1. ITEM 1: COVER PAGE
______________________________________________________________________________________
Part 2A of Form ADV: Firm Brochure
Greenwich Asset Management Group, LLC
March 30, 2012
______________________________________________________________________________________
Two Greenwich Office Park, Suite 300
Greenwich, CT 06831 USA
SEC File Number 801-60497
CRD Number 114871
Telephone Number: US +1-203-622-1305
Peter.Lundstedt@Gamgllc.com
www.Gamgllc.com
This brochure provides information about the qualifications and business practices of Greenwich Asset
Management Group, LLC. If you have any questions about the contents of this brochure, please contact us
at 203-622-1305 or Peter.Lundstedt@Gamgllc.com. The information in this brochure has not been approved
or verified by the United States Securities and Exchange Commission (the "SEC") or by any state securities
authority.
Additional information about Greenwich Asset Management Group, LLC also is available on the SEC's
website at www.adviserinfo.sec.gov. Registration with the SEC or with any state securities authority does
not imply a certain level of skill or training.
Greenwich Asset Management Group, LLC
FORM ADV, PART 2 – MARCH 30, 2012
SEC File Number 801-60497 - CRD Number 114871
2. ITEM 2: MATERIAL CHANGES
The following is a summary of the material changes to this Brochure since the last annual update on Dec
31, 2011:
None
Greenwich Asset Management Group, LLC will provide you with a new Brochure at any time upon
request without charge. You may request a Brochure by email at Peter.Lundstedt@Gamgllc.com or by
phone at 203-622-1305. The Brochure is also available on Greenwich Asset Management Group LLC’s
website free of charge at www.Gamgllc.com. Additional information about Greenwich Asset Management
Group, LLC may also be obtained on the SEC’s website www.adviserinfo.sec.gov.
ITEM 3: TABLE OF CONTENTS
Greenwich Asset Management Group, LLC
FORM ADV, PART 2 – MARCH 30, 2012
SEC File Number 801-60497 - CRD Number 114871
3. ITEM 4: ADVISORY BUSINESS
A. General Description of Advisory Firm
Greenwich Asset Management Group, LLC (“Gamgllc”) provides investment advisory and investment
management services designed for institutional and accredited clients. Gamgllc is a sole proprietorship
entity which collaborates with outside resources to provide investment management results. Gamgllc was
organized in 2001 by Peter Lundstedt after gaining experience for 15 years on the brokerage side which
included a U.S. listed equity strategy that was successfully run for over five years with a former $30 billion
State Common Retirement Fund Manager. Greenwich Asset Management Group, LLC provides
Independent, unbiased, transparent, and “investment banking and brokerage free” advice.
B. Description of Advisory Services
Gamgllc provides discretionary investment management services designed for institutional and accredited
clients and other client portfolios focusing mainly on separately managed U.S. listed equity accounts held
at and traded through independent unaffiliated custodians and never holds or takes possession of any
assets. Gamgllc manages accounts with limited discretion as to buying or selling stocks for clients as well
as deducting management fees only.
Gamgllc may in the future serve as investment sub-adviser to a number of investment companies
registered under the Investment Company Act of 1940 (“1940 Act”).complete information concerning each
such investment company will be disclosed in its prospectus and statement of additional information.
Principal strategies currently offered by Gamgllc include the following:
Long Term US Listed Equity Portfolio Separately Managed Account (SMA).
Gamgllc manages U.S. listed equity assets by using a disciplined process which is designed to create
value from three sources: (i) high fundamental buy ratings graded by multiple independent and
unaffiliated equity ranking firms (multiple outside buy opinions), (ii) technical analysis, and (iii) portfolio
equal weighting and quarterly rebalancing of security selections.
Managed Accounts offered: Large Cap, Mid Cap, Small Cap, Blue Chip Growth, Growth, Value, All Cap,
Sector, Industry, Index, Global, Country, Geographically Agnostic or Investor Selected Equity Universes
using U.S. stocks and ADR's only.
Availability of Customized Services for Individual Clients
Gamgllc may tailor the investment program for certain accounts based on the client’s particular needs as
well as overall financial condition, goals, risk tolerance and other factors unique to the client’s particular
circumstances including regulatory restrictions. Gamgllc may also agree to investment guidelines for
certain accounts which restrict or prohibit investments in certain securities or asset classes.
Wrap Fee Programs
None
Greenwich Asset Management Group, LLC
FORM ADV, PART 2 – MARCH 30, 2012
SEC File Number 801-60497 - CRD Number 114871
4. ITEM 5: FEES AND COMPENSATION
Advisory Fees and Compensation
Gamgllc generally receives a percentage of assets under management as compensation for its services.
The fee schedule may vary due to servicing requirements, account inception date and other factors. Fee
schedules for different styles of fixed income and equity management will vary depending on research
intensity, degree of active management. Gamgllc may, in its sole discretion, negotiate terms and charge
different fees for certain accounts based on a client’s particular needs as well as overall financial
condition, goals, risk tolerance and other factors unique to the client’s particular circumstances. Gamgllc’s
standard investment advisory agreement is mutually revocable at any time without penalty and continues
in effect until 30 days after written notice of termination is given by either party. Standard fee schedules
are as follows:
1.95% per year paid quarterly in advance.
Payment of Fees
Fees are generally payable to Gamgllc at the beginning of the quarterly based on the quarter-end market
value or average value for the quarter. Clients are responsible for verifying that the fee was correctly
calculated. If a client terminates the relationship prior to the end of a period, the fee is prorated.
Additional Fees and Expenses
Clients will pay all interest, charges, taxes, fees, commissions, brokerage costs and expenses of every
kind related to their account. Clients may also bear expenses “passed through” from third parties
performing services such as of audit, administration and custody expenses. In addition, clients whose un-
invested assets are swept into money market mutual funds for short-term cash management purposes by
their custodian will also bear the additional fees and expenses assessed by such money market mutual
funds to the extent of their investment in such funds. To the extent that the investment guidelines for an
account permit the investment of account assets in mutual funds or other collective investment vehicles,
the account may (depending on the arrangement) bear the fees and costs associated with such collective
investment vehicles, as well as the investment advisory fee of Gamgllc. Clients investing directly in
mutual funds sub-advised by Gamgllc will bear the fees and expenses disclosed in such mutual fund’s
prospectus.
Additional Compensation and Conflicts of Interest
Gamgllc may compensate certain independent contactors for their activities related to institutional sales.
A portion of the compensation of certain employees includes a percentage of the first year’s advisory fees
paid to Gamgllc by clients or investors referred to Gamgllc by such sales personnel.
1. These practices present a conflict of interest as such independent contactors could be incentivized to
recommend investment products based on the compensation received, rather than on a client’s needs.
Any one eligible to receive compensation related to institutional sales are required to provide certain
disclosures to prospective clients as mandated by Rule 206(4)-3 of the Investment Advisers Act, which
includes disclosing to prospective clients the solicitor’s position with Gamgllc or its affiliate and the nature
of the relationship. The disclosures required by Rule 206(4)-3 are necessary to inform prospective clients
about the nature of the solicitor’s financial interest in the recommendation so they may consider the
solicitor’s potential bias, and to protect prospective clients against solicitation activities being carried out
in a manner inconsistent with the firm’s fiduciary duty to clients.
5. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Gamgllc may receive performance based fees from certain "qualified" accounts and certain investment
professionals manage both accounts that are charged a performance based fee and accounts that are
charged other types of fees.
Typical performance based fees are 1% base fee then 1% for every 11% earned for client accounts with
high water marks taken during the quarter when it occurs. This fee structure can be 50% of a traditional 2
and 20 structure which may be charged on certain accounts.
Side-by-side management by Gamgllc, if any, of registered investment companies and non-U.S. mutual
funds, managed accounts and private investment funds may raise potential conflicts of interest, including
conflicts associated with the differences in fee structures for such products.
Performance-based fees may provide an incentive for Gamgllc to purchase investments that are more
speculative and/or involve a higher degree of risk than might otherwise be the case in the absence of
such performance-based compensation. The prospect of earning a higher compensation from a portfolio
with a higher fee structure (such as a private fund with a performance based fee) may provide Gamgllc
with an incentive to favor the portfolio with the higher fee structure when, for example, allocating
securities transactions expected to more likely result in favorable performance. In addition, in connection
with organizing a private investment fund which focuses on a particular asset class, such as structured
securities, Gamgllc may contractually promise to provide such fund with the first consideration of relevant
investment opportunities before offering such opportunities to other clients’ accounts which may be
eligible to invest therein. Such private investment funds may provide greater fees (including performance
based fees) or may be funds in which related persons of Gamgllc have an interest.
Portfolio managers at Gamgllc manage multiple portfolios for multiple clients. These accounts may
include affiliated and non-affiliated mutual funds, separate accounts (assets managed on behalf of
institutions such as pension funds, insurance companies, foundations), commingled trust accounts,
collective trusts and other types of funds. The portfolios managed by portfolio managers may have
investment objectives, strategies and risk profiles that differ from each other. The portfolio manager
makes investment decisions for each portfolio based on the investment objectives, policies, practices and
other relevant investment considerations applicable to that portfolio. Consequently, the portfolio manager
may purchase securities for one portfolio and not another portfolio. Securities purchased in one portfolio
may perform differently than the securities purchased for another portfolio. A portfolio manager may place
transactions, including short sale transactions, on behalf of one portfolio that are directly or indirectly
contrary to investment decisions made on behalf of other portfolios, or make investment decisions that
are similar to those made for other portfolios, both of which have the potential to adversely impact one
portfolio and not another, depending on market conditions. In addition, some portfolios may have fee
structures that are or have the potential to be higher, in some cases significantly higher, than the fees
paid by other portfolios to Gamgllc. Because a portfolio managers' compensation is affected by revenues
earned by Gamgllc, the incentives associated with any given portfolio may be significantly higher or lower
than those associated with other portfolios managed by the portfolio manager.
Gamgllc's goal is to provide high quality investment services to all of its clients, while meeting Gamgllc's
fiduciary obligation to treat all clients fairly, and Gamgllc has adopted and implemented policies and
procedures, including brokerage and trade allocation policies and procedures, that it believes address the
conflicts associated with managing multiple accounts for multiple clients. Moreover, Gamgllc monitors a
variety of areas, including compliance with applicable laws and regulations, investment guidelines, the
allocation of securities, and compliance with Gamgllc 's Code of Ethics.
6. ITEM 7: TYPES OF CLIENTS
Gamgllc may provide investment management services to institutional and other client portfolios including
affiliated and unaffiliated insurance companies, registered and unregistered investment companies,
corporate retirement plans, public funds, endowments, foundations, and other institutional accounts, state
and local government enterprises and religious organizations.
Gamgllc requires a minimum investment of $5 million for institutional accounts and a minimum investment
of $1 million is required in accredited accounts. Gamgllc retains the ability to waive minimum amounts.
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Methods of Analysis and Investment Strategies
This manager is hired to make money by screening all US listed stocks and ADR's using a series of fixed
fundamental measurements, including several independent unbiased equity ranking firms, resulting in 40
investment "grade A" stocks. Then, with these 40 stocks, buy 40 equal positions in a separately
managed account with limited discretion, using a reputable unaffiliated custodian. This manager has over
25 years of US market experience focusing on building long term growth, normally in excess of three
years. Time is what most short-term investors dislike. Long-term investors appreciate time as a great
asset because equity prices eventually catch up with fundamentals.
Available Separately Managed Accounts: Large Cap, Mid Cap, Small Cap, Sector, Industry, Index,
Global, Country, Geographically Agnostic, Investor Selected Equity Universes, using U.S. stocks and
ADR's listed on U.S. Exchanges.
For Institutional or Accredited Investors Only. Not a guaranteed investment product. All stocks gain and
loose value within economic cycles.
Gamgllc uses the quantitative research and technical analysis of leading financial information providers
as well as other sources of qualitative and other data and the client’s individual circumstances to develop
customized portfolio recommendations.
Gamgllc uses more than seven measurements, to start, when searching for stocks to add to a portfolio.
Very few stocks have all seven measurements, at the same time. These measurements reflect a stocks’
strength on a fundamental level first and then a technical level. These are companies that rank in the top
15% on all seven levels as measured by leading financial information providers and represent the
financial health and overall demand by stock buyers. Gamgllc then gives each stock a score; (a higher
score = higher confidence).
Every evening at one financial information provider, the latest company filings and daily stock prices are
updated from multiple data vendors and stored in their database. Every night their system re-calculates
all financial indicators for all companies under coverage and generates a letter grade for each indicator. A
total of 24 indicators are graded for every company and are broken down into Gamgllc's main groups:
Growth, Value, Profitability and Cash Flow. Finally, all 24 indicators are combined into an overall
fundamental grade ranging from zero to 100.
Risks Generally Associated with Equity Securities:
Equity securities are subject to market risk. Market risk is the risk that one or more securities in which a
strategy invests will go down in value, including the possibility that the securities will go down sharply and
unpredictably. Equity securities may decline in value due to the activities and financial prospects of
individual companies or due to general market and economic movements and trends. Investments in
small capitalization and mid capitalization companies involve greater risks than investments in larger,
more established companies. These securities may be subject to more abrupt or erratic price movements
and may be subject to greater liquidity risk. In addition, these issuers often face greater business risks.
ADR's are subject to various risks of loss that are different from the risks of investing in securities of U.S.-
based companies. Investments in the securities of foreign issuers, including emerging markets, involve
7. significant risks that are not typically associated with investing in the securities of domestic issuers.
Risks Generally Associated with Derivatives:
Derivatives are instruments whose value depends on, or is derived from, the value of an underlying asset,
reference rate or index. Derivatives are volatile and may involve significant risks. In addition to credit risk
liquidity risk and currency risk, derivatives may be subject to leverage risk and index risk.
• Leverage Risk refers to the risk that relatively small market movements may result in large changes in
the value of an investment. Certain investments that involve leverage can result in losses that greatly
exceed the amount originally invested.
• Index Risk refers to the risk that if the derivative is linked to the performance of an index, it will be
subject to the risks associated with changes in that index. If the index changes, the portfolio could receive
lower interest payments or experience a reduction in the value of the derivative to below what the portfolio
paid. Certain indexed securities, including inverse securities (which move in an opposite direction to the
index), may create leverage, to the extent that they increase or decrease in value at a rate that is a
multiple of the changes in the applicable index.
Risks Generally Associated with Structured Products:
Structured products include agency and non-agency mortgage-related securities (e.g., collateralized
mortgage obligations (CMOs)), including (a) interest-only (IO) and principal-only (PO) classes, (b) real
estate mortgage investment conduits (REMICs), (c) stripped mortgage-backed securities (SMBs), (d)
asset-backed securities (ABS), which may include pass-through securities, securities backed by or
representing interests in any financial assets the terms of which generate cash flows, (e) collateralized
debt obligation (CDO) securities, (f) collateralized loan obligations (CLOs), (g) structured notes and (h)
mortgage derivatives.
A class of structured securities may be subordinated to the right of payment of another class.
Subordinated structured securities typically have higher yields and present greater risks than
unsubordinated structured securities. Structured securities markets have recovered substantially from the
extremely distressed conditions during 2008-2009; however, certain sectors and/or structures may
continue to experience pricing and liquidity challenges. Mortgage- and asset-backed securities represent
interests in “pools” of mortgages or other assets, including consumer loans or receivables held in trust.
Mortgage-backed securities are subject to “prepayment risk” and “extension risk.” Holders of mortgage
backed or asset-backed securities that are subordinated to other interests in the same mortgage pool
may only receive payments after the pool’s obligations to other investors have been satisfied. An
unexpectedly high rate of defaults on the mortgages held by a mortgage pool may limit substantially the
pool’s ability to make payments of principal or interest, reducing the values of those securities or in some
cases rendering them worthless. The risk of such defaults is generally higher in the case of mortgage
pools that include so-called “sub prime” mortgages.
The main risk of real estate related securities is that the value of the underlying real estate may go down.
Many factors may affect real estate values. These factors include both the general and local economies,
the amount of new construction in a particular area, the laws and regulations (including zoning and tax
laws) affecting real estate and the costs of owning, maintaining and improving real estate. The availability
of mortgages and changes in interest rates may also affect real estate values. The real estate industry is
particularly sensitive to economic downturns. If real estate related investments are concentrated in one
geographic area or in one property type, the portfolio risks associated with that area or property type will
be greater.
Risks Generally Associated with ETFs, Unregistered Investment Products and Pooled Investment
Vehicles:
Gamgllc may also invest in mutual funds and exchange traded funds (“ETFs”) and exchange traded notes
(“ETNs”). Gamgllc may also buy and sell interests in investment companies which may not be registered
under the 1940 Act, such as holding company depository receipts (“HOLDRs”) as well as private
placements in pooled investment vehicles and other private issuers if requested to do so. An investment
in an ETF generally presents the following risks: the same primary risks as an investment in a fund that is
8. not exchange-traded that has the same investment objectives, strategies and policies as the ETF; the risk
that the ETF may fail to accurately track the market segment or index that underlies its investment
objective; price fluctuation, resulting in a loss to the fund; the risk that the ETF may trade at a price that is
lower than its NAV; and the risk that an active market for the ETF’s shares may not develop or be
maintained. The portfolio will indirectly pay a proportional share of the asset-based fees of the ETFs.
ETFs are also subject to specific risks depending on the nature of the ETF, such as liquidity risk, sector
risk, and foreign and emerging market risk, as well as risks associated with fixed income securities, real
estate investments and commodities. An investment in an ETF presents the risk that the ETF may no
longer meet the listing requirements of any applicable exchanges on which the ETF is listed.
ITEM 9: DISCIPLINARY INFORMATION
A. Criminal or Civil Proceedings
None
B. Administrative Proceedings Before Regulatory Authorities
None.
C. Self-Regulatory Organization (SRO) Proceedings
None
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
A. Broker-Dealer Registration Status
None
B. Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Adviser Registration
Status
None
C. Material Relationships or Arrangements with Industry Participants
None
Other Pooled Investment Vehicles:
None
Other Investment adviser or financial planner:
None
Futures commission merchant, commodity pool operator, or commodity trading advisor:.
None
Banking or thrift institution:
None
Accountant or accounting firm:
None
9. Lawyer or law firm:
None
Insurance company or agency:
None
Pension consultant:
Gamgllc may have agreements with independent consultants.
Real estate broker or dealer;
None
Sponsor or syndicator of limited partnerships:
None
D. Material Conflicts of Interest Relating to Other Investment Advisers
Gamgllc does not recommend or select other investment advisers for Gamgllc's clients.
ITEM 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics
Gamgllc has adopted a Code of Ethics. Gamgllc will provide a copy of the Code of Ethics to any Client or
prospective Client upon request. The Code of Ethics also addresses issues such as political
contributions, market timing, late trading, gifts and entertainment, service on boards of directors and
outside business activities.
Securities that Gamgllc or a Related Person Has a Material Financial Interest In
From time to time Gamgllc may have a material financial interest in securities owned by or recommended
to clients of Gamgllc. Such investments may not be balanced among strategies and accordingly, these
situations may give rise to potential conflicts of interests since Gamgllc may have an economic interest in
maximizing performance in a fund or account in which they are invested. Any such transactions will be
conducted in compliance with the requirements of the Advisers Act and the 1940 Act, as applicable.
Gamgllc is not obligated to recommend, buy or sell, or take any short position with respect to, or to refrain
from recommending, buying or selling or taking any short position with respect to, any security that
Gamgllc, its affiliates or their respective access persons, as defined by the Advisers Act, may buy or sell
for its or their own account or for the accounts of any other client. In addition, Gamgllc is not obligated to
seek information or to make available to or share with any client any information, investment strategies or
investment opportunities developed or used in connection with other clients, and Gamgllc personnel may
act on the basis of such information for certain portfolios in a manner that may have an adverse effect on
other portfolios. Gamgllc is not obligated to refrain from investing in securities held by funds or accounts
that it manages except to the extent that such investments violate the Code of Ethics adopted by Gamgllc
in accordance with Rule 204A-1 of the Advisers Act and Rule 17j-1 under the 1940 Act.
Conflicts of Interest Created by Contemporaneous Trading
None
10. ITEM 12: BROKERAGE PRACTICES
Research and Other Soft Dollar Benefits:
None
Gamgllc may consider selecting broker-dealers identified by the client if such request is supported by a
written request. Gamgllc may advise clients that directing it to use a particular broker dealer to execute
transactions for their accounts may result in: (1) higher transaction costs for the client; (2) reduce the
firm’s flexibility in securing most favorable execution; (3) that a client who directs Gamgllc to use a
specific broker may forego any benefits from savings on execution costs that Gamgllc could obtain for its
clients through negotiating volume discounts on batched transactions; (4) that a client who directs
Gamgllc to use a specific broker may not be able to participate in a new issue if that new issue is
provided by another broker; (5) Gamgllc may not begin to execute client securities transactions with
broker-dealers which have been directed by clients until all non-directed brokerage orders are completed;
and (6) the accounts of clients directing broker-dealers may not generate returns equal to clients that do
not direct broker-dealers. Gamgllc will not direct trades to any broker-dealer as compensation for or in
recognition of any promotion or sale of shares of or interests in mutual funds, unregistered funds, or
separately managed accounts.
Order Aggregation: Gamgllc may aggregate portfolio management orders into a single order (absent
specific client direction to the contrary) when it determines that it is consistent with best execution and in
the best interests of the clients. It is the policy of Gamgllc that when a decision is made to aggregate
transactions on behalf of more than one account, such transactions will be allocated to all participating
client accounts in a fair and equitable manner. Such combined or “batched” trades may be used to
facilitate best execution including negotiating more favorable prices, obtaining more timely or equitable
execution or reducing overall transactions costs. Gamgllc may include affiliated accounts in such
aggregated trades. Equity trades will carry the average dollar weighted execution price. Due to the
nature of the over-the-counter (OTC) fixed income market (with limited liquidity among different
counterparties and no centralized exchange), the concept of average dollar weighted execution price
does not apply to fixed income trades. Gamgllc will not receive additional compensation or remuneration
as a result of block transactions.
ITEM 13: REVIEW OF ACCOUNTS
Frequency and Nature of Review of Client Accounts or Financial Plans
Gamgllc periodically reviews all accounts. This does not absolve the client of their responsibility to
monitor their own account and ask questions on a regular basis as any normal account holder would do.
Content and Frequency of Account Reports to Clients
Gamgllc does not custody client accounts. Clients receive regular statements from their custodian. Due
to the variety of managed accounts, reporting may be customized to meet client needs.
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
Economic Benefits for Providing Services to Clients
Gamgllc does not receive any economic benefits from persons who are not Clients in exchange for
providing advisory services to Gamgllc's Clients.
11. Compensation to Non-Supervised Persons for Client Referrals
From time to time, Gamgllc or its affiliates may pay investment consultants or their parent or affiliated
companies for certain services including industry data services, technology, operations, tax, or audit
consulting services, and/or may pay such firms for Gamgllc’s attendance at investment forums,
conferences or seminars or for various studies, surveys, or access to databases. Gamgllc or its affiliates
may also provide investment advisory services to investment consultants and/or their affiliates. These
investment consultants and/or their affiliates may, in the ordinary course of their investment consultant
business, recommend Gamgllc’s services or products sponsored by Gamgllc and/or its affiliates to their
clients. To this end, Gamgllc from time to time provides information about its various investment styles to
investment consultants, who may use that information in connection with searches they conduct for their
clients. Gamgllc also from time to time responds to requests for proposals and requests for information
received from investment consultants in connection with such searches. Gamgllc reserves the right to
enter into arrangements pursuant to which certain unaffiliated persons and entities may be compensated,
directly or indirectly, for referring clients to Gamgllc. To the extent deemed applicable, such
arrangements will be entered into in accordance with the terms and conditions of Rule 206(4)-3 under the
Advisers Act. Clients will be advised of the nature of these arrangements prior to the time of the referral.
ITEM 15: CUSTODY
Gamgllc does not custody assets.
ITEM 16: INVESTMENT DISCRETION
Gamgllc accepts "limited" discretionary authority to manage securities accounts on behalf of clients.
Gamgllc may provide investment management services to several non-discretionary accounts as well.
ITEM 17: VOTING CLIENT SECURITIES
Policies and Procedures Relating to Voting Client Securities
Gamgllc does not vote on client securities or class actions and similar matters
ITEM 18: FINANCIAL INFORMATION
A. Balance Sheet
Gamgllc does not produce standalone balance sheets.
B. Financial Conditions Likely to Impair Ability to Meet Contractual Commitments to Clients
Gamgllc is not aware of any financial condition that is reasonably likely to impair the firm’s ability to
meet contractual commitments to Clients.
C. Bankruptcy Filings
Gamgllc has never been the subject of a bankruptcy petition.
Greenwich Asset Management Group, LLC
FORM ADV, PART 2 – MARCH 30, 2012
SEC File Number 801-60497 - CRD Number 114871