GPIM is a Delaware limited liability company formed on September 29, 2005. Guggenheim Capital, LLC
(“Guggenheim Capital”) is the sole owner of GPIM through a series of holding companies, including
Guggenheim Manager, Inc.; Guggenheim Partners, LLC (“Guggenheim Partners”); GI Holdco II LLC; GI
Holdco LLC; GMI GPIMH, LLC; GMI GPIM, LLC; and Guggenheim Partners Investment Management
Holdings, LLC (“GPIMH”). Sage Assets, Inc. holds a minority ownership interest in Guggenheim Capital,
LLC. Consolidated Investment Services, Inc. owns SAGE Assets, Inc. Sammons Corporation owns
Consolidated Investment Services, Inc. Sammons Enterprises, Inc. owns Sammons Corporation. Sammons
Enterprises, Inc. Employee Stock Ownership Trust owns Sammons Enterprises, Inc. GreatBanc Trust
Company is the Trustee for Sammons Enterprises, Inc. Employee Stock Ownership Trust.
As of December 31, 2023, GPIM managed approximately $208,355,233,993 of Regulatory Assets Under
Management (“RAUM”) on a discretionary basis and $398,388,763 of RAUM on a non-discretionary basis.
GPIM provides investment advisory and supervisory services, primarily focused on implementing fixed income
and equity asset management strategies, to a variety of institutional clients through separately managed accounts
(“SMAs”) and registered and unregistered pooled investment vehicles.
An SMA client selects a custodian for the SMA and is charged a periodic fee for management of assets and, in
some cases, a performance or incentive fee or allocation on profits or gains generally subject to a benchmark
or threshold agreed upon by the client and GPIM. For SMAs, a client’s initial investment objectives are
determined in consultation with the client. Investment guidelines and these objectives are memorialized by
GPIM and the client prior to implementation of a strategy. Certain SMA clients impose restrictions on GPIM’s
authority to invest in specific securities and types of securities, or to use leverage, for example. The investment
guidelines are documented in each client’s investment management agreement (“IMA”) and may be updated
with the client’s consent for reasons including a change in the client’s situation or needs or a change in relevant
market conditions. GPIM reviews these objectives, guidelines, and restrictions in the normal course of
business, but no less frequently than annually.
GPIM also provides advisory and sub-advisory services to pooled investment vehicles (“Funds”), some of
which are registered investment companies (“Registered Funds”) under the Investment Company Act of 1940,
as amended (“1940 Act”). For both unregistered Funds (“Private Funds”) and Registered Funds, the Fund’s
investment objective, strategies, and any applicable investment restrictions are generally described in that Fund’s
offering documents and may be changed in accordance with the Fund’s offering and organizational documents
and as permitted by law. GPIM and/or the Private Funds have entered into, and may in the future enter into,
side letters or other agreements (“Side Letters”) with certain investors in the Private Funds that have the effect
of establishing different or preferential rights or terms (including but not limited to different fee structures,
economic terms, information rights, co-investment rights, and/or liquidity rights) under, or altering or
supplementing the terms of, the relevant offering and organizational documents with respect to such investors.
Other investors in such Private Funds, including SMAs and other vehicles advised by GPIM will, generally, not
be notified of such Side Letters or offered similar terms, unless GPIM has contractually undertaken to provide
such notification or otherwise determines to provide it.
Additionally, GPIM provides advisory and sub-advisory services to one or more Collective Investment Trusts
(“CIT”). Each CIT’s investment objective,
strategies, and any applicable investment restrictions are generally
described in that CIT’s offering documents and may be changed in accordance with the CIT’s offering and
organizational documents and as permitted by law. GPIM and/or the CIT have entered into, and may in the
future enter into agreements with certain investors in the CIT that have the effect of establishing different or
preferential rights or terms (including but not limited to different fee structures and/or customized reporting)
under, or altering or supplementing the terms of, the relevant offering and organizational documents with
respect to such investors. Other investors in the CIT, including but not limited to SMAs and other clients
advised by GPIM will, generally, not be notified of such arrangements or offered similar terms, unless GPIM
has contractually undertaken to provide such notification or otherwise determines to provide it.
GPIM may on occasion prepare written commentary on general market conditions. The commentary is
prepared to educate and inform current and prospective clients, consultants, and other business contacts about
market conditions or trends that GPIM may consider of interest. GPIM does not charge a fee for providing
this written commentary.
In addition, GPIM provides recommendations on investment opportunities and investment advice to particular
clients. The client receiving these recommendations ultimately decides how and if it will use such
recommendations. GPIM charges a separate fee for such services.
GPIM does not participate in any wrap fee program.
The description of GPIM’s investment advisory clients above is a summary and not intended to be exhaustive.
Guggenheim Corporate Funding, LLC (“GCF”), an affiliate of GPIM, provides services to both GPIM and
GCF clients with respect to the sourcing, origination and execution of Private Corporate Debt investments (as
defined in “Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss – Private Corporate Debt”).
GPIM has executed sub-advisory arrangements with GCF pursuant to which GCF provides investment advice
to GPIM, focused on originated private corporate debt and structured corporate equity investments, for
GPIM’s use in connection with managing (i) a limited number of existing legacy GPIM originated private debt
single-strategy client accounts, (ii) a limited number of existing GPIM co-mingled vehicles that invest in
originated private debt (together the “Applicable Private Debt Legacy Clients”), and (iii) a limited number of
other legacy existing GPIM client accounts, that have purchased originated private corporate debt (“Other
Legacy Clients”). Investments that are sourced by GCF, will be provided first to GCF clients and GPIM for
allocation to Applicable Private Debt Legacy Clients and a portion of the remainder to GPIM for allocation to
Other Legacy Clients, as described herein.
Certain GCF personnel also serve as senior advisers to one or more GPIM investment committees. In addition,
GPIM has entered into one or more agreements with GCF pursuant to which certain GCF personnel serve as
portfolio managers with respect to certain Applicable Private Debt Legacy Clients. GPIM expects to continue
to periodically source private corporate debt or structured corporate equity investments only for GPIM clients.
Further, a team of 90 Corporate Credit investment professionals, including 11 GCF personnel, continues to
serve GPIM clients in connection with researching, investing in and managing corporate credit assets, including
bank loans, high yield bonds and investment grade bonds in both public and private companies.
GPIM for many years provided macro research services to clients, investors and funds. These services have
transitioned back to GPIM from Guggenheim Partners Advisors, LLC (an affiliated investment adviser), which
assumed these responsibilities for a short period.