Overview
A. General Description of Advisory Firm
GIA is a Delaware Limited Liability Company and began operations in July 2000. GIA is wholly owned
by GWM Holdco, LLC. GWM Holdco, LLC is a subsidiary of Guggenheim Partners, LLC, which in turn
is a subsidiary of Guggenheim Capital, LLC (“Guggenheim Capital”). Guggenheim Capital is owned in
part by Sage Assets, Inc. Sage Assets, Inc. is wholly owned by Consolidated Investment Services, Inc.,
which is wholly owned by Sammons Corporation, which is wholly owned by Sammons Enterprises, Inc.,
which is owned by Sammons Enterprises, Inc. Employee Stock Ownership Trust. GreatBanc Trust
Company is the Trustee for Sammons Enterprises, Inc. Employee Stock Ownership Trust.
B. Description of Advisory Services
GIA provides investment advisory services on a discretionary and non-discretionary basis to individuals
and entities in accordance with their respective stated objectives, investment guidelines, restrictions and
risk tolerance in separately managed accounts (“Wealth Management”). GIA’s business also provides
services to insurance company and other institutional clients that include implementation of quantitative
investment strategies whereby GIA will engage in hedging and event-driven strategies, primarily through
derivatives transactions. Additionally, GIA provides its clients ongoing evaluation, monitoring and
reporting of its strategies
(“Hedging Strategies”).
Please see “Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss” for more details on and
descriptions of GIA’s investment strategies.
The descriptions set forth in this Brochure of specific advisory services that GIA offers to clients should
not be understood to limit in any way GIA’s investment activities. GIA may, in the future, offer any
advisory services, engage in any investment strategy and make any investment that GIA considers
appropriate, subject to each client’s investment objectives and guidelines.
GIA does not restrict its investment advice to certain specific types of investments; however, decisions
regarding portfolio recommendations will be made in accordance with the applicable investor and/or stated
investment objectives, including limitations on investment.
C. Wrap Fee Programs
Currently, GIA does not sponsor a wrap fee program.
D. Assets Under Management
As of December 31, 2023, GIA managed approximately $690,263,539 of Regulatory Assets Under
Management (“RAUM”) on a discretionary basis and $186,222,882 of RAUM on a non-discretionary basis.
Approximately $530,034,767 of the discretionary RAUM is calculated based on the notional amount of
transactions entered into on behalf of GIA’s Hedging Strategies clients, rather than on market value; see
