Pinebridge Investments LLC

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
METLIFE, INC.
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DELAWARE AMERICAN LIFE
INSURANCE COMPANY (DELAM)
(For individuals, Last, First,

Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (DFS) DISTRICT ATTORNEY, NEW YORK COUNTY (DANY)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/09/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
M 2012 0 00197126 (DANY)
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Insurance
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN 2009, ALICO AND ITS OUTSIDE COUNSEL MADE CERTAIN REPRESENTATIONS IN A LETTER TO THE NEW YORK STATE INSURANCEDEPARTMENT (THE
PREDECESSOR OF DFS) CONCERNING ITS OPERATIONS IN NEW YORK. IT WAS ALLEGED THAT CONTRARY TO THESEREPRESENTATIONS, ALICO AND
DELAM, SUBSIDIARIES OF AMERICAN INTERNATIONAL GROUP ("AIG") UNTIL NOVEMBER 2010, ANDLATER OF METLIFE AFTER NOVEMBER 2010, WERE
DOING INSURANCE BUSINESS IN NEW YORK WITHOUT A LICENSE. FURTHER, IT WASALLEGED THAT, BY CONDUCTING CERTAIN ACTIVITIES IN NEW
YORK, REPRESENTATIVES ON BEHALF OF ALICO, DELAM, AIG ANDMETLIFE WERE SOLICITING INSURANCE BUSINESS WITHOUT A LICENSE.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
03/31/2014
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:

A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 60,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
AS REQUIRED BY THE CONSENT ORDER WITH DFS, REPRESENTATIVES ENGAGING IN CERTAIN ACTIVITIES IN NEW YORK MUSTOBTAIN AN
INSURANCE LICENSE AND AN AUTHORIZED INSURER IN NEW YORK MUST FILE CERTAIN INFORMATION CONCERNINGISSUANCE OF COVERAGE BY
INSURERS LICENSED OUTSIDE THE UNITED STATES.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
$50,000,000 PAID BY METLIFE, INC. TO DFS [PAYMENT DATE - MARCH 31, 2014] $10,000,000 PAID BY METLIFE, INC. TO DANY[PAYMENT DATE -
MARCH 31, 2014]
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
CONSENT ORDER WITH DFS, METLIFE, ALICO AND DELAM, EFFECTIVE MARCH 31, 2014. FINE OF $50,000,000 ASSESSED AGAINSTMETLIFE TO BE PAID
WITHIN SEVEN DAYS OF EFFECTIVE DATE. DEFERRED PROSECUTION AGREEMENT (THE "AGREEMENT") SIGNED BYDANY, METLIFE, ALICO AND DELAM ON
MARCH 28, 2014. PAYMENT OF $10,000,000 TO BE MADE BY METLIFE. IF COMPLIANCE WITH THEAGREEMENT FOR 24 MONTHS, THE AGREEMENT SHALL
EXPIRE AND BE OF NO FURTHER FORCE AND EFFECT. AS REQUIRED BY THECONSENT ORDER WITH DFS, REPRESENTATIVES ENGAGING IN CERTAIN
ACTIVITIES IN NEW YORK MUST OBTAIN AN INSURANCELICENSE AND AN AUTHORIZED INSURER IN NEW YORK MUST FILE CERTAIN INFORMATION
CONCERNING ISSUANCE OF COVERAGE BYINSURERS LICENSED OUTSIDE THE UNITED STATES. METLIFE, ALICO AND DELAM ARE CONTINUING TO
COOPERATE WITH A PARALLELINVESTIGATION BY THE NEW YORK STATE OFFICE OF THE ATTORNEY GENERAL TAXPAYER PROTECTION BUREAU
CONCERNING ALICOAND DELAM'S NEW YORK STATE TAX FILINGS.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
METLIFE, INC.
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/18/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-19624
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
METLIFE, INC. PREVIOUSLY DISCLOSED ERRORS IN ITS ACCOUNTING FOR RESERVES ASSOCIATED WITH CERTAIN ANNUITIES, ANDREMEDIATED THESE
ERRORS AS OF DECEMBER 31, 2018. THE U.S. SECURITIES AND EXCHANGE COMMISSION CHARGED METLIFE, INC.WITH VIOLATING THE BOOKS AND
RECORDS AND INTERNAL ACCOUNTING CONTROLS PROVISIONS OF THE FEDERAL SECURITIES LAWSRELATING TO THESE ERRORS. WITHOUT ADMITTING
OR DENYING THE COMMISSION'S FINDINGS, METLIFE AGREED TO PAY A CIVILPENALTY.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
12/18/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 10,000,000.00

 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
METLIFE, INC. PREVIOUSLY DISCLOSED ERRORS IN ITS ACCOUNTING FOR RESERVES ASSOCIATED WITH CERTAIN ANNUITIES,AND REMEDIATED
THESE ERRORS AS OF DECEMBER 31, 2018. THE U.S. SECURITIES AND EXCHANGE COMMISSION CHARGEDMETLIFE, INC. WITH VIOLATING THE
BOOKS AND RECORDS AND INTERNAL ACCOUNTING CONTROLS PROVISIONS OF THEFEDERAL SECURITIES LAWS RELATING TO THESE ERRORS.
WITHOUT ADMITTING OR DENYING THE COMMISSION'S FINDINGS,METLIFE AGREED TO PAY A CIVIL PENALTY.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
METLIFE, INC. PREVIOUSLY DISCLOSED ERRORS IN ITS ACCOUNTING FOR RESERVES ASSOCIATED WITH CERTAIN ANNUITIES, ANDREMEDIATED THESE
ERRORS AS OF DECEMBER 31, 2018. THE U.S. SECURITIES AND EXCHANGE COMMISSION CHARGED METLIFE, INC.WITH VIOLATING THE BOOKS AND
RECORDS AND INTERNAL ACCOUNTING CONTROLS PROVISIONS OF THE FEDERAL SECURITIES LAWSRELATING TO THESE ERRORS. WITHOUT ADMITTING
OR DENYING THE COMMISSION'S FINDINGS, METLIFE AGREED TO PAY A CIVILPENALTY.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
METLIFE, INC.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any

event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
COMMONWEALTH OF MASSACHUSETTS, OFFICE OF THE SECRETARY OF THE COMMONWEALTH - SECURITIES DIVISION, ENFORCEMENTSECTION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/25/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
E-2017-0119
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
METLIFE, INC. IS ALLEGED TO HAVE MADE MATERIALLY MISLEADING STATEMENTS IN ITS PUBLIC FILINGS REGARDING THEEFFECTIVENESS OF ITS
INTERNAL CONTROLS OVER FINANCIAL REPORTING FOR ITS PENSION RISK TRANSFER BUSINESS AND THESUFFICIENCY OF ITS RESERVES FOR GROUP
ANNUITY CONTRACTS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
12/18/2018
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 1,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
IN ADDITION, AS REQUIRED BY THE CONSENT ORDER WITH THE MSD, MLIC WILL UNDERTAKE SEVERAL MEASURES WITHRESPECT TO ANNUITANT
OUTREACH AND PAYMENT OF BENEFITS TO THE RELEVANT POPULATION, INCLUDING: UNDERTAKINGREASONABLE STEPS TO LOCATE
MASSACHUSETTS ANNUITANTS FROM THE RELEVANT POPULATION THAT HAVE NOT YET BEEN LOCATED; PROVIDING A CERTIFICATION OF THE

MASSACHUSETTS ANNUITANTS FROM THE RELEVANT POPULATION THAT HAVEBEEN PAID AS OF THE DATE OF THE ORDER; IDENTIFYING THOSE
MASSACHUSETTS ANNUITANTS FROM THE RELEVANTPOPULATION THAT ARE CONFIRMED TO BE DECEASED AS OF THE DATE OF THE ORDER;
COMMENCING PAYMENT WITHIN FIFTEEN(15) BUSINESS DAYS UPON RECEIVING A RETIREMENT PACKAGE IN GOOD ORDER; AND MAKING
ADDITIONAL OUTREACHEFFORTS TO ASSIST MASSACHUSETTS ANNUITANTS FROM THE RELEVANT POPULATION WHO HAVE NOT COMPLETED
ANDRETURNED THE RETIREMENT PACKAGE OR HAVE RETURNED THOSE PACKAGES NOT IN GOOD ORDER.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
ON DECEMBER 18, 2018 A CONSENT ORDER WAS ISSUED, WITH METLIFE, INC. NEITHER ADMITTING NOR DENYING THEFINDINGS CONTAINED IN
THE ORDER (EXCEPT AS TO METLIFE, INC.'S CORPORATE IDENTITY AND ORGANIZATION). THECONSENT ORDER PROVIDES FOR A CEASE AND
DESIST, A CENSURE, THE PROVISION OF INFORMATION TO THE MSD REGARDINGCERTAIN ANNUITANTS IN MASSACHUSETTS, UNDERTAKING
SEVERAL MEASURES WITH RESPECT TO OUTREACH AND PAYMENT OFBENEFITS TO THOSE ANNUITANTS, AND THE PAYMENT BY METLIFE, INC. OF A
$1 MILLION ADMINISTRATIVE FINE.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON DECEMBER 17, 2018, METLIFE, INC. SUBMITTED AN OFFER OF SETTLEMENT TO THE MASSACHUSETTS SECURITIES DIVISION("MSD") IN
CONNECTION WITH THE MSD'S ADMINISTRATIVE COMPLAINT FILED ON JUNE 25, 2018. ON DECEMBER 18, 2018 A CONSENTORDER WAS ISSUED, WITH
METLIFE, INC. NEITHER ADMITTING NOR DENYING THE FINDINGS CONTAINED IN THE ORDER (EXCEPT ASTO METLIFE, INC.'S CORPORATE IDENTITY AND
ORGANIZATION). THE CONSENT ORDER PROVIDES FOR A CEASE AND DESIST, ACENSURE, THE PROVISION OF INFORMATION TO THE MSD REGARDING
CERTAIN ANNUITANTS IN MASSACHUSETTS, UNDERTAKINGSEVERAL MEASURES WITH RESPECT TO OUTREACH AND PAYMENT OF BENEFITS TO THOSE
ANNUITANTS, AND THE PAYMENT BYMETLIFE, INC. OF A $1 MILLION ADMINISTRATIVE FINE.