GAM USA Inc.

• A percentage of assets under your management
• Performance-based fees

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

See the firm's brochure (dated July 2, 2026) for its fees and any account minimum, on the SEC's IAPD site.

$1,474,378,061 as of October 2026, filing dated August 4, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Portfolio management for pooled investment vehicles (other than investment companies)
• Portfolio management for businesses (other than small businesses) or institutional clients
• Selection of other advisers (including private fund managers)

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

1989 (36 years)

Employees

Total: 14. Performing investment advisory functions: 10.

Wrap fee program participation

No.

Custodians (Schedule D, Section 5.K(3))

Bank of AmericaBNY MellonThe Northern Trust Company

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

Other offices (Schedule D, Section 1.F)

1 other office, as of the September 2026 filing

Miami, FL

States registered or notice-filed

Not reported.

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

1 Reports 1 disclosure item on Form ADV Item 11. View on IAPD.

Questions answered yes on this filing

Regulatory matters Items 11.C to 11.G

• 11.E(2) Has a self-regulatory organization or a commodities exchange ever found that the firm or an advisory affiliate was involved in a violation of its rules, other than a minor rule violation under a plan the SEC approved?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. What happened, and who was involved, is on the Disclosure Reporting Pages of the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $1,893,608,946 in the October 2021 data and $1,474,378,061 in the October 2026 data, down 22%.

Total employees: 19 in October 2021 and 14 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. September 2026
   • Updated its list of owners and control persons (Schedule A).
2. April 2026
   • Employees performing advisory functions went from 4 to 10.
   • Regulatory assets under management went from $1,148,242,839 to $1,547,157,091 (+35%).
3. January 2026
   • Updated its list of owners and control persons (Schedule A).

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.