Description of Firm GAMMA Investing LLC is an independent, woman-owned registered investment adviser and is primarily based in Foster City, California. We are organized as a limited liability company ("LLC") under the laws of the State of Delaware. We have been providing investment advisory services since March 2021. The firm was founded in January 2021 by the majority owner, Lorraine Fang. RiverFront Investment Holding Group, LLC and Baird Financial Corporation are minority, direct owners of GAMMA Investing LLC.
The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to GAMMA Investing LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
Portfolio Management Services We offer discretionary and non-discretionary portfolio management services to wealth management intermediaries and Registered Investment Advisor (RIA) firms (collectively "clients"). The clients we work with service individuals, families and family offices. We specialize in delivering custom indexing solutions tailored to each investor's needs. Our core offering is delivered as a separately managed account (SMA) for each end investor. We deliver SMAs primarily as a sub-advisor to the clients we work with. We work as the primary advisor for a limited set of individuals ("direct clients") who are friends and families of the firm's employees. However, we are currently not taking on new direct clients.
If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms.
You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing.
In general, we manage each SMA by investing in a portfolio of individual securities that comprise an index strategy ("target strategy") selected by the client. While such portfolios are passive investments in that they are managed in an effort to match the performance of the target strategy, they differfrom other passive investments such as index mutual funds or ETFs in the following ways:
•They are separately managed accounts in which the account owner directly owns the securities underlying the target strategy.
•Each portfolio may be optimized to hold fewer securities than the target strategy while still tracking the performance of the target strategy.
•Each portfolio can be customized and individually tax managed. Customization may include specific investment restrictions and limitations directed by the client (e.g., social screens, security/sector restrictions). Tax management can include tax loss harvesting, gains deferral and transition services that incorporate legacy holdings into the index holdings as appropriate. SRI/ESG Choices We will generally not consider non-financial

objectives of a client when managing investments. However, from time to time, a client may express a desire that we consider client's non-financial objectives when managing his/her account.
4 In furtherance of that desire, a client will provide consent to GAMMA to incorporate one or more social or other non-financial objectives when making investment decisions and recommendations. These non-financial factors are defined by the client and must be confirmed with the client's financial advisor. Client will acknowledge and understand that incorporating a non-financial objective, such as a social or environmental objective, into investment decisions will result in investments that are not solely focused on maximizing a financial return for the client or client's account.
Client also acknowledges and understands that we rely on third-party data vendors to incorporate a social or environmental objective and cannot guarantee the completeness and accuracy of such data. It is incumbent on the client to provide written instruction if additional stocks should be removed/restricted from the client's account. Client also understands that these instructions may be modified or revoked at any time upon written notice to client's financial advisor.
Sub-Advisory Services to Registered Investment Advisers We deliver portfolio management services on behalf of third-party Registered Investment Advisors or wealth managers (the "Primary Investment Adviser") on a sub-advisory basis. In this arrangement, we enter into a sub-advisory agreement with the Primary Investment Adviser who appoints GAMMA to manage all or a portion of its client's accounts. GAMMA has no direct relationship with the Primary Investment Adviser's clients, and the Primary Investment Adviser is solely responsible for selecting the appropriate investment strategies that are suitable for its clients based on their needs, goals, time horizon and risk tolerance. We will work closely with the Primary Investment Adviser to deliver portfolio management services in-line with the specific mandate assigned to us. Wrap Fee Programs For certain clients, we may become a portfolio manager of wrap fee programs sponsored and administered by other investment advisers. We manage wrap fee accounts on a discretionary basis. If you participate in this wrap fee program, you will receive a separate Wrap Fee Program Brochure (Form ADV Part 2A Appendix 1) from the investment adviser explaining the program and costs associated with the program. You should also review this Part 2A thoroughly to evaluate any differences between our portfolio management services offered through the investment advisers' Wrap Fee Program versus the services we offer on a non-wrap basis.
Types of Investments We offer advice on listed equity securities, mutual funds, fixed income securities (other than commercial paper), ETFs and American Depositary Receipts (ADRs). Additionally, we may advise you on other types of investments based on your stated goals and objectives in your portfolio at the inception of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
Assets Under Management As of February 16, 2024, we manage $445,133,271 in client assets on a discretionary basis.