ITEM 1: COVER PAGE______________________________________________________________________________________                  ...
ITEM 2: MATERIAL CHANGESThe following is a summary of the material changes to this Brochure since the last annual update o...
ITEM 4: ADVISORY BUSINESSA. General Description of Advisory FirmGreenwich Asset Management Group, LLC (“Gamgllc”) provides...
ITEM 5: FEES AND COMPENSATIONAdvisory Fees and CompensationGamgllc generally receives a percentage of assets under managem...
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENTGamgllc may receive performance based fees from certain "qualifi...
ITEM 7: TYPES OF CLIENTSGamgllc may provide investment management services to institutional and other client portfolios in...
significant risks that are not typically associated with investing in the securities of domestic issuers.Risks Generally A...
not exchange-traded that has the same investment objectives, strategies and policies as the ETF; the riskthat the ETF may ...
Lawyer or law firm:  None  Insurance company or agency:  None  Pension consultant:  Gamgllc may have agreements with indep...
ITEM 12: BROKERAGE PRACTICES  Research and Other Soft Dollar Benefits:  NoneGamgllc may consider selecting broker-dealers ...
Compensation to Non-Supervised Persons for Client ReferralsFrom time to time, Gamgllc or its affiliates may pay investment...
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ADV Part II Gamgllc

  1. 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 www.Gamgllc.comThis brochure provides information about the qualifications and business practices of Greenwich AssetManagement Group, LLC. If you have any questions about the contents of this brochure, please contact usat 203-622-1305 or The information in this brochure has not been approvedor verified by the United States Securities and Exchange Commission (the "SEC") or by any state securitiesauthority.Additional information about Greenwich Asset Management Group, LLC also is available on the SECswebsite at Registration with the SEC or with any state securities authority doesnot 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. 2. ITEM 2: MATERIAL CHANGESThe following is a summary of the material changes to this Brochure since the last annual update on Dec31, 2011:NoneGreenwich Asset Management Group, LLC will provide you with a new Brochure at any time uponrequest without charge. You may request a Brochure by email at or byphone at 203-622-1305. The Brochure is also available on Greenwich Asset Management Group LLC’swebsite free of charge at Additional information about Greenwich Asset ManagementGroup, LLC may also be obtained on the SEC’s website 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. 3. ITEM 4: ADVISORY BUSINESSA. General Description of Advisory FirmGreenwich Asset Management Group, LLC (“Gamgllc”) provides investment advisory and investmentmanagement services designed for institutional and accredited clients. Gamgllc is a sole proprietorshipentity which collaborates with outside resources to provide investment management results. Gamgllc wasorganized in 2001 by Peter Lundstedt after gaining experience for 15 years on the brokerage side whichincluded a U.S. listed equity strategy that was successfully run for over five years with a former $30 billionState Common Retirement Fund Manager. Greenwich Asset Management Group, LLC providesIndependent, unbiased, transparent, and “investment banking and brokerage free” advice.B. Description of Advisory ServicesGamgllc provides discretionary investment management services designed for institutional and accreditedclients and other client portfolios focusing mainly on separately managed U.S. listed equity accounts heldat and traded through independent unaffiliated custodians and never holds or takes possession of anyassets. Gamgllc manages accounts with limited discretion as to buying or selling stocks for clients as wellas deducting management fees only.Gamgllc may in the future serve as investment sub-adviser to a number of investment companiesregistered under the Investment Company Act of 1940 (“1940 Act”).complete information concerning eachsuch 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 createvalue from three sources: (i) high fundamental buy ratings graded by multiple independent andunaffiliated equity ranking firms (multiple outside buy opinions), (ii) technical analysis, and (iii) portfolioequal 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 Universesusing U.S. stocks and ADRs only.Availability of Customized Services for Individual ClientsGamgllc may tailor the investment program for certain accounts based on the client’s particular needs aswell as overall financial condition, goals, risk tolerance and other factors unique to the client’s particularcircumstances including regulatory restrictions. Gamgllc may also agree to investment guidelines forcertain 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. 4. ITEM 5: FEES AND COMPENSATIONAdvisory Fees and CompensationGamgllc 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. Feeschedules for different styles of fixed income and equity management will vary depending on researchintensity, degree of active management. Gamgllc may, in its sole discretion, negotiate terms and chargedifferent fees for certain accounts based on a client’s particular needs as well as overall financialcondition, goals, risk tolerance and other factors unique to the client’s particular circumstances. Gamgllc’sstandard investment advisory agreement is mutually revocable at any time without penalty and continuesin effect until 30 days after written notice of termination is given by either party. Standard fee schedulesare as follows:1.95% per year paid quarterly in advance.Payment of FeesFees are generally payable to Gamgllc at the beginning of the quarterly based on the quarter-end marketvalue or average value for the quarter. Clients are responsible for verifying that the fee was correctlycalculated. If a client terminates the relationship prior to the end of a period, the fee is prorated.Additional Fees and ExpensesClients will pay all interest, charges, taxes, fees, commissions, brokerage costs and expenses of everykind related to their account. Clients may also bear expenses “passed through” from third partiesperforming 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 bytheir custodian will also bear the additional fees and expenses assessed by such money market mutualfunds to the extent of their investment in such funds. To the extent that the investment guidelines for anaccount 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 collectiveinvestment vehicles, as well as the investment advisory fee of Gamgllc. Clients investing directly inmutual funds sub-advised by Gamgllc will bear the fees and expenses disclosed in such mutual fund’sprospectus.Additional Compensation and Conflicts of InterestGamgllc 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 feespaid 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 torecommend 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 certaindisclosures to prospective clients as mandated by Rule 206(4)-3 of the Investment Advisers Act, whichincludes disclosing to prospective clients the solicitor’s position with Gamgllc or its affiliate and the natureof the relationship. The disclosures required by Rule 206(4)-3 are necessary to inform prospective clientsabout the nature of the solicitor’s financial interest in the recommendation so they may consider thesolicitor’s potential bias, and to protect prospective clients against solicitation activities being carried outin a manner inconsistent with the firm’s fiduciary duty to clients.
  5. 5. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENTGamgllc may receive performance based fees from certain "qualified" accounts and certain investmentprofessionals manage both accounts that are charged a performance based fee and accounts that arecharged other types of fees.Typical performance based fees are 1% base fee then 1% for every 11% earned for client accounts withhigh water marks taken during the quarter when it occurs. This fee structure can be 50% of a traditional 2and 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. mutualfunds, managed accounts and private investment funds may raise potential conflicts of interest, includingconflicts associated with the differences in fee structures for such products.Performance-based fees may provide an incentive for Gamgllc to purchase investments that are morespeculative and/or involve a higher degree of risk than might otherwise be the case in the absence ofsuch performance-based compensation. The prospect of earning a higher compensation from a portfoliowith a higher fee structure (such as a private fund with a performance based fee) may provide Gamgllcwith an incentive to favor the portfolio with the higher fee structure when, for example, allocatingsecurities transactions expected to more likely result in favorable performance. In addition, in connectionwith organizing a private investment fund which focuses on a particular asset class, such as structuredsecurities, Gamgllc may contractually promise to provide such fund with the first consideration of relevantinvestment opportunities before offering such opportunities to other clients’ accounts which may beeligible to invest therein. Such private investment funds may provide greater fees (including performancebased 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 mayinclude affiliated and non-affiliated mutual funds, separate accounts (assets managed on behalf ofinstitutions such as pension funds, insurance companies, foundations), commingled trust accounts,collective trusts and other types of funds. The portfolios managed by portfolio managers may haveinvestment objectives, strategies and risk profiles that differ from each other. The portfolio managermakes investment decisions for each portfolio based on the investment objectives, policies, practices andother relevant investment considerations applicable to that portfolio. Consequently, the portfolio managermay purchase securities for one portfolio and not another portfolio. Securities purchased in one portfoliomay perform differently than the securities purchased for another portfolio. A portfolio manager may placetransactions, including short sale transactions, on behalf of one portfolio that are directly or indirectlycontrary to investment decisions made on behalf of other portfolios, or make investment decisions thatare similar to those made for other portfolios, both of which have the potential to adversely impact oneportfolio and not another, depending on market conditions. In addition, some portfolios may have feestructures that are or have the potential to be higher, in some cases significantly higher, than the feespaid by other portfolios to Gamgllc. Because a portfolio managers compensation is affected by revenuesearned by Gamgllc, the incentives associated with any given portfolio may be significantly higher or lowerthan those associated with other portfolios managed by the portfolio manager.Gamgllcs goal is to provide high quality investment services to all of its clients, while meeting Gamgllcsfiduciary obligation to treat all clients fairly, and Gamgllc has adopted and implemented policies andprocedures, including brokerage and trade allocation policies and procedures, that it believes address theconflicts associated with managing multiple accounts for multiple clients. Moreover, Gamgllc monitors avariety of areas, including compliance with applicable laws and regulations, investment guidelines, theallocation of securities, and compliance with Gamgllc s Code of Ethics.
  6. 6. ITEM 7: TYPES OF CLIENTSGamgllc may provide investment management services to institutional and other client portfolios includingaffiliated and unaffiliated insurance companies, registered and unregistered investment companies,corporate retirement plans, public funds, endowments, foundations, and other institutional accounts, stateand local government enterprises and religious organizations.Gamgllc requires a minimum investment of $5 million for institutional accounts and a minimum investmentof $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 LOSSMethods of Analysis and Investment StrategiesThis manager is hired to make money by screening all US listed stocks and ADRs using a series of fixedfundamental measurements, including several independent unbiased equity ranking firms, resulting in 40investment "grade A" stocks. Then, with these 40 stocks, buy 40 equal positions in a separatelymanaged account with limited discretion, using a reputable unaffiliated custodian. This manager has over25 years of US market experience focusing on building long term growth, normally in excess of threeyears. Time is what most short-term investors dislike. Long-term investors appreciate time as a greatasset 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 andADRs listed on U.S. Exchanges.For Institutional or Accredited Investors Only. Not a guaranteed investment product. All stocks gain andloose value within economic cycles.Gamgllc uses the quantitative research and technical analysis of leading financial information providersas well as other sources of qualitative and other data and the client’s individual circumstances to developcustomized 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 top15% on all seven levels as measured by leading financial information providers and represent thefinancial health and overall demand by stock buyers. Gamgllc then gives each stock a score; (a higherscore = higher confidence).Every evening at one financial information provider, the latest company filings and daily stock prices areupdated from multiple data vendors and stored in their database. Every night their system re-calculatesall financial indicators for all companies under coverage and generates a letter grade for each indicator. Atotal of 24 indicators are graded for every company and are broken down into Gamgllcs main groups:Growth, Value, Profitability and Cash Flow. Finally, all 24 indicators are combined into an overallfundamental 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 astrategy invests will go down in value, including the possibility that the securities will go down sharply andunpredictably. Equity securities may decline in value due to the activities and financial prospects ofindividual companies or due to general market and economic movements and trends. Investments insmall 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 movementsand may be subject to greater liquidity risk. In addition, these issuers often face greater business risks.ADRs 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. 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 riskliquidity 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 inthe value of an investment. Certain investments that involve leverage can result in losses that greatlyexceed the amount originally invested.• Index Risk refers to the risk that if the derivative is linked to the performance of an index, it will besubject to the risks associated with changes in that index. If the index changes, the portfolio could receivelower interest payments or experience a reduction in the value of the derivative to below what the portfoliopaid. Certain indexed securities, including inverse securities (which move in an opposite direction to theindex), may create leverage, to the extent that they increase or decrease in value at a rate that is amultiple 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., collateralizedmortgage obligations (CMOs)), including (a) interest-only (IO) and principal-only (PO) classes, (b) realestate mortgage investment conduits (REMICs), (c) stripped mortgage-backed securities (SMBs), (d)asset-backed securities (ABS), which may include pass-through securities, securities backed by orrepresenting interests in any financial assets the terms of which generate cash flows, (e) collateralizeddebt 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 thanunsubordinated structured securities. Structured securities markets have recovered substantially from theextremely distressed conditions during 2008-2009; however, certain sectors and/or structures maycontinue to experience pricing and liquidity challenges. Mortgage- and asset-backed securities representinterests 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 mortgagebacked or asset-backed securities that are subordinated to other interests in the same mortgage poolmay only receive payments after the pool’s obligations to other investors have been satisfied. Anunexpectedly high rate of defaults on the mortgages held by a mortgage pool may limit substantially thepool’s ability to make payments of principal or interest, reducing the values of those securities or in somecases rendering them worthless. The risk of such defaults is generally higher in the case of mortgagepools 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 taxlaws) affecting real estate and the costs of owning, maintaining and improving real estate. The availabilityof mortgages and changes in interest rates may also affect real estate values. The real estate industry isparticularly sensitive to economic downturns. If real estate related investments are concentrated in onegeographic area or in one property type, the portfolio risks associated with that area or property type willbe greater.Risks Generally Associated with ETFs, Unregistered Investment Products and Pooled InvestmentVehicles: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 registeredunder the 1940 Act, such as holding company depository receipts (“HOLDRs”) as well as privateplacements in pooled investment vehicles and other private issuers if requested to do so. An investmentin an ETF generally presents the following risks: the same primary risks as an investment in a fund that is
  8. 8. not exchange-traded that has the same investment objectives, strategies and policies as the ETF; the riskthat the ETF may fail to accurately track the market segment or index that underlies its investmentobjective; price fluctuation, resulting in a loss to the fund; the risk that the ETF may trade at a price that islower than its NAV; and the risk that an active market for the ETF’s shares may not develop or bemaintained. 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, sectorrisk, and foreign and emerging market risk, as well as risks associated with fixed income securities, realestate investments and commodities. An investment in an ETF presents the risk that the ETF may nolonger meet the listing requirements of any applicable exchanges on which the ETF is listed. ITEM 9: DISCIPLINARY INFORMATIONA. Criminal or Civil Proceedings NoneB. Administrative Proceedings Before Regulatory Authorities None.C. Self-Regulatory Organization (SRO) Proceedings None ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONSA. Broker-Dealer Registration Status NoneB. Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Adviser Registration Status NoneC. 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. 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: NoneD. Material Conflicts of Interest Relating to Other Investment Advisers Gamgllc does not recommend or select other investment advisers for Gamgllcs clients. ITEM 11: Code of Ethics, Participation or Interest in Client Transactions and Personal TradingCode of EthicsGamgllc has adopted a Code of Ethics. Gamgllc will provide a copy of the Code of Ethics to any Client orprospective Client upon request. The Code of Ethics also addresses issues such as politicalcontributions, market timing, late trading, gifts and entertainment, service on boards of directors andoutside business activities.Securities that Gamgllc or a Related Person Has a Material Financial Interest InFrom time to time Gamgllc may have a material financial interest in securities owned by or recommendedto clients of Gamgllc. Such investments may not be balanced among strategies and accordingly, thesesituations may give rise to potential conflicts of interests since Gamgllc may have an economic interest inmaximizing performance in a fund or account in which they are invested. Any such transactions will beconducted 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 refrainfrom recommending, buying or selling or taking any short position with respect to, any security thatGamgllc, its affiliates or their respective access persons, as defined by the Advisers Act, may buy or sellfor its or their own account or for the accounts of any other client. In addition, Gamgllc is not obligated toseek information or to make available to or share with any client any information, investment strategies orinvestment opportunities developed or used in connection with other clients, and Gamgllc personnel mayact on the basis of such information for certain portfolios in a manner that may have an adverse effect onother portfolios. Gamgllc is not obligated to refrain from investing in securities held by funds or accountsthat it manages except to the extent that such investments violate the Code of Ethics adopted by Gamgllcin 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. 10. ITEM 12: BROKERAGE PRACTICES Research and Other Soft Dollar Benefits: NoneGamgllc may consider selecting broker-dealers identified by the client if such request is supported by awritten request. Gamgllc may advise clients that directing it to use a particular broker dealer to executetransactions for their accounts may result in: (1) higher transaction costs for the client; (2) reduce thefirm’s flexibility in securing most favorable execution; (3) that a client who directs Gamgllc to use aspecific broker may forego any benefits from savings on execution costs that Gamgllc could obtain for itsclients through negotiating volume discounts on batched transactions; (4) that a client who directsGamgllc to use a specific broker may not be able to participate in a new issue if that new issue isprovided by another broker; (5) Gamgllc may not begin to execute client securities transactions withbroker-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 donot direct broker-dealers. Gamgllc will not direct trades to any broker-dealer as compensation for or inrecognition of any promotion or sale of shares of or interests in mutual funds, unregistered funds, orseparately managed accounts.Order Aggregation: Gamgllc may aggregate portfolio management orders into a single order (absentspecific client direction to the contrary) when it determines that it is consistent with best execution and inthe best interests of the clients. It is the policy of Gamgllc that when a decision is made to aggregatetransactions on behalf of more than one account, such transactions will be allocated to all participatingclient accounts in a fair and equitable manner. Such combined or “batched” trades may be used tofacilitate best execution including negotiating more favorable prices, obtaining more timely or equitableexecution or reducing overall transactions costs. Gamgllc may include affiliated accounts in suchaggregated trades. Equity trades will carry the average dollar weighted execution price. Due to thenature of the over-the-counter (OTC) fixed income market (with limited liquidity among differentcounterparties and no centralized exchange), the concept of average dollar weighted execution pricedoes not apply to fixed income trades. Gamgllc will not receive additional compensation or remunerationas a result of block transactions. ITEM 13: REVIEW OF ACCOUNTS Frequency and Nature of Review of Client Accounts or Financial PlansGamgllc periodically reviews all accounts. This does not absolve the client of their responsibility tomonitor their own account and ask questions on a regular basis as any normal account holder would do.Content and Frequency of Account Reports to ClientsGamgllc does not custody client accounts. Clients receive regular statements from their custodian. Dueto the variety of managed accounts, reporting may be customized to meet client needs. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATIONEconomic Benefits for Providing Services to ClientsGamgllc does not receive any economic benefits from persons who are not Clients in exchange forproviding advisory services to Gamgllcs Clients.
  11. 11. Compensation to Non-Supervised Persons for Client ReferralsFrom time to time, Gamgllc or its affiliates may pay investment consultants or their parent or affiliatedcompanies for certain services including industry data services, technology, operations, tax, or auditconsulting 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 affiliatesmay also provide investment advisory services to investment consultants and/or their affiliates. Theseinvestment consultants and/or their affiliates may, in the ordinary course of their investment consultantbusiness, recommend Gamgllc’s services or products sponsored by Gamgllc and/or its affiliates to theirclients. To this end, Gamgllc from time to time provides information about its various investment styles toinvestment consultants, who may use that information in connection with searches they conduct for theirclients. Gamgllc also from time to time responds to requests for proposals and requests for informationreceived from investment consultants in connection with such searches. Gamgllc reserves the right toenter 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, sucharrangements will be entered into in accordance with the terms and conditions of Rule 206(4)-3 under theAdvisers Act. Clients will be advised of the nature of these arrangements prior to the time of the referral. ITEM 15: CUSTODYGamgllc does not custody assets. ITEM 16: INVESTMENT DISCRETIONGamgllc 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 SECURITIESPolicies and Procedures Relating to Voting Client SecuritiesGamgllc does not vote on client securities or class actions and similar matters ITEM 18: FINANCIAL INFORMATIONA. 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