Our History 
Wasatch was founded in 1975 and is headquartered in Salt Lake City, Utah.  Wasatch has 
developed a fundamental, bottom-up research method that focuses on the long-term growth 
potential of companies and finding market inefficiencies. Wasatch initially focused on investing 
in the stocks of companies with small market capitalizations (small cap), and over time has 
organically evolved into additional asset classes.  
Our Culture 
Today, Wasatch is 100% employee owned with over 40 shareholders and no single employee 
owning 20% or more of the firm. Our autonomy fosters an entrepreneurial spirit and pride that 
promotes collaboration and teamwork. Years of experience have convinced us that the best ideas 
and insights come from subjecting our efforts to the scrutiny of multiple eyes.  At Wasatch, we 
generate our own investment ideas and leverage our collective experience to create results for our 
clients.  
Our People 
The substance of our success has always been our people. The portfolio managers at Wasatch 
play a critical role in our investment philosophy and process. In addition to the individual 
strengths brought to each portfolio, our lead portfolio managers average over 20 years of 
experience in the industry.  Our employee shareholders elect a Board of Directors (currently 
consisting of seven employees and one former employee) to govern the company’s affairs. 
Our Services 
A.  Discretionary Investment Advice 
Wasatch provides discretionary investment advice for a variety of clients, including mutual funds, 
collective trusts, separately managed accounts and sub-advised products. Across its different 
clients, Wasatch managed a total of $26.7 billion in assets as of 12/31/2023.  
Wasatch’s advisory services are typically provided on a discretionary basis, meaning that 
Wasatch has full discretion to determine, consistent with clients’ investment objectives and 
restrictions, which securities and the total amount of securities that should be bought or sold for 
clients’ accounts. Wasatch may buy, sell, or otherwise trade securities that include, but are not 
limited to, common stocks in markets around the globe, initial public offerings (IPOs), private 
placements, 144A restricted stocks, convertible stocks and bonds, options, warrants, rights, 
preferred stocks and corporate, municipal and government bonds, notes and bills. Wasatch 
provides investment management services in several investment styles, including growth, core 
and value styles in micro, small, mid and large cap securities located in domestic and 
international markets.  Wasatch’s discretionary investment authority may be limited by conditions 
imposed by clients in their stated investment objectives or guidelines, and mutually agreed to by 
Wasatch.  
1.  Mutual Funds 
Wasatch provides discretionary investment management services to an open-end registered 
investment company, Wasatch Funds Trust (“Wasatch Funds”). In total, Wasatch is the 
investment advisor to 20 separate portfolios in Wasatch Funds, although a sub-adviser has been 
retained to manage one of the portfolios.  
Wasatch manages five U.S. domestic growth funds (Micro Cap, Small Cap Growth, Ultra 
Growth, U.S. Select and Core Growth); two U.S. domestic value funds (Micro Cap Value and 
Small Cap Value); three global funds (Global Opportunities, Global Select and Global Value); 
five emerging markets funds (Emerging Markets Small Cap, Emerging India, Emerging Markets 
Select, Frontier Emerging Small Countries and Greater China); three developed markets 
international funds (International Growth, International Select and International Opportunities); 
one long-short fund (Long/Short Alpha) and one sub-advised treasury fund (Wasatch-Hoisington 
U.S. Treasury Fund). Wasatch has retained Hoisington Investment Management Company 
(HIMCO) to sub-advise the Wasatch-Hoisington U.S. Treasury Fund. 
As of 12/31/2023, Wasatch Funds had $12.6 billion in assets under management.  Each Wasatch 
Fund other than the Wasatch-Hoisington U.S. Treasury Fund has adopted both an investor share 
class and an institutional share class. The two share classes are invested in the same portfolio of 
securities but have different expenses. The investor share class of each Wasatch Fund is available 
to retail investors as the minimum investment size is $2,000.  The institutional shares are 
available to investors who have a minimum of $100,000 invested in the fund.  Each Fund is more 
fully described in the Wasatch Funds prospectus available online at www.wasatchglobal.com or 
www.sec.gov.  
One difference between the management of the Wasatch Funds and all other accounts managed 
by Wasatch relates to private investments and private offerings.  From time-to-time one or more 
Wasatch Fund may participate in a private offering, including private investments in public 
equities (PIPEs).  Wasatch does not typically purchase private investments or participate in 
private transactions for any of its other clients. 
2.  Separate Accounts 
As of December 31, 2023, Wasatch managed portfolios for separate account clients in investment 
styles similar to those of the Wasatch Funds. Wasatch currently manages separate account 
portfolios in fourteen investment styles (Micro Cap Growth, Micro Cap Value, Small Cap 
Growth, Small Cap Core Growth, Small Cap Ultra Growth, Small Cap Value, Large Cap Value, 
Global Small Cap, International Small Cap Growth, Emerging Markets Small Cap, Emerging 
India, Frontier Emerging Small Countries  and Emerging Markets Select).  In addition, Wasatch 
is willing to manage separate account portfolios in six other investment styles (International 
Micro Cap, International Select, Global Value, Global Select, Greater China, U.S. Select and 
Long/Short Alpha).  
Each of the separate account styles is generally managed similarly to the respective Wasatch 
Fund, although variations in the products can exist. For example, certain of the domestic products 
also offer a hybrid style that permits a significant portion of a portfolio to be invested in 
international small cap stocks. Or, certain of the global and international styles offer versions that 
constrain the amount of the portfolio to be invested in emerging markets.  Within an investment 
style, the principal variations result from specific guidelines and restrictions placed on separate 
account portfolios by clients. Restrictions on the management of the account must be mutually 
agreed upon by Wasatch and the client. Clients who place restrictions, including restrictions as to 
types of securities, concentrations, cash balances, brokers to be used or not used, etc., must 
recognize that the performance of their accounts will not be consistent with the performance of 
accounts managed in the same style with no restrictions and as a result their performance may be 
better or worse than the other accounts. 
As of 12/31/2023, Wasatch managed $8.9 billion in separate account assets. The minimum 
account size for a new separate account is generally $1 million in assets under management in a 
domestic style, or $10 million for an international style. Wasatch has the discretion to accept 
accounts with a value less than the stated minimums depending on the nature of the account, the 
potential for future additions to the account and other factors. Some Wasatch clients have 
accounts smaller than $1 million. Depending on the investment style of a new account, the 
minimum account size may be negotiated.  
3.  Sub-Advised Funds 
As of 12/31/2023, Wasatch managed $3.11 billion as a sub-advisor to six registered funds. These 
funds are generally aimed at retail investors in their jurisdictions and the minimum account size 
varies by fund. 
  The Advisor acts as a sub-advisor to the St. James’s Place Emerging Markets Equity Unit 
Trust GBP, a UCITs vehicle domiciled in the United Kingdom.  The Advisor manages 
the St. James’s UCIT in Wasatch’s Emerging Select style.  As of 12/31/2023 the St. 
James’s Place UCIT had $2.2 billion.
                                        
                                        
                                               
  Wasatch acts as a sub-advisor to a sleeve of assets in the Counsel Global Small Cap 
Fund, a mutual fund registered in Canada.  The sleeve is managed in Wasatch’s 
International Small Cap Growth investment style.  Wasatch has investment discretion 
over the sleeve which as of 12/31/2023 had AUM of $136 million. 
  Wasatch serves as a sub-advisor for the Renaissance Global Small-Cap Fund, a mutual 
fund registered in Canada.  The Fund is managed in Wasatch’s Global Small Cap Growth 
investment style.  Wasatch has investment discretion over the Fund.  As of 12/31/2023 
the Fund had AUM of $467 million. 
  Wasatch serves as a sub-advisor to the Brinker Capital Destinations International Equity 
Fund, a U.S. registered mutual fund.  The Brinker fund employs a multi-manager 
approach and Wasatch is one of four managers (alongside Baron, MFS and T. Rowe 
Price) advising the fund. Wasatch manages its sleeve in the International Opportunities 
investment style.  As of 12/31/2023 the sleeve in the Brinker fund which Wasatch 
manages had AUM of $131 million. 
  Wasatch serves as a sub-advisor to the Morningstar U.S. Equity Fund, a U.S. registered 
mutual fund.  The Morningstar fund employs a multi-manager approach and Wasatch is 
one of five managers (alongside Diamond Hill Capital Management, Levin Capital 
Strategies, MFS Investment Management and Westwood Management) advising the 
fund.  Wasatch manages its sleeve in the Small Cap Core Growth investment style.  As of 
12/31/2023 the sleeve in the Morningstar fund which Wasatch manages had AUM of 
$114 million. 
  Wasatch serves as a sub-advisor to the Clearwater Select Equity Fund, a U.S. registered 
mutual fund.  The Clearwater Fund employs a multi-manager approach and Wasatch is 
one of six managers (alongside Cooke & Bieler, L.P., Jackson Square Partners, LLC, 
Parametric Portfolio Associates LLC, Pzena Investment Management LLC, Rice Hall 
James & Associates, LLC) advising the fund. Wasatch manages its sleeve in the Micro 
Cap Value investment style.  As of 12/31/2023 the sleeve in the Clearwater fund which 
Wasatch manages had AUM of $64 million. 
4.  Collective Investment Trusts 
Wasatch manages four collective investment trusts.  The collective investment trusts are 
institutional-only investment vehicles aimed at the retirement plan market. A CIT is similar to a 
mutual fund in that it is comprised of pooled assets invested with a specific philosophy and 
strategy; however, since it is exempt from the 1940 Investment Company Act, it has a simpler 
structure and generally lower operating costs.   
All four collective investment trusts are sponsored by their trustee, SEI Trust Company. As of 
12/31/2023 the Emerging Markets Small Cap CIT had $132 million in assets, the Small Cap 
Growth CIT had $15 million in assets, the Core Growth CIT had $450 million in assets and the 
Emerging Markets Select CIT had $134 million in assets. 
5.  Private Fund 
Wasatch  launched a private fund, Wasatch Emerging Markets Select Fund, in the second quarter 
of 2023.  The vehicle is a master-feeder fund, with a Delaware limited partnership serving as an 
onshore feeder and a Cayman Islands registered mutual fund serving as an offshore feeder.  The 
two feeder funds  invest substantially all of their assets in the Master Fund, Wasatch Emerging 
Markets Select Master Fund, Ltd., which is also registered as a Cayman mutual fund.  The Master 
fund is managed by Wasatch in the Wasatch Emerging Markets Select investment style.  Both 
feeders  conduct their investment and trading activities through the Master Fund which has the 
same investment objectives, policies and strategies as the feeder funds.  The fund is intended for 
qualified purchasers and should not be deemed an “investment company” under the Investment 
Company Act of 1940.   
6.  Non-discretionary Account 
Wasatch manages a single account over which Wasatch does not have investment discretion.  
Instead, Wasatch proposes the same trades to the account that it makes in other accounts in the 
same investment style.  The client then either approves or rejects each trade.  This client’s 
investment execution and performance may at times differ substantially from the performance of 
Wasatch’s discretionary accounts in the same investment style due to the approval requirement.  
As of 12/31/2023 the non-discretionary account managed by Wasatch had $289 million in assets.  
B.  Services Other Than Continuous Investment Services  
1.  Model Delivery Platforms/UMAs 
Model delivery platforms (“MDPs”) are platforms for which Wasatch designs, monitors and, as 
necessary, updates a model portfolio and provides the model and updates to these platforms on a 
regular basis. The platforms receiving models may adopt or ignore Wasatch’s recommendations. 
Wasatch does not have investment or voting discretion over MDPs. Wasatch does not have 
responsibility for trade execution, proxy voting or any other services to MDPs other than to 
provide investment recommendations with respect to the model portfolio. The investment 
performance of any account on a MDP is attributable to the client, not to Wasatch, and may differ 
substantially from the performance of Wasatch’s discretionary accounts in the same strategy.  
Accounts on MDPs will not receive access to limited offerings in which other Wasatch clients 
participate.  Wasatch also provides advice to unified managed accounts (“UMAs”) which 
Wasatch considers to be a form of MDP. As of 12/31/2023 the aggregate assets reported to 
Wasatch as following Wasatch’s models on the various platforms was $455 million in assets.   
2.  Administrative Services 
Wasatch provides certain back office services for the various clients to which it provides 
investment management services. Wasatch provides several services to Wasatch Funds, including 
providing officers to the Funds, all of whom are compensated by Wasatch and are provided at no 
additional charge to the shareholders of Wasatch Funds. Wasatch provides certain services to its 
separate account clients, including account reconciliation and statement generation, which are 
provided as part of its investment services.  
Wasatch has also been hired to provide administrative services to the Cross Creek Funds, a group 
of venture funds and funds-of-venture funds unaffiliated with Wasatch.  The Cross Creek Funds 
were started inside of Wasatch in 2006 and remained a part of Wasatch until they were separated 
in 2012.  The Cross Creek Funds are now managed by Cross Creek Advisors, LLC, a registered 
investment adviser.  Wasatch provides the Cross Creek Funds services including accounting 
services, capital call management and preparation of financial statements.   
Services Wasatch Does Not Typically Provide to Clients 
1.  Significant Shareholder Reporting 
When Wasatch takes significant positions in an issuer, Wasatch is required to file reports with 
issuers and regulators around the globe regarding its clients’ holdings of the issuer.  Those reports 
are often made available to the public and at times require disclosure to the public of a client’s 
identity and holdings. While Wasatch monitors the holdings of its clients on an aggregate basis 
and makes filings as necessary, Wasatch does not monitor or advise its clients on reporting 
requirements clients might have in those jurisdictions. 
2.  Class Actions 
Wasatch will pass along to its clients and their custodians information it receives in connection 
with a portfolio security held by the client in a Wasatch account if the client might have a claim 
in connection with its ownership of that security.  However, Wasatch does not file class actions 
claims for clients and does not pro-actively seek out information regarding potential class actions 
in securities held by Wasatch.  If Wasatch receives this information, it will make a good faith 
effort to pass this information along to the client’s custodian, but Wasatch will not give any 
advice related to the claim or potential claim.