GLOBAL STRATEGIC INVESTMENT SOLUTIONS, LLC

This brochure provides information about the qualifications and business practices of Global Strategic Investment Solutions. If you have any questions about the contents of this brochure, please contact us at 480-935-2210 or by email at: munderwood@gsisus.com The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Global Strategic Investment Solutions is also available on the SEC’s website at www.adviserinfo.sec.gov. Global Strategic Investment Solutions, LLC’s CRD number is: 175300. 7337 East Doubletree Ranch Road, Suite C-165 Scottsdale, AZ 85258 480-935-2210 www.gsisus.com munderwood@gsisus.com Registration does not imply a certain level of skill or training. Version Date: 03/28/2025 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Global Strategic Investment Solutions, LLC on 03/28/2024 are described below. Material changes relate to Global Strategic Investment Solutions, LLC’s policies, practices or conflicts of interests. • Global Strategic Investment Solutions, LLC has updated its new email id. • Global Strategic Investment Solutions, LLC has updated their primary office address (Front Page). ii  Item 3: Table of Contents Item 1: Cover Page Contents Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................1 A. Description of the Advisory Firm ................................................................................................................1 B. Types of Advisory Services ...........................................................................................................................1 C. Client Tailored Services and Client Imposed Restrictions ........................................................................2 D. Wrap Fee Programs ........................................................................................................................................3 E. Assets Under Management ............................................................................................................................3 Item 5: Fees and Compensation .............................................................................................................................3 A. Fee Schedule ....................................................................................................................................................3 B. Payment of Fees ...............................................................................................................................................4 C. Client Responsibility For Third Party Fees .................................................................................................4 D. Prepayment of Fees ........................................................................................................................................4 E. Outside Compensation For the Sale of Securities to Clients .....................................................................4 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................4 Item 7: Types of Clients ..........................................................................................................................................5 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss............................................................5 A. Methods of Analysis and Investment Strategies ..................................................................................5 B. Material Risks Involved ...........................................................................................................................7 C. Risks of Specific Securities Utilized ........................................................................................................8 Item 9: Disciplinary Information .........................................................................................................................12 A. Criminal or Civil Actions .......................................................................................................................12 B. Administrative Proceedings ..................................................................................................................12 C. Self-regulatory Organization (SRO) Proceedings ...............................................................................12 Item 10: Other Financial Industry Activities and Affiliations .........................................................................12 A. Registration as a Broker/Dealer or Broker/Dealer Representative ................................................12 Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity B. Trading Advisor ................................................................................................................................................12 iii  Registration Relationships Material to this Advisory Business and Possible Conflicts of C. Interests ...............................................................................................................................................................13 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ............................................................................................................................................................13 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............13 A. Code of Ethics ..........................................................................................................................................13 B. Recommendations Involving Material Financial Interests ...............................................................13 C. Investing Personal Money in the Same Securities as Clients ............................................................14 D. Trading Securities At/Around the Same Time as Clients’ Securities .............................................14 Item 12: Brokerage Practices ................................................................................................................................14 A. Factors Used to Select Custodians and/or Broker/Dealers..............................................................14 1. Research and Other Soft-Dollar Benefits ..........................................................................................14 2. Brokerage for Client Referrals ...........................................................................................................15 3. Clients Directing Which Broker/Dealer/Custodian to Use ..........................................................15 B. Aggregating (Block) Trading for Multiple Client Accounts .............................................................15 Item 13: Reviews of Accounts ..............................................................................................................................15 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ..............................15 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ............................................16 C. Content and Frequency of Regular Reports Provided to Clients .....................................................16 Item 14: Client Referrals and Other Compensation ..........................................................................................16 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales A. Awards or Other Prizes) ...................................................................................................................................16 B. Compensation to Non – Advisory Personnel for Client Referrals ...................................................17 Item 15: Custody ....................................................................................................................................................17 Item 16: Investment Discretion ............................................................................................................................17 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................18 Item 18: Financial Information .............................................................................................................................18 A. Balance Sheet ...........................................................................................................................................18 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ..................................................................................................................................................................18 C. Bankruptcy Petitions in Previous Ten Years .......................................................................................18 iv  Item 4: Advisory Business A. Description of the Advisory Firm Global Strategic Investment Solutions, LLC (hereinafter “GSIS”) is a Limited Liability Company organized in the State of Arizona. The firm was formed in March 2015, and the principal owners are Donald E. Callaghan and Curt R. Thompson. B. Types of Advisory Services Portfolio Management Services GSIS offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. GSIS creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring GSIS evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. GSIS will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. GSIS seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of GSIS’s economic, investment or other financial interests. To meet its fiduciary obligations, GSIS attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, GSIS’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is GSIS’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time.  Selection of Other Advisers GSIS may direct clients to third-party investment advisers to manage a portion of the client's assets. Before selecting other advisers for clients, GSIS will always ensure those other advisers are properly licensed or registered as an investment adviser. GSIS conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. GSIS then makes investments with a third-party investment adviser by referring the client to the third-party adviser. GSIS may also allocate among one or more private equity funds or private equity fund advisers. GSIS will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Services Limited to Specific Types of Investments GSIS generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), equities, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, interval and tender offer funds, venture capital funds and other private equity funds. GSIS may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions GSIS will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by GSIS on behalf of the client. GSIS may use “model portfolios” together with 2  a specific set of recommendations for each client based on their personal finances, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. GSIS does not participate in any wrap fee programs. E. Assets Under Management GSIS has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 17,419,855 December 2024 $ 1,431,074,927 Item 5: Fees and Compensation A. Fee Schedule Asset-Based Fees for Portfolio Management GSIS provides customized solutions based on the unique situation of each client. The base advisory fee is individually negotiated and generally ranges between 0.15% and 0.70% of assets under management subject to a minimum annual fee of $25,000. Considerations include the size of the relationship, number of accounts, custodial relationship, external parties, and complexity of reporting for managed assets. A separate fee may be negotiated for additional project-based services including support of externally-held investment assets such as legacy private market investment interests. The final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of GSIS's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. GSIS uses month-end values in the client's account for purposes of determining the market value of the assets upon which the advisory fee is based. Lower fees for comparable services may be available from other sources. 3  Selection of Other Advisers Fees GSIS will receive its standard fee on top of the fee paid to any third-party adviser; GSIS will not receive a portion of the fee charged by the third-party adviser. The fees will not exceed any limit imposed by any regulatory agency. The notice of termination requirement and payment of fees for third-party investment advisers will depend on the specific third-party adviser selected. These fees are negotiable. B. Payment of Fees Payment of Asset-Based Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization monthly in arrears. The custodian is provided with the applicable fee schedule upon commencement of the client’s account opening and will calculate monthly fees, issuing a statement to the client each month reflecting the advisory fees. Payment of Selection of Other Advisers Fees The timing, frequency, and method of paying fees for selection of third-party managers will depend on the specific third-party adviser selected. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by GSIS. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees GSIS collects its fees in arrears. It does not collect fees in advance. E. Outside Compensation For the Sale of Securities to Clients Neither GSIS nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management GSIS does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. 4  Item 7: Types of Clients GSIS generally provides advisory services to High-Net-Worth Individuals, Donor-Advised Funds, Endowments and Foundations. There is no account minimum. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis GSIS has an investment committee chaired by the firm’s Chief Investment Strategist. We leverage our own research and insights from our thought leader partnerships to develop proprietary models that execute a systematic investment strategy that is dynamic and customizable to each client. We rely heavily on quantitative models (both proprietary models and those sourced from third parties) and information and data sourced from third parties (“Models and Data”). Quantitative investment analysis is a method of evaluating securities and other assets by analyzing a large amount of data using models to generate investment decisions. Our models may consider a wide breadth of factors from valuation, macroeconomic risk regime, sentiment and relative strength. These inputs, combined with our model construction methodology, dynamic allocation process, and trading technology, are the foundation of our investment process. Investment Strategies GSIS utilizes a long-term investment strategy that includes our dynamic strategic asset allocation framework explained above. This is implemented through the following processes: Asset Allocation Generally, GSIS initiates a new client relationship with a review that is designed to: • identify and describe the major components and characteristics essential to the long- term success of the client’s investment portfolio under our care; • provide a brief review of such components and the client’s present investment portfolio status based on all disclosed information; and 5  • develop a long-term action plan, including the priority level for each action. Aided by statistical models and Capital Market Assumptions sourced an ensemble composite model of forward expectations of return, risk, and asset co-movement, we develop forecasts for the potential returns and risks of various investment allocations. Using this information, we recommend several viable strategic asset allocation policies, consistent with the particular client’s objectives and limitations. We then work with the client to select the desired asset allocation policy to implement. A client’s ability, willingness, and need for risk are taken into consideration when implementing an asset allocation. This policy serves as the anchor for our dynamic portfolio construction framework that is implemented via investments made with third-party investment managers across public and private market universes. Quantitative and qualitative factors in our dynamic active strategic allocation are used to determine clients’ positioning relative to their strategic asset allocation targets. Investment Selection and Due Diligence GSIS performs due diligence on a range of investment products and/or managers, including, but not limited to, publicly traded ETFs and mutual funds, public and private alternative investments, private funds, closed-end funds/BDCs, subadvisors/separate account managers, exchange traded notes, and structured notes. Key diligence includes areas such as investment philosophy, performance track record, organizational structure, alignment of interests, portfolio construction and fit, risk management and compliance, transparency of data and valuation policy, ethics and duties of care, and references/reputation. Both quantitative and qualitative analyses are core to the investment selection process. Quantitative analysis is used to measure a strategy’s construction, ex-ante risk contributions, and historical risk-adjusted performance relative to an appropriate peer group. GSIS looks at factors such as return, internal rate of return, volatility, upside and downside capture, Sharpe ratio, drawdown, and others. Qualitative analysis focuses on a manager’s process, philosophy, and alignment of interests with the client. The goal of this analysis is to determine whether a strategy can generate superior risk-adjusted results in a sustainable manner while fulfilling a fiduciary standard of care for our clients. Rebalancing Rebalancing is the process of balancing the portfolio allocation that has deviated away from the client’s asset allocation targets through the buying of underweight securities and selling overweight securities. This process helps maintain allocations nearer to a 6  constant mix of risk-seeking and risk-mitigating assets that aligns with the agreed upon investment policy allocation ranges and active strategic positioning. GSIS implements investment strategies through the process of asset allocation, investment selection, and ongoing rebalancing to target allocations. B. Material Risks Involved Methods of Analysis Valuation analysis concentrates on factors that determine a company’s or sector’s value and expected future earnings. This strategy would normally encourage equity or asset sector purchases in stocks, mutual funds, or ETFs that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Quantitative Model Risk: Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Modern Portfolio Theory assumes that investors are risk adverse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Rebalancing is implemented as a key process to aid in managing the overall portfolio risk such that it does not increase to a level where a downside market event would impair the portfolio to an extent that would create an unrecoverable shortfall relative to client goals. This process of decreasing downside potential could also reduce returns relative to an non-rebalanced portfolio over the long-term. Investment Strategies Long-Term Investing is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. 7  Asset Allocation: The selection and weighting of asset classes and/or underlying funds can cause it to underperform other funds with a similar investment objective. Further, client constraints may cause additional deviation and opportunity cost relative to the unconstrained portfolio allocation. Selection of Other Advisers: Although GSIS will seek to select only money managers who will invest clients' assets with the highest level of integrity, GSIS's selection process cannot ensure that money managers will perform as desired and GSIS will have no control over the day-to-day operations of any of its selected money managers. GSIS would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulator breach or fraud. Margin Accounts and Borrowing Risk: Clients may elect to add a margin loan balance to an eligible account. A margin account is a type of account in which a brokerage firm lends a client cash, using securities in the account as collateral, to purchase additional marginable securities or withdraw cash from the account. Margin borrowing is a type of leveraged transaction in which the obligations are secured by the investments within a portfolio. Leveraged transactions entail greater risk than non-leveraged transactions. As a result, GSIS does not endorse the use of margin for purposes of leveraging an investment portfolio. The use of margin presents significant additional risks, including but not limited to margin interest debt, risk of loss, reduced flexibility for future income, leverage risk and margin call risk. Margin can magnify losses just as dramatically as it can boost returns. If the value of the securities being used as collateral for the margin loan falls below the minimum equity maintenance requirement, the account may incur a margin call, meaning that cash or securities will need to be added to the account to increase equity and maintain the line of credit. Clients should obtain a complete copy of the custodian's account agreement, to fully understand margin-related activities. Investing in public and private capital markets involves bearing a meaningful risk of loss and impairment of capital. Clients should be prepared to bear this risk and review all regulatory documents, prospectuses, and private placement memoranda (PPM) pertaining to the purchase of investments in their portfolio. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. 8  Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Short-term debt (such as US Treasury Bills and commercial paper) are issued at a discount to their par value, and do not pay any interim income before maturity. Fixed income securities also carry inflation risk, liquidity risk, reinvestment risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing principal value due to deflation (negative inflation) adjustments. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Real Estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. 9  Interval Funds and Tender Offer Funds are non-diversified, closed-end management investment companies, registered under the Investment Company Act of 1940. Investments in an interval fund or tender offer fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. Additionally, the fund may have a limited amount of capacity and may not be able to fulfill all purchase orders. While an interval or tender offer fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. The closed- end interval funds recommended by GSIS impose liquidity thresholds (often 5% per quarter) for each repurchase offer and in the event the offer is oversubscribed, the requested redemption amount may be reduced. Tender offer funds target a similar liquidity threshold, but can potentially reduce/remove this liquidity (called gating) with approval from the fund’s board. As interval and tender offer funds may expose investors to liquidity risk, investors should consider these fund shares to be an illiquid investment. Typically, the interval and tender funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Clients should carefully review the fund’s prospectus to more fully understand the interval and tender offer fund structure and the corresponding liquidity risks. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some or all of the investment. These funds also have higher average costs due to management fees, higher administrative costs, and performance incentive fees (“carry”) of the fund manager. Although interval funds most often have a daily net asset value (NAV) for purchases, tender offer funds price their shares less frequently (either monthly or quarterly). These NAV calculations may be published several weeks after the end of the performance period. Alternative Fund Risk: Certain alternative funds (registered under the Investment Company Act of 1940) utilized may employ the use of derivatives, options, futures and/or short sales. Use of derivatives, options or futures by a Fund may be for purposes of gaining exposure to a particular asset group, for hedging purposes or for leverage purposes. The use of derivatives, options and futures exposes the funds to additional risks and transaction costs. In addition, if the Fund uses leverage through activities such as entering into short sales or purchasing derivative instruments, there are additional risks, including the fund having the risk that losses may exceed the net assets of the fund. The net asset value of a fund while employing leverage will be more volatile and 10  sensitive to market movements. Clients should carefully review the fund’s prospectus to more fully understand the risk of funds employing the use of derivatives, options, futures and/or short sales. Investments in these funds should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some or all the investment. Other potential risk factors include lack of liquidity, lack of transparency, layering of fees, and other risks as identified by such managers in their disclosure documents. Private equity funds carry certain risks. Capital calls will be made on short notice, and the failure to meet capital calls can result in significant adverse consequences, including but not limited to a total loss of investment. These funds often may be illiquid for long periods of time. These funds also have higher average costs due to management fees, higher administrative costs, and performance incentive fees (“carry”) of the fund manager. Net Asset Value (NAV) calculations may be published several months after the end of the performance period. Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. In addition, they carry the same categories of risk as other private equity funds. These funds often may be illiquid for long periods of time. These funds also have higher average costs due to management fees, higher administrative costs, and performance incentive fees (“carry”) of the fund manager. Net Asset Value (NAV) calculations may be published several months after the end of the performance period. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Derivatives such as options, futures and swaps, can be volatile, and a small investment in a derivative can have a large impact on the performance of the portfolio. Other risks of investments in derivatives include imperfect correlation between the value of these instruments and the underlying assets; risks of default by the other party to the derivative transactions; risks that the transactions may result in losses that partially or completely offset gains in portfolio positions; and risks that the derivative transactions may not be liquid. Seller of options additionally bear option assignment risk. Option Assignment occurs when the option seller is forced to buy (for a put) or sell (for a call) stock when the short option is exercised by the long option holder, causing the position's risk profile to change. This change could increase the margin requirements, or 11  subject a trader to a margin call, or both. This can happen at or before expiration during an early assignment. The exercise of a long option position can be more likely to trigger a margin call since naked short option trades (where the client does not hold the reference asset in the account) typically carry substantial margin requirements. Even with early exercise, a client can still be assigned on a short option any time prior to the option's expiration. Past performance is not indicative of future results. Investing in public and private capital markets involves bearing a meaningful risk of loss and impairment of capital. Clients should be prepared to bear this risk and review all regulatory documents, prospectuses, and private placement memoranda (PPM) pertaining to the purchase of investments in their portfolio. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither GSIS nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither GSIS nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. 12  C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Matthew K. Underwood is a Limited Agent on his parent's retirement accounts at Vanguard. All material conflicts of interest under California Code of Regulations Section 260.238(k) are disclosed regarding the investment adviser, its representatives or any of its employees, which could be reasonably expected to impair the rendering of unbiased and objective advice. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections GSIS may direct clients to third-party investment advisers to manage all or a portion of the client's assets. GSIS will receive its standard fee on top of the fee paid to any third- party adviser; GSIS will not receive a portion of the fee charged by the third-party adviser. The fees will not exceed any limit imposed by any regulatory agency. GSIS will always act in the best interests of the client, including when determining which third-party investment adviser to recommend to clients. GSIS will ensure that all recommended advisers are licensed, or notice filed in the states in which GSIS is recommending them to clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics GSIS has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. GSIS's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests GSIS does not recommend that clients buy or sell any security in which a related person to GSIS or GSIS has a material financial interest. 13  C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of GSIS may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of GSIS to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. GSIS will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of GSIS may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of GSIS to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, GSIS will never engage in trading that operates to the client’s disadvantage if representatives of GSIS buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on GSIS’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and GSIS may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in GSIS's research efforts. GSIS will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. While clients can request a particular broker-dealer, GSIS recommends clients use Charles Schwab & Co., Inc. Advisor Services. 1. Research and Other Soft-Dollar Benefits 14  GSIS has no soft dollars program in which soft dollars are used to pay for third party services, GSIS may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). GSIS does not anticipate entering enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and GSIS does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. GSIS benefits by not having to produce or pay for the research, products or services, and GSIS will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that GSIS’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals GSIS receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use In general, GSIS will request that clients use a specific broker-dealer (Charles Schwab & Co., Inc. Advisor Services) to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If GSIS buys or sells the same securities on behalf of more than one client, it might, but would be under no obligation to, aggregate or bunch, to the extent permitted by applicable law and regulations, the securities to be purchased or sold for multiple Clients in order to seek more favorable prices, lower brokerage commissions or more efficient execution. In such case, GSIS would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. GSIS would determine the appropriate number of shares to place with brokers and will select the appropriate brokers consistent with GSIS’s duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews 15  All client accounts for GSIS's advisory services provided on an ongoing basis are reviewed at least quarterly by Curt Thompson, Matthew Underwood and Nicholas Botticelli with regard to clients’ respective investment policies and risk tolerance levels. All accounts at GSIS are assigned to these reviewers. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of GSIS's advisory services provided on an ongoing basis will receive a monthly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. GSIS will also provide at least quarterly a separate written report to the client that includes additional data including performance and aggregated longer-term cashflow reconciliation. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Charles Schwab & Co., Inc. Advisor Services provides GSIS with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For GSIS client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. 16  information Charles Schwab & Co., Inc. Advisor Services also makes available to GSIS other products and services that benefit GSIS but may not benefit its clients’ accounts. These benefits may include national, regional or GSIS specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of GSIS by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist GSIS in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of GSIS’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of GSIS’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to GSIS other services intended to help GSIS manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to GSIS by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to GSIS. GSIS is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. B. Compensation to Non – Advisory Personnel for Client Referrals GSIS does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, GSIS will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Clients will also receive statements from GSIS and are urged to compare the account statements they received from custodian with those they received from GSIS. Item 16: Investment Discretion 17  GSIS provides discretionary investment advisory services to clients. The Investment Advisory Contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, GSIS generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, GSIS’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to GSIS. Other than any limits outlined in Item 4C, clients may place no limits on GSIS’s discretionary authority. Item 17: Voting Client Securities (Proxy Voting) GSIS will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet GSIS neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither GSIS nor its management have any financial conditions that are likely to reasonably impair our ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years GSIS has not been the subject of a bankruptcy petition in the last ten years. 18