A. Description of Advisory firm
WisdomTree was incorporated in Delaware on February 11, 2005 and maintains its principal place of
business in New York. The Adviser is registered as an investment adviser with the SEC under the
Investment Advisers Act of 1940, as amended (the “Advisers Act”). The principal and sole owner of the
Adviser is WisdomTree, Inc. (“WTI”), a publicly held Delaware corporation.
B. Types of advisory services and types of investment advice
As further described below, the Adviser is an investment adviser to the Funds (defined below) and
develops asset allocation models, which often include WisdomTree ETFs (defined below) and occasionally
securities included in proprietary indexes created and maintained by WTI, based on different investment
strategies, which are made available to certain parties.
Adviser to the Funds
The Adviser has been appointed to act as an investment adviser to the separate series of the WisdomTree
Trust (the “WisdomTree ETFs” or the “Funds”).
The WisdomTree Trust (the “ETF Trust”) is an open-end management investment company registered
under the Investment Company Act of 1940, as amended (the “1940 Act”), and the shares of the ETF Trust
are registered under the Securities Act of 1933, as amended (the “1933 Act”). Each WisdomTree ETF is
an exchange traded fund (each an “ETF”), meaning that the shares of the WisdomTree ETFs are listed on
a national securities exchange, such as the NYSE Arca, Inc., NASDAQ or Cboe BZX Exchange, Inc., and trade
at market prices. Certain series of the ETF Trust obtain investment exposure by investing through a foreign
domiciled wholly-owned subsidiary (which is not a series of the ETF Trust or itself an exchanged traded
fund registered under the 1933 Act or the 1940 Act) of such series, for which subsidiary the Adviser also
serves as the investment adviser.
SPECIFIC INVESTMENT STRATEGIES
EQUITY STRATEGIES
The Adviser has created both index-based (based on either proprietary or non-proprietary indexes) and
actively managed equity ETFs designed to provide exposure to U.S. and global equity markets. WTI
engages unaffiliated third parties to calculate the indexes, and to calculate and disseminate the index
values. The Adviser also works with unaffiliated third-party sub-advisers to facilitate portfolio
management of such WisdomTree ETFs. Funds pursuing an index strategy may be referred to as “Index
Funds.” Currently, the majority of the WisdomTree ETFs are Index Funds.
CURRENCY STRATEGIES
The Adviser has created a suite of actively managed currency strategy ETFs designed to provide exposure
to non-U.S. currencies, by generally collateralizing assets in U.S. money market securities. The Adviser
works with unaffiliated third-party sub-advisers to facilitate portfolio management of such WisdomTree
ETFs. Funds pursuing a currency strategy may be referred to as “Currency Strategy Funds.”
FIXED INCOME STRATEGIES
The Adviser has created both index-based (based on either proprietary or non-proprietary indexes) and
actively managed fixed income ETFs designed to provide exposure to U.S. and global fixed income
markets. WTI engages unaffiliated third parties to calculate the indexes, and to calculate and disseminate
the index values. The Adviser works with unaffiliated third-party sub-advisers to facilitate portfolio
management of such WisdomTree ETFs. Funds pursuing a fixed income strategy may be referred to as
“Fixed Income Funds.”
ALTERNATIVE STRATEGIES
The Adviser has created both index-based (based on either proprietary or non-proprietary indexes) and
actively managed alternative ETFs designed to provide exposure to a variety of alternative investment
strategies. WTI engages unaffiliated third parties to calculate the indexes, and to calculate and
disseminate the index values. The Adviser works with unaffiliated third-party sub-advisers to facilitate
portfolio management of such WisdomTree ETFs. Funds pursuing an alternative strategy may be referred
to as “Alternative Strategy Funds.”
SPECIFIC INVESTMENTS
The Adviser may invest in a wide range of investments in implementing the above strategies. These
investments may include, but are not limited to: equity securities, fixed income securities, Rule
144A/private placement securities, cash and cash equivalents, money market securities and money
market funds, affiliated funds, and derivatives in general. The Adviser does not directly make investments,
but the Adviser has delegated portfolio management to the sub-adviser for each Fund pursuant to a Sub-
Advisory Agreement.
OVERSIGHT AND CONTROL OF THE FUNDS; ADVISER SERVICES
Adviser to the Funds
The WisdomTree ETFs are subject to the general supervision of the Board of Trustees of the ETF Trust (the
“ETF Board”).
The Adviser renders investment advice to the Funds. The services provided by the Adviser include: (i)
furnishing continuously an investment program for each Fund; (ii) providing investment advice regarding
the investment and reinvestment of Fund assets; (iii) determining which investments shall be purchased,
held, sold or exchanged for each Fund; (iv) providing the ETF Trust with records concerning the activities
that it is required to maintain; (v) serving as the valuation designee of the Funds to perform all fair
valuations of the Funds’ portfolio investments; and (vi) rendering reports to the ETF Trust’s officers and
the ETF Board concerning the Adviser’s discharge of the foregoing responsibilities. In addition, the
Adviser may arrange for other necessary services, including custodial, transfer agency and administration,
subject to approval by the ETF Board. The Adviser may carry out its responsibilities directly or it may
appoint one or more sub-advisers or other
third parties to provide such services on behalf of the Adviser
with respect to any of the Funds.
Asset Allocation Models
WisdomTree creates, maintains and makes available asset allocation models (each a “Model Portfolio”),
whose underlying allocations generally consist of individual ETFs, including WisdomTree ETFs, other
exchange traded products sponsored, advised or managed by a WisdomTree affiliate (“WisdomTree ETPs”
and hereafter included in “ETFs”), ETFs and funds offered and advised by third-parties, and other
securities, including securities included in proprietary indexes created and maintained by WTI, and/or
digital assets, such as bitcoin and/or ether. Each Model Portfolio is built with a particular strategy focus.
For example, certain strategies focus on income generation, while others focus on market growth or the
incorporation of alternative investments. Each Model Portfolio generally includes allocations to ETFs,
including WisdomTree ETFs, in accordance with applicable target allocations established for the Model
Portfolio. The Model Portfolios are not limited to allocations to WisdomTree ETFs; however, a Model
Portfolio may be allocated up to 100% to WisdomTree ETFs. The Model Portfolios themselves are not
Funds.
The Model Portfolios are made available to registered investment advisers and other financial services
companies, including insurance companies (“Third-Party Advisers”). The Model Portfolios may be
provided directly to a Third-Party Adviser or indirectly through platforms (“Platforms”) maintained and
operated by third-party platform providers (“Platform Providers”). WisdomTree makes the Model
Portfolios available to Third-Party Advisers so that such Third-Party Advisers may use such Model
Portfolios in providing advice to the underlying clients of such Third-Party Advisers. The Model Portfolios
are periodically rebalanced on a pre-determined schedule. Third-Party Advisers or their respective
underlying clients, not WisdomTree, are responsible for selecting the underlying investment options for
such client’s account, including recommending, selecting and managing the client’s investment strategy.
The Third-Party Adviser or the underlying client, not WisdomTree, is responsible for making investment
decisions for the underlying client, including taking into account the underlying clients’ specific investment
objectives, risk tolerances and financial circumstances. In certain arrangements, the Third-Party Adviser
is an affiliate of the Platform Provider. WisdomTree provides periodic updates to the allocations in each
Model Portfolio. To the extent a Third-Party Adviser or its underlying client determines in its discretion
to rebalance based on a Model Portfolio change, tax consequences may occur. WisdomTree does not
have, and will not have, trading authority over any underlying client account of a Third-Party Adviser,
including any such client account which is based on a Model Portfolio and any trading effected by a Third-
Party Adviser or its underlying client may incur tax consequences, commissions and other costs. Third-
Party Advisers may use multiple strategies, including strategies of other investment managers. The
implementation of any such investment strategy for an underlying client of a Third-Party Adviser, including
one based on a Model Portfolio, will be conducted by the applicable Third-Party Adviser, who is
responsible for making its own independent judgment as to how to incorporate any Model Portfolio
information for any underlying client of such Third-Party Adviser.
C. Tailoring of advisory services for individual clients
With respect to the Funds, the Adviser will tailor its advisory services for each Fund only as set forth in a
written investment advisory agreement and, if applicable, the registration statement or other governing
document for such Fund. Any restrictions on the Adviser’s investment discretion are set forth in the
written investment advisory agreement.
WisdomTree generally does not tailor any Model Portfolios to meet the needs of any specifically identified
underlying clients of any Third-Party Advisers. In such instances, WisdomTree generally licenses the
Model Portfolios and does not directly provide individualized investment advice to any specifically
identified underlying client of any Third-Party Adviser through the provision of Model Portfolios.
WisdomTree occasionally helps build custom Model Portfolios for certain Third-Party Advisers that are
designed to help address the specific goals of the Third-Party Adviser’s clients. WisdomTree does not
manage any assets of any underlying clients of any Third-Party Advisers through the provision of the
Model Portfolios. Model Portfolios, any related information and any digital tools made available by
WisdomTree should not be considered or relied upon as a recommendation by WisdomTree regarding
the use or suitability of any Model Portfolio, any particular security or any strategy. The Model Portfolios,
any related information and any digital tools are intended for use only by Third-Party Advisers as an
educational resource among other resources deemed appropriate by such Third-Party Advisers.
D. Wrap fee program participation
The Adviser does not sponsor or maintain any wrap fee programs. The Model Portfolios may be used by
Third-Party Advisers as part of such Third-Party Advisers’ own wrap fee programs, but the Third-Party
Adviser, not WisdomTree, is responsible for providing individualized investment advice to participants in
such programs.
E. Amount of client assets managed
As of December 31, 2023, WisdomTree had assets under management totaling approximately $72.5
billion.