Overview
GAM USA, a Delaware corporation with a principal place of business in New York, has been in business since
1989 and provides investment management services to pooled investment vehicles (including advisory services
to European regulated commingled funds referred to as “UCITS” and publicly traded open-end investment fund
structures offered in Europe referred to as “SICAVs”), corporate and public pension plans, trusts, estates,
charitable organizations, foundations, endowments, corporations, and other business entities. GAM USA is a
subsidiary of GAM Holding AG (“GAM Holding”), an independent asset management firm headquartered in
Zurich, Switzerland with shares listed on the SIX Swiss Exchange.
As of December 31, 2023, GAM USA’s assets under management were approximately $983,500,120, which are
managed on a discretionary basis.
GAM USA offers and advises on various investment products and services through separately managed
accounts and investment fund structures trading pursuant to strategies of GAM USA and/or its affiliates. In
addition to trading client accounts directly, these strategies could involve allocating a client’s assets among a
portfolio of funds and accounts managed by other affiliated and non-affiliated investment managers, including
private funds that operate pursuant to an exemption from registration as an investment company under the
Investment Company Act of 1940, as amended (the “Investment Company Act”), and that are offered to U.S.
clients and investors in private placements pursuant to Regulation D under the Securities Act of 1933, as
amended (the “Securities Act”). Strategies utilized by institutional accounts or separately managed accounts
involve investing a client’s assets directly in shares, bonds or other instruments in investment strategies as
described below. GAM USA does not provide financial planning services.
Institutional (Separately
Managed) Accounts
GAM USA offers institutional investors the flexibility of investing through individually customized managed
accounts, dedicated single investor private funds, or U.S. and non-U.S. domiciled commingled funds designed
for multiple investors that are managed by GAM USA or one or more of its affiliates (these commingled funds
are referred to as “GAM Funds”). For purposes of convenience, the privately-offered funds and other client
accounts that GAM USA manages or advises directly are sometimes referred herein as “GAM Accounts.”
GAM Accounts may invest and/or advise on:
• directly in securities, currencies, derivatives (for hedging purposes) and other financial instruments; or
• in pooled investment vehicles, including GAM Funds managed by GAM USA’s affiliates in the GAM group
of companies (the “GAM Group”), and/or funds managed by unrelated investment managers (“Portfolio
Managers”);
GAM USA’s affiliate, GAM International Management Limited (“GIML”), a non-U.S. based SEC-registered
investment adviser1, and other affiliates may serve as sub-advisers to some GAM Accounts. Investors meeting
GAM USA’s investment minimum of $100 million (which may be waived, modified or negotiated at GAM USA’s
sole discretion) may qualify for separately managed accounts.
1Such registration does not imply any level of skill or training or that the SEC has passed on the merits of the services provided by GIML.
2There are no guarantees that the risk management techniques utilized will eliminate or mitigate risk of loss.
GAM Accounts may invest in a wide range of investment strategies recommended by GAM USA depending
upon a client’s’/investor’s particular mandate. Prospective investors should refer to the applicable relevant
governing materials. Recommended investment strategies are typically managed either by GAM USA or its
affiliate GIML.