A. Description of the Advisory Firm
Gramercy Strategic Capital LLC (hereinafter “GSC”) is a Limited Liability Company
organized in the State of New York. The firm was formed in June 2021, and the principal
owners are Keith Cho and Yoon Hwang.
B. Types of Advisory Services
Portfolio Management Services
GSC offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. GSC creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels). Portfolio management services include, but are not
limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
GSC evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. GSC 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.
GSC seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of GSC’s economic, investment or
other financial interests. To meet its fiduciary obligations, GSC attempts to avoid, among
other things, investment or trading practices that systematically advantage or
disadvantage certain client portfolios, and accordingly, GSC’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 GSC’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.
GSC may direct clients to third-party investment advisers to manage all or a portion of
the client's assets. Before selecting other advisers for clients, GSC will always ensure those
other advisers are properly licensed or registered as an investment adviser. GSC 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. GSC then makes investments with a third-party investment
adviser by referring the client to the third-party adviser. These investments may be
allocated either through the third-party adviser's fund or through a separately managed
account managed by such third party adviser on behalf of GSC's client. GSC may also
allocate among one or more private equity funds or private equity fund advisers. GSC
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
GSC generally limits its investment advice to mutual funds, fixed income securities, real
estate funds (including REITs), equities, hedge funds, private equity funds, ETFs
(including ETFs in the gold and precious metal sectors), treasury inflation
protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds
and private placements. GSC may use other securities as well to help diversify a portfolio
when applicable.
C. Client Tailored Services and Client Imposed Restrictions
GSC offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon the client Investment
Policy Statement which outlines each client’s current situation (income, tax levels, and risk
tolerance levels). Clients may impose restrictions in investing in certain securities or types
of securities in accordance with their values or beliefs. However, if the restrictions prevent
GSC from properly servicing the client account, or if the restrictions would require GSC
to deviate from its standard suite of services, GSC reserves the right to end the
relationship.
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. GSC does not participate in any wrap fee programs.
E. Assets Under Management
GSC has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 50,553,200.00 $ 94,392,449.00 December 2023