Overview
Summary
SG Trading Solutions, LLC (“SGTS”) is Limited Liability Company, formed in 2022 and registered
with the SEC as a Registered Investment Advisor. SGTS’s is to provide investment management
services to other Registered Investment Advisors, Investment Managements and Broker/Dealers.
SGTS, acts as a sub-adviser to ETFs and Mutual Funds that utilize different investment strategies.
SGTS is dedicated to understanding, researching, and managing assets within the expanding
exchange-traded fund (ETF) universe. SGTS’s investment philosophy emulates many of the values
and benefits inherent in ETFs such as: transparency, semi-transparency, liquidity, and tax efficiency.
SGTS has agreed to serve as a sub- adviser to investment companies (each a “Fund” and collectively,
the “Funds”) registered under the Investment Company Act of 1940 (“1940 Act”). SGTS has the
responsibility to oversee and ensure that all transactions comply with applicable regulations and
prospectus covenants.
SGTS's investment advisory services are primarily limited to the management of investment trading
for investment companies, institutional investors, and other advisers that manage Funds. SGTS's
headquarter is located in Bountiful, Utah.
Advisory Services
SGTS performs adviser and sub-advisory services for a client under the terms of an investment
subadvisor agreement. SGTS’s primary responsibility is through trading, which may include limited
investment selection and weighting of portfolio securities in coordination with and subject to
oversight by each investment advisor. As compensation for its services, each client pays SGTS an
advisory fee based upon the asset under management which may be the Fund’s average daily net
assets, the assets traded, advised, or sub-advised by SGTS.
Warranty
SGTS does not represent, warranty, or imply that the services or methods of analysis and investment
management used can or will predict future results, successfully identify market tops or bottoms, or
insulate clients from losses due to market conditions. All trading of securities is subject to loss and
although every effort may be exhausted losses still can and may incur.
Conflict of Interest
SGTS provides investment management services primarily
to investment companies registered
under the 1940 Act and provides discretionary and non-discretionary investment management
services to separately managed accounts as described above. They will NOT be responsible for
growing assets under management and thus will have limited conflicts of interest.
SGTS has procedures reasonably designed to treat all portfolios fairly and equally over time. By
utilizing these procedures, SGTS believes that client’s best interest are maintained, and best
execution may be achieved.
Investment Management Services
SGTS is an investment management and advisory firm that focuses on providing clients best
execution and trading practices. For clients subject to the 1940 Act, SGTS will observe the
investment parameters described in the respective Fund prospectuses as well as those required by
the Investment Company Act of 1940 and any regulations issued in addition.
SGTS implements strategies focused on risk and return determined by the underlying objectives of
each client and/or respective Fund prospectus. SGTS strives to adhere to industry best practices of
execution and implements rigorous quantitative and fundamental analysis to achieve the best
execution and coordination with other trading partners, such as but not limited to, Lead Market
Makers, Broker/Dealers, Authorized Participants and other Market Makers whose role is to provide
efficient and effective pricing and trading of securities and Funds.
Clients investing in SGTS's strategies are exposed to various risks including, but not limited to, market
risk, equity risk, and volatility risk.
Individual clients generally are referred to SGTS by Advisers and others who have, or will look to
launch, 1940 Act Funds, SMA or other investment vehicles that require the trading of securities.
Account Restrictions
Clients may impose restrictions on investing in certain securities or types of securities in
consultation with SGTS. If client request to place certain restrictions as to the type of investments
that may be held in their accounts, SGTS may buy alternative holdings compared to other clients of
SGTS not subject to such account restrictions.
Discretionary Assets Under Management
SGTS manages on a discretionary basis approximately $100 Million of client assets as of March 29,
2022.