to returning to work in our offices in our locations where people could gather safely.

We know flexibility is increasingly important, and flexibility has been and continues to be a tenant of our operating model and are offering balanced flexibility that meets the needs of our clients, advisors, employees and shareholders.

Going forward, we are building on our learnings from the ongoing pandemic and listening to our clients, advisors, employees, and shareholders to continue to reinforce our culture, strengthen relationships, meet our business objectives, and serve our clients well.

(1) This does not include employees who joined in November 2021 as part of our acquisition of the BMO Global Asset Management (EMEA) business.

Intellectual Property

We rely on a combination of contractual rights and copyright, trademark, patent and trade secret laws to establish and protect our intellectual property.

and other jurisdictions, we have established and registered, or filed applications to register, certain trademarks and service marks that we consider important to the marketing of our products and services, including but not limited to Ameriprise Financial, Threadneedle, RiverSource and Columbia Threadneedle Investments.

We have in the past and will continue to establish and protect our intellectual property.

We rely on a combination of contractual rights and copyright, trademark, patent and trade secret laws and registrations to establish and protect our intellectual property.

We have in the past and will continue to establish and protect our intellectual property rights.

Enterprise Risk Management

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and foreign securities exchanges.

The costs of complying with such laws and

regulations can be significant, and the consequences for the failure to comply may include civil or criminal charges, fines, censure, the suspension of individual employees, restrictions on or prohibitions from engaging in certain lines of business (or in certain states or countries), revocation of certain registrations and reputational damage.

The costs of complying with such laws and regulations are significant, and the consequences for the failure to comply may include civil or criminal charges, fines, censure, the suspension of individual employees, restrictions on or prohibitions from engaging in certain lines of business (or in certain states or countries), revocation of certain registrations and reputational damage.

We have made and expect to continue to make significant investments in our compliance and supervision processes, enhancing policies, procedures and oversight to monitor our compliance with the numerous legal and regulatory requirements applicable to our business.

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Regulatory developments, both in and outside of the U.S., have resulted or are expected to result in greater regulatory oversight and internal compliance obligations for firms across the financial services industry.

In addition, we continue to see enhanced legislative and regulatory interest regarding retirement investing and fiduciary initiatives, as well as cybersecurity, responsible information, financial crime and privacy matters, and we will continue to closely review and monitor any legislative or regulatory proposals and changes.

States continue to add new complexity to the patchwork of laws already in existence relating to privacy and cybersecurity and we are expecting similar new laws this year in multiple states.

In addition, we continue to see enhanced legislative and regulatory interest regarding retirement investing and fiduciary initiatives, as well as environmental, social and governance (“ESG”), cybersecurity, responsible information and data use, financial crime and privacy matters, and we will continue to closely review and monitor any legislative or regulatory proposals and changes.

States in the U.S.

and jurisdictions outside the U.S.

continue to add new complexity to the patchwork of laws already in existence relating to privacy and cybersecurity and we are expecting similar new laws this year in multiple states in the U.S.

The same complexity resulting from multiple standards exists for retirement investing where individual states and federal regulators continue to propose or enact their own rules.

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The discussion and overview set forth below provides a general framework of the primary laws and regulations impacting our businesses.

Certain of our subsidiaries may be subject to one or more elements of this regulatory framework depending on the nature of their business, the products and services they provide and the geographic locations in which they operate.

Certain of our subsidiaries may be subject to one or more elements of this regulatory framework depending on the nature

of their business, the products and services they provide and the geographic locations in which they operate.

To the extent the discussion includes references to statutory and regulatory provisions, it is qualified in its entirety by reference to these statutory and regulatory provisions and is current only as of the date of this report.

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Department of Labor (“DOL”)) in the U.S.

foreign jurisdictions (such as the European Securities and Markets Authority and the national financial regulator for each European country) where we do business.

and in foreign jurisdictions (such as the European Securities and Markets Authority, the national financial regulator for each European country, Australian Securities and Investment Commission and various Canadian provinces) where we do business.

Advice & Wealth Management Regulation

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As noted earlier, we continue to see enhanced legislative and regulatory interest regarding retirement investing and financial advisors, including proposed rules, regulatory priorities or general discussions around transparency and disclosure in advisor compensation and recruiting, identifying and managing conflicts of interest and enhanced data collection.

The SEC’s Regulation Best Interest became effective on June 30, 2020.

Regulation Best Interest requires a broker-dealer to act in the best interest of a retail customer when making a recommendation to that customer of any securities transaction or investment strategy involving securities.

The SEC’s Regulation Best Interest standard of care became effective June 30, 2020 and the SEC continues to issue various statements and other pieces of guidance on complying with the regulation.

Furthermore, several states have either issued their own best interest or fiduciary rules or are considering doing so and those rules may be limited to certain types of products (e.g.

insurance and annuities, financial planning, etc.) or may broadly cover all recommendations made by financial advisors.

The DOL has finalized its voluntary exemption for providing investment advice to retirement account clients and has reinstated prior guidance for determining who is an investment advice fiduciary under pension regulations.

The Certified Financial Planner Board updated its professional standards of conduct to include a fiduciary standard that will apply to financial advisors who hold a Certified Financial Planner designation.

Currently, Ameriprise has approximately 4,100 financial advisors who hold a Certified Financial Planner designation.

The DOL finalized its voluntary exemption for providing investment advice to retirement account clients and has reinstated prior guidance for determining who is an investment advice fiduciary under pension regulations.

While not a regulator, the Certified Financial Planner Board professional standards of conduct includes a fiduciary standard that applies to financial advisors who hold a Certified Financial Planner designation.

Considering the various fiduciary rules and regulations that continue to be proposed, finalized, and sometimes withdrawn or amended, we continue to exert significant efforts to evaluate and prepare to comply with each rule.

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In this regard, we are subject to additional registration and reporting requirements with respect to certain registered investment companies and other pooled vehicles that use or trade in futures, swaps and other derivatives that are subject to CFTC regulation.

Outside of the U.S., Columbia Threadneedle Investments is authorized to conduct its financial services business in the U.K.

Outside of the U.S., Columbia Threadneedle Investments, now including the BMO Global Asset Management (EMEA) business, is authorized to conduct its financial services business in the U.K.

under the Financial Services and Markets Act 2000.

Threadneedle is currently regulated by the Financial Conduct Authority (“FCA”) and the Prudential Regulation Authority (“PRA”).

A number of legal entities in the Threadneedle and BMO Global Asset Management (EMEA) business are currently regulated by the Financial Conduct Authority (“FCA”) and one entity in the Threadneedle business is also regulated by the Prudential Regulation Authority (“PRA”).

FCA and PRA rules impose certain capital, operational and compliance requirements and allow for disciplinary action in the event of noncompliance.

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regulatory developments and trends include the following:

The trade and cooperation agreement between the U.K.

and EU does not include cross-border financial services.

As a result, our U.K.

asset management business is no longer able to market its services into the EU on a passporting basis and must now comply with local EU and country requirements as a non-EU firm, which includes leveraging our Luxembourg-based management company affiliate to provide services and marketing to EU clients and investors.

• Operational Resilience.

regulators have published proposals to improve the “operational resilience” of the U.K.

financial systems and firms and these new rules will be phased in from 2021.

Under this new U.K.

regulatory requirement, in scope firms must identify their important business services, which if unavailable, could cause intolerable harm to clients, which they could not reasonably recover, or market disruption.

The regulations introduce a new concept of impact tolerance and firms are also required to stress test their important business services and appoint a senior manager accountable for the regime.

• Financial Resilience.

regulators will revise the prudential regime applying to asset managers.

This will be phased in from 2021 over a five-year period.

Having withdrawn from the EU, the U.K.

and others will need to negotiate the terms of multiple new relationships, which will take some time.

The full impact of Brexit and its related consequences remain uncertain, including with respect to ongoing negotiations between the U.K.

and EU on financial services and new trade agreements with global trading partners.

We continue to actively monitor the dynamic Brexit situation and political activity around Brexit.

We have an established fund range domiciled in Luxembourg (both UCITS and Alternative Investment Funds) along with a Luxembourg-based management company, and Columbia Threadneedle Investments has expanded the regulated permissions of the Luxembourg management company to perform fund management, administration and distribution functions.

regulators regulators have revised the prudential regime applying to asset managers and investment firms.

This will be phased in over a five-year period and introduces a number of new concepts, including new capital requirements.

• FCA Consumer Duty .

The FCA is proposing to introduce a new Consumer Duty that will set higher expectations for the standard of care that firms provide to retail consumers.

In addition, following Brexit the trade and cooperation agreement between the U.K.

and EU does not include cross-border financial services.

As a result, our U.K.

asset management business is no longer able to market its services into the EU on a passporting basis and must now comply with local EU and country requirements as a non-EU firm, which includes leveraging our various EU-based affiliated entities (such as those in Luxembourg and the Netherlands) to provide services and marketing to EU clients and investors.

We continue to actively monitor the dynamic Brexit situation and political activity around Brexit, including with respect to the continued permissibility of the delegation of asset management services from the EU to non-EU countries such as the US and UK.

We have an established fund range domiciled in Luxembourg (both UCITS and Alternative Investment Funds), Ireland and the Netherlands, along with Luxembourg-based and Netherlands-based affiliated management companies.

Our Luxembourg and Netherlands affiliates may perform fund management, administration and distribution functions.

Therefore, we are well placed to continue to serve investors in the EU.

We have replicated, and will continue to replicate, appropriate funds from our U.K.-based open-ended investment company (“OEIC”) range within our Luxembourg SICAV platform.

We have a well-resourced and experienced product development team with the capacity to ensure the needs of our clients are met in an efficient and transparent manner.

As a result of our expansion of regulated permissions in Luxembourg, we expect to have greater engagement with the Commission de Surveillance du Secteur Financier (“CSSF”), as the primary regulator of our Luxembourg business and its EU branches and funds.

Pan-European and Other Non-U.S.

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Certain of these directives have impacted and will continue to impact our global asset management business.

These requirements impact the way we manage assets and place, settle and report on trades for our clients, as well as market to clients and prospects.

For example, certain of our asset management subsidiaries are required to comply with the Markets in Financial Instruments Directive (“MiFID II”), Markets in Financial Instruments Regulation (“MiFIR”), Alternative Investment Fund Managers Directive (“AIFMD”), European Market Infrastructure Regulation (“EMIR”) , Undertakings for Collective Investment in Transferable Securities Directives (“UCITS”) and the Sustainable Finance Disclosure Regulation (“SFDR”) These requirements impact the way we manage assets and place, settle and report on trades for our clients, as well as market to clients and prospects.

EMIR provides a framework for the regulation of over the counter and exchange-traded derivative markets.

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we have been and will continue to address regulatory reforms or structural changes including but not limited to:

enhanced regulatory focus and specific EU regulations on sustainable finance and environmental, social and governance (ESG);

Senior Manager and Certification Regime;

enhanced regulatory focus and specific EU regulations on sustainable finance and ESG;

Senior Manager and Certification Regime U.K.

Packaged Retail and Insurance-based Investment Products;

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potentially with significant variation from the EU regulations and potentially increasing the complexity and costs for our compliance.

The EU’s General Data Protection Regulation (“GDPR”) sought to harmonize data protection legislation and introduced changes in areas such as:

(i) governance and oversight, (ii) processing of personal data, (iii) enhancements around consent and data subject rights, and (iv) international data transfers.

GDPR is a step change in the way personal data is regulated in Europe and outside of Europe to the extent that goods or services are being marketed to EU citizens and their personal information is collected and processed in the course of that interaction.

We are mindful of other upcoming regulatory changes (including those arising from Brexit) and the impact data privacy regulations will have on our current business model post-Brexit.

In Singapore, our asset management subsidiary Threadneedle Investments Singapore (Pte.) Ltd.

(“Threadneedle Singapore”) is regulated by the Monetary Authority of Singapore (“MAS”) under the Securities and Futures Act.

Threadneedle Singapore holds a

capital markets services license with MAS, and employees of Threadneedle Singapore engaging in regulated activities are required to be licensed.

MAS rules impose certain capital, operational and compliance (including Senior Manager) requirements and allow for disciplinary action in the event of noncompliance.

Threadneedle companies and activities are also subject to other local country regulations and regulators in Europe, Dubai, Hong Kong, the U.S., South Korea, South America and Australia.

Additionally, many of our subsidiaries, including Columbia Management, are also subject to foreign, state and local laws with respect to advisory services that are currently offered and provided by these subsidiaries, including services provided to government pension plans.

Columbia Threadneedle companies or activities (including those we acquired as part of the BMO Global Asset Management (EMEA) business) are also subject to various local country or jurisdiction regulations and to corresponding regulators in Europe, Canada, Dubai, Hong Kong, Singapore, South Korea, South America and Australia.

With our growth in the EU, including the recent acquisition of the BMO Global Asset Management (EMEA) business, we expect to have greater engagement with the Luxembourg, Irish and Dutch regulators.

Other Securities Regulation

Ameriprise Certificate Company is regulated as an investment company under the Investment Company Act.

As a registered investment company, Ameriprise Certificate Company must observe certain governance, disclosure, record-keeping, operational and marketing requirements.

As a registered investment company, Ameriprise Certificate Company must observe certain governance, disclosure, record-keeping, operational and

marketing requirements.

Ameriprise Certificate Company pays dividends to the parent company and is subject to capital requirements under applicable law and understandings with the SEC and the Minnesota Department of Commerce (Banking Division).

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Ameriprise Trust Company, as well as our investment adviser subsidiaries, may be subject to ERISA, and the regulations thereunder, insofar as they act as a “fiduciary” under ERISA with respect to certain ERISA clients.

Retirement & Protection Solutions Regulation

Insurance Regulation

Our insurance subsidiaries are subject to supervision and regulation by states and other territories where they are domiciled or otherwise licensed to do business.

These regulations impact our Retirement & Protection Solutions segment and our closed-blocks included in Corporate & Other segment.

The primary purpose of this regulation and supervision is to protect the interests of contract holders and policyholders.

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Financial regulation of our RiverSource Life companies is extensive, and their financial transactions (such as intercompany dividends and investment activity) may be subject to pre-approval and/or continuing evaluation by the Domiciliary Regulators.

Aspects of the regulation applicable to our Advice & Wealth Management segment also apply to our Retirement & Protection Solutions segment.

Aspects of the regulation applicable to our Advice & Wealth Management segment also apply to our Retirement & Protection Solutions segment and the closed blocks in our Corporate & Other segment.

For example, RiverSource Distributors is registered as a broker-dealer for the limited purpose of acting as the principal underwriter and/or distributor for our RiverSource annuities and insurance products sold through Ameriprise Financial Services, LLC (“AFS”) and third-party channels.

Additionally, ERISA, the SEC’s best interest standards, state and other fiduciary or best interest rules, as well as other similar standards and any rulemaking from the DOL are relevant to the our insurance and annuities business.

We continue to review and analyze the potential impact of these regulations across each of our business lines.

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The National Association of Insurance Commissioners (“NAIC”) has established RBC standards that all state insurance departments have adopted.

The RBC requirements are used by the NAIC and state insurance regulators to identify companies that merit regulatory actions designed to

protect policyholders.

The RBC requirements are used by the NAIC and state insurance regulators to identify companies that merit regulatory actions designed to protect policyholders.

The NAIC RBC report is completed as of December 31 and filed annually, along with the statutory financial statements.

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Further, FRB regulation and supervisory oversight of Ameriprise Financial includes examinations, regular financial reporting, and prudential standards, such as capital, liquidity risk management, and parameters for business conduct and internal governance.

Under the Bank Holding Company Act, bank holding companies and their banking subsidiaries are generally limited to the business of banking and activities closely related or incidental to banking.

Under the Bank Holding Company Act, bank holding companies and their banking subsidiaries are generally limited to the business of banking and activities closely related or incidental to banking and going beyond these activities would require a conformance period request from the FRB.

As a financial holding company we may engage in activities that are financial in nature, incidental to an activity that is financial in nature, or complementary to a financial activity and that do not pose a substantial risk to the safety and soundness of depository institutions or the financial system generally.

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Failure to meet one or more of these requirements would mean, depending on the violation and any agreement then reached with the FRB, Ameriprise Financial could not undertake new activities, continue certain activities or make acquisitions other than those generally permissible for bank holding companies until such violation is cured.

After a conformance period that ends in May 2021, we will be subject to what is commonly referred to as the Volcker Rule.

We are subject to what is commonly referred to as the Volcker Rule.

The Volcker Rule prohibits “banking entities,” including us and our affiliates, from engaging in certain “proprietary trading” activities, as defined in the Volcker Rule, subject to exemptions for underwriting, market-making-related activities, asset management, risk-mitigating hedging and certain other activities.

The Volcker Rule also prohibits certain investments and relationships by banking entities with “covered funds,” with a number of exemptions and exclusions.

The Volcker Rule also prohibits certain investments and relationships by banking entities with “covered funds,” with a number of exemptions and

It also requires banking entities to have comprehensive compliance programs reasonably designed to ensure and monitor compliance with the Volcker Rule.

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Because of the mix of business activities we conduct, we assess the impact of, and monitor our status under, the EU Financial Conglomerates Directive, which contemplates global supervision and prudential regulation of certain financial conglomerates involved in banking, insurance and investment activities.

In 2017, the FCA, announced that London Interbank Offered Rate (“LIBOR”) is to be phased out and secured agreement with panel banks to continue to submit to LIBOR until the end of 2021.

In 2017 and subsequent announcements, the FCA announced that London Interbank Offered Rate (“LIBOR”) is to be phased out and secured agreement with panel banks to continue to submit to LIBOR during a transition period.

All currencies, except U.S.

Dollar, are expected to cease publication on December 31, 2021, and U.S.

Dollar, ceased publication on December 31, 2021, and U.S.

Dollar LIBOR will cease publication in June 2023.

We are reviewing products and documents that rely on LIBOR and plan to migrate them to an alternate rate.

Following our transition for currencies other than the U.S.

Dollar which went as expected, we are preparing for the discontinuation and transition of U.S.

Dollar LIBOR and other interbank offering rates (“IBORS”) on various aspects of our business and believe we will be well positioned as those benchmark rates transition to risk free rates.

Privacy, Environmental and Anti-Money Laundering Laws

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This includes rules adopted pursuant to the Gramm-Leach-Bliley Act, the Fair and Accurate Credit Transactions Act, the Health Insurance Portability and Accountability Act (“HIPAA”), the Health Information Technology for Economic and Clinical Health (“HITECH”) Act, an ever increasing number of state laws and regulations such as the New York State Department of Financial Services’ Cybersecurity Requirements for Financial Services Companies, the California Consumer Privacy Act, EU data protection legislation as implemented in the respective EU member states, and data protection rules in other regions in which we operate outside the U.S.

and the EU (including GDPR).

We have also implemented policies and procedures, including a cybersecurity incident response manual, in response to such requirements.

and the EU (including in the U.K.

which has implemented data protection legislation that closely mirrors the EU’s Global Data Protection Regulation).

We have also implemented policies and procedures in response to such requirements.

We continue our efforts to safeguard the data entrusted to us in accordance with applicable laws and our internal data protection policies, including taking steps to reduce the potential for identity theft or other improper use or disclosure of personal information, while seeking to collect only the data that is necessary to properly achieve our business objectives and best serve our clients.

As the owner and operator of real property, we are subject to federal, state and local environmental laws and regulations.

We periodically conduct environmental reviews on our own real estate as well as investment real estate to assess and ensure our compliance with these laws and regulations.

To the extent we do experience an incident, we have developed and implemented a cybersecurity incident response manual, which we regularly exercise and update, as appropriate.

As the owner and operator of real property, we are subject to federal, state, local and foreign environmental laws and regulations.

We periodically conduct certain air and water reviews on our own real estate as well as investment real estate to assess and support our compliance with these laws and regulations.

The Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act, commonly referred to as the USA Patriot Act, was enacted in October 2001.

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What changed 10-K

Item 1. Business