DESCRIPTION OF THE COMPANY This Disclosure Brochure describes the advisory services offered by AssetMark, Inc. (“AssetMark”) through its Retirement Services division to defined contribution retirement plans qualified under Internal Revenue Code (“IRC”) Section 401(k) and to IRC Section 403(b) Client Plans (“Client” or “Client Plans”).
AssetMark is an investment adviser registered with the U.S. Securities and Exchange Commission providing various investment advisory services pursuant to Investment Management Services Agreements (“IMSAs”) or Client Services Agreements (“CSAs”) (“Client Agreements”) since 1999. AssetMark is a wholly-owned subsidiary of AssetMark Financial Holdings, Inc. AssetMark Financial Holdings, Inc. is an indirect subsidiary of Huatai Securities, Co., Ltd. (“HTSC”). HTSC is a financial services and securities brokerage firm, incorporated in China and listed on the Shanghai and Hong Kong stock exchanges with global depository receipts (“GDRs”) listed on the London stock exchanges. Entities incorporated in China may be subject to China’s laws and regulations that differ from those in the United States. AssetMark Financial Holdings, Inc., is publicly listed on the New York Stock Exchange (ticker: AMK).
AssetMark is the sponsor of the AssetMark Platform (the “Platform”) through which it offers its advisory services to its clients. AssetMark Wealth Solutions includes AssetMark Asset Management (AAM), Due Diligence, Investment Consulting and other portfolio, wealth, and practice solutions. AAM manages AssetMark’s proprietary investment strategies. AAM replaces AssetMark Portfolio Solutions (APS) (formerly referred to as AssetMark Investment Management).
AssetMark also serves as the investment adviser for the following registered investment companies (“Proprietary Funds”): 1) GuideMark Funds (no-load sub-advised mutual funds) 2) GuidePath Funds (no-load funds of funds and a sub-advised managed futures mutual fund) AssetMark is responsible for the selection and management of subadvisors for each of the GuideMark Funds. AssetMark is not registered with the Commodity Futures Trading Commission (“CFTC”) as a commodity trading advisor, based on its determination that it may rely on certain exemptions from registration provided by the Commodity Exchange Act (“CEA”) and the rules thereunder. The CFTC has not passed upon the availability of these exemptions to AssetMark. AssetMark currently acts as a registered “commodity pool operator” (“CPO”) with respect to the GuidePath Managed Futures Strategy Fund and its wholly owned controlled foreign corporation, the GuidePath Managed Futures Strategy Cayman Fund. AssetMark is registered as a CPO under the CEA and the rules of the CFTC.
DESCRIPTION OF THE RETIREMENT ADVISORY SERVICES I. IRC 401(k) and IRS 413(e) Retirement Advisory Services Through its Retirement Services division and pursuant to Client Agreements with Client, AssetMark provides advisory services to defined contribution retirement plans intended to be qualified under Internal Revenue Code of 1986 (“IRC”) Section 401(a) that maintain individual accounts (“Accounts”) for their Participants (generally IRC 401(k) plans). AssetMark also provides advisory services to Clients that are employers that have been admitted to a pooled employer plan (the “PEP”) that has been established under IRC Section 413(e)and Section 3(43) of Employee Retirement Income Security Act of 1974, as amended, (“ERISA”) and is administered by a registered pooled plan provider (the “Pooled Plan Provider”) within the meaning of Section 3(44) of ERISA and Section 413(e) (3) of the IRC. The Pooled Plan Provider is independent of and not affiliated with AssetMark.
Pursuant to the Client Agreements, AssetMark acknowledges that it is providing investment advice to the Client Plan and is a “fiduciary” (within the meaning of section 3(21) of the Employee Retirement Income Security Act of 1974), and accepts appointment as an “investment manager” (within the meaning of Section 3(38) of ERISA) with discretion, in all instances, to the extent that a Client Plan is subject to ERISA and to the extent it provides: i. investment advisory services to Client Plan assets pursuant to the Client Agreements, and ii. in the case of Clients admitted to the PEP, to the extent it provides investment advisory services to the Client with respect to the assets in the PEP, that are attributable to employees of the Client.
AssetMark develops and maintains Investment Alternatives for use by the Client Plans’ Participants and beneficiaries. These Investment Alternatives include individual mutual funds and/or exchange traded funds (“ETFs”) (collectively, “Individual Funds”) and Managed Accounts Solutions (as described below). AssetMark provides the investment advisory services in accordance with any reasonable investment restrictions specified by the Client Plan and accepted by AssetMark.
AssetMark provides the Managed Accounts Solutions through the maintenance of “Asset Allocation Models,” which specify the percentage of specific securities to be held by each Account. AssetMark has contracted with investment management firms (“Portfolio Strategists”) to provide Asset Allocation Models comprised of recommended portfolio allocations. Portfolio

Strategists do not provide discretionary investment management services to Accounts. A Client may specify the initial Investment Alternatives to be provided by the Plan to Plan Participants. AssetMark has the authority to replace Investment Alternatives at its discretion. AssetMark has the authority to select, remove and replace securities, including mutual fund and ETF shares, and other investments, as Investment Alternatives, in Client Plan Accounts, and with regard to the Managed Accounts, to determine the portion of assets in the Managed Account that shall be allocated to each fund share, security, investment or asset class and to change such allocations. AssetMark has the authority to remove an Individual Fund or Managed Account Solution as an Investment Alternative, including but not limited to a Qualified Default Investment Alternative (“QDIA”) and, at its discretion, direct, or not, that Page 3 of 9AssetMark Retirement Services Disclosure Brochure Client Plan assets invested in the removed Investment Alternative be moved to another (existing or new) replacement Investment Alternative. AssetMark can also act as a Portfolio Strategist for AssetMark‘s proprietary Investment Alternatives offered to the Client Plans. Information about specific Investment Alternatives offered to the Client Plans is included in the AssetMark Retirement Services Quarterly Performance Review that can be obtained from the client’s financial advisor.
AssetMark does not provide Plan Participants and beneficiaries individualized investment advice. AssetMark does not know the individual investment objectives of Plan Participants and beneficiaries and AssetMark has no responsibility for determining whether any Investment Alternative is suitable for any particular Plan Participant or Client Plan. AssetMark is responsible for determining whether the Investment Alternatives are generally suitable to be investments for Client Plans.
II. IRC 403(b) Advisory Services Pursuant to Client Agreements, AssetMark provides advisory services to plans intended to be qualified under IRC Section 403(b) that maintain individual accounts (“Accounts”) for their Participants. Pursuant to the Client Agreements, AssetMark acknowledges that it is providing investment advice to the Client Account and is a “fiduciary” (within the meaning of section 3(21) of ERISA) and accepts appointment as an “investment manager” (within the meaning of Section 3(38) of ERISA) with discretion for ERISA, in all instances, to the extent a Plan is subject to ERISA and to the extent it provides investment advisory services to Client Plan assets pursuant to the Client Agreements.
Fidelity 403(b) Portfolios AssetMark provides asset allocation services to participants of 403(b) plans where Fidelity Institutional Wealth Services (“Fidelity”) is an authorized provider under the Participant’s plan. AssetMark provides asset allocation services to participants based upon investment choices made available through the Participants’ plans or through Brokerage Link, if available. Mutual fund options for the Fidelity 403(b) portfolios generally do not include all mutual funds offered by Fidelity, and in most cases, are limited to only certain Fidelity family mutual funds. As a result, risk characteristics and returns of Fidelity 403(b) portfolios could vary significantly from non-Fidelity 403(b) portfolios. AssetMark provides investment advisory services in accordance with any reasonable investment restrictions specified by the Clients’ Plans and accepted by AssetMark. Minimum account size is $50,000 and is subject to negotiation.
TIAA CREF – 403(b) Portfolios (closed to new accounts) AssetMark provides asset allocation services to participants of 403(b) plans where TIAA CREF is an authorized provider under the participant’s plan. AssetMark provides asset allocation services to participants based upon investment choices made available through the Client Plan. Mutual fund options for the TIAA CREF portfolios typically include all (or almost all) mutual funds offered by TIAA CREF. Minimum account size is $50,000 and subject to negotiation.
Screened Portfolios (Values Based Portfolios) AssetMark offers portfolios screened for various values-based considerations (“Screened Portfolios”) Screened Portfolio allocations are typically constructed from mutual funds, but also include Managed Accounts Solutions, individual securities, closed-end funds and exchange traded funds. Mutual funds utilized in Screened Portfolios are selected from a more limited menu of mutual funds than non-screened allocations offered by AssetMark. As a result, risk characteristics and returns of Screened Portfolios could vary significantly from non-screened portfolios. Minimum account sizes for applicable services apply and are subject to negotiation.
AssetMark’s Retirement Services division does not participate in a Wrap Fee program.
SERVICES NO LONGER OFFERED AssetMark continues to provide other advisory services which are no longer offered to new Clients. Clients with these services may contact AssetMark for more information.
ASSETS UNDER MANAGEMENT As of December 31, 2023, AssetMark had $1.4 billion in assets under management under the Retirement Services division programs.