Pacific Investment Management Company LLC: Manager Rating and Record

Why Pacific Investment Management Company LLC has three stars

PIMCO runs USD 3.7 trillion of regulatory assets and has been registered with the SEC since 1994. It reports five matters in its Form ADV, the most recent brought by ICE Futures U.S. in 2025. Its one rated insurance-dedicated fund has four stars.

The rating looks only at the areas below, which matter to a family holding this manager's funds through a private placement policy. Past returns play no part: these funds do not report them in their SEC filings, and they say little about what a policy will earn.

Conduct and regulatory record

What regulators and courts have recorded against the manager, and for platform series against the platform, as the advisers report it to the SEC. Several proceedings on one set of facts count as one matter. Recent and serious matters count most, matters of other companies in the group count for less, matters of individuals are weighed by the person's role and their bearing on the business, and the size of the firm is taken into account.

Reported controls

What the adviser reports to the SEC for the fund: whether the accounts are audited every year by an accountant registered with the PCAOB and subject to its regular inspection, whether audited statements go to investors and what the audit opinion says, whether the administrator and custodian are outside the adviser's group, and what share of the assets was valued last year by a person not related to the adviser.

Depth and experience of the manager

The assets the manager runs, its investment staff and how long it has been registered with the SEC.

PPLI.comManager Rating

Investor experience. What policyholders, insurers and advisers tell us is shown separately and never changes the stars. A factual point they raise is checked against the filings, and if it holds, the data is corrected. We never publish names. Tell us about yours

The rating expresses the opinion of PPLI.com on the date shown. It is not a statement of fact about the fund or its manager, not a credit rating, not a forecast of returns and not investment advice. Read about the rating.

Registration and size

Identity

Legal namePacific Investment Management Company LLC

SEC registrationRegistered investment adviser, 801-48187 IAPD

CRD number104559

Latest Form ADV23 October 2026 ADV

Registered with the SEC since14 November 1994

Assets and staff, as filed

Regulatory assets under managementUSD 3,666,935,000,000

Of which discretionaryUSD 3,666,479,000,000

Employees1,968

Of which investment advisory staff628

Private funds listed in Schedule D210

Regulatory assets are calculated under the SEC's Form ADV instructions and include all funds and accounts the adviser manages, not only those open to insurers. Figures come from the SEC's adviser files of November 2026.

Regulatory and legal record

What the adviser itself discloses in Item 11 of its Form ADV, summarised from the disclosure pages, with a link to the filing. Item 11 is filed for the adviser as a whole, so under each matter the fund it concerns is read from the disclosure itself.

20257 May 2025

Regulatory action by New York Mercantile Exchange ("NYMEX"): civil penalty

Fund concerned: none named in the filing. The matter concerns the adviser itself, not a specific fund, and none of the insurance-dedicated funds in this file is named.

The registrant was alleged to have violated NYMEX Rule 562 by exceeding position limits in the October 2024 crude oil Futures as of the close of business on September 17, 2024.

New York Mercantile Exchange ("NYMEX") · Settled 9 May 2025 · USD 26,220 · Concerns the adviser itself · Form ADV, Item 11 disclosure

202519 March 2025

Regulatory action by ICE Futures U.S. ("ICE"): civil penalty

Fund concerned: none named in the filing. The matter concerns the adviser itself, not a specific fund, and none of the insurance-dedicated funds in this file is named.

On March 19, 2025, a subcommittee of the Exchange's business Conduct committee ("BCC") determined that PIMCO May have violated Exchange Rule 4.02(c) in September 2023, when employees placed orders, including through different and independent executing Brokers, for two accounts with common beneficial ownership in the California carbon allowance vintage 2023 contract ("CB1"), a portion of which ultimately matched opposite one another. Based on information obtained, it appeared that the employees did not intend for the orders to match, however, they should have known that the orders would Trade opposite one another.

ICE Futures U.S. ("ICE") · Settled 19 March 2025 · USD 100,000 · Concerns the adviser itself · Form ADV, Item 11 disclosure

202316 June 2023

Regulatory action by US Securities and Exchange Commission: civil penalty

Fund concerned: PIMCO All Asset All Authority Fund, a public mutual fund. None of the insurance-dedicated funds in this file is named.

On June 16, 2023, PIMCO entered into a settlement agreement with the SEC relating to an error in the fee waiver calculation used by PIMCO'S third-party vendor that caused certain advisory fees to be under-waived from April 2011 to November 2017 and charged to PIMCO all Asset all Authority Fund ("A4"). Under the terms of the settlement, PIMCO agreed to pay to the SEC a civil Monetary penalty in the amount of $2.5 million. Prior to the SEC'S investigation, PIMCO had identified the error, publicly disclosed the issue and implemented a plan that reimbursed a4 and its shareholders for any losses associated with the fee waiver miscalculation. In addition, PIMCO has enhanced its policies and ...

US Securities and Exchange Commission · Settled 16 June 2023 · USD 2.5 million · Concerns the adviser itself · Form ADV, Item 11 disclosure

202316 June 2023

Regulatory action by US Securities and Exchange Commission: civil penalty

Fund concerned: none named in the filing. The matter concerns the adviser itself, not a specific fund, and none of the insurance-dedicated funds in this file is named.

On June 16, 2023, PIMCO entered into a settlement agreement with the SEC relating to certain disclosures in the 2014 and 2015 annual shareholder reports of PIMCO Global stocksplus & income Fund ("PGP") regarding pgp's use of paired interest rate swaps in its portfolio. Under the terms of the settlement, PIMCO agreed to pay to the SEC a civil Monetary penalty in the amount of $6.5 million. Prior to the SEC'S investigation, PIMCO had updated the disclosures in pgp's 2016 annual shareholder report.

US Securities and Exchange Commission · Settled 16 June 2023 · USD 6.5 million · Concerns the adviser itself · Form ADV, Item 11 disclosure

20161 December 2016

Regulatory action by US Securities and Exchange Commission: civil penalty

Fund concerned: PIMCO Total Return Active Exchange-Traded Fund (BOND), a public ETF. None of the insurance-dedicated funds in this file is named.

On December 1, 2016, PIMCO entered into an agreement with the U.S. Securities and Exchange Commission ("SEC") to settle charges relating to the PIMCO total return active exchange-traded Fund ("bond"). The SEC alleged that from February 29, 2012 to June 30, 2012, PIMCO did not sufficiently disclose the sources of performance for bond, inaccurately valued 43 smaller-sized ("ODD lot") positions of non-agency mortgage backed Securities using third-party vendor prices, and did not adopt and implement adequate written policies and procedures related to these matters. The SEC found, and PIMCO neither admitted nor denied, that PIMCO violated Section 206(2) of the Investment Advisers Act of 1940 ...

US Securities and Exchange Commission · Settled 1 December 2016 · USD 18.3 million · Concerns the adviser itself · Form ADV, Item 11 disclosure

These are the matters Pacific Investment Management Company LLC reports in Item 11 of its Form ADV, filed 23 October 2026. A reported matter is a fact disclosed by the adviser, not a finding by PPLI.com. None of them concerns the insurance-dedicated funds listed above.

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Pacific Investment Management Company LLC

Insurance-dedicated funds managed by PIMCO

Why Pacific Investment Management Company LLC has three stars

Conduct and regulatory record

Reported controls

Depth and experience of the manager

Registration and size

Identity

Assets and staff, as filed

Regulatory and legal record

Regulatory action by New York Mercantile Exchange ("NYMEX"): civil penalty

Regulatory action by ICE Futures U.S. ("ICE"): civil penalty

Regulatory action by US Securities and Exchange Commission: civil penalty

Regulatory action by US Securities and Exchange Commission: civil penalty

Regulatory action by US Securities and Exchange Commission: civil penalty

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