DUNHAM

Dunham runs a manager selection and monitoring process that evaluates institutional sub-advisors on performance, investment process, organizational stability, and alignment with fund mandates. The firm retains full discretion to replace sub-advisors, which is structurally different from a fund-of-funds that buys and sells positions in underlying vehicles. Specific selection criteria and quantitative thresholds are proprietary and not publicly detailed, but Dunham's prospectus disclosures confirm it can terminate sub-advisory agreements without shareholder vote.

Portfolio management authority is divided: each fund's sub-advisor makes day-to-day security selection decisions within the mandate, while Dunham — led by Jeffrey Dunham as CEO — controls manager selection, asset allocation framework, and the decision to retain or replace sub-advisors. This dual structure means investment decision accountability sits with a named institutional sub-advisor for security-level outcomes and with Dunham for manager-level outcomes.