X0201

N-CEN: Filer Information

Submission Contact Information

Name
 
Phone
 
E-Mail Address
 

Notification Information

Notify via Filing Website only?Checkbox not checked

N-CEN:Series/Class (Contract) Information

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N-CEN:Part A: General Information

Item A.1. Reporting period covered.

a. Report for period ending:
2019-09-30 
b. Does this report cover a period of less than 12 months?Radio button not checked Yes Radio button checked No

N-CEN:Part B: Information About the Registrant


Item B.1. Background information.

a. Full name of Registrant
SEI INSTITUTIONAL MANAGED TRUST 
b. Investment Company Act file number ( e.g., 811-)
811-04878 
c. CIK
0000804239 
d. LEI
9FTE3UO0Y1HGMNV0D371 

Item B.2. Address and telephone number of Registrant.

a. Street 1
1 FREEDOM VALLEY DRIVE 
Street 2
 
b. City
OAKS 
c. State, if applicable
PENNSYLVANIA  
d. Foreign country, if applicable
UNITED STATES OF AMERICA  
e. Zip code and zip code extension, or foreign postal code
19456 
f. Telephone number (including country code if foreign)
610-676-1000 
g. Public Website, if any
http://www.seic.com 

Item B.3. Location of books and records.

Instruction. Provide the requested information for each person maintaining physical possession of each account, book, or other document required to be maintained by section 31(a) of the Act (15 U.S.C. 80a-30(a)) and the rules under that section.
Location books Record: 1
a. Name of person (e.g., a custodian of records)
ACADIAN ASSET MANAGEMENT LLC 
b. Street 1
260 Franklin St 
Street 2
 
c. City
Boston 
d. State, if applicable
MASSACHUSETTS  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
2110 
g. Telephone number (including country code if foreign)
617-850-3500 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 2
a. Name of person (e.g., a custodian of records)
BENEFIT STREET PARTNERS, LLC 
b. Street 1
9 West 57th Street 
Street 2
Suite 4920 
c. City
New York 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
10019 
g. Telephone number (including country code if foreign)
212-588-6770 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 3
a. Name of person (e.g., a custodian of records)
Fiera Capital 
b. Street 1
375 Park Ave 
Street 2
8th Floor 
c. City
New York 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
10152 
g. Telephone number (including country code if foreign)
212-300-1600 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 4
a. Name of person (e.g., a custodian of records)
SCHAFER CULLEN CAPITAL MANAGEMENT INC 
b. Street 1
645 5th Avenue 
Street 2
Suite 1201 
c. City
New York 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
10022 
g. Telephone number (including country code if foreign)
212-644-1800 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 5
a. Name of person (e.g., a custodian of records)
Dynamic Beta Investments LLC 
b. Street 1
575 5th Ave 
Street 2
 
c. City
New York 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
10017 
g. Telephone number (including country code if foreign)
646-837-7030 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 6
a. Name of person (e.g., a custodian of records)
GUGGENHEIM INVESTMENT Management, LLC 
b. Street 1
100 Wilshire Boulevard 
Street 2
Suite 500 
c. City
Santa Monica 
d. State, if applicable
CALIFORNIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
90401 
g. Telephone number (including country code if foreign)
610-313-0910 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 7
a. Name of person (e.g., a custodian of records)
Columbia Management Investment Advisers, LLC 
b. Street 1
225 Franklin St 
Street 2
 
c. City
Boston 
d. State, if applicable
MASSACHUSETTS  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
2110 
g. Telephone number (including country code if foreign)
617-385-9840 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 8
a. Name of person (e.g., a custodian of records)
Kettle Hill Capital Management, LLC 
b. Street 1
655 Third Avenue 
Street 2
 
c. City
New York 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
10017 
g. Telephone number (including country code if foreign)
212-488-1728 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 9
a. Name of person (e.g., a custodian of records)
RAMIUS Advisors, LLC 
b. Street 1
599 Lexington Avenue 
Street 2
19th Floor 
c. City
New York 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
10022 
g. Telephone number (including country code if foreign)
NA 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 10
a. Name of person (e.g., a custodian of records)
BRIGADE CAPITAL MANAGEMENT, LP 
b. Street 1
399 Park Ave 
Street 2
16th Floor 
c. City
New York 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
10022 
g. Telephone number (including country code if foreign)
212-745-9700 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 11
a. Name of person (e.g., a custodian of records)
WESTERN ASSET MANAGEMENT Company 
b. Street 1
385 East Colorado Boulevard 
Street 2
 
c. City
Pasadena 
d. State, if applicable
CALIFORNIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
91101 
g. Telephone number (including country code if foreign)
626-844-9400 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 12
a. Name of person (e.g., a custodian of records)
BlackRock Investment Management, LLC 
b. Street 1
1 University Square Drive 
Street 2
 
c. City
Princeton 
d. State, if applicable
NEW JERSEY  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
08540 
g. Telephone number (including country code if foreign)
800-441-7762 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 13
a. Name of person (e.g., a custodian of records)
WELLINGTON MANAGEMENT Company LLP 
b. Street 1
280 Congress Street 
Street 2
 
c. City
Boston 
d. State, if applicable
MASSACHUSETTS  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
2210 
g. Telephone number (including country code if foreign)
610-631-3500 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 14
a. Name of person (e.g., a custodian of records)
J.P. MORGAN Investment Management Inc. 
b. Street 1
270 Park Avenue 
Street 2
 
c. City
New York 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
10017 
g. Telephone number (including country code if foreign)
215-640-3400 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 15
a. Name of person (e.g., a custodian of records)
CASTLEARK MANAGEMENT LLC 
b. Street 1
1 North Wacker Drive 
Street 2
Suite 3950 
c. City
Chicago 
d. State, if applicable
ILLINOIS  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
60606 
g. Telephone number (including country code if foreign)
312-456-9682 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 16
a. Name of person (e.g., a custodian of records)
LMCG Investments, Inc. 
b. Street 1
200 Clarendon Street 
Street 2
28th Floor 
c. City
Boston 
d. State, if applicable
MASSACHUSETTS  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
2116 
g. Telephone number (including country code if foreign)
617-380-5600 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 17
a. Name of person (e.g., a custodian of records)
EAM Investors LLC 
b. Street 1
2533 South Coast Highway 101 
Street 2
Suite 240 
c. City
Cardiff-by-the-Sea 
d. State, if applicable
CALIFORNIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
92007 
g. Telephone number (including country code if foreign)
760-479-5080 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 18
a. Name of person (e.g., a custodian of records)
Janus Capital Management LLC 
b. Street 1
151 Detroit St 
Street 2
 
c. City
Denver 
d. State, if applicable
COLORADO  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
80206 
g. Telephone number (including country code if foreign)
303-333-3863 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 19
a. Name of person (e.g., a custodian of records)
ARROWPOINT ASSET MANAGEMENT, LLC 
b. Street 1
100 Fillmore street 
Street 2
suite 325 
c. City
Denver 
d. State, if applicable
COLORADO  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
80206 
g. Telephone number (including country code if foreign)
303-398-2929 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 20
a. Name of person (e.g., a custodian of records)
BROWN BROTHERS HARRIMAN & CO. 
b. Street 1
40 Water Street 
Street 2
 
c. City
Boston 
d. State, if applicable
MASSACHUSETTS  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
02109 
g. Telephone number (including country code if foreign)
617-772-1818 
h. Briefly describe the books and records kept at this location:
Records as Custodian of Trust 
Location books Record: 21
a. Name of person (e.g., a custodian of records)
SEI Investments Distribution Company 
b. Street 1
1 Freedom Valley Drive 
Street 2
 
c. City
Oaks 
d. State, if applicable
PENNSYLVANIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
19456 
g. Telephone number (including country code if foreign)
610-676-1000 
h. Briefly describe the books and records kept at this location:
Records as Distributor for Trust 
Location books Record: 22
a. Name of person (e.g., a custodian of records)
US BANK, N.A. 
b. Street 1
425 Walnut Street 
Street 2
 
c. City
Cincinnati 
d. State, if applicable
OHIO  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
45202 
g. Telephone number (including country code if foreign)
NA 
h. Briefly describe the books and records kept at this location:
Records as Custodian for Trust 
Location books Record: 23
a. Name of person (e.g., a custodian of records)
QS INVESTORS, LLC 
b. Street 1
880 Third Avenue 
Street 2
7th Floor 
c. City
New York 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
10022 
g. Telephone number (including country code if foreign)
212-886-9200 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 24
a. Name of person (e.g., a custodian of records)
AQR CAPITAL MANAGEMENT, LLC 
b. Street 1
Two Greenwich Plaza 
Street 2
 
c. City
Greenwich 
d. State, if applicable
CONNECTICUT  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
6830 
g. Telephone number (including country code if foreign)
203-742.3600 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 25
a. Name of person (e.g., a custodian of records)
Credit Suisse Asset Management 
b. Street 1
11 Madison Ave 
Street 2
 
c. City
New York 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
10010 
g. Telephone number (including country code if foreign)
NA 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 26
a. Name of person (e.g., a custodian of records)
WESTERN ASSET MANAGEMENT Company Limited 
b. Street 1
385 East Colorado Boulevard 
Street 2
 
c. City
Pasadena 
d. State, if applicable
CALIFORNIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
91101 
g. Telephone number (including country code if foreign)
626-844-9400 
h. Briefly describe the books and records kept at this location:
Records as Sub-Advisor for Trust 
Location books Record: 27
a. Name of person (e.g., a custodian of records)
Falcon Point Capital, LLC 
b. Street 1
Two Embarcadero Center 
Street 2
Suite 420 
c. City
San Francisco 
d. State, if applicable
CALIFORNIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
94111 
g. Telephone number (including country code if foreign)
415-782-9600 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 28
a. Name of person (e.g., a custodian of records)
ARES MANAGEMENT LLC 
b. Street 1
2000 Avenue of the Stars 
Street 2
12th Floor 
c. City
Los Angeles 
d. State, if applicable
CALIFORNIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
90067-4733 
g. Telephone number (including country code if foreign)
800-940-6347 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 29
a. Name of person (e.g., a custodian of records)
ALLIANCEBERNSTEIN L.P. 
b. Street 1
1345 Avenue of the Americas 
Street 2
 
c. City
New York 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
10105 
g. Telephone number (including country code if foreign)
212-969-1000 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 30
a. Name of person (e.g., a custodian of records)
Rice Hall James & Associates, LLC 
b. Street 1
600 West Broadway, Suite 1000 
Street 2
 
c. City
San Diego 
d. State, if applicable
CALIFORNIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
92101 
g. Telephone number (including country code if foreign)
619-239-9005 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 31
a. Name of person (e.g., a custodian of records)
Ceredex Value Advisors LLC 
b. Street 1
301 E Pine St #500 
Street 2
 
c. City
Orlando 
d. State, if applicable
FLORIDA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
32801 
g. Telephone number (including country code if foreign)
407-674-1270 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 32
a. Name of person (e.g., a custodian of records)
SSGA FUNDS MANAGEMENT 
b. Street 1
State Street Financial Center 
Street 2
One Lincoln Street 
c. City
Boston 
d. State, if applicable
MASSACHUSETTS  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
2210 
g. Telephone number (including country code if foreign)
NA 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 33
a. Name of person (e.g., a custodian of records)
Brandywine Global Investment Management LLC 
b. Street 1
2929 Arch Street 
Street 2
8th Floor 
c. City
Philadelphia 
d. State, if applicable
PENNSYLVANIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
19104 
g. Telephone number (including country code if foreign)
215-609-3500 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 34
a. Name of person (e.g., a custodian of records)
ANALYTIC INVESTORS LLC 
b. Street 1
555 West Fifth Street 
Street 2
50th Floor 
c. City
Los Angeles 
d. State, if applicable
CALIFORNIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
90013 
g. Telephone number (including country code if foreign)
213-688-3015 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 35
a. Name of person (e.g., a custodian of records)
Coho Partners, Ltd. 
b. Street 1
300 Berwyn Park, 801 Cassatt Road 
Street 2
Suite 100 
c. City
Berwyn 
d. State, if applicable
PENNSYLVANIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
19312 
g. Telephone number (including country code if foreign)
484-318-7575 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 36
a. Name of person (e.g., a custodian of records)
ESMO ASSET MANAGEMENT Limited 
b. Street 1
Iron Trades House 
Street 2
21 Grosvenor Place 
c. City
London 
d. State, if applicable
 
e. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
f. Zip code and zip code extension, or foreign postal code
SW1X 7HN 
g. Telephone number (including country code if foreign)
44-20-7150-3700 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 37
a. Name of person (e.g., a custodian of records)
PANAGORA ASSET MANAGEMENT, Inc. 
b. Street 1
470 Atlantic Ave 
Street 2
8th Floor 
c. City
Boston 
d. State, if applicable
MASSACHUSETTS  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
2210 
g. Telephone number (including country code if foreign)
617-439-6300 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 38
a. Name of person (e.g., a custodian of records)
AXIOM INTERNATIONAL Investors LLC 
b. Street 1
33 Benedict Place 
Street 2
2nd Floor 
c. City
Greenwich 
d. State, if applicable
CONNECTICUT  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
6830 
g. Telephone number (including country code if foreign)
NA 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 39
a. Name of person (e.g., a custodian of records)
Mar Vista Investment Partners, LLC 
b. Street 1
11150 Santa Monica Blvd 
Street 2
Suite 320 
c. City
Los Angeles 
d. State, if applicable
CALIFORNIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
90025 
g. Telephone number (including country code if foreign)
NA 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 40
a. Name of person (e.g., a custodian of records)
QUANTITATIVE MANAGEMENT Associates LLC 
b. Street 1
Gateway Center 2 
Street 2
McCarter Highway and Market Street 
c. City
Newark 
d. State, if applicable
NEW JERSEY  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
7102 
g. Telephone number (including country code if foreign)
866-748-0643 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 41
a. Name of person (e.g., a custodian of records)
McKinley Capital Management, LLC 
b. Street 1
300 South Wacker Drive 
Street 2
Suite 1610 
c. City
Chicago 
d. State, if applicable
ILLINOIS  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
60606 
g. Telephone number (including country code if foreign)
NA 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 42
a. Name of person (e.g., a custodian of records)
BlackRock Advisors, LLC 
b. Street 1
100 Bellevue Parkway 
Street 2
 
c. City
Wilmington 
d. State, if applicable
DELAWARE  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
19809 
g. Telephone number (including country code if foreign)
800-441-7762 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 43
a. Name of person (e.g., a custodian of records)
Logan Circle Partners, L.P. 
b. Street 1
1717 Arch St #15 
Street 2
 
c. City
Philadelphia 
d. State, if applicable
PENNSYLVANIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
19103 
g. Telephone number (including country code if foreign)
267-330-0000 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 44
a. Name of person (e.g., a custodian of records)
GOLDMAN SACHS ASSET Management, L.P. 
b. Street 1
200 West St 
Street 2
 
c. City
New York 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
10282 
g. Telephone number (including country code if foreign)
212-902-1000 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 45
a. Name of person (e.g., a custodian of records)
Jennison Associates LLC 
b. Street 1
466 Lexington Ave 
Street 2
 
c. City
New York 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
10017 
g. Telephone number (including country code if foreign)
212-421-1000 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 46
a. Name of person (e.g., a custodian of records)
Parametric Portfolio Associates, LLC 
b. Street 1
1918 Eighth Avenue 
Street 2
Suite 3100 
c. City
Seattle 
d. State, if applicable
WASHINGTON  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
98101 
g. Telephone number (including country code if foreign)
206-694-5575 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 47
a. Name of person (e.g., a custodian of records)
CENTER SQUARE INVESTMENT Management Inc. 
b. Street 1
630 W. Germantown Pike 
Street 2
Suite 300 
c. City
Plymouth Meeting 
d. State, if applicable
PENNSYLVANIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
19462 
g. Telephone number (including country code if foreign)
610-834-9500 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 48
a. Name of person (e.g., a custodian of records)
SEI INVESTMENT MANAGEMENT Corporation 
b. Street 1
1 Freedom Valley Drive 
Street 2
 
c. City
OAKS 
d. State, if applicable
PENNSYLVANIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
19456 
g. Telephone number (including country code if foreign)
610-676-1000 
h. Briefly describe the books and records kept at this location:
Records as Adviser for Trust 
Location books Record: 49
a. Name of person (e.g., a custodian of records)
SEI Institutional Transfer Agent, Inc. 
b. Street 1
1 Freedom Valley Drive 
Street 2
 
c. City
OAKS 
d. State, if applicable
PENNSYLVANIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
19456 
g. Telephone number (including country code if foreign)
610-676-1000 
h. Briefly describe the books and records kept at this location:
Records as Transfer Agent for Trust 
Location books Record: 50
a. Name of person (e.g., a custodian of records)
WELLS CAPITAL MANAGEMENT, Inc 
b. Street 1
525 Market Street 
Street 2
10th Floor 
c. City
San Francisco 
d. State, if applicable
CALIFORNIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
94105 
g. Telephone number (including country code if foreign)
415-396-8000 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 51
a. Name of person (e.g., a custodian of records)
MOUNTAINEER PARTNERS Management, LLC 
b. Street 1
150 East 58th Street 14th Floor 
Street 2
 
c. City
New York 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
10155 
g. Telephone number (including country code if foreign)
NA 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 52
a. Name of person (e.g., a custodian of records)
CARDINAL CAPITAL MANAGEMENT, L.L.C. 
b. Street 1
Four Greenwich Office Park 
Street 2
 
c. City
Greenwich 
d. State, if applicable
CONNECTICUT  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
6831 
g. Telephone number (including country code if foreign)
203-863-8990 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 53
a. Name of person (e.g., a custodian of records)
Caerus Investors, LLC 
b. Street 1
599 Lexington Avenue 
Street 2
 
c. City
New York 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
10022 
g. Telephone number (including country code if foreign)
NA 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 54
a. Name of person (e.g., a custodian of records)
LSV Asset Management 
b. Street 1
155 N. Wacker Drive 
Street 2
 
c. City
Chicago 
d. State, if applicable
ILLINOIS  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
60606 
g. Telephone number (including country code if foreign)
312-460-2443 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 55
a. Name of person (e.g., a custodian of records)
METROPOLITAN WEST Asset Management LLC 
b. Street 1
865 S. Figueroa Street 
Street 2
Suite 1800 
c. City
Los Angeles 
d. State, if applicable
CALIFORNIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
90017 
g. Telephone number (including country code if foreign)
213-244-1050 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 56
a. Name of person (e.g., a custodian of records)
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
b. Street 1
1 Freedom Valley Drive 
Street 2
 
c. City
OAKS 
d. State, if applicable
PENNSYLVANIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
19456 
g. Telephone number (including country code if foreign)
610-676-1000 
h. Briefly describe the books and records kept at this location:
Records as Administrator for Trust 
Location books Record: 57
a. Name of person (e.g., a custodian of records)
T. Rowe Price Associates, Inc. 
b. Street 1
100 East Pratt St 
Street 2
 
c. City
Baltimore 
d. State, if applicable
MARYLAND  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
21202 
g. Telephone number (including country code if foreign)
NA 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 58
a. Name of person (e.g., a custodian of records)
Snow Capital Management 
b. Street 1
2000 Georgetowne Drive, Suite 200 
Street 2
 
c. City
Sewickley 
d. State, if applicable
PENNSYLVANIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
15143 
g. Telephone number (including country code if foreign)
724-934-5800 
h. Briefly describe the books and records kept at this location:
Records as Sub-Adviser for Trust 
Location books Record: 59
a. Name of person (e.g., a custodian of records)
Fred Alger Management, LLC. 
b. Street 1
360 Park Avenue South 
Street 2
 
c. City
New York 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
10010 
g. Telephone number (including country code if foreign)
212-806-8800 
h. Briefly describe the books and records kept at this location:
Records as sub-advisor for Trust 
Location books Record: 60
a. Name of person (e.g., a custodian of records)
Copeland Capital Management, LLC 
b. Street 1
8th Tower Bridge 161 Washington Street 
Street 2
Suite 1325 
c. City
Conshohocken 
d. State, if applicable
PENNSYLVANIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
19428 
g. Telephone number (including country code if foreign)
484-351-3700 
h. Briefly describe the books and records kept at this location:
Records as sub-advisor for Trust 
Location books Record: 61
a. Name of person (e.g., a custodian of records)
361 Capital LLC 
b. Street 1
4600 South Syracuse St 
Street 2
Suite 500 
c. City
Denver 
d. State, if applicable
COLORADO  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
80237 
g. Telephone number (including country code if foreign)
303-224-3900 
h. Briefly describe the books and records kept at this location:
Records as sub-advisor for Trust 
Location books Record: 62
a. Name of person (e.g., a custodian of records)
Martingale Asset Management, L.P. 
b. Street 1
888 Boylston Street Suite 1400 
Street 2
 
c. City
Boston 
d. State, if applicable
MASSACHUSETTS  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
2199 
g. Telephone number (including country code if foreign)
617-424-4700 
h. Briefly describe the books and records kept at this location:
Records as sub-advisor for Trust 
Location books Record: 63
a. Name of person (e.g., a custodian of records)
Hillsdale Investment Management Inc. 
b. Street 1
1 First Canadian Place 
Street 2
100 King Street West Suite 5900 
c. City
Toronto 
d. State, if applicable
 
e. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
f. Zip code and zip code extension, or foreign postal code
M5X 1E4 
g. Telephone number (including country code if foreign)
416-913-3900 
h. Briefly describe the books and records kept at this location:
Records as sub-advisor for Trust 

Item B.4. Initial of final filings.

Instruction. Respond "yes" to Item B.4.b only if the Registrant has filed an application to deregister or will file an application to deregister before its next required filing on this form.
a. Is this the first filing on this form by the Registrant? Radio button not checked Yes Radio button checked No
b. Is this the last filing on this form by the Registrant? Radio button not checked Yes Radio button checked No

Item B.5. Family of investment companies.

Instruction. "Family of investment companies" means, except for insurance company separate accounts, any two or more registered investment companies that (i) share the same investment adviser or principal underwriter; and (ii) hold themselves out to investors as related companies for purposes of investment and investor services.In responding to this item, all Registrants in the family of investment companies should report the name of the family of investment companies identically.
Insurance company separate accounts that may not hold themselves out to investors as related companies (products) for purposes of investment and investor services should consider themselves part of the same family if the operational or accounting or control systems under which these entities function are substantially similar.
a. Is the Registrant part of a family of investment companies? Radio button checked Yes Radio button not checked No
i. Full name of family of investment companies
SEI Funds 

Item B.6. Organization.

Instruction. For Item B.6.a.i., the Registrant should include all Series that have been established by the Registrant and have shares outstanding (other than shares issued in connection with an initial investment to satisfy section 14(a) of the Act).
Indicate the classification of the Registrant by checking the applicable item below.
Checkbox checked  a. Open-end management investment company registered under the Act on Form N-1A 
Checkbox not checked  b. Closed-end management investment company registered under the Act on Form N-2  
Checkbox not checked  c. Separate account offering variable annuity contracts which is registered under the Act as a management investment company on Form N-3 
Checkbox not checked  d. Separate account offering variable annuity contracts which is registered under the Act as a unit investment trust on Form N-4 
Checkbox not checked  e. Small business investment company registered under the Act on Form N-5 
Checkbox not checked  f. Separate account offering variable insurance contracts which is registered under the Act as a unit investment trust on Form N-6 
Checkbox not checked  g. Unit investment trust registered under the Act on Form N-8B-2 
i. Total number of Series of the Registrant
27 
ii. If a Series of the Registrant with a fiscal year end covered by the report was terminated during the reporting period, provide the following information:
Terminated Organization Record: 1
i. Name of the Series
SIMT Long Short Alternative Fund 
ii. Series identification number
S000047600 
iii. Date of termination (month/year)
09/2019 
ii. If a Series of the Registrant with a fiscal year end covered by the report was terminated during the reporting period, provide the following information:
Terminated Organization Record: 2
i. Name of the Series
SIMT Enhanced Income Fund 
ii. Series identification number
S000010829 
iii. Date of termination (month/year)
05/2019 

Item B.7. Securities Act registration.

Is the Registrant the issuer of a class of securities registered under the Securities Act of 1933 ("Securities Act")? Radio button checked Yes Radio button not checked No

Item B.8. Directors.

Provide the information requested below about each person serving as director of the Registrant (management investment companies only):
Director Record: 1
a. Full Name
Hubert L. Harris, Jr. 
b. CRD number, if any
N/A 
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button not checked Yes Radio button checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
811-05601 
File Number Record: 2
File Number Record:
811-07257 
File Number Record: 3
File Number Record:
811-07445 
File Number Record: 4
File Number Record:
811-09025 
File Number Record: 5
File Number Record:
811-22480 
File Number Record: 6
File Number Record:
811-03447 
File Number Record: 7
File Number Record:
811-03451 
File Number Record: 8
File Number Record:
811-23015 
File Number Record: 9
File Number Record:
811-22862 
Director Record: 2
a. Full Name
Mitchell A. Johnson 
b. CRD number, if any
N/A 
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button not checked Yes Radio button checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
811-08572 
File Number Record: 2
File Number Record:
811-07257 
File Number Record: 3
File Number Record:
811-07102 
File Number Record: 4
File Number Record:
811-09025 
File Number Record: 5
File Number Record:
811-03447 
File Number Record: 6
File Number Record:
811-03451 
File Number Record: 7
File Number Record:
811-22862 
File Number Record: 8
File Number Record:
811-22480 
File Number Record: 9
File Number Record:
811-05601 
File Number Record: 10
File Number Record:
811-07445 
File Number Record: 11
File Number Record:
811-06400 
File Number Record: 12
File Number Record:
811-22838 
File Number Record: 13
File Number Record:
811-23015 
Director Record: 3
a. Full Name
William M. Doran 
b. CRD number, if any
N/A 
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button checked Yes Radio button not checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
811-22862 
File Number Record: 2
File Number Record:
811-03451 
File Number Record: 3
File Number Record:
811-07257 
File Number Record: 4
File Number Record:
811-03447 
File Number Record: 5
File Number Record:
811-05601 
File Number Record: 6
File Number Record:
811-23091 
File Number Record: 7
File Number Record:
811-23015 
File Number Record: 8
File Number Record:
811-07445 
File Number Record: 9
File Number Record:
811-22920 
File Number Record: 10
File Number Record:
811-22480 
File Number Record: 11
File Number Record:
811-09025 
File Number Record: 12
File Number Record:
811-21364 
File Number Record: 13
File Number Record:
811-07840 
Director Record: 4
a. Full Name
George J. Sullivan Jr. 
b. CRD number, if any
N/A 
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button not checked Yes Radio button checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
811-05601 
File Number Record: 2
File Number Record:
811-22107 
File Number Record: 3
File Number Record:
811-06400 
File Number Record: 4
File Number Record:
811-03447 
File Number Record: 5
File Number Record:
811-07445 
File Number Record: 6
File Number Record:
811-07257 
File Number Record: 7
File Number Record:
811-09025 
File Number Record: 8
File Number Record:
811-07102 
File Number Record: 9
File Number Record:
811-08572 
File Number Record: 10
File Number Record:
811-22862 
File Number Record: 11
File Number Record:
811-03451 
File Number Record: 12
File Number Record:
811-22480 
File Number Record: 13
File Number Record:
811-23015 
File Number Record: 14
File Number Record:
811-22838 
Director Record: 5
a. Full Name
Nina Lesavoy 
b. CRD number, if any
N/A 
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button not checked Yes Radio button checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
811-07445 
File Number Record: 2
File Number Record:
811-03447 
File Number Record: 3
File Number Record:
811-22862 
File Number Record: 4
File Number Record:
811-22480 
File Number Record: 5
File Number Record:
811-23015 
File Number Record: 6
File Number Record:
811-05601 
File Number Record: 7
File Number Record:
811-03451 
File Number Record: 8
File Number Record:
811-09025 
File Number Record: 9
File Number Record:
811-22107 
File Number Record: 10
File Number Record:
811-07257 
Director Record: 6
a. Full Name
Susan C. Cote 
b. CRD number, if any
N/A 
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button not checked Yes Radio button checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
811-23015 
File Number Record: 2
File Number Record:
811-09025 
File Number Record: 3
File Number Record:
811-22107 
File Number Record: 4
File Number Record:
811-03447 
File Number Record: 5
File Number Record:
811-05601 
File Number Record: 6
File Number Record:
811-07445 
File Number Record: 7
File Number Record:
811-22862 
File Number Record: 8
File Number Record:
811-22480 
File Number Record: 9
File Number Record:
811-03451 
File Number Record: 10
File Number Record:
811-07257 
Director Record: 7
a. Full Name
Robert A. Nesher 
b. CRD number, if any
N/A 
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button checked Yes Radio button not checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
811-06400 
File Number Record: 2
File Number Record:
811-23015 
File Number Record: 3
File Number Record:
811-22107 
File Number Record: 4
File Number Record:
811-22480 
File Number Record: 5
File Number Record:
811-07257 
File Number Record: 6
File Number Record:
811-07102 
File Number Record: 7
File Number Record:
811-05601 
File Number Record: 8
File Number Record:
811-03447 
File Number Record: 9
File Number Record:
811-22862 
File Number Record: 10
File Number Record:
811-22838 
File Number Record: 11
File Number Record:
811-09025 
File Number Record: 12
File Number Record:
811-07445 
File Number Record: 13
File Number Record:
811-08572 
File Number Record: 14
File Number Record:
811-03451 
Director Record: 8
a. Full Name
James B. Taylor 
b. CRD number, if any
N/A 
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button not checked Yes Radio button checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
811-09025 
File Number Record: 2
File Number Record:
811-07445 
File Number Record: 3
File Number Record:
811-05601 
File Number Record: 4
File Number Record:
811-03451 
File Number Record: 5
File Number Record:
811-03447 
File Number Record: 6
File Number Record:
811-22480 
File Number Record: 7
File Number Record:
811-22862 
File Number Record: 8
File Number Record:
811-07257 
File Number Record: 9
File Number Record:
811-23015 
Director Record: 9
a. Full Name
James M. Williams 
b. CRD number, if any
N/A 
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button not checked Yes Radio button checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
811-04786 
File Number Record: 2
File Number Record:
811-07445 
File Number Record: 3
File Number Record:
811-03447 
File Number Record: 4
File Number Record:
811-22480 
File Number Record: 5
File Number Record:
811-03451 
File Number Record: 6
File Number Record:
811-09025 
File Number Record: 7
File Number Record:
811-05601 
File Number Record: 8
File Number Record:
811-22862 
File Number Record: 9
File Number Record:
811-23015 
File Number Record: 10
File Number Record:
811-22107 
File Number Record: 11
File Number Record:
811-07257 

Item B.9. Chief compliance officer.

Provide the information requested below about each person serving as chief compliance officer of the Registrant for purposes of rule 38a-1 (17 CFR 270.38a- 1):
Chief compliance officer Record: 1
a. Full Name
Russell Emery 
b. CRD Number, if any
N/A 
c. Street Address 1
1 Freedom Valley Drive 
Street Address 2
 
d. City
Oaks 
e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Zip code and zip code extension, or foreign postal code
19456 
h. Telephone number (including country code if foreign)
XXXXXX 
i. Has the chief compliance officer changed since the last filing? Radio button not checked Yes Radio button checked No
If the chief compliance officer is compensated or employed by any person other than the Registrant, or an affiliated person of the Registrant, for providing chief compliance officer services, provide:
CCO employer Record: 1
i. Name of the person
N/A 
ii. Person's IRS Employer Identification Number
N/A 

Item B.10. Matters for security holder vote.

Instruction. Registrants registered on Forms N-3, N-4 or N-6, should respond "yes" to this Item only if security holder votes were solicited on contract-level matters.
Were any matters submitted by the Registrant for its security holders' vote during the reporting period? Radio button not checked Yes Radio button checked No

Item B.11. Legal proceeding.

Instruction. For purposes of this Item, the following proceedings should be described: (1) any bankruptcy, receivership or similar proceeding with respect to the Registrant or any of its significant subsidiaries; (2) any proceeding to which any director, officer or other affiliated person of the Registrant is a party adverse to the Registrant or any of its subsidiaries; and (3) any proceeding involving the revocation or suspension of the right of the Registrant to sell securities.
a. Have there been any material legal proceedings, other than routine litigation incidental to the business, to which the Registrant or any of its subsidiaries was a party or of which any of their property was the subject during the reporting period? Radio button not checked Yes Radio button checked No
b. Has any proceeding previously reported been terminated? Radio button not checked Yes Radio button checked No

Item B.12. Fidelity bond and insurance (management investment companies only).

a. Were any claims with respect to the Registrant filed under a fidelity bond (including, but not limited to, the fidelity insuring agreement of the bond) during the reporting period? Radio button not checked Yes Radio button checked No

Item B.13. Directors and officers/errors and omissions insurance (management investment companies only).

a. Are the Registrant's officers or directors covered in their capacities as officers or directors under any directors and officers/errors and omissions insurance policy owned by the Registrant or anyone else? Radio button checked Yes Radio button not checked No
i. If yes, were any claims filed under the policy during the reporting period with respect to the Registrant? Radio button not checked Yes Radio button checked No

Item B.14. Provision of financial support.

Instruction. For purposes of this Item, a provision of financial support includes any (1) capital contribution, (2) purchase of a security from a Money Market Fund in reliance on rule 17a-9 under the Act (17 CFR 270.17a-9), (3) purchase of any defaulted or devalued security at fair value reasonably intended to increase or stabilize the value or liquidity of the Registrant's portfolio, (4) execution of letter of credit or letter of indemnity, (5) capital support agreement (whether or not the Registrant ultimately received support), (6) performance guarantee, or (7) other similar action reasonably intended to increase or stabilize the value or liquidity of the Registrant's portfolio. Provision of financial support does not include any (1) routine waiver of fees or reimbursement of Registrant's expenses, (2) routine inter-fund lending, (3) routine inter-fund purchases of Registrant's shares, or (4) action that would qualify as financial support as defined above, that the board of directors has otherwise determined not to be reasonably intended to increase or stabilize the value or liquidity of the Registrant's portfolio.
Did an affiliated person, promoter, or principal underwriter of the Registrant, or an affiliated person of such a person, provide any form of financial support to the Registrant during the reporting period? Radio button not checked Yes Radio button checked No

Item B.15. Exemptive orders.

a. During the reporting period, did the Registrant rely on any orders from the Commission granting an exemption from one or more provisions of the Act, Securities Act or Exchange Act? Radio button checked Yes Radio button not checked No
Release number Record: 1
i. If yes, provide below the release number for each order
IC-21921 
Release number Record: 2
i. If yes, provide below the release number for each order
IC-26783 

Item B.16. Principal underwriters.

a. Provide the information requested below about each principal underwriter:
Principal underwriter Record: 1
i. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
ii. SEC file number (e.g., 8-)
8-27897 
iii. CRD number
000010690 
iv. LEI, if any
N/A 
v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the principal underwriter an affiliated person of the Registrant, or its investment adviser(s) or depositor? Radio button checked Yes Radio button not checked No
b. Have any principal underwriters been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item B.17. Independent public accountant.

Provide the following information about eachthe independent public accountant:
Public accountant Record: 1
a. Full Name
KPMG, LLP 
b. PCAOB Number
185 
c. LEI, if any
549300G1CEVDWVMRLW77 
d. State, if applicable
NEW YORK  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Has the independent public accountant changed since the last filing?Radio button not checked Yes Radio button checked No

Item B.18. Report on internal control (management investment companies only).

Instruction. Small business investment companies are not required to respond to this item.
For the reporting period, did an independent public accountant's report on internal control note any material weaknesses? Radio button not checked Yes Radio button checked No

Item B.19. Audit opinion.

For the reporting period, did an independent public accountant issue an opinion other than an unqualified opinion with respect to its audit of the Registrant's financial statements? Radio button not checked Yes Radio button checked No

Item B.20. Change in valuation methods.

Instruction. Responses to this item need not include changes to valuation techniques used for individual securities (e.g., changing from market approach to income approach for a private equity security). In responding to Item B.20.c., provide the applicable "asset type" category specified in Item C.4.a. of Form N-PORT. In responding to Item B.20.d., provide a brief description of the type of investments involved. If the change in valuation methods applies only to certain sub-asset types included in the response to Item B.20.c., please provide the sub-asset types in the response to Item B.20.d. The responses to Item B.20.c. and Item B.20.d. should be identical only if the change in valuation methods applies to all assets within that category.
Have there been material changes in the method of valuation (e.g., change from use of bid price to mid price for fixed income securities or change in trigger threshold for use of fair value factors on international equity securities) of the Registrant's assets during the reporting period? Radio button not checked Yes Radio button checked No

Item B.21. Change in accounting principles and practices.

Have there been any changes in accounting principles or practices, or any change in the method of applying any such accounting principles or practices, which will materially affect the financial statements filed or to be filed for the current year with the Commission and which has not been previously reported? Radio button not checked Yes Radio button checked No

Item B.22. Net asset value error corrections (open-end management investment companies only).

a. During the reporting period, were any payments made to shareholders or shareholder accounts reprocessed as a result of an error in calculating the Registrant's net asset value (or net asset value per share)? Radio button checked Yes Radio button not checked No
Payment error series info Record: 1
a. If yes, and to the extent the response relates only to certain series of the Registrant, indicate the series involved:
1. Series name
SIMT Multi-Asset Accumulation Fund 
2. Series identification number
S000035779 
Payment error series info Record: 2
a. If yes, and to the extent the response relates only to certain series of the Registrant, indicate the series involved:
1. Series name
SIMT Multi-Strategy Alternative Fund 
2. Series identification number
S000028026 
Payment error series info Record: 3
a. If yes, and to the extent the response relates only to certain series of the Registrant, indicate the series involved:
1. Series name
SIMT S&P 500 Index Fund 
2. Series identification number
S000018490 

Item B.23. Rule 19a-1 notice (management investment companies only).

During the reporting period, did the Registrant pay any dividend or make any distribution in the nature of a dividend payment, required to be accompanied by a written statement pursuant to section 19(a) of the Act (15 U.S.C. 80a-19(a)) and rule 19a-1 thereunder (17 CFR 270.19a-1)? Radio button not checked Yes Radio button checked No

N-CEN:Part C: Additional Questions for Management Investment Companies

General Instruction.

Management investment companies that offer multiple series must complete Part C as to each series separately, even if some information is the same for two or more series. To begin this section or add an additional series(s), click on the bar labeled "Add a New Series" below.
Management Investment Record: 1

Item C.1. Background information.

a. Full Name of the Fund

SIMT Conservative Income Fund 

b. Series identication number, if any

S000053394 

c. LEI

5493002XIJ6NU072HS98 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

2 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000167938 

iii. Ticker symbol, if any

COIYX 

Shares Outstanding Record: 2
i. Full name of Class
Class F 
ii. Class identification number, if any

C000167937 

iii. Ticker symbol, if any

COIAX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button not checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button not checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A 

g. Provide the net income from securities lending activities

N/A 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI Investments Management Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
BlackRock Advisors, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-47710 

iii. CRD number
000106614 
iv. LEI, if any

5493001LN9MRM6A35J74 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 7
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
i. Full name of broker
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Gross commissions paid by the Fund for the reporting period

b. Aggregate brokerage commissions paid by Fund during the reporting period:

0 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
WELLS FARGO SECURITIES 
ii. SEC file number

008-65876 

iii. CRD number
000126292 
iv. LEI, if any

VYVVCKR63DVZZN70PB21 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

5,798,972.66999999 

Principal Transactions Record: 2
i. Full name of dealer
BEDFORD SECURITIES, INC. 
ii. SEC file number

8-44300 

iii. CRD number
000029398 
iv. LEI, if any

N/A 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

7,999,577.78 

Principal Transactions Record: 3
i. Full name of dealer
RABOBANK SECURITIES 
ii. SEC file number

8-65525 

iii. CRD number
000122647 
iv. LEI, if any

254900FIE91QX3QICK79 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

7,997,480 

Principal Transactions Record: 4
i. Full name of dealer
ADVANCED CLEARING 
ii. SEC file number

8-16335 

iii. CRD number
000005633 
iv. LEI, if any

MRK678VXOI09YSSN8X19 

v. State, if applicable
NEBRASKA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

6,997,060 

Principal Transactions Record: 5
i. Full name of dealer
CIBC 
ii. SEC file number

N/A 

iii. CRD number
N/A 
iv. LEI, if any

2IGI19DL77OX0HC3ZE78 

v. State, if applicable
 
vi. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

4,500,000 

Principal Transactions Record: 6
i. Full name of dealer
NEW ALBION PARTNERS 
ii. SEC file number

8-65205 

iii. CRD number
000119518 
iv. LEI, if any

549300GK0HFBJTBOYG15 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

6,997,019.16999999 

Principal Transactions Record: 7
i. Full name of dealer
TORONTO DOMINION BANK 
ii. SEC file number

008-36747 

iii. CRD number
000018476 
iv. LEI, if any

SUVUFHICNZMP2WKHG940 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

5,498,876.83 

Principal Transactions Record: 8
i. Full name of dealer
BARCLAYS CAPITAL INC. 
ii. SEC file number

008-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

16,991,911.11 

Principal Transactions Record: 9
i. Full name of dealer
FAIRWAY SECURITIES, INC. 
ii. SEC file number

8-41027 

iii. CRD number
000024191 
iv. LEI, if any

N/A 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

5,999,675 

Principal Transactions Record: 10
i. Full name of dealer
TOYOTA MOTOR CREDIT 
ii. SEC file number

8-66961 

iii. CRD number
000135978 
iv. LEI, if any

Z2VZBHUMB7PWWJ63I008 

v. State, if applicable
TEXAS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

5,000,000 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

107,674,021.72 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

286,611,780.67 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 2

Item C.1. Background information.

a. Full Name of the Fund

SIMT Multi-Asset Inflation Managed Fund 

b. Series identication number, if any

S000035781 

c. LEI

VR4A14E2HCR37V0WEJ03 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

2 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147405 

iii. Ticker symbol, if any

SLFYX 

Shares Outstanding Record: 2
i. Full name of Class
Class F 
ii. Class identification number, if any

C000109626 

iii. Ticker symbol, if any

SIFAX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button checked Yes Radio button not checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button checked Yes Radio button not checked No
b. If yes, provide the following information:
Foreign Investments Record: 1
Full name of subsidiary
Inflation Commodity Strategy Subsidiary, Ltd. 
LEI of subsidiary, if any

N/A 


Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button not checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button not checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A 

g. Provide the net income from securities lending activities

N/A 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Columbia Management Investment Advisers, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-25943 

iii. CRD number
000108257 
iv. LEI, if any

6YVO3H2OUHJXER5SGR23 

v. State, if applicable
MASSACHUSETTS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
QS INVESTORS, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-70974 

iii. CRD number
000152688 
iv. LEI, if any

XYXE20K9DEB40ZT62J94 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 3
i. Full name
ALLIANCEBERNSTEIN, L.P 
ii. SEC file number ( e.g., 801- ), if applicable

801-56720 

iii. CRD number
000108477 
iv. LEI, if any

0JK55UGWSWNF3X7KLQ85 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 4
i. Full name
Credit Suisse Asset Management 
ii. SEC file number ( e.g., 801- ), if applicable

801-37170 

iii. CRD number
000106012 
iv. LEI, if any

5493008W2093UORD3V27 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
BROWN BROTHERS HARRIMAN & CO. 
ii. LEI, if any

5493006KMX1VFTPYPW14 

iii. State, if applicable
MASSACHUSETTS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 2
i. Full name
HSBC KOREA 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
KOREA (THE REPUBLIC OF)  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 3
i. Full name
HSBC MALAYS BERHAD 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
MALAYSIA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 4
i. Full name
HSBC PHILIPPINES 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
PHILIPPINES  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 5
i. Full name
HSBC INDIA 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
INDIA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 6
i. Full name
BANK OF TAIWAN 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
TAIWAN  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 7
i. Full name
CITIBANK DEL PERU 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
PERU  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 8
i. Full name
CITIBANK, N.A., SAO PAULO 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
BRAZIL  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
UBS SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

NA 

Description of other identifying number

NA 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 11
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
i. Full name of broker
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Gross commissions paid by the Fund for the reporting period

b. Aggregate brokerage commissions paid by Fund during the reporting period:

0 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
BNP PARIBAS 
ii. SEC file number

008-32682 

iii. CRD number
000015794 
iv. LEI, if any

RCNB6OTYUAMMP879YW96 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

48,336,059.8 

Principal Transactions Record: 2
i. Full name of dealer
NORTHERN CAPITAL ADVISORS 
ii. SEC file number

008-49130 

iii. CRD number
000040659 
iv. LEI, if any

254900ZANH7XTB94LS53 

v. State, if applicable
MASSACHUSETTS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

32,497,305.76 

Principal Transactions Record: 3
i. Full name of dealer
JP MORGAN 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

473,166,857.09 

Principal Transactions Record: 4
i. Full name of dealer
CHASE SECURITIES, INC. 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

1,203,145,750.7 

Principal Transactions Record: 5
i. Full name of dealer
GOLDMAN, SACHS & CO. 
ii. SEC file number

008-00129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
UTAH  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

97,885,781.36 

Principal Transactions Record: 6
i. Full name of dealer
MERRILL LYNCH, PIERCE, FENNER & SMITH 
ii. SEC file number

008-07221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

57,076,585.57 

Principal Transactions Record: 7
i. Full name of dealer
UBS SECURITIES LLC 
ii. SEC file number

008-22651 

iii. CRD number
000007654 
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

36,251,604.71 

Principal Transactions Record: 8
i. Full name of dealer
MORGAN STANLEY & CO, INC 
ii. SEC file number

008-15869 

iii. CRD number
000008209 
iv. LEI, if any

9R7GPTSO7KV3UQJZQ078 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

34,815,606.61 

Principal Transactions Record: 9
i. Full name of dealer
MONTGOMERY/BANK OF AMERICA 
ii. SEC file number

008-69787 

iii. CRD number
000283942 
iv. LEI, if any

549300HN4UKV1E2R3U73 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

78,136,680.07 

Principal Transactions Record: 10
i. Full name of dealer
STANDARD CHARTERED BANK 
ii. SEC file number

N/A 

iii. CRD number
N/A 
iv. LEI, if any

RILFO74KP1CM8P6PCT96 

v. State, if applicable
 
vi. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

287,322,682.35 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

2,509,454,863.1 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

870,821,728.26674 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 3

Item C.1. Background information.

a. Full Name of the Fund

SIMT Small Cap Fund 

b. Series identication number, if any

S000026001 

c. LEI

7EXRUFK4XBML0EXVTI68 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

2 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147401 

iii. Ticker symbol, if any

SMYFX 

Shares Outstanding Record: 2
i. Full name of Class
Class F 
ii. Class identification number, if any

C000078067 

iii. Ticker symbol, if any

SLLAX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
Securities Finance Trust Company 
ii. LEI, if any

549300TG9E1QX4XYSB91 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
SEI Investments Management Corporation 
ii. LEI, if any:

Q33VOZOFSDXYC0TV0J12 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox not checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

24,434,427.03000000 

g. Provide the net income from securities lending activities

251,624.02847323 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Parametric Portfolio Associates, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-60485 

iii. CRD number
000114310 
iv. LEI, if any

549300S4WU4W1Z92RF77 

v. State, if applicable
WASHINGTON  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
Snow Capital Management 
ii. SEC file number ( e.g., 801- ), if applicable

801-37238 

iii. CRD number
000106516 
iv. LEI, if any

N/A 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 3
i. Full name
Rice Hall James & Associates, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-61905 

iii. CRD number
000125410 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 4
i. Full name
EAM Investors LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-70305 

iii. CRD number
000144908 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 5
i. Full name
AQR Capital Management, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-55543 

iii. CRD number
000111883 
iv. LEI, if any

549300GC5MDF1KXYMP06 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 6
i. Full name
LMCG Investments, Inc. 
ii. SEC file number ( e.g., 801- ), if applicable

801-70357 

iii. CRD number
000149936 
iv. LEI, if any

54930043E7LYHQYMV608 

v. State, if applicable
MASSACHUSETTS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 7
i. Full name
Falcon Point Capital, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-61442 

iii. CRD number
000122459 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 8
i. Full name
Copeland Capital Management, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-68586 

iii. CRD number
000135822 
iv. LEI, if any

549300F580MX332YTG45 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button checked Yes Radio button not checked No
1. If the sub-adviser was hired during the period, indicate the sub-adviser's start date:

2018-12-06 

d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
SubAdvisors Terminated Record: 1
i. Full name
AQR Capital Management, LLC 
ii. SEC file number ( e.g., 801- )

801-55543 

iii. CRD number
000111883 
iv. LEI, if any

549300GC5MDF1KXYMP06 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Termination date

2018-12-04 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 3
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
WELLS FARGO BANK 
ii. LEI, if any, or provide and describe other identifying number

KB1H1DSPRFMYMCUFXT09 

Description of other identifying number

 

iii. State, if applicable
NORTH CAROLINA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
J.P. MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

N/A 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 14
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
INSTINET CLEARING SERVICES, INC. 
ii. SEC file number

008-23669 

iii. CRD number
000007897 
iv. LEI, if any

549300MGMN3RKMU8FT57 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

18,146.14 

Brokers Record: 2
i. Full name of broker
UBS SECURITIES LLC 
ii. SEC file number

008-22651 

iii. CRD number
000007654 
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

19,182.01999999 

Brokers Record: 3
i. Full name of broker
WEEDEN & COMPANY 
ii. SEC file number

008-37267 

iii. CRD number
000016835 
iv. LEI, if any

549300OYBLKSN8M8EW67 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

76,117.00999999 

Brokers Record: 4
i. Full name of broker
RBC DAIN RAUSCHER INC. 
ii. SEC file number

008-45411 

iii. CRD number
000031194 
iv. LEI, if any

549300LCO2FLSSVFFR64 

v. State, if applicable
MINNESOTA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

13,954.77 

Brokers Record: 5
i. Full name of broker
ITG 
ii. SEC file number

008-44218 

iii. CRD number
000029299 
iv. LEI, if any

549300S41SMIODVIT266 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

35,368.42 

Brokers Record: 6
i. Full name of broker
LOOP CAPITAL 
ii. SEC file number

008-50140 

iii. CRD number
000043098 
iv. LEI, if any

254900FPPM2WN90D4786 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

26,790.02 

Brokers Record: 7
i. Full name of broker
JONES & ASSOCIATES 
ii. SEC file number

8-26089 

iii. CRD number
000006888 
iv. LEI, if any

N/A 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

3,304.74 

Brokers Record: 8
i. Full name of broker
JP MORGAN - OLD BEAR STEARNS 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

15,778.61 

Brokers Record: 9
i. Full name of broker
CREDIT SUISSE FIRST BOSTON LLC. 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

3,126.92 

Brokers Record: 10
i. Full name of broker
JEFFERIES LLC 
ii. SEC file number

008-15074 

iii. CRD number
000002347 
iv. LEI, if any

58PU97L1C0WSRCWADL48 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

48,238.78 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

265,490.3 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

618,854,056.888329 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 4

Item C.1. Background information.

a. Full Name of the Fund

SIMT Large Cap Value Fund 

b. Series identication number, if any

S000006674 

c. LEI

BR7X1WYLZTTJJGHBQS37 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class F 
ii. Class identification number, if any

C000018198 

iii. Ticker symbol, if any

TRMVX 

Shares Outstanding Record: 2
i. Full name of Class
Class I 
ii. Class identification number, if any

C000018197 

iii. Ticker symbol, if any

SEUIX 

Shares Outstanding Record: 3
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147390 

iii. Ticker symbol, if any

SVAYX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
Securities Finance Trust Company 
ii. LEI, if any

549300TG9E1QX4XYSB91 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
SEI Investments Management Corporation 
ii. LEI, if any:

Q33VOZOFSDXYC0TV0J12 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox not checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

6,320,397.25000000 

g. Provide the net income from securities lending activities

107,785.58290673 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENTS MANAGEMENT CORPORATION 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Parametric Portfolio Associates, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-60485 

iii. CRD number
000114310 
iv. LEI, if any

549300S4WU4W1Z92RF77 

v. State, if applicable
WASHINGTON  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
LSV ASSET MANAGEMENT 
ii. SEC file number ( e.g., 801- ), if applicable

801-47689 

iii. CRD number
000109918 
iv. LEI, if any

EOAQF6H83OMJLRM1LZ09 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button checked Yes Radio button not checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 3
i. Full name
AQR CAPITAL MANAGEMENT, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-55543 

iii. CRD number
000111883 
iv. LEI, if any

549300GC5MDF1KXYMP06 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 4
i. Full name
Schafer Cullen Capital Management, Inc. 
ii. SEC file number ( e.g., 801- ), if applicable

801-18407 

iii. CRD number
000105799 
iv. LEI, if any

6354006MUUWYCDHNAA37 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 5
i. Full name
Brandywine Global Investment Management LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-27797 

iii. CRD number
000110783 
iv. LEI, if any

8GTBE30G9EQQ2JEJZ302 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
SAFRA SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

E51AOUORNWWT747CBW71 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

NA 

Description of other identifying number

NA 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
WELLS FARGO BANK 
ii. LEI, if any, or provide and describe other identifying number

KB1H1DSPRFMYMCUFXT09 

Description of other identifying number

 

iii. State, if applicable
NORTH CAROLINA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 14
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 15
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

008-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
CREDIT SUISSE FIRST BOSTON LLC. 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

7,443.57 

Brokers Record: 2
i. Full name of broker
J.P. MORGAN SECURITIES 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

6,049.1 

Brokers Record: 3
i. Full name of broker
RBC DAIN RAUSCHER INC. 
ii. SEC file number

008-45411 

iii. CRD number
000031194 
iv. LEI, if any

549300LCO2FLSSVFFR64 

v. State, if applicable
MINNESOTA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

9,442 

Brokers Record: 4
i. Full name of broker
JEFFERIES LLC 
ii. SEC file number

008-15074 

iii. CRD number
000002347 
iv. LEI, if any

58PU97L1C0WSRCWADL48 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

37,836.87 

Brokers Record: 5
i. Full name of broker
ITG 
ii. SEC file number

008-44218 

iii. CRD number
000029299 
iv. LEI, if any

549300S41SMIODVIT266 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

11,178.79 

Brokers Record: 6
i. Full name of broker
JP MORGAN - OLD BEAR STEARNS 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

8,618.77 

Brokers Record: 7
i. Full name of broker
WEEDEN & COMPANY 
ii. SEC file number

008-37267 

iii. CRD number
000016835 
iv. LEI, if any

549300OYBLKSN8M8EW67 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

16,069.22 

Brokers Record: 8
i. Full name of broker
UBS SECURITIES LLC 
ii. SEC file number

008-22651 

iii. CRD number
000007654 
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

7,369.74 

Brokers Record: 9
i. Full name of broker
INSTINET CLEARING SERVICES, INC. 
ii. SEC file number

008-23669 

iii. CRD number
000007897 
iv. LEI, if any

549300MGMN3RKMU8FT57 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

10,115.33 

Brokers Record: 10
i. Full name of broker
LOOP CAPITAL 
ii. SEC file number

008-50140 

iii. CRD number
000043098 
iv. LEI, if any

254900FPPM2WN90D4786 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

28,891 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

145,249.86 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

1,334,361,968.01964 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 5

Item C.1. Background information.

a. Full Name of the Fund

SIMT U.S. Managed Volatility Fund 

b. Series identication number, if any

S000006678 

c. LEI

TQAKQ5YQ7BHG3AN4SL54 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147394 

iii. Ticker symbol, if any

SUSYX 

Shares Outstanding Record: 2
i. Full name of Class
Class I 
ii. Class identification number, if any

C000036885 

iii. Ticker symbol, if any

SEVIX 

Shares Outstanding Record: 3
i. Full name of Class
Class F 
ii. Class identification number, if any

C000018203 

iii. Ticker symbol, if any

SVOAX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button not checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button not checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A 

g. Provide the net income from securities lending activities

N/A 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
LSV ASSET MANAGEMENT 
ii. SEC file number ( e.g., 801- ), if applicable

801-47689 

iii. CRD number
000109918 
iv. LEI, if any

EOAQF6H83OMJLRM1LZ09 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button checked Yes Radio button not checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
ANALYTIC INVESTORS, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-21122 

iii. CRD number
000104973 
iv. LEI, if any

549300B3H2IOO2L85I90 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
SAFRA SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

E51AOUORNWWT747CBW71 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
WELLS FARGO BANK 
ii. LEI, if any, or provide and describe other identifying number

KB1H1DSPRFMYMCUFXT09 

Description of other identifying number

 

iii. State, if applicable
NORTH CAROLINA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 10
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

NA 

Description of other identifying number

NA 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 14
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 15
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
INSTINET 
ii. SEC file number

008-23669 

iii. CRD number
000007897 
iv. LEI, if any

549300MGMN3RKMU8FT57 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

8,581.29999999 

Brokers Record: 2
i. Full name of broker
CREDIT SUISSE - FIRST BOSTON 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

23,972.88 

Brokers Record: 3
i. Full name of broker
MORGAN STANLEY & CO, INC 
ii. SEC file number

008-15869 

iii. CRD number
000008209 
iv. LEI, if any

9R7GPTSO7KV3UQJZQ078 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

18,541.32 

Brokers Record: 4
i. Full name of broker
GOLDMAN SACHS & CO 
ii. SEC file number

008-00129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
UTAH  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

6,859.58 

Brokers Record: 5
i. Full name of broker
MERRILL LYNCH MONEY MARKETS INC. 
ii. SEC file number

008-07221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

22,743.11 

Brokers Record: 6
i. Full name of broker
CITIGROUP 
ii. SEC file number

008-08177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

19,272.37 

Brokers Record: 7
i. Full name of broker
INVESTMENT TECHNOLOGY GROUP, INC. 
ii. SEC file number

008-44218 

iii. CRD number
000029299 
iv. LEI, if any

549300S41SMIODVIT266 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

16,666.55 

Brokers Record: 8
i. Full name of broker
J.P. MORGAN SECURITIES 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

6,494.95 

Brokers Record: 9
i. Full name of broker
WEEDEN & COMPANY 
ii. SEC file number

008-37267 

iii. CRD number
000016835 
iv. LEI, if any

549300OYBLKSN8M8EW67 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

30,051.5 

Brokers Record: 10
i. Full name of broker
UBS SECURITIES 
ii. SEC file number

008-22651 

iii. CRD number
000007654 
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

18,318.27 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

191,810.89 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

1,698,684,076.51912 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 6

Item C.1. Background information.

a. Full Name of the Fund

SIMT Real Return Fund 

b. Series identication number, if any

S000013604 

c. LEI

WBHL45U11OB3Z1HV2E14 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

2 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147397 

iii. Ticker symbol, if any

SRYRX 

Shares Outstanding Record: 2
i. Full name of Class
Class F 
ii. Class identification number, if any

C000036881 

iii. Ticker symbol, if any

SRAAX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button not checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button not checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A 

g. Provide the net income from securities lending activities

N/A 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
i. Full name
 
ii. SEC file number ( e.g., 801- ), if applicable

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button not checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button not checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

NA 

Description of other identifying number

NA 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

84-27897 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 14
i. Full name
NATIONAL FINANCIAL SVCS, LLC 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
i. Full name of broker
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Gross commissions paid by the Fund for the reporting period

b. Aggregate brokerage commissions paid by Fund during the reporting period:

0 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
BARCLAYS CAPITAL INC. FIXED INCOME 
ii. SEC file number

008-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

43,303,391.11 

Principal Transactions Record: 2
i. Full name of dealer
BNP PARIBAS 
ii. SEC file number

008-32682 

iii. CRD number
000015794 
iv. LEI, if any

RCNB6OTYUAMMP879YW96 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

1,083,894.45 

Principal Transactions Record: 3
i. Full name of dealer
CITIGROUP GLOBAL MARKETS 
ii. SEC file number

008-08177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

2,742,018.89 

Principal Transactions Record: 4
i. Full name of dealer
GOLDMAN, SACHS & CO. 
ii. SEC file number

008-00129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
UTAH  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

101,631,812.12 

Principal Transactions Record: 5
i. Full name of dealer
CHASE SECURITIES, INC. 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

12,074,242.13 

Principal Transactions Record: 6
i. Full name of dealer
CHASE/GREENWICH CAP 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

878,134.44 

Principal Transactions Record: 7
i. Full name of dealer
WACHOVIA SECURITIES, INC. 
ii. SEC file number

008-65876 

iii. CRD number
000126292 
iv. LEI, if any

VYVVCKR63DVZZN70PB21 

v. State, if applicable
NORTH CAROLINA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

1,309,599.15999999 

Principal Transactions Record: 8
i. Full name of dealer
HSBC 
ii. SEC file number

008-41562 

iii. CRD number
000019585 
iv. LEI, if any

CYYGQCGNHMHPSMRL3R97 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

7,103,859.14 

Principal Transactions Record: 9
i. Full name of dealer
SOCIETE GENERALE COWEN SECURITIES CORP. 
ii. SEC file number

008-40756 

iii. CRD number
000023857 
iv. LEI, if any

5493008QI0EFC5WBED75 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

7,146,814.16999999 

Principal Transactions Record: 10
i. Full name of dealer
MONTGOMERY/BANK OF AMERICA 
ii. SEC file number

008-69787 

iii. CRD number
000283942 
iv. LEI, if any

549300HN4UKV1E2R3U73 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

2,810,022.55 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

227,466,691.65 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

249,143,797.075973 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 7

Item C.1. Background information.

a. Full Name of the Fund

SIMT Tax-Managed Large Cap Fund 

b. Series identication number, if any

S000006676 

c. LEI

HVOIYDF2QGEPX6OCCC52 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

2 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class F 
ii. Class identification number, if any

C000018201 

iii. Ticker symbol, if any

TMLCX 

Shares Outstanding Record: 2
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147392 

iii. Ticker symbol, if any

STLYX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button checked Yes Radio button not checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
Securities Finance Trust Company 
ii. LEI, if any

549300TG9E1QX4XYSB91 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
SEI Investments Management Corporation 
ii. LEI, if any:

Q33VOZOFSDXYC0TV0J12 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox not checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

31,880,874.05999999 

g. Provide the net income from securities lending activities

156,494.87611020 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Coho Partners, Ltd. 
ii. SEC file number ( e.g., 801- ), if applicable

801-60111 

iii. CRD number
000111335 
iv. LEI, if any

N/A 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
Mar Vista Investment Partners, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-68369 

iii. CRD number
000144906 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 3
i. Full name
LSV Asset Management 
ii. SEC file number ( e.g., 801- ), if applicable

801-47689 

iii. CRD number
000109918 
iv. LEI, if any

EOAQF6H83OMJLRM1LZ09 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button checked Yes Radio button not checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 4
i. Full name
BlackRock Investment Management, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-56972 

iii. CRD number
000108928 
iv. LEI, if any

5493006MRTEZZ4S4CQ20 

v. State, if applicable
NEW JERSEY  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 5
i. Full name
SCHAFER CULLEN CAPITAL MANAGEMENT INC 
ii. SEC file number ( e.g., 801- ), if applicable

801-18407 

iii. CRD number
000105799 
iv. LEI, if any

6354006MUUWYCDHNAA37 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 6
i. Full name
Brandywine Global Investment Management, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-27797 

iii. CRD number
000110783 
iv. LEI, if any

8GTBE30G9EQQ2JEJZ302 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 7
i. Full name
Parametric Portfolio Associates LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-60485 

iii. CRD number
000114310 
iv. LEI, if any

549300S4WU4W1Z92RF77 

v. State, if applicable
WASHINGTON  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 8
i. Full name
Fiera Capital 
ii. SEC file number ( e.g., 801- ), if applicable

801-8948 

iii. CRD number
000113638 
iv. LEI, if any

5493005M9ILUC8ZKES86 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
SubAdvisors Terminated Record: 1
i. Full name
BlackRock Investment Management, LLC 
ii. SEC file number ( e.g., 801- )

801-56972 

iii. CRD number
000108928 
iv. LEI, if any

5493006MRTEZZ4S4CQ20 

v. State, if applicable
NEW JERSEY  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Termination date

2019-01-02 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
SAFRA SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

E51AOUORNWWT747CBW71 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 6
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
JEFFERIES LLC 
ii. SEC file number

008-15074 

iii. CRD number
000002347 
iv. LEI, if any

58PU97L1C0WSRCWADL48 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

38,490.99 

Brokers Record: 2
i. Full name of broker
PERSHING LLC 
ii. SEC file number

008-17574 

iii. CRD number
000007560 
iv. LEI, if any

ZI8Q1A8EI8LQFJNM0D94 

v. State, if applicable
NEW JERSEY  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

41,071.59999999 

Brokers Record: 3
i. Full name of broker
LOOP CAPITAL 
ii. SEC file number

008-50140 

iii. CRD number
000043098 
iv. LEI, if any

254900FPPM2WN90D4786 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

59,369.8 

Brokers Record: 4
i. Full name of broker
J.P. MORGAN SECURITIES 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

37,944.76 

Brokers Record: 5
i. Full name of broker
RBC DAIN RAUSCHER INC. 
ii. SEC file number

008-45411 

iii. CRD number
000031194 
iv. LEI, if any

549300LCO2FLSSVFFR64 

v. State, if applicable
MINNESOTA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

8,107.57 

Brokers Record: 6
i. Full name of broker
MERRILL LYNCH, PIERCE, FENNER & SMITH 
ii. SEC file number

008-07221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

3,348.44 

Brokers Record: 7
i. Full name of broker
ITG 
ii. SEC file number

008-44218 

iii. CRD number
000029299 
iv. LEI, if any

549300S41SMIODVIT266 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

36,741.69 

Brokers Record: 8
i. Full name of broker
CREDIT SUISSE FIRST BOSTON LLC. 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

2,425.03 

Brokers Record: 9
i. Full name of broker
WEEDEN & COMPANY 
ii. SEC file number

008-37267 

iii. CRD number
000016835 
iv. LEI, if any

549300OYBLKSN8M8EW67 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

133,436.82 

Brokers Record: 10
i. Full name of broker
INSTINET CLEARING SERVICES, INC. 
ii. SEC file number

008-23669 

iii. CRD number
000007897 
iv. LEI, if any

549300MGMN3RKMU8FT57 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

40,433.74 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

3,883,285,296.94359 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

3,883,285,296.94359 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 8

Item C.1. Background information.

a. Full Name of the Fund

SIMT Global Managed Volatility Fund 

b. Series identication number, if any

S000010830 

c. LEI

758HSR516L0TPUTIWG96 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147396 

iii. Ticker symbol, if any

SGLYX 

Shares Outstanding Record: 2
i. Full name of Class
Class I 
ii. Class identification number, if any

C000036887 

iii. Ticker symbol, if any

SGMIX 

Shares Outstanding Record: 3
i. Full name of Class
Class F 
ii. Class identification number, if any

C000030063 

iii. Ticker symbol, if any

SVTAX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button not checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button not checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A 

g. Provide the net income from securities lending activities

N/A 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI Investments Management Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
ANALYTIC INVESTORS LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-07082 

iii. CRD number
000104963 
iv. LEI, if any

Z3MU650ZFGLYFSRINB42 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
ACADIAN ASSET MANAGEMENT LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-28078 

iii. CRD number
000106609 
iv. LEI, if any

RQTOM0CI0L1JQEIRRN40 

v. State, if applicable
MASSACHUSETTS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
BROWN BROTHERS HARRIMAN & CO. 
ii. LEI, if any

5493006KMX1VFTPYPW14 

iii. State, if applicable
MASSACHUSETTS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 8
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

N/A 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
WELLS FARGO BANK 
ii. LEI, if any, or provide and describe other identifying number

KB1H1DSPRFMYMCUFXT09 

Description of other identifying number

 

iii. State, if applicable
NORTH CAROLINA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 14
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 15
i. Full name
SAFRA SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

E51AOUORNWWT747CBW71 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
JP MORGAN 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

31,944.80999999 

Brokers Record: 2
i. Full name of broker
GOLDMAN, SACHS & CO. 
ii. SEC file number

008-00129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
UTAH  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

46,541.67 

Brokers Record: 3
i. Full name of broker
MORGAN STANLEY & CO, INC 
ii. SEC file number

008-15869 

iii. CRD number
000008209 
iv. LEI, if any

9R7GPTSO7KV3UQJZQ078 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

21,332.46 

Brokers Record: 4
i. Full name of broker
WEEDEN & COMPANY 
ii. SEC file number

008-37267 

iii. CRD number
000016835 
iv. LEI, if any

549300OYBLKSN8M8EW67 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

16,966.84999999 

Brokers Record: 5
i. Full name of broker
SANFORD C. BERNSTEIN & CO., LLC 
ii. SEC file number

008-52942 

iii. CRD number
000104474 
iv. LEI, if any

549300I7JYZHT7D5CO04 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

15,696.91 

Brokers Record: 6
i. Full name of broker
CITIGROUP 
ii. SEC file number

008-08177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

16,184.44 

Brokers Record: 7
i. Full name of broker
INVESTMENT TECHNOLOGY GROUP, INC. 
ii. SEC file number

008-44218 

iii. CRD number
000029299 
iv. LEI, if any

549300S41SMIODVIT266 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

39,647.01999999 

Brokers Record: 8
i. Full name of broker
INSTINET 
ii. SEC file number

008-23669 

iii. CRD number
000007897 
iv. LEI, if any

549300MGMN3RKMU8FT57 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

49,926.01 

Brokers Record: 9
i. Full name of broker
NOMURA SECURITIES INTERNATIONAL, INC. 
ii. SEC file number

008-15255 

iii. CRD number
000004297 
iv. LEI, if any

OXTKY6Q8X53C9ILVV871 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

16,101.27 

Brokers Record: 10
i. Full name of broker
MERRILL LYNCH 
ii. SEC file number

008-07221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

18,758.14 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

358,723.58 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

1,294,994,483.03 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 9

Item C.1. Background information.

a. Full Name of the Fund

SIMT Large Cap Fund 

b. Series identication number, if any

S000026000 

c. LEI

CD2HEFSZXLPTY1EBMD82 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

2 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class F 
ii. Class identification number, if any

C000078064 

iii. Ticker symbol, if any

SLGAX 

Shares Outstanding Record: 2
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147400 

iii. Ticker symbol, if any

SLYCX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
Securities Finance Trust Company 
ii. LEI, if any

549300TG9E1QX4XYSB91 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
SEI Investments Management Corporation 
ii. LEI, if any:

Q33VOZOFSDXYC0TV0J12 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox not checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

31,065,716.78000000 

g. Provide the net income from securities lending activities

130,956.98489700 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Ceredex Value Advisors LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-68739 

iii. CRD number
000146023 
iv. LEI, if any

54930068N867YSPRX748 

v. State, if applicable
FLORIDA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
Mar Vista Investment Partners, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-68369 

iii. CRD number
000144906 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 3
i. Full name
Brandywine Global Investment Management LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-27797 

iii. CRD number
000110783 
iv. LEI, if any

8GTBE30G9EQQ2JEJZ302 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 4
i. Full name
LSV Asset Management 
ii. SEC file number ( e.g., 801- ), if applicable

801-47689 

iii. CRD number
000109918 
iv. LEI, if any

EOAQF6H83OMJLRM1LZ09 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button checked Yes Radio button not checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 5
i. Full name
Fiera Capital Inc. 
ii. SEC file number ( e.g., 801- ), if applicable

801-8948 

iii. CRD number
000113638 
iv. LEI, if any

5493005M9ILUC8ZKES86 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 6
i. Full name
Parametric Portfolio Associates, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-60485 

iii. CRD number
000114310 
iv. LEI, if any

549300S4WU4W1Z92RF77 

v. State, if applicable
WASHINGTON  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 7
i. Full name
BlackRock Investment Management, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-56972 

iii. CRD number
000108928 
iv. LEI, if any

5493006MRTEZZ4S4CQ20 

v. State, if applicable
NEW JERSEY  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 8
i. Full name
Coho Partners, Ltd. 
ii. SEC file number ( e.g., 801- ), if applicable

801-60111 

iii. CRD number
000111335 
iv. LEI, if any

N/A 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 9
i. Full name
Fred Alger Management, LLC. 
ii. SEC file number ( e.g., 801- ), if applicable

801-06709 

iii. CRD number
000106750 
iv. LEI, if any

549300DJT5ERKM01RD40 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button checked Yes Radio button not checked No
1. If the sub-adviser was hired during the period, indicate the sub-adviser's start date:

2018-12-18 

d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
SubAdvisors Terminated Record: 1
i. Full name
Fiera Capital Inc. 
ii. SEC file number ( e.g., 801- )

801-08948 

iii. CRD number
000113638 
iv. LEI, if any

5493005M9ILUC8ZKES86 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Termination date

2018-12-27 

SubAdvisors Terminated Record: 2
i. Full name
BlackRock Investment Management, LLC 
ii. SEC file number ( e.g., 801- )

801-56972 

iii. CRD number
000108928 
iv. LEI, if any

5493006MRTEZZ4S4CQ20 

v. State, if applicable
NEW JERSEY  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Termination date

2019-01-02 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
SEI Investments Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 4
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
SAFRA SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

E51AOUORNWWT747CBW71 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 14
i. Full name
WELLS FARGO BANK 
ii. LEI, if any, or provide and describe other identifying number

KB1H1DSPRFMYMCUFXT09 

Description of other identifying number

 

iii. State, if applicable
NORTH CAROLINA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 15
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
J.P. MORGAN SECURITIES 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

31,239.84 

Brokers Record: 2
i. Full name of broker
UBS SECURITIES LLC 
ii. SEC file number

008-22651 

iii. CRD number
000007654 
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

21,839.52 

Brokers Record: 3
i. Full name of broker
PERSHING LLC 
ii. SEC file number

008-17574 

iii. CRD number
000007560 
iv. LEI, if any

ZI8Q1A8EI8LQFJNM0D94 

v. State, if applicable
NEW JERSEY  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

9,798.79999999 

Brokers Record: 4
i. Full name of broker
JEFFERIES LLC 
ii. SEC file number

008-15074 

iii. CRD number
000002347 
iv. LEI, if any

58PU97L1C0WSRCWADL48 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

61,437.44 

Brokers Record: 5
i. Full name of broker
INSTINET CLEARING SERVICES, INC. 
ii. SEC file number

008-23669 

iii. CRD number
000007897 
iv. LEI, if any

549300MGMN3RKMU8FT57 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

19,314.91999999 

Brokers Record: 6
i. Full name of broker
CREDIT SUISSE FIRST BOSTON LLC. 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

7,126.2 

Brokers Record: 7
i. Full name of broker
ITG 
ii. SEC file number

008-44218 

iii. CRD number
000029299 
iv. LEI, if any

549300S41SMIODVIT266 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

32,801.31 

Brokers Record: 8
i. Full name of broker
RBC DAIN RAUSCHER INC. 
ii. SEC file number

008-45411 

iii. CRD number
000031194 
iv. LEI, if any

549300LCO2FLSSVFFR64 

v. State, if applicable
MINNESOTA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

21,987.74 

Brokers Record: 9
i. Full name of broker
WEEDEN & COMPANY 
ii. SEC file number

008-37267 

iii. CRD number
000016835 
iv. LEI, if any

549300OYBLKSN8M8EW67 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

43,007.3 

Brokers Record: 10
i. Full name of broker
LOOP CAPITAL 
ii. SEC file number

008-50140 

iii. CRD number
000043098 
iv. LEI, if any

254900FPPM2WN90D4786 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

33,286.16 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

282,302.82999999 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

2,335,571,981.79498 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 10

Item C.1. Background information.

a. Full Name of the Fund

SIMT Tax-Managed Small/Mid Cap Fund 

b. Series identication number, if any

S000006677 

c. LEI

PHST7EBWWR1QHOOSSV69 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

2 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147393 

iii. Ticker symbol, if any

STMPX 

Shares Outstanding Record: 2
i. Full name of Class
Class F 
ii. Class identification number, if any

C000018202 

iii. Ticker symbol, if any

STMSX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
Securities Finance Trust Company 
ii. LEI, if any

549300TG9E1QX4XYSB91 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
SEI Investments Management Corporation 
ii. LEI, if any:

Q33VOZOFSDXYC0TV0J12 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox not checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

97,111,056.70000000 

g. Provide the net income from securities lending activities

321,810.31141288 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
CASTLEARK MANAGEMENT LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-56239 

iii. CRD number
000109587 
iv. LEI, if any

2549008PS4JNZDMVF460 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
Rice Hall James & Associates, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-61905 

iii. CRD number
000125410 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 3
i. Full name
AQR CAPITAL MANAGEMENT, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-55543 

iii. CRD number
000111883 
iv. LEI, if any

549300GC5MDF1KXYMP06 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 4
i. Full name
SNOW CAPITAL MANAGEMENT, L.P. 
ii. SEC file number ( e.g., 801- ), if applicable

801-37238 

iii. CRD number
000106516 
iv. LEI, if any

N/A 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 5
i. Full name
CARDINAL CAPITAL MANAGEMENT, L.L.C. 
ii. SEC file number ( e.g., 801- ), if applicable

801-49090 

iii. CRD number
000109824 
iv. LEI, if any

N/A 

v. State, if applicable
WISCONSIN  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 6
i. Full name
PARAMETRIC PORTFOLIO Associates LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-60485 

iii. CRD number
000114310 
iv. LEI, if any

549300S4WU4W1Z92RF77 

v. State, if applicable
WASHINGTON  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 7
i. Full name
Martingale Asset Management, L.P. 
ii. SEC file number ( e.g., 801- ), if applicable

801-30067 

iii. CRD number
000108526 
iv. LEI, if any

549300GXM5ZGZJXZ1Y74 

v. State, if applicable
MASSACHUSETTS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button checked Yes Radio button not checked No
1. If the sub-adviser was hired during the period, indicate the sub-adviser's start date:

2018-12-06 

Sub Advisors Record: 8
i. Full name
Hillsdale Investment Management Inc. 
ii. SEC file number ( e.g., 801- ), if applicable

801-65665 

iii. CRD number
000137883 
iv. LEI, if any

549300KFIUFNDF5RLX60 

v. State, if applicable
 
vi. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button checked Yes Radio button not checked No
1. If the sub-adviser was hired during the period, indicate the sub-adviser's start date:

2018-12-06 

d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
SubAdvisors Terminated Record: 1
i. Full name
AQR Capital Management, LLC 
ii. SEC file number ( e.g., 801- )

801-55543 

iii. CRD number
000111883 
iv. LEI, if any

549300GC5MDF1KXYMP06 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Termination date

2018-12-04 

SubAdvisors Terminated Record: 2
i. Full name
CastleArk Management LLC 
ii. SEC file number ( e.g., 801- )

801-56239 

iii. CRD number
000109587 
iv. LEI, if any

2549008PS4JNZDMVF460 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Termination date

2018-12-04 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 4
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
SAFRA SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

E51AOUORNWWT747CBW71 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
J.P. MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
CANTOR FITZGERALD & CO. 
ii. SEC file number

008-00201 

iii. CRD number
000000134 
iv. LEI, if any

5493004J7H4GCPG6OB62 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

2,646.13 

Brokers Record: 2
i. Full name of broker
JEFFERIES LLC 
ii. SEC file number

008-15074 

iii. CRD number
000002347 
iv. LEI, if any

58PU97L1C0WSRCWADL48 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

87,580.11 

Brokers Record: 3
i. Full name of broker
CREDIT SUISSE FIRST BOSTON LLC. 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

9,264.46999999 

Brokers Record: 4
i. Full name of broker
UBS SECURITIES LLC 
ii. SEC file number

008-22651 

iii. CRD number
000007654 
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

7,504.44 

Brokers Record: 5
i. Full name of broker
JP MORGAN - OLD BEAR STEARNS 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

31,511.2 

Brokers Record: 6
i. Full name of broker
RBC DAIN RAUSCHER INC. 
ii. SEC file number

008-45411 

iii. CRD number
000031194 
iv. LEI, if any

549300LCO2FLSSVFFR64 

v. State, if applicable
MINNESOTA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

50,227.38 

Brokers Record: 7
i. Full name of broker
INSTINET CLEARING SERVICES, INC. 
ii. SEC file number

008-23669 

iii. CRD number
000007897 
iv. LEI, if any

549300MGMN3RKMU8FT57 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

20,095.79 

Brokers Record: 8
i. Full name of broker
LOOP CAPITAL 
ii. SEC file number

008-50140 

iii. CRD number
000043098 
iv. LEI, if any

254900FPPM2WN90D4786 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

53,865.53 

Brokers Record: 9
i. Full name of broker
WEEDEN & COMPANY 
ii. SEC file number

008-37267 

iii. CRD number
000016835 
iv. LEI, if any

549300OYBLKSN8M8EW67 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

137,998.9 

Brokers Record: 10
i. Full name of broker
ITG 
ii. SEC file number

008-44218 

iii. CRD number
000029299 
iv. LEI, if any

549300S41SMIODVIT266 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

60,563.95 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

463,922.92 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

870,549,020.393863 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 11

Item C.1. Background information.

a. Full Name of the Fund

SIMT Small Cap Value Fund 

b. Series identication number, if any

S000006672 

c. LEI

T7C5A2UXC3THVGJ1KG82 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147388 

iii. Ticker symbol, if any

SPVYX 

Shares Outstanding Record: 2
i. Full name of Class
Class I 
ii. Class identification number, if any

C000018194 

iii. Ticker symbol, if any

SMVIX 

Shares Outstanding Record: 3
i. Full name of Class
Class F 
ii. Class identification number, if any

C000018195 

iii. Ticker symbol, if any

SESVX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
Securities Finance Trust Company 
ii. LEI, if any

549300TG9E1QX4XYSB91 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
SEI Investments Management Corporation 
ii. LEI, if any:

Q33VOZOFSDXYC0TV0J12 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox not checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

22,004,431.53999999 

g. Provide the net income from securities lending activities

132,683.15760853 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
SNOW CAPITAL MANAGEMENT, L.P. 
ii. SEC file number ( e.g., 801- ), if applicable

801-37238 

iii. CRD number
000106516 
iv. LEI, if any

N/A 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
PARAMETRIC PORTFOLIO Associates LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-60485 

iii. CRD number
000114310 
iv. LEI, if any

549300S4WU4W1Z92RF77 

v. State, if applicable
WASHINGTON  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 3
i. Full name
CARDINAL CAPITAL MANAGEMENT, L.L.C. 
ii. SEC file number ( e.g., 801- ), if applicable

801-49090 

iii. CRD number
000109824 
iv. LEI, if any

N/A 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 4
i. Full name
LSV ASSET MANAGEMENT 
ii. SEC file number ( e.g., 801- ), if applicable

801-47689 

iii. CRD number
000109918 
iv. LEI, if any

EOAQF6H83OMJLRM1LZ09 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button checked Yes Radio button not checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 5
i. Full name
AQR CAPITAL MANAGEMENT, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-55543 

iii. CRD number
000111883 
iv. LEI, if any

549300GC5MDF1KXYMP06 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
SubAdvisors Terminated Record: 1
i. Full name
AQR Capital Management, LLC 
ii. SEC file number ( e.g., 801- )

801-55543 

iii. CRD number
000111883 
iv. LEI, if any

549300GC5MDF1KXYMP06 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Termination date

2018-12-04 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

N/A 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
SAFRA SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

E51AOUORNWWT747CBW71 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 11
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
WELLS FARGO BANK 
ii. LEI, if any, or provide and describe other identifying number

KB1H1DSPRFMYMCUFXT09 

Description of other identifying number

 

iii. State, if applicable
NORTH CAROLINA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 14
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 15
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
RBC DAIN RAUSCHER INC. 
ii. SEC file number

008-45411 

iii. CRD number
000031194 
iv. LEI, if any

549300LCO2FLSSVFFR64 

v. State, if applicable
MINNESOTA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

2,334.16 

Brokers Record: 2
i. Full name of broker
ITG 
ii. SEC file number

008-44218 

iii. CRD number
000029299 
iv. LEI, if any

549300S41SMIODVIT266 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

4,393.76 

Brokers Record: 3
i. Full name of broker
INSTINET CLEARING SERVICES, INC. 
ii. SEC file number

008-23669 

iii. CRD number
000007897 
iv. LEI, if any

549300MGMN3RKMU8FT57 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

14,863.67 

Brokers Record: 4
i. Full name of broker
CREDIT SUISSE FIRST BOSTON LLC. 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

1,197.40999999 

Brokers Record: 5
i. Full name of broker
CANTOR FITZGERALD & CO. 
ii. SEC file number

008-00201 

iii. CRD number
000000134 
iv. LEI, if any

5493004J7H4GCPG6OB62 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

312.43 

Brokers Record: 6
i. Full name of broker
J.P. MORGAN SECURITIES 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

26,356.3 

Brokers Record: 7
i. Full name of broker
WEEDEN & COMPANY 
ii. SEC file number

008-37267 

iii. CRD number
000016835 
iv. LEI, if any

549300OYBLKSN8M8EW67 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

18,793.37 

Brokers Record: 8
i. Full name of broker
UBS SECURITIES LLC 
ii. SEC file number

008-22651 

iii. CRD number
000007654 
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

11,446.59 

Brokers Record: 9
i. Full name of broker
LOOP CAPITAL 
ii. SEC file number

008-50140 

iii. CRD number
000043098 
iv. LEI, if any

254900FPPM2WN90D4786 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

9,567.04 

Brokers Record: 10
i. Full name of broker
JEFFERIES LLC 
ii. SEC file number

008-15074 

iii. CRD number
000002347 
iv. LEI, if any

58PU97L1C0WSRCWADL48 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

23,434.27 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

113,513.95 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

322,619,006.896658 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 12

Item C.1. Background information.

a. Full Name of the Fund

SIMT Multi-Asset Accumulation Fund 

b. Series identication number, if any

S000035779 

c. LEI

CVCNKSRMQ9EYZG6CF762 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

2 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class F 
ii. Class identification number, if any

C000109624 

iii. Ticker symbol, if any

SAAAX 

Shares Outstanding Record: 2
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147403 

iii. Ticker symbol, if any

SMOYX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button checked Yes Radio button not checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button checked Yes Radio button not checked No
b. If yes, provide the following information:
Foreign Investments Record: 1
Full name of subsidiary
Accumulation Commodity Strategy Subsidiary, Ltd. 
LEI of subsidiary, if any

N/A 


Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button not checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button not checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A 

g. Provide the net income from securities lending activities

N/A 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
PANAGORA ASSET MANAGEMENT, Inc. 
ii. SEC file number ( e.g., 801- ), if applicable

801-35497 

iii. CRD number
000105201 
iv. LEI, if any

2DVKF3E9IHIO1BZTN664 

v. State, if applicable
MASSACHUSETTS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
AQR CAPITAL MANAGEMENT, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-55543 

iii. CRD number
000111883 
iv. LEI, if any

549300GC5MDF1KXYMP06 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
BANCO DE CHILE 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
CHILE  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 2
i. Full name
HBME DIFC 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED ARAB EMIRATES  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 3
i. Full name
HSBC MALAYS BERHAD 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
MALAYSIA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 4
i. Full name
BROWN BROTHERS HARRIMAN & CO. 
ii. LEI, if any

5493006KMX1VFTPYPW14 

iii. State, if applicable
MASSACHUSETTS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 5
i. Full name
SCB (PAKISTAN) LTD 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
PAKISTAN  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 6
i. Full name
BANK OF TAIWAN 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
TAIWAN  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 7
i. Full name
STANBIC IBTC BK PLC 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
NIGERIA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 8
i. Full name
CITITRUST COLOMBIA 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
COLOMBIA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 9
i. Full name
HSBC KOREA 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
KOREA (THE REPUBLIC OF)  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 10
i. Full name
SCB (CHINA) LTD 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
CHINA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 11
i. Full name
CITIBANK, N.A., SAO PAULO 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
BRAZIL  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 12
i. Full name
CITIBANK DEL PERU 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
PERU  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 13
i. Full name
HSBC PHILIPPINES 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
PHILIPPINES  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 14
i. Full name
HSBC INDIA 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
INDIA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 15
i. Full name
CITIBANK CAIRO 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
EGYPT  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 16
i. Full name
HBME QATAR 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
QATAR  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

NA 

Description of other identifying number

NA 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
WELLS FARGO BANK 
ii. LEI, if any, or provide and describe other identifying number

KB1H1DSPRFMYMCUFXT09 

Description of other identifying number

 

iii. State, if applicable
NORTH CAROLINA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 11
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 14
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
i. Full name of broker
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Gross commissions paid by the Fund for the reporting period

b. Aggregate brokerage commissions paid by Fund during the reporting period:

0 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
BARCLAYS CAPITAL (DMA) 
ii. SEC file number

008-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

146,018,847.14 

Principal Transactions Record: 2
i. Full name of dealer
MERRILL LYNCH, PIERCE, FENNER & SMITH 
ii. SEC file number

008-07221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

108,523,254.34 

Principal Transactions Record: 3
i. Full name of dealer
MONTGOMERY/BANK OF AMERICA 
ii. SEC file number

008-69787 

iii. CRD number
000283942 
iv. LEI, if any

549300HN4UKV1E2R3U73 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

209,167,073.58 

Principal Transactions Record: 4
i. Full name of dealer
MORGAN STANLEY & CO, INC 
ii. SEC file number

008-15869 

iii. CRD number
000008209 
iv. LEI, if any

9R7GPTSO7KV3UQJZQ078 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

304,004,162.21 

Principal Transactions Record: 5
i. Full name of dealer
UBS SECURITIES LLC 
ii. SEC file number

008-22651 

iii. CRD number
000007654 
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

177,456,857.67 

Principal Transactions Record: 6
i. Full name of dealer
CITIGROUP/SALOMON SMITH BARNEY INC. 
ii. SEC file number

008-08177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

495,747,952.97 

Principal Transactions Record: 7
i. Full name of dealer
GOLDMAN, SACHS & CO. 
ii. SEC file number

008-00129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
UTAH  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

236,584,993.65 

Principal Transactions Record: 8
i. Full name of dealer
NOMURA SECURITIES INTERNATIONAL, INC. 
ii. SEC file number

008-15255 

iii. CRD number
000004297 
iv. LEI, if any

OXTKY6Q8X53C9ILVV871 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

143,523,673.33 

Principal Transactions Record: 9
i. Full name of dealer
SCOTIA CAPITAL (USA) INC. 
ii. SEC file number

008-03716 

iii. CRD number
000002739 
iv. LEI, if any

549300BLWPABP1VNME36 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

91,642,756.14 

Principal Transactions Record: 10
i. Full name of dealer
BONY/TORONTO DOMINION SECURITIES INC. 
ii. SEC file number

008-36747 

iii. CRD number
000018476 
iv. LEI, if any

SUVUFHICNZMP2WKHG940 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

617,056,975.77 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

3,777,572,743.27 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button checked Yes Radio button not checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

2,791,740,296.6218 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button checked Yes Radio button not checked No
If yes, for each loan provide the information requested below:
i. What was the average amount of the interfund loan when the loan was outstanding?
7,300,000 
ii. What was the number of days that the interfund loan was outstanding?
1 
i. What was the average amount of the interfund loan when the loan was outstanding?
6,000,000 
ii. What was the number of days that the interfund loan was outstanding?
3 
i. What was the average amount of the interfund loan when the loan was outstanding?
9,000,000 
ii. What was the number of days that the interfund loan was outstanding?
2 

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 13

Item C.1. Background information.

a. Full Name of the Fund

SIMT Large Cap Growth Fund 

b. Series identication number, if any

S000006671 

c. LEI

WGI7ZUQP5MRO14CT3729 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class F 
ii. Class identification number, if any

C000018193 

iii. Ticker symbol, if any

SELCX 

Shares Outstanding Record: 2
i. Full name of Class
Class I 
ii. Class identification number, if any

C000018192 

iii. Ticker symbol, if any

SPGIX 

Shares Outstanding Record: 3
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147387 

iii. Ticker symbol, if any

SLRYX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
Securities Finance Trust Company 
ii. LEI, if any

549300TG9E1QX4XYSB91 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
SEI Investments Management Corporation 
ii. LEI, if any:

Q33VOZOFSDXYC0TV0J12 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox not checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

12,387,358.36999999 

g. Provide the net income from securities lending activities

142,062.01759060 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
BlackRock Investment Management, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-56972 

iii. CRD number
000108928 
iv. LEI, if any

5493006MRTEZZ4S4CQ20 

v. State, if applicable
NEW JERSEY  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
McKinely Capital Management, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-38751 

iii. CRD number
000106173 
iv. LEI, if any

549300Q8IB2KWGTWCR28 

v. State, if applicable
ALASKA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 3
i. Full name
Fierra Capital 
ii. SEC file number ( e.g., 801- ), if applicable

801-8948 

iii. CRD number
000113638 
iv. LEI, if any

5493005M9ILUC8ZKES86 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 4
i. Full name
Parametric Portfolio Associates, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-60485 

iii. CRD number
000114310 
iv. LEI, if any

549300S4WU4W1Z92RF77 

v. State, if applicable
WASHINGTON  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 5
i. Full name
Fred Alger Management, LLC. 
ii. SEC file number ( e.g., 801- ), if applicable

801-06709 

iii. CRD number
000106750 
iv. LEI, if any

549300DJT5ERKM01RD40 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button checked Yes Radio button not checked No
1. If the sub-adviser was hired during the period, indicate the sub-adviser's start date:

2019-01-03 

d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
SubAdvisors Terminated Record: 1
i. Full name
BlackRock Investment Management, LLC 
ii. SEC file number ( e.g., 801- )

801-56972 

iii. CRD number
000108928 
iv. LEI, if any

5493006MRTEZZ4S4CQ20 

v. State, if applicable
NEW JERSEY  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Termination date

2019-01-02 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Tranfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
J.P. MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

NA 

Description of other identifying number

NA 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
SEI Investments Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 9
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
WELLS FARGO BANK 
ii. LEI, if any, or provide and describe other identifying number

KB1H1DSPRFMYMCUFXT09 

Description of other identifying number

 

iii. State, if applicable
NORTH CAROLINA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 14
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
J.P. MORGAN SECURITIES 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

7,316.76 

Brokers Record: 2
i. Full name of broker
INSTINET CLEARING SERVICES, INC. 
ii. SEC file number

008-23669 

iii. CRD number
000007897 
iv. LEI, if any

549300MGMN3RKMU8FT57 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

6,482.06 

Brokers Record: 3
i. Full name of broker
UBS SECURITIES LLC 
ii. SEC file number

008-22651 

iii. CRD number
000007654 
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

6,240.37 

Brokers Record: 4
i. Full name of broker
LOOP CAPITAL 
ii. SEC file number

008-50140 

iii. CRD number
000043098 
iv. LEI, if any

254900FPPM2WN90D4786 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

34,368.1 

Brokers Record: 5
i. Full name of broker
ITG 
ii. SEC file number

008-44218 

iii. CRD number
000029299 
iv. LEI, if any

549300S41SMIODVIT266 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

9,240.66 

Brokers Record: 6
i. Full name of broker
CREDIT SUISSE FIRST BOSTON LLC. 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

6,051.33999999 

Brokers Record: 7
i. Full name of broker
RBC DAIN RAUSCHER INC. 
ii. SEC file number

008-45411 

iii. CRD number
000031194 
iv. LEI, if any

549300LCO2FLSSVFFR64 

v. State, if applicable
MINNESOTA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

19,540.56 

Brokers Record: 8
i. Full name of broker
JEFFERIES LLC 
ii. SEC file number

008-15074 

iii. CRD number
000002347 
iv. LEI, if any

58PU97L1C0WSRCWADL48 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

29,682.86 

Brokers Record: 9
i. Full name of broker
WEEDEN & COMPANY 
ii. SEC file number

008-37267 

iii. CRD number
000016835 
iv. LEI, if any

549300OYBLKSN8M8EW67 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

33,695.26999999 

Brokers Record: 10
i. Full name of broker
JP MORGAN - OLD BEAR STEARNS 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

10,349.49 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

164,605.99 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

1,461,489,429.29203 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 14

Item C.1. Background information.

a. Full Name of the Fund

SIMT LARGE CAP INDEX FUND 

b. Series identication number, if any

S000061211 

c. LEI

549300DGG40F5X8EQL10 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

1 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class F 
ii. Class identification number, if any

C000198269 

iii. Ticker symbol, if any

SLGFX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox checked  Index Fund 
i. Is the index whose performance the Fund tracks, constructed:
1. By an affiliated person of the fund?Radio button not checked Yes Radio button checked No
2. Exclusively for the fund?Radio button not checked Yes Radio button checked No
ii. Provide the annualized difference between the Fund's total return during the reporting period and the index's return during the reporting period (i.e., the Fund's total return less the index's return):
1. Before Fund fees and expenses:
0 
2. After Fund fees and expenses (i.e., net asset value):
-0.26 
iii. Provide the annualized standard deviation of the daily difference between the Fund's total return and the index's return during the reporting period:
1. Before Fund fees and expenses:
0.648559421 
2. After Fund fees and expenses (i.e., net asset value):
0.648733319 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox not checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
Securities Finance Trust Company 
ii. LEI, if any

549300TG9E1QX4XYSB91 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
SEI Investments Management Corporation 
ii. LEI, if any:

Q33VOZOFSDXYC0TV0J12 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox not checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

214,880.35000000 

g. Provide the net income from securities lending activities

10,718.90314378 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
SSGA Funds Management, Inc. 
ii. SEC file number ( e.g., 801- ), if applicable

801-60103 

iii. CRD number
000111242 
iv. LEI, if any

FT3UGI3NU6B7EELQF380 

v. State, if applicable
MASSACHUSETTS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 2
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
INVESTMENT TECHNOLOGY GROUP, INC. 
ii. SEC file number

008-44218 

iii. CRD number
000029299 
iv. LEI, if any

549300S41SMIODVIT266 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

358.99 

Brokers Record: 2
i. Full name of broker
BANK OF AMERICA 
ii. SEC file number

008-69787 

iii. CRD number
000283942 
iv. LEI, if any

549300HN4UKV1E2R3U73 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

433.2 

Brokers Record: 3
i. Full name of broker
CREDIT SUISSE FIRST BOSTON LLC. 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

1,104.23 

Brokers Record: 4
i. Full name of broker
MORGAN STANLEY & CO, INC 
ii. SEC file number

008-15869 

iii. CRD number
000008209 
iv. LEI, if any

9R7GPTSO7KV3UQJZQ078 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

866.3 

Brokers Record: 5
i. Full name of broker
CITIGROUP GLOBAL MARKETS 
ii. SEC file number

008-08177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

3,056.01 

Brokers Record: 6
i. Full name of broker
MERRILL LYNCH, PIERCE, FENNER & SMITH 
ii. SEC file number

008-07221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

1,937.72 

Brokers Record: 7
i. Full name of broker
BARCLAYS CAPITAL INC. 
ii. SEC file number

008-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

1,378.08 

Brokers Record: 8
i. Full name of broker
BEAR STEARNS & CO INC. 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

802.85 

Brokers Record: 9
i. Full name of broker
UBS SECURITIES LLC 
ii. SEC file number

008-22651 

iii. CRD number
000007654 
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

1,452.8 

Brokers Record: 10
i. Full name of broker
GOLDMAN, SACHS & CO. 
ii. SEC file number

008-00129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
UTAH  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

1,144.22 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

13,790.84 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

316,095,550.261095 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 15

Item C.1. Background information.

a. Full Name of the Fund

SIMT Real Estate Fund 

b. Series identication number, if any

S000006669 

c. LEI

549300W7DJL1DMCXI543 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147385 

iii. Ticker symbol, if any

SREYX 

Shares Outstanding Record: 2
i. Full name of Class
Class F 
ii. Class identification number, if any

C000018189 

iii. Ticker symbol, if any

SETAX 

Shares Outstanding Record: 3
i. Full name of Class
Class I 
ii. Class identification number, if any

C000036883 

iii. Ticker symbol, if any

SEIRX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
Securities Finance Trust Company 
ii. LEI, if any

549300TG9E1QX4XYSB91 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
SEI Investments Management Corporation 
ii. LEI, if any:

Q33VOZOFSDXYC0TV0J12 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox not checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

413,434.96000000 

g. Provide the net income from securities lending activities

430.48000000 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
CENTER SQUARE INVESTMENT Management Inc. 
ii. SEC file number ( e.g., 801- ), if applicable

801-31359 

iii. CRD number
000106983 
iv. LEI, if any

549300472EWJAQJ5WO23 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

N/A 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 3
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
SAFRA SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

E51AOUORNWWT747CBW71 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
NATIONAL FINANCIAL SVCS, LLC 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
MASSACHUSETTS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
WELLS FARGO BANK 
ii. LEI, if any, or provide and describe other identifying number

KB1H1DSPRFMYMCUFXT09 

Description of other identifying number

 

iii. State, if applicable
NORTH CAROLINA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 14
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI Investments Distribution Co. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

10,396.66 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
STIFEL NICOLAUS & CO., INC. 
ii. SEC file number

008-01447 

iii. CRD number
000000793 
iv. LEI, if any

5WUVMA08EYG4KEUPW589 

v. State, if applicable
MISSOURI  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

6,793.06 

Brokers Record: 2
i. Full name of broker
MORGAN STANLEY & CO, INC 
ii. SEC file number

008-15869 

iii. CRD number
000008209 
iv. LEI, if any

9R7GPTSO7KV3UQJZQ078 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

11,757.69 

Brokers Record: 3
i. Full name of broker
MERRILL LYNCH 
ii. SEC file number

008-07221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

12,819.99 

Brokers Record: 4
i. Full name of broker
GOLDMAN SACHS & CO 
ii. SEC file number

008-00129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
UTAH  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

5,705.25 

Brokers Record: 5
i. Full name of broker
LIQUIDNET 
ii. SEC file number

008-52461 

iii. CRD number
000103987 
iv. LEI, if any

213800HSKBBO1GCVRG79 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

25,231.15 

Brokers Record: 6
i. Full name of broker
ITG 
ii. SEC file number

008-44218 

iii. CRD number
000029299 
iv. LEI, if any

549300S41SMIODVIT266 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

5,705.79999999 

Brokers Record: 7
i. Full name of broker
CITIGROUP 
ii. SEC file number

008-08177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

8,232.52 

Brokers Record: 8
i. Full name of broker
RAYMOND JAMES 
ii. SEC file number

008-10999 

iii. CRD number
000000705 
iv. LEI, if any

U4ONQX15J3RO8XCKE979 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

4,818.62 

Brokers Record: 9
i. Full name of broker
JP MORGAN 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

16,034.31 

Brokers Record: 10
i. Full name of broker
WACHOVIA SECURITIES, INC. 
ii. SEC file number

008-65876 

iii. CRD number
000126292 
iv. LEI, if any

VYVVCKR63DVZZN70PB21 

v. State, if applicable
NORTH CAROLINA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

11,218.57 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

146,959.72999999 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

132,236,335.087123 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 16

Item C.1. Background information.

a. Full Name of the Fund

SIMT High Yield Bond Fund 

b. Series identication number, if any

S000006673 

c. LEI

TBMZUQ3I44DXC0KQI298 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class F 
ii. Class identification number, if any

C000018196 

iii. Ticker symbol, if any

SHYAX 

Shares Outstanding Record: 2
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147389 

iii. Ticker symbol, if any

SIYYX 

Shares Outstanding Record: 3
i. Full name of Class
Class I 
ii. Class identification number, if any

C000036884 

iii. Ticker symbol, if any

SEIYX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
Securities Finance Trust Company 
ii. LEI, if any

549300TG9E1QX4XYSB91 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
SEI Investments Management Corporation 
ii. LEI, if any:

Q33VOZOFSDXYC0TV0J12 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A 

g. Provide the net income from securities lending activities

N/A 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI Investments Management Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
T. Rowe Price Associates, Inc. 
ii. SEC file number ( e.g., 801- ), if applicable

801-856 

iii. CRD number
000105496 
iv. LEI, if any

7HTL8AEQSEDX602FBU63 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
ARES MANAGEMENT LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-63800 

iii. CRD number
000130074 
iv. LEI, if any

3M096E5S0PEUTB0I8L53 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 3
i. Full name
J.P. MORGAN Investment Management Inc. 
ii. SEC file number ( e.g., 801- ), if applicable

801-21011 

iii. CRD number
000107038 
iv. LEI, if any

549300W78QHV4XMM6K69 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 4
i. Full name
BENEFIT STREET PARTNERS, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-72843 

iii. CRD number
000158672 
iv. LEI, if any

N/A 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 5
i. Full name
BRIGADE CAPITAL MANAGEMENT, LP 
ii. SEC file number ( e.g., 801- ), if applicable

801-69965 

iii. CRD number
000144078 
iv. LEI, if any

0OK00T8HAYS2LL2RVU43 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 5
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

N/A 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
SAFRA SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

E51AOUORNWWT747CBW71 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 14
i. Full name
WELLS FARGO BANK 
ii. LEI, if any, or provide and describe other identifying number

KB1H1DSPRFMYMCUFXT09 

Description of other identifying number

 

iii. State, if applicable
NORTH CAROLINA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 15
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
i. Full name of broker
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Gross commissions paid by the Fund for the reporting period

b. Aggregate brokerage commissions paid by Fund during the reporting period:

0 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
BARCLAYS CAPITAL INC. FIXED INCOME 
ii. SEC file number

008-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

190,136,098.07 

Principal Transactions Record: 2
i. Full name of dealer
GOLDMAN, SACHS & CO. 
ii. SEC file number

008-00129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
UTAH  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

199,998,121.38 

Principal Transactions Record: 3
i. Full name of dealer
CHASE SECURITIES, INC. 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

196,918,750.71 

Principal Transactions Record: 4
i. Full name of dealer
MORGAN STANLEY & CO, INC 
ii. SEC file number

008-15869 

iii. CRD number
000008209 
iv. LEI, if any

9R7GPTSO7KV3UQJZQ078 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

133,026,848.4 

Principal Transactions Record: 5
i. Full name of dealer
DEUTSCHE BANK SECURITIES, INC. 
ii. SEC file number

008-17822 

iii. CRD number
000002525 
iv. LEI, if any

9J6MBOOO7BECTDTUZW19 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

111,408,197.1 

Principal Transactions Record: 6
i. Full name of dealer
MONTGOMERY/BANK OF AMERICA 
ii. SEC file number

008-69787 

iii. CRD number
000283942 
iv. LEI, if any

549300HN4UKV1E2R3U73 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

190,854,010.37 

Principal Transactions Record: 7
i. Full name of dealer
JEFFERIES LLC 
ii. SEC file number

008-15074 

iii. CRD number
000002347 
iv. LEI, if any

58PU97L1C0WSRCWADL48 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

117,823,991.85 

Principal Transactions Record: 8
i. Full name of dealer
CREDIT SUISSE FIRST BOSTON LLC. 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

137,444,353.7 

Principal Transactions Record: 9
i. Full name of dealer
CITIGROUP GLOBAL MARKETS 
ii. SEC file number

008-08177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

190,826,038.71 

Principal Transactions Record: 10
i. Full name of dealer
WACHOVIA SECURITIES, INC. 
ii. SEC file number

008-65876 

iii. CRD number
000126292 
iv. LEI, if any

VYVVCKR63DVZZN70PB21 

v. State, if applicable
NORTH CAROLINA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

84,169,851.98 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

3,564,756,900.17 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button checked Yes Radio button not checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

1,591,668,086.76891 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button checked Yes Radio button not checked No
If yes, for each loan provide the information requested below:
i. What was the average amount of the interfund loan when the loan was outstanding?
7,300,000 
ii. What was the number of days that the interfund loan was outstanding?
1 

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 17

Item C.1. Background information.

a. Full Name of the Fund

SIMT Multi-Strategy Alternatives Fund 

b. Series identication number, if any

S000028026 

c. LEI

ATT1ZPDBFPY84CU0TR19 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

2 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147402 

iii. Ticker symbol, if any

SMUYX 

Shares Outstanding Record: 2
i. Full name of Class
Class F 
ii. Class identification number, if any

C000085250 

iii. Ticker symbol, if any

SMSAX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button not checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button not checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A 

g. Provide the net income from securities lending activities

N/A 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
ESMO ASSET MANAGEMENT Limited 
ii. SEC file number ( e.g., 801- ), if applicable

801-78177 

iii. CRD number
000167999 
iv. LEI, if any

N/A 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
Brigade Capital Management, LP 
ii. SEC file number ( e.g., 801- ), if applicable

801-69965 

iii. CRD number
000144078 
iv. LEI, if any

0OK00T8HAYS2LL2RVU43 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 3
i. Full name
Kettle Hill Capital Management, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-77815 

iii. CRD number
000163722 
iv. LEI, if any

549300OHRCMHUQLJUU75 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 4
i. Full name
RAMIUS Advisors, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-60159 

iii. CRD number
000110879 
iv. LEI, if any

VR4B1033DFSW6GD35B69 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 5
i. Full name
Caerus Investors, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-106581 

iii. CRD number
000281292 
iv. LEI, if any

2549000Z21XSDGYCJ311 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 6
i. Full name
MOUNTAINEER PARTNERS Management, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-78304 

iii. CRD number
000163089 
iv. LEI, if any

N/A 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
SubAdvisors Terminated Record: 1
i. Full name
Caerus Investors, LLC 
ii. SEC file number ( e.g., 801- )

801-106581 

iii. CRD number
000281292 
iv. LEI, if any

2549000Z21XSDGYCJ311 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Termination date

2019-06-27 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

N/A 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

0 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 12
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
i. Full name of broker
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Gross commissions paid by the Fund for the reporting period

b. Aggregate brokerage commissions paid by Fund during the reporting period:

0 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
MORGAN STANLEY & CO, INC 
ii. SEC file number

008-15869 

iii. CRD number
000008209 
iv. LEI, if any

9R7GPTSO7KV3UQJZQ078 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

12,298,021.72 

Principal Transactions Record: 2
i. Full name of dealer
MERRILL LYNCH 
ii. SEC file number

008-07221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

4,891,794.79 

Principal Transactions Record: 3
i. Full name of dealer
CHASE SECURITIES, INC. 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

4,998,763.8 

Principal Transactions Record: 4
i. Full name of dealer
DEUTSCHE BANK SECURITIES, INC. 
ii. SEC file number

008-17822 

iii. CRD number
000002525 
iv. LEI, if any

9J6MBOOO7BECTDTUZW19 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

6,632,343.7 

Principal Transactions Record: 5
i. Full name of dealer
CITIGROUP GLOBAL MARKETS 
ii. SEC file number

008-08177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

40,406,490.98 

Principal Transactions Record: 6
i. Full name of dealer
JEFFERIES LLC 
ii. SEC file number

008-15074 

iii. CRD number
000002347 
iv. LEI, if any

58PU97L1C0WSRCWADL48 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

12,583,699.82 

Principal Transactions Record: 7
i. Full name of dealer
CREDIT SUISSE FIRST BOSTON LLC. 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

4,898,153.29 

Principal Transactions Record: 8
i. Full name of dealer
JP MORGAN 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

27,294,896.46 

Principal Transactions Record: 9
i. Full name of dealer
HSBC 
ii. SEC file number

008-41562 

iii. CRD number
000019585 
iv. LEI, if any

CYYGQCGNHMHPSMRL3R97 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

6,485,811.93999999 

Principal Transactions Record: 10
i. Full name of dealer
BARCLAYS CAPITAL INC. 
ii. SEC file number

008-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

12,431,642.41 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

1,561,634,169.64 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button checked Yes Radio button not checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

483,936,859.32863 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 18

Item C.1. Background information.

a. Full Name of the Fund

SIMT S&P 500 Index Fund 

b. Series identication number, if any

S000018490 

c. LEI

549300316G5IVCJ7MJ25 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

2 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class I 
ii. Class identification number, if any

C000051282 

iii. Ticker symbol, if any

SPIIX 

Shares Outstanding Record: 2
i. Full name of Class
Class F 
ii. Class identification number, if any

C000051280 

iii. Ticker symbol, if any

SSPIX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox checked  Index Fund 
i. Is the index whose performance the Fund tracks, constructed:
1. By an affiliated person of the fund?Radio button not checked Yes Radio button checked No
2. Exclusively for the fund?Radio button not checked Yes Radio button checked No
ii. Provide the annualized difference between the Fund's total return during the reporting period and the index's return during the reporting period (i.e., the Fund's total return less the index's return):
1. Before Fund fees and expenses:
0.08 
2. After Fund fees and expenses (i.e., net asset value):
-0.6 
iii. Provide the annualized standard deviation of the daily difference between the Fund's total return and the index's return during the reporting period:
1. Before Fund fees and expenses:
0.126904806 
2. After Fund fees and expenses (i.e., net asset value):
0.126246654 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox not checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
Securities Finance Trust Company 
ii. LEI, if any

549300TG9E1QX4XYSB91 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
SEI Investments Management Corporation 
ii. LEI, if any:

Q33VOZOFSDXYC0TV0J12 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox not checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

1,064,917.59000000 

g. Provide the net income from securities lending activities

14,436.71820409 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
SSGA FUNDS MANAGEMENT, INC. 
ii. SEC file number ( e.g., 801- ), if applicable

801-60103 

iii. CRD number
000111242 
iv. LEI, if any

FT3UGI3NU6B7EELQF380 

v. State, if applicable
MASSACHUSETTS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

N/A 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
SAFRA SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

E51AOUORNWWT747CBW71 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 10
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
UBS SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 14
i. Full name
WELLS FARGO BANK 
ii. LEI, if any, or provide and describe other identifying number

KB1H1DSPRFMYMCUFXT09 

Description of other identifying number

 

iii. State, if applicable
NORTH CAROLINA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 15
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
BEAR STEARNS & CO INC. 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

446.64 

Brokers Record: 2
i. Full name of broker
MERRILL LYNCH 
ii. SEC file number

008-07221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

4,842.76 

Brokers Record: 3
i. Full name of broker
GOLDMAN, SACHS & CO. 
ii. SEC file number

008-00129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
UTAH  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

1,133.34999999 

Brokers Record: 4
i. Full name of broker
BARCLAYS CAPITAL INC. 
ii. SEC file number

008-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

642.54999999 

Brokers Record: 5
i. Full name of broker
UBS SECURITIES LLC 
ii. SEC file number

008-22651 

iii. CRD number
000007654 
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

885.07 

Brokers Record: 6
i. Full name of broker
DEUTSCHE BANK SECURITIES, INC. 
ii. SEC file number

008-17822 

iii. CRD number
000002525 
iv. LEI, if any

9J6MBOOO7BECTDTUZW19 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

414.38 

Brokers Record: 7
i. Full name of broker
LOOP CAPITAL MARKETS INC. 
ii. SEC file number

8-50140 

iii. CRD number
000043098 
iv. LEI, if any

254900FPPM2WN90D4786 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

3,033.39 

Brokers Record: 8
i. Full name of broker
CREDIT SUISSE - FIRST BOSTON 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

2,465.66 

Brokers Record: 9
i. Full name of broker
MORGAN STANLEY & CO, INC 
ii. SEC file number

008-15869 

iii. CRD number
000008209 
iv. LEI, if any

9R7GPTSO7KV3UQJZQ078 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

1,096.15 

Brokers Record: 10
i. Full name of broker
INVESTMENT TECHNOLOGY GROUP, INC. 
ii. SEC file number

008-44218 

iii. CRD number
000029299 
iv. LEI, if any

549300S41SMIODVIT266 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

500.25 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

17,859.59999999 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

826,115,072.5 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 19

Item C.1. Background information.

a. Full Name of the Fund

SIMT Tax-Managed International Managed Volatility Fund 

b. Series identication number, if any

S000054731 

c. LEI

549300LMFI6LKRRM4U86 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

2 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000171911 

iii. Ticker symbol, if any

SIMYX 

Shares Outstanding Record: 2
i. Full name of Class
Class F 
ii. Class identification number, if any

C000171910 

iii. Ticker symbol, if any

SMINX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button not checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button not checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A 

g. Provide the net income from securities lending activities

N/A 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
LSV ASSET MANAGEMENT 
ii. SEC file number ( e.g., 801- ), if applicable

801-47689 

iii. CRD number
000109918 
iv. LEI, if any

EOAQF6H83OMJLRM1LZ09 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button checked Yes Radio button not checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
ANALYTIC INVESTORS, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-21122 

iii. CRD number
000104973 
iv. LEI, if any

549300B3H2IOO2L85I90 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 3
i. Full name
PARAMETRIC PORTFOLIO Associates LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-60485 

iii. CRD number
000114310 
iv. LEI, if any

549300S4WU4W1Z92RF77 

v. State, if applicable
WASHINGTON  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 4
i. Full name
Acadian Asset Management LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-28078 

iii. CRD number
000106609 
iv. LEI, if any

RQTOM0CI0L1JQEIRRN40 

v. State, if applicable
MASSACHUSETTS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
BROWN BROTHERS HARRIMAN & CO. 
ii. LEI, if any

5493006KMX1VFTPYPW14 

iii. State, if applicable
MASSACHUSETTS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
SAFRA SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

E51AOUORNWWT747CBW71 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 10
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
ITG 
ii. SEC file number

008-44218 

iii. CRD number
000029299 
iv. LEI, if any

549300S41SMIODVIT266 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

6,065.17 

Brokers Record: 2
i. Full name of broker
PEEL HUNT INCORPORATED 
ii. SEC file number

008-68845 

iii. CRD number
000157321 
iv. LEI, if any

549300GM5MYK4SWM4B33 

v. State, if applicable
 
vi. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
vii. Gross commissions paid by the Fund for the reporting period

10,482.39 

Brokers Record: 3
i. Full name of broker
MERRILL LYNCH 
ii. SEC file number

008-07221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

31,292.85 

Brokers Record: 4
i. Full name of broker
MACQUARIE CAPITAL 
ii. SEC file number

008-47198 

iii. CRD number
000036368 
iv. LEI, if any

549300670K07JRB5UQ40 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

23,656.27 

Brokers Record: 5
i. Full name of broker
CSFB 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

9,258.89 

Brokers Record: 6
i. Full name of broker
BT BROKERAGE CORP 
ii. SEC file number

008-17822 

iii. CRD number
000002525 
iv. LEI, if any

9J6MBOOO7BECTDTUZW19 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

3,647.98 

Brokers Record: 7
i. Full name of broker
J.P. MORGAN SECURITIES 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

14,152.25 

Brokers Record: 8
i. Full name of broker
MORGAN STANLEY & CO, INC 
ii. SEC file number

008-15869 

iii. CRD number
000008209 
iv. LEI, if any

9R7GPTSO7KV3UQJZQ078 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

41,603.77 

Brokers Record: 9
i. Full name of broker
INSTINET 
ii. SEC file number

008-23669 

iii. CRD number
000007897 
iv. LEI, if any

549300MGMN3RKMU8FT57 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

33,713.82 

Brokers Record: 10
i. Full name of broker
CITIGROUP GLOBAL MARKETS 
ii. SEC file number

008-08177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

21,228.39 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

200,406.24 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

361,988,704.194384 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 20

Item C.1. Background information.

a. Full Name of the Fund

SIMT Tax-Managed Managed Volatility Fund 

b. Series identication number, if any

S000017259 

c. LEI

7JIBZQTMH4YWBINPMS36 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

2 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147398 

iii. Ticker symbol, if any

STVYX 

Shares Outstanding Record: 2
i. Full name of Class
Class F 
ii. Class identification number, if any

C000047774 

iii. Ticker symbol, if any

TMMAX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button not checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button not checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A 

g. Provide the net income from securities lending activities

N/A 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
LSV ASSET MANAGEMENT 
ii. SEC file number ( e.g., 801- ), if applicable

801-47689 

iii. CRD number
000109918 
iv. LEI, if any

EOAQF6H83OMJLRM1LZ09 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button checked Yes Radio button not checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
ANALYTIC INVESTORS, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-21122 

iii. CRD number
000104973 
iv. LEI, if any

549300B3H2IOO2L85I90 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 3
i. Full name
PARAMETRIC PORTFOLIO Associates, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-60485 

iii. CRD number
000114310 
iv. LEI, if any

549300S4WU4W1Z92RF77 

v. State, if applicable
WASHINGTON  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
SAFRA SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

E51AOUORNWWT747CBW71 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 12
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
INSTINET CLEARING SERVICES, INC. 
ii. SEC file number

008-23669 

iii. CRD number
000007897 
iv. LEI, if any

549300MGMN3RKMU8FT57 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

5,448.52 

Brokers Record: 2
i. Full name of broker
CITATION GROUP/MERRILL LYNCH 
ii. SEC file number

008-07221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

4,434.02 

Brokers Record: 3
i. Full name of broker
MERRILL LYNCH, PIERCE, FENNER & SMITH 
ii. SEC file number

008-07221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

23,198.41 

Brokers Record: 4
i. Full name of broker
RBC DAIN RAUSCHER INC. 
ii. SEC file number

008-45411 

iii. CRD number
000031194 
iv. LEI, if any

549300LCO2FLSSVFFR64 

v. State, if applicable
MINNESOTA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

11,718.32 

Brokers Record: 5
i. Full name of broker
CREDIT SUISSE FIRST BOSTON LLC. 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

6,205.8 

Brokers Record: 6
i. Full name of broker
J.P. MORGAN SECURITIES 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

8,474.86999999 

Brokers Record: 7
i. Full name of broker
MORGAN STANLEY & CO, INC 
ii. SEC file number

008-15869 

iii. CRD number
000008209 
iv. LEI, if any

9R7GPTSO7KV3UQJZQ078 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

7,514.3 

Brokers Record: 8
i. Full name of broker
JEFFERIES LLC 
ii. SEC file number

008-15074 

iii. CRD number
000002347 
iv. LEI, if any

58PU97L1C0WSRCWADL48 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

4,656.64999999 

Brokers Record: 9
i. Full name of broker
WEEDEN & COMPANY 
ii. SEC file number

008-37267 

iii. CRD number
000016835 
iv. LEI, if any

549300OYBLKSN8M8EW67 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

16,180.68 

Brokers Record: 10
i. Full name of broker
NATIONAL FINANCIAL SERVICES CORPORATION 
ii. SEC file number

008-26740 

iii. CRD number
000013041 
iv. LEI, if any

549300JRHF1MHHWUAW04 

v. State, if applicable
TEXAS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

3,654.97 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

104,471.59 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

1,056,650,334.30162 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 21

Item C.1. Background information.

a. Full Name of the Fund

SIMT Multi-Asset Income Fund 

b. Series identication number, if any

S000035780 

c. LEI

0ZCM0U5P3NFTL2OJ8D74 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

2 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147404 

iii. Ticker symbol, if any

SLIYX 

Shares Outstanding Record: 2
i. Full name of Class
Class F 
ii. Class identification number, if any

C000109625 

iii. Ticker symbol, if any

SIOAX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button not checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button not checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A 

g. Provide the net income from securities lending activities

N/A 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
GOLDMAN SACHS ASSET Management, L.P. 
ii. SEC file number ( e.g., 801- ), if applicable

801-37591 

iii. CRD number
000107738 
iv. LEI, if any

CF5M58QA35CFPUX70H17 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
Western Asset Management Company Limited 
ii. SEC file number ( e.g., 801- ), if applicable

801-21068 

iii. CRD number
000110427 
iv. LEI, if any

549300IVCLHPHPOYT226 

v. State, if applicable
 
vi. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 3
i. Full name
SSGA FUNDS MANAGEMENT, Inc. 
ii. SEC file number ( e.g., 801- ), if applicable

801-60103 

iii. CRD number
000111242 
iv. LEI, if any

FT3UGI3NU6B7EELQF380 

v. State, if applicable
MASSACHUSETTS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 4
i. Full name
Western Asset Management Company 
ii. SEC file number ( e.g., 801- ), if applicable

801-8162 

iii. CRD number
000110441 
iv. LEI, if any

549300C5A561UXUICN46 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 5
i. Full name
GUGGENHEIM INVESTMENT Management, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-62515 

iii. CRD number
000129288 
iv. LEI, if any

549300XWQLVNUK615E79 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
SubAdvisors Terminated Record: 1
i. Full name
Guggenheim Partners Investment Management, LLC 
ii. SEC file number ( e.g., 801- )

801-66786 

iii. CRD number
000129288 
iv. LEI, if any

549300XWQLVNUK615E79 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Termination date

2018-10-11 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
CITIBANK, N.A., SAO PAULO 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
BRAZIL  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 2
i. Full name
HSBC MALAYS BERHAD 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
MALAYSIA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 3
i. Full name
BROWN BROTHERS HARRIMAN & CO. 
ii. LEI, if any

5493006KMX1VFTPYPW14 

iii. State, if applicable
MASSACHUSETTS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 4
i. Full name
CITITRUST COLOMBIA 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
COLOMBIA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
J.P. MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

NA 

Description of other identifying number

NA 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 6
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
SAFRA SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

E51AOUORNWWT747CBW71 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 14
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
i. Full name of broker
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Gross commissions paid by the Fund for the reporting period

b. Aggregate brokerage commissions paid by Fund during the reporting period:

0 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
MONTGOMERY/BANK OF AMERICA 
ii. SEC file number

008-69787 

iii. CRD number
000283942 
iv. LEI, if any

549300HN4UKV1E2R3U73 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

160,854,215.53 

Principal Transactions Record: 2
i. Full name of dealer
WACHOVIA SECURITIES, INC. 
ii. SEC file number

008-65876 

iii. CRD number
000126292 
iv. LEI, if any

VYVVCKR63DVZZN70PB21 

v. State, if applicable
NORTH CAROLINA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

32,554,007.07 

Principal Transactions Record: 3
i. Full name of dealer
CREDIT SUISSE FIRST BOSTON LLC. 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

164,563,002.77 

Principal Transactions Record: 4
i. Full name of dealer
BARCLAYS CAPITAL INC. FIXED INCOME 
ii. SEC file number

008-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

97,342,253.47 

Principal Transactions Record: 5
i. Full name of dealer
JP MORGAN 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

101,091,683.2 

Principal Transactions Record: 6
i. Full name of dealer
MERRILL LYNCH, PIERCE, FENNER & SMITH 
ii. SEC file number

008-07221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

33,122,713.52 

Principal Transactions Record: 7
i. Full name of dealer
CITIGROUP GLOBAL MARKETS 
ii. SEC file number

008-08177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

153,000,228.61 

Principal Transactions Record: 8
i. Full name of dealer
DEUTSCHE BANK SECURITIES, INC. 
ii. SEC file number

008-17822 

iii. CRD number
000002525 
iv. LEI, if any

9J6MBOOO7BECTDTUZW19 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

31,523,496.69 

Principal Transactions Record: 9
i. Full name of dealer
MORGAN STANLEY & CO, INC 
ii. SEC file number

008-15869 

iii. CRD number
000008209 
iv. LEI, if any

9R7GPTSO7KV3UQJZQ078 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

196,615,135.86 

Principal Transactions Record: 10
i. Full name of dealer
CHASE SECURITIES, INC. 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

262,905,048.88 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

1,535,834,493.63 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

953,519,464.3 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 22

Item C.1. Background information.

a. Full Name of the Fund

SIMT Mid-Cap Fund 

b. Series identication number, if any

S000006675 

c. LEI

LI3K1I1CWFE1VGL9N347 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class F 
ii. Class identification number, if any

C000018199 

iii. Ticker symbol, if any

SEMCX 

Shares Outstanding Record: 2
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147391 

iii. Ticker symbol, if any

SFDYX 

Shares Outstanding Record: 3
i. Full name of Class
Class I 
ii. Class identification number, if any

C000030067 

iii. Ticker symbol, if any

SIPIX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
Securities Finance Trust Company 
ii. LEI, if any

549300TG9E1QX4XYSB91 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
SEI Investments Management Corporation 
ii. LEI, if any:

Q33VOZOFSDXYC0TV0J12 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox not checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

392,966.64000000 

g. Provide the net income from securities lending activities

3,752.02981866 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
QUANTITATIVE MANAGEMENT Associates LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-62692 

iii. CRD number
000129752 
iv. LEI, if any

5493005W4V54W55C4K03 

v. State, if applicable
NEW JERSEY  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

NA 

Description of other identifying number

NA 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 7
i. Full name
WELLS FARGO BANK 
ii. LEI, if any, or provide and describe other identifying number

KB1H1DSPRFMYMCUFXT09 

Description of other identifying number

 

iii. State, if applicable
NORTH CAROLINA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
MORGAN STANLEY & CO, INC 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
LOOP CAPITAL MARKETS INC. 
ii. SEC file number

8-50140 

iii. CRD number
000043098 
iv. LEI, if any

254900FPPM2WN90D4786 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

77.2 

Brokers Record: 2
i. Full name of broker
SANFORD C. BERNSTEIN & CO., LLC 
ii. SEC file number

008-52942 

iii. CRD number
000104474 
iv. LEI, if any

549300I7JYZHT7D5CO04 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

708 

Brokers Record: 3
i. Full name of broker
J.P. MORGAN SECURITIES 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

262.69 

Brokers Record: 4
i. Full name of broker
BCAP 
ii. SEC file number

008-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

851.9 

Brokers Record: 5
i. Full name of broker
EVERCORE 
ii. SEC file number

008-49830 

iii. CRD number
000042405 
iv. LEI, if any

5493008F0LRLS5N8LZ81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

133 

Brokers Record: 6
i. Full name of broker
STIFEL NICOLAUS & CO., INC. 
ii. SEC file number

008-01447 

iii. CRD number
000000793 
iv. LEI, if any

5WUVMA08EYG4KEUPW589 

v. State, if applicable
MISSOURI  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

1,954.51 

Brokers Record: 7
i. Full name of broker
INVESTMENT TECHNOLOGY GROUP, INC. 
ii. SEC file number

008-44218 

iii. CRD number
000029299 
iv. LEI, if any

549300S41SMIODVIT266 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

339.25 

Brokers Record: 8
i. Full name of broker
SCOTIA CAPITAL (USA) INC. 
ii. SEC file number

008-03716 

iii. CRD number
000002739 
iv. LEI, if any

549300BLWPABP1VNME36 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

4,699.47999999 

Brokers Record: 9
i. Full name of broker
MERRILL LYNCH, PIERCE, FENNER & SMITH 
ii. SEC file number

008-07221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

4,114.14 

Brokers Record: 10
i. Full name of broker
RAMIREZ, SAMUEL A. AND COMPANY 
ii. SEC file number

008-19014 

iii. CRD number
000006963 
iv. LEI, if any

254900CBKVW7O2ENQA21 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

13.5 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

13,153.67 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

110,584,647.25 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 23

Item C.1. Background information.

a. Full Name of the Fund

SIMT Core Fixed Income Fund 

b. Series identication number, if any

S000006667 

c. LEI

FPNUFBNI42IT0696WN30 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147384 

iii. Ticker symbol, if any

SCFYX 

Shares Outstanding Record: 2
i. Full name of Class
Class I 
ii. Class identification number, if any

C000018186 

iii. Ticker symbol, if any

SCXIX 

Shares Outstanding Record: 3
i. Full name of Class
Class F 
ii. Class identification number, if any

C000018187 

iii. Ticker symbol, if any

TRLVX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
Securities Finance Trust Company 
ii. LEI, if any

549300TG9E1QX4XYSB91 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
SEI Investments Management Corporation 
ii. LEI, if any:

Q33VOZOFSDXYC0TV0J12 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox not checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

168,893,194.55000001 

g. Provide the net income from securities lending activities

220,329.39000000 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Logan Circle Partners, L.P. 
ii. SEC file number ( e.g., 801- ), if applicable

801-67753 

iii. CRD number
000143633 
iv. LEI, if any

F2OFNL1W7020BH7GN108 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
WELLS CAPITAL MANAGEMENT, Inc 
ii. SEC file number ( e.g., 801- ), if applicable

801-64341 

iii. CRD number
000135455 
iv. LEI, if any

549300B3H2IOO2L85I90 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 3
i. Full name
METROPOLITAN WEST Asset Management LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-53332 

iii. CRD number
000104571 
iv. LEI, if any

5493004MDKGXC00IY283 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 4
i. Full name
WESTERN ASSET MANAGEMENT Company Limited 
ii. SEC file number ( e.g., 801- ), if applicable

801-21068 

iii. CRD number
000110427 
iv. LEI, if any

549300IVCLHPHPOYT226 

v. State, if applicable
 
vi. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 5
i. Full name
Jennison Associates LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-5608 

iii. CRD number
000107959 
iv. LEI, if any

549300FH843OWV8IPG14 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 6
i. Full name
WESTERN ASSET MANAGEMENT Company 
ii. SEC file number ( e.g., 801- ), if applicable

801-8162 

iii. CRD number
000110441 
iv. LEI, if any

549300C5A561UXUICN46 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
SAFRA SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

E51AOUORNWWT747CBW71 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

N/A 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

8-17574 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 14
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 15
i. Full name
WELLS FARGO BANK 
ii. LEI, if any, or provide and describe other identifying number

KB1H1DSPRFMYMCUFXT09 

Description of other identifying number

 

iii. State, if applicable
NORTH CAROLINA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
i. Full name of broker
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Gross commissions paid by the Fund for the reporting period

b. Aggregate brokerage commissions paid by Fund during the reporting period:

0 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
EDWARD D. JONES & CO. 
ii. SEC file number

8-759 

iii. CRD number
000000250 
iv. LEI, if any

YZRCLX72FTV74B522G90 

v. State, if applicable
MISSOURI  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

195,000,000 

Principal Transactions Record: 2
i. Full name of dealer
MORGAN STANLEY & CO, INC 
ii. SEC file number

008-15869 

iii. CRD number
000008209 
iv. LEI, if any

9R7GPTSO7KV3UQJZQ078 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

72,357,609.2099999 

Principal Transactions Record: 3
i. Full name of dealer
GOLDMAN, SACHS & CO. 
ii. SEC file number

008-00129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
UTAH  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

90,537,950.3299999 

Principal Transactions Record: 4
i. Full name of dealer
JP MORGAN 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

67,943,821.2 

Principal Transactions Record: 5
i. Full name of dealer
PIERPONT SECURITIES 
ii. SEC file number

008-68282 

iii. CRD number
000150696 
iv. LEI, if any

549300LGG2RLWD21SU97 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

424,000,704 

Principal Transactions Record: 6
i. Full name of dealer
CITICORP SECURITY SERVICES INC. 
ii. SEC file number

008-08177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

62,878,449.72 

Principal Transactions Record: 7
i. Full name of dealer
BARCLAYS CAPITAL INC. 
ii. SEC file number

008-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

64,173,672.74 

Principal Transactions Record: 8
i. Full name of dealer
BMO CAPITAL 
ii. SEC file number

008-34344 

iii. CRD number
000016686 
iv. LEI, if any

RUC0QBLBRPRCU4W1NE59 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

59,824,128.37 

Principal Transactions Record: 9
i. Full name of dealer
DEUTSCHE BANK 
ii. SEC file number

008-17822 

iii. CRD number
000002525 
iv. LEI, if any

9J6MBOOO7BECTDTUZW19 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

7,802,698,077.5 

Principal Transactions Record: 10
i. Full name of dealer
CREDIT SUISSE - FIRST BOSTON 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

160,836,136.33 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

9,001,104,401.62999 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

4,017,350,277.54 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 24

Item C.1. Background information.

a. Full Name of the Fund

SIMT Dynamic Asset Allocation Fund 

b. Series identication number, if any

S000050286 

c. LEI

549300CH15ZL74DTQD54 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

2 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000158775 

iii. Ticker symbol, if any

SDYYX 

Shares Outstanding Record: 2
i. Full name of Class
Class F 
ii. Class identification number, if any

C000158774 

iii. Ticker symbol, if any

SDYAX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button checked Yes Radio button not checked No
b. If yes, provide the following information:
Foreign Investments Record: 1
Full name of subsidiary
Dynamic Commodity Strategy Subsidiary, Ltd. 
LEI of subsidiary, if any

N/A 


Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button not checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button not checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A 

g. Provide the net income from securities lending activities

N/A 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
SSGA FUNDS MANAGEMENT, INC. 
ii. SEC file number ( e.g., 801- ), if applicable

801-60103 

iii. CRD number
000111242 
iv. LEI, if any

FT3UGI3NU6B7EELQF380 

v. State, if applicable
MASSACHUSETTS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
BROWN BROTHERS HARRIMAN & CO. 
ii. LEI, if any

5493006KMX1VFTPYPW14 

iii. State, if applicable
MASSACHUSETTS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 5
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

0 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
SAFRA SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

E51AOUORNWWT747CBW71 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
BEAR STEARNS & CO INC. 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

1,067.13 

Brokers Record: 2
i. Full name of broker
CREDIT SUISSE FIRST BOSTON LLC. 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

964 

Brokers Record: 3
i. Full name of broker
UBS WARBURG 
ii. SEC file number

008-16267 

iii. CRD number
000008174 
iv. LEI, if any

ETYRV6ORNFJB5NONI676 

v. State, if applicable
NEW JERSEY  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

1,213.56 

Brokers Record: 4
i. Full name of broker
CITIGROUP GLOBAL MARKETS 
ii. SEC file number

008-08177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

5,694.82 

Brokers Record: 5
i. Full name of broker
MORGAN STANLEY & CO, INC 
ii. SEC file number

008-15869 

iii. CRD number
000008209 
iv. LEI, if any

9R7GPTSO7KV3UQJZQ078 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

6,934.61 

Brokers Record: 6
i. Full name of broker
JP MORGAN 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

24,311.92 

Brokers Record: 7
i. Full name of broker
INVESTMENT TECHNOLOGY GROUP, INC. 
ii. SEC file number

008-44218 

iii. CRD number
000029299 
iv. LEI, if any

549300S41SMIODVIT266 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

2,517.01 

Brokers Record: 8
i. Full name of broker
GOLDMAN SACHS & CO 
ii. SEC file number

008-00129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
UTAH  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

11,483.39 

Brokers Record: 9
i. Full name of broker
MERRILL LYNCH, PIERCE, FENNER & SMITH 
ii. SEC file number

008-07221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

20,250.99 

Brokers Record: 10
i. Full name of broker
SOCIETE GENERALE COWEN SECURITIES CORP. 
ii. SEC file number

008-40756 

iii. CRD number
000023857 
iv. LEI, if any

5493008QI0EFC5WBED75 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

914.95 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

78,686.41 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

796,270,071.65326 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 25

Item C.1. Background information.

a. Full Name of the Fund

SIMT Small Cap Growth Fund 

b. Series identication number, if any

S000006670 

c. LEI

PR639JCQG2DNH2EK6Q95 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class F 
ii. Class identification number, if any

C000018191 

iii. Ticker symbol, if any

SSCGX 

Shares Outstanding Record: 2
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147386 

iii. Ticker symbol, if any

SMAYX 

Shares Outstanding Record: 3
i. Full name of Class
Class I 
ii. Class identification number, if any

C000018190 

iii. Ticker symbol, if any

SPWIX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
Securities Finance Trust Company 
ii. LEI, if any

549300TG9E1QX4XYSB91 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
SEI Investments Management Corporation 
ii. LEI, if any:

Q33VOZOFSDXYC0TV0J12 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox not checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

18,172,520.94000000 

g. Provide the net income from securities lending activities

210,627.94909102 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
ARROWPOINT ASSET MANAGEMENT, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-69868 

iii. CRD number
000149120 
iv. LEI, if any

IF16UMXNLJ3CKISVCS83 

v. State, if applicable
COLORADO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
PARAMETRIC PORTFOLIO Associates LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-60485 

iii. CRD number
000114310 
iv. LEI, if any

549300S4WU4W1Z92RF77 

v. State, if applicable
WASHINGTON  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 3
i. Full name
AXIOM INTERNATIONAL Investors LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-56651 

iii. CRD number
000109605 
iv. LEI, if any

549300AT4OLE6P7NTD88 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 4
i. Full name
FALCON POINT CAPITAL, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-61442 

iii. CRD number
000122459 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 5
i. Full name
EAM INVESTORS, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-70305 

iii. CRD number
000144908 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 6
i. Full name
361 Capital LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-60813 

iii. CRD number
000118203 
iv. LEI, if any

2549009YD5ABPHX2QW05 

v. State, if applicable
COLORADO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button checked Yes Radio button not checked No
1. If the sub-adviser was hired during the period, indicate the sub-adviser's start date:

2018-12-06 

d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
SubAdvisors Terminated Record: 1
i. Full name
Axiom International Investors LLC 
ii. SEC file number ( e.g., 801- )

801-56651 

iii. CRD number
000109605 
iv. LEI, if any

549300AT4OLE6P7NTD88 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Termination date

2018-12-04 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
WELLS FARGO BANK 
ii. LEI, if any, or provide and describe other identifying number

KB1H1DSPRFMYMCUFXT09 

Description of other identifying number

 

iii. State, if applicable
NORTH CAROLINA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
ASCENSUS TRUST COMPANY 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

N/A 

iii. State, if applicable
NORTH DAKOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
RBC CAPITAL MARKETS CORPORATION 
ii. LEI, if any, or provide and describe other identifying number

008-45411 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 9
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 12
i. Full name
UBS FINANCIAL SERVICES 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 13
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 14
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
JP MORGAN - OLD BEAR STEARNS 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

17,907.23 

Brokers Record: 2
i. Full name of broker
PERSHING LLC 
ii. SEC file number

008-17574 

iii. CRD number
000007560 
iv. LEI, if any

ZI8Q1A8EI8LQFJNM0D94 

v. State, if applicable
NEW JERSEY  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

2,307.59 

Brokers Record: 3
i. Full name of broker
LOOP CAPITAL 
ii. SEC file number

008-50140 

iii. CRD number
000043098 
iv. LEI, if any

254900FPPM2WN90D4786 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

25,827.46 

Brokers Record: 4
i. Full name of broker
UBS SECURITIES 
ii. SEC file number

008-22651 

iii. CRD number
000007654 
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

18,801.21 

Brokers Record: 5
i. Full name of broker
WEEDEN & COMPANY 
ii. SEC file number

008-37267 

iii. CRD number
000016835 
iv. LEI, if any

549300OYBLKSN8M8EW67 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

59,446.07 

Brokers Record: 6
i. Full name of broker
INSTINET CLEARING SERVICES, INC. 
ii. SEC file number

008-23669 

iii. CRD number
000007897 
iv. LEI, if any

549300MGMN3RKMU8FT57 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

14,858.31 

Brokers Record: 7
i. Full name of broker
RBC DAIN RAUSCHER INC. 
ii. SEC file number

008-45411 

iii. CRD number
000031194 
iv. LEI, if any

549300LCO2FLSSVFFR64 

v. State, if applicable
MINNESOTA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

13,800.44 

Brokers Record: 8
i. Full name of broker
CREDIT SUISSE FIRST BOSTON LLC. 
ii. SEC file number

008-00422 

iii. CRD number
000000816 
iv. LEI, if any

1V8Y6QCX6YMJ2OELII46 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

5,744.85 

Brokers Record: 9
i. Full name of broker
JEFFERIES LLC 
ii. SEC file number

008-15074 

iii. CRD number
000002347 
iv. LEI, if any

58PU97L1C0WSRCWADL48 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

58,361.69 

Brokers Record: 10
i. Full name of broker
ITG 
ii. SEC file number

008-44218 

iii. CRD number
000029299 
iv. LEI, if any

549300S41SMIODVIT266 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

17,453.59 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

234,740.57 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

339,063,440.16 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 26

Item C.1. Background information.

a. Full Name of the Fund

SIMT Tax-Free Conservative Income Fund 

b. Series identication number, if any

S000053395 

c. LEI

549300LEBYWU57B8NW33 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

2 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000167940 

iii. Ticker symbol, if any

TFCYX 

Shares Outstanding Record: 2
i. Full name of Class
Class F 
ii. Class identification number, if any

C000167939 

iii. Ticker symbol, if any

TFCAX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button not checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button not checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A 

g. Provide the net income from securities lending activities

N/A 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI Investments Management Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Blackrock Advisors, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-56972 

iii. CRD number
000108928 
iv. LEI, if any

5493006MRTEZZ4S4CQ20 

v. State, if applicable
NEW JERSEY  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US BANK, N.A. 
ii. LEI, if any

N/A 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
NATIONAL FINANCIAL SVCS, LLC 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 5
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 8
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
i. Full name of broker
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Gross commissions paid by the Fund for the reporting period

b. Aggregate brokerage commissions paid by Fund during the reporting period:

0 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
WELLS FARGO MUNICIPAL 
ii. SEC file number

008-65876 

iii. CRD number
000126292 
iv. LEI, if any

VYVVCKR63DVZZN70PB21 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

70,510,000 

Principal Transactions Record: 2
i. Full name of dealer
GOLDMAN, SACHS & CO. 
ii. SEC file number

008-00129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
UTAH  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

29,842,650 

Principal Transactions Record: 3
i. Full name of dealer
BARCLAYS CAPITAL INC. FIXED INCOME 
ii. SEC file number

008-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

36,550,000 

Principal Transactions Record: 4
i. Full name of dealer
CITIGROUP GLOBAL MARKETS 
ii. SEC file number

008-08177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

90,869,925 

Principal Transactions Record: 5
i. Full name of dealer
MORGAN STANLEY & CO, INC 
ii. SEC file number

008-15869 

iii. CRD number
000008209 
iv. LEI, if any

9R7GPTSO7KV3UQJZQ078 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

59,600,000 

Principal Transactions Record: 6
i. Full name of dealer
NATIONAL FINANCIAL SERVICES CORPORATION 
ii. SEC file number

008-26740 

iii. CRD number
000013041 
iv. LEI, if any

549300JRHF1MHHWUAW04 

v. State, if applicable
TEXAS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

48,062,900.93 

Principal Transactions Record: 7
i. Full name of dealer
CHASE SECURITIES, INC. 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

152,387,030 

Principal Transactions Record: 8
i. Full name of dealer
RBC DAIN RAUSCHER INC. 
ii. SEC file number

008-45411 

iii. CRD number
000031194 
iv. LEI, if any

549300LCO2FLSSVFFR64 

v. State, if applicable
MINNESOTA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

14,954,770 

Principal Transactions Record: 9
i. Full name of dealer
MIZUHO SECURITIES USA INC 
ii. SEC file number

008-37710 

iii. CRD number
000019647 
iv. LEI, if any

7TK5RJIZDFROZCA6XF66 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

12,600,000 

Principal Transactions Record: 10
i. Full name of dealer
MERRILL LYNCH, PIERCE, FENNER & SMITH 
ii. SEC file number

008-07221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

45,860,000 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

614,375,264.03 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

178,437,951.058853 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 27

Item C.1. Background information.

a. Full Name of the Fund

SIMT Multi-Asset Capital Stability Fund 

b. Series identication number, if any

S000035782 

c. LEI

C7C50PC2E3ID1LW1C681 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

2 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Class F 
ii. Class identification number, if any

C000109627 

iii. Ticker symbol, if any

SCLAX 

Shares Outstanding Record: 2
i. Full name of Class
Class Y 
ii. Class identification number, if any

C000147406 

iii. Ticker symbol, if any

SMLYX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
i. Full name of securities lending agent
ii. LEI, if any

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button not checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
1. Name of person providing indemnification
2. LEI, if any, of person providing indemnification

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button not checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
i. Full name of cash collateral manager:
ii. LEI, if any:

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button not checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button not checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox not checked  vi. Other  
Checkbox checked   N/A  
f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

N/A 

g. Provide the net income from securities lending activities

N/A 


Item C.7. Reliance on certain rules.

Did the Fund rely on any of the following rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox not checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button checked Yes Radio button not checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button checked Yes Radio button not checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
SEI INVESTMENT MANAGEMENT Corporation 
ii. SEC file number ( e.g., 801- )

801-24593 

iii.CRD number
000105146 
iv. LEI, if any

Q33VOZOFSDXYC0TV0J12 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
ALLIANCEBERNSTEIN L.P. 
ii. SEC file number ( e.g., 801- ), if applicable

801-56720 

iii. CRD number
000108477 
iv. LEI, if any

0JK55UGWSWNF3X7KLQ85 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
Sub Advisors Record: 2
i. Full name
Janus Capital Management LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-13991 

iii. CRD number
000104652 
iv. LEI, if any

G7D5LKZKIBRMES6BO437 

v. State, if applicable
COLORADO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
SEI Institutional Transfer Agent, Inc. 
ii.SEC file number ( e.g., 84- or 85- )

84-27897 

iii. LEI, if any

N/A 

iv. State, if applicable
PENNSYLVANIA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

549300WIC0TOJ7N7GD54 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Bloomberg 
ii. LEI, if any, or provide and describe other identifying number

254900BF4G8VMW8GG471 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
Thomson Reuters Corporation 
ii. LEI, if any, or provide and describe other identifying number

549300561UZND4C7B569 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
CANADA (FEDERAL LEVEL)  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 4
i. Full name
S&P 
ii. LEI, if any, or provide and describe other identifying number

549300U4VWNITEKO2881 

Description of other identifying number

 

iii. State, if applicable
DELAWARE  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 5
i. Full name
IHS Markit 
ii. LEI, if any, or provide and describe other identifying number

549300HLPTRASHS0E726 

Description of other identifying number

 

iii. State, if applicable
 
iv. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 6
i. Full name
Intercontinental Exchange, Inc. 
ii. LEI, if any, or provide and describe other identifying number

5493000F4ZO33MV32P92 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
CITIBANK, N.A., SAO PAULO 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
BRAZIL  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 2
i. Full name
HSBC MALAYS BERHAD 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
MALAYSIA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 3
i. Full name
SCB (CHINA) LTD 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
CHINA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 4
i. Full name
HSBC PHILIPPINES 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
PHILIPPINES  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 5
i. Full name
BROWN BROTHERS HARRIMAN & CO. 
ii. LEI, if any

5493006KMX1VFTPYPW14 

iii. State, if applicable
MASSACHUSETTS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other
Custodians Record: 6
i. Full name
CITIBANK DEL PERU 
ii. LEI, if any

N/A 

iii. State, if applicable
 
iv. Foreign country, if applicable
PERU  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button checked Yes Radio button not checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button not checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
NATIONAL FINANCIAL SVCS CORP 
ii. LEI, if any, or provide and describe other identifying number

549300JRHF1MHHWUAW04 

Description of other identifying number

 

iii. State, if applicable
TEXAS  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 2
i. Full name
UBS SECURITIES LLC 
ii. LEI, if any, or provide and describe other identifying number

8-16267 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 3
i. Full name
JP MORGAN SECURITIES 
ii. LEI, if any, or provide and describe other identifying number

008-35008 

Description of other identifying number

SEC File Number 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 4
i. Full name
SEI INVESTMENTS Distribution Company 
ii. LEI, if any, or provide and describe other identifying number

8-27897 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 5
i. Full name
RAYMOND JAMES & ASSOCIATES, INC. 
ii. LEI, if any, or provide and describe other identifying number

U4ONQX15J3RO8XCKE979 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 6
i. Full name
WELLS FARGO ADVISORS 
ii. LEI, if any, or provide and describe other identifying number

8-37180 

Description of other identifying number

SEC File Number 

iii. State, if applicable
MISSOURI  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 7
i. Full name
CHARLES SCHWAB & CO., INC 
ii. LEI, if any, or provide and describe other identifying number

549300ZP8XN77GK5BS04 

Description of other identifying number

 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 8
i. Full name
MORGAN STANLEY & CO. 
ii. LEI, if any, or provide and describe other identifying number

9R7GPTSO7KV3UQJZQ078 

Description of other identifying number

 

iii. State, if applicable
MARYLAND  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 9
i. Full name
AMERICAN ENTERPRISE INVESTMENT SERVICES, INC. 
ii. LEI, if any, or provide and describe other identifying number

549300NT7GLLVGTH0249 

Description of other identifying number

 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 10
i. Full name
SEI Private Trust Company 
ii. LEI, if any, or provide and describe other identifying number

5LJTIFADGZ6XH1RVOC11 

Description of other identifying number

 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
Shareholder servicing agents Record: 11
i. Full name
PERSHING LLC 
ii. LEI, if any, or provide and describe other identifying number

ZI8Q1A8EI8LQFJNM0D94 

Description of other identifying number

 

iii. State, if applicable
NEW JERSEY  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button checked Yes Radio button not checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button checked Yes Radio button not checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
SEI INVESTMENTS GLOBAL FUNDS SERVICES 
ii. LEI, if any, or other identifying number

801-24593 

Description of other identifying number

SEC File Number 

iii. State, if applicable
PENNSYLVANIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
Broker Dealers Record: 1
a. Full name
SEI INVESTMENTS DISTRIBUTION CO. 
b. SEC file number

8-27897 

c. CRD number
000010690 
d. LEI, if any

N/A 

e. State, if applicable
PENNSYLVANIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Total commissions paid to the affiliated broker-dealer for the reporting period:

0 


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
i. Full name of broker
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Gross commissions paid by the Fund for the reporting period

b. Aggregate brokerage commissions paid by Fund during the reporting period:

0 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
BARCLAYS CAPITAL INC. 
ii. SEC file number

008-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

254,950,388.1 

Principal Transactions Record: 2
i. Full name of dealer
GOLDMAN, SACHS & CO. 
ii. SEC file number

008-00129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
UTAH  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

135,185,408.09 

Principal Transactions Record: 3
i. Full name of dealer
MITSUBISHI SEC 
ii. SEC file number

008-43026 

iii. CRD number
000019685 
iv. LEI, if any

K5HU16E3LMSVCCJJJ255 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

383,161,419.11 

Principal Transactions Record: 4
i. Full name of dealer
WELLS FARGO BROKERAGE SERVICES, LLC 
ii. SEC file number

008-65876 

iii. CRD number
000126292 
iv. LEI, if any

VYVVCKR63DVZZN70PB21 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

135,895,645.18 

Principal Transactions Record: 5
i. Full name of dealer
JP MORGAN 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

2,236,573,554.03 

Principal Transactions Record: 6
i. Full name of dealer
MONTGOMERY/BANK OF AMERICA 
ii. SEC file number

008-69787 

iii. CRD number
000283942 
iv. LEI, if any

549300HN4UKV1E2R3U73 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

406,362,691.37 

Principal Transactions Record: 7
i. Full name of dealer
CITIGROUP GLOBAL MARKETS 
ii. SEC file number

008-08177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

350,120,163.8 

Principal Transactions Record: 8
i. Full name of dealer
MIZUHO SECURITIES 
ii. SEC file number

008-37710 

iii. CRD number
000019647 
iv. LEI, if any

7TK5RJIZDFROZCA6XF66 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

137,290,629.86 

Principal Transactions Record: 9
i. Full name of dealer
NORTHERN CAPITAL ADVISORS 
ii. SEC file number

008-49130 

iii. CRD number
000040659 
iv. LEI, if any

254900ZANH7XTB94LS53 

v. State, if applicable
MASSACHUSETTS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

518,046,512.03 

Principal Transactions Record: 10
i. Full name of dealer
CHASE SECURITIES, INC. 
ii. SEC file number

008-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

2,182,790,754.7 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

7,254,525,002.45 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button checked Yes Radio button not checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

719,149,603.620219 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button not checked Yes Radio button checked No

b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No

N-CEN:Part G: Attachments

Item G.1a. Attachments.

Attachments applicable to all Registrants. All Registrants shall file the following attachments, as applicable, with the current report. Indicate the attachments filed with the current report by checking the applicable items below: Checkbox not checked   i. Legal proceedings  
Checkbox not checked  ii. Provision of financial support  
Checkbox checked  iii. Independent public accountant's report on internal control (management investment companies other than small business investment companies only)  
Checkbox not checked  iv. Change in accounting principles and practices  
Checkbox not checked  v. Information required to be filed pursuant to exemptive orders  
Checkbox not checked  vi. Other information required to be included as an attachment pursuant to Commission rules and regulations 

Instructions.

1. Item G.1.a.i. Legal proceedings.

(a) If the Registrant responded "YES" to Item B.11.a., provide a brief description of the proceedings. As part of the description, provide the case or docket number (if any), and the full names of the principal parties to the proceeding.
(b) If the Registrant responded "YES" to Item B.11.b., identify the proceeding and give its date of termination.

2. Item G.1.a.ii. Provision of financial support. If the Registrant responded "YES" to Item B.14., provide the following information (unless the Registrant is a Money Market Fund): (a) Description of nature of support.

(b) Person providing support.

(c) Brief description of relationship between the person providing support and the Registrant.

(d) Date support provided.

(e) Amount of support.

(f) Security supported (if applicable). Disclose the full name of the issuer, the title of the issue (including coupon or yield, if applicable) and at least two identifiers, if available (e.g., CIK, CUSIP, ISIN, LEI).
(g) Value of security supported on date support was initiated (if applicable).

(h) Brief description of reason for support.

(i) Term of support.

(j) Brief description of any contractual restrictions relating to support.

3. Item G.1.a.iii. Independent public accountant's report on internal control (management investment companies other than small business investment companies only). Each management investment company shall furnish a report of its independent public accountant on the company's system of internal accounting controls. The accountant's report shall be based on the review, study and evaluation of the accounting system, internal accounting controls, and procedures for safeguarding securities made during the audit of the financial statements for the reporting period. The report should disclose any material weaknesses in: (a) the accounting system; (b) system of internal accounting control; or (c) procedures for safeguarding securities which exist as of the end of the Registrant's fiscal year.

The accountant's report shall be furnished as an exhibit to the form and shall: (1) be addressed to the Registrant's shareholders and board of directors; (2) be dated; (3) be signed manually; and (4) indicate the city and state where issued.

Attachments that include a report that discloses a material weakness should include an indication by the Registrant of any corrective action taken or proposed.

The fact that an accountant's report is attached to this form shall not be regarded as acknowledging any review of this form by the independent public accountant.

4. Item G.1.a.iv. Change in accounting principles and practices. If the Registrant responded "YES" to Item B.21, provide an attachment that describes the change in accounting principles or practices, or the change in the method of applying any such accounting principles or practices. State the date of the change and the reasons therefor. A letter from the Registrant's independent accountants, approving or otherwise commenting on the change, shall accompany the description.

5. Item G.1.a.v. Information required to be filed pursuant to exemptive orders. File as an attachment any information required to be reported on Form N-CEN or any predecessor form to Form N-CEN (e.g., Form N-SAR) pursuant to exemptive orders issued by the Commission and relied on by the Registrant.

6. Item G.1.a.vi. Other information required to be included as an attachment pursuant to Commission rules and regulations. File as an attachment any other information required to be included as an attachment pursuant to Commission rules and regulations.

N-CEN: Signature

Pursuant to the requirements of the Investment Company Act of 1940, the Registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
Registrant
SEI INSTITUTIONAL MANAGED TRUST 
Date
2019-12-13 
Signature
James Hoffmayer  
Title
CFO