IRON GATE GLOBAL ADVISORS, LLC

Item 1: Cover Page Part 2A of Form ADV: Firm Brochure March 2025 960 North 400 East North Salt Lake, Utah 84054 www.IGGA.com Firm Contact: Brian Hunsaker Chief Compliance Officer This brochure provides information about the qualifications and business practices of Iron Gate Global Advisors LLC. If clients have any questions about the contents of this brochure, please contact us at (801) 575-6427 or brian@igga.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any State Securities Authority. Additional information about our firm is also available on the SEC’s website at 111177. www.adviserinfo.sec.gov by searching CRD # Please note that the use of the term “registered investment adviser” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on the qualifications of our firm and our employees.  Item 2: Material Changes Iron Gate Global Advisors LLC is required to make clients aware of information that has changed since the last annual update to the Firm Brochure (“Brochure”) and that may be important to them. Clients can then determine whether to review the brochure in its entirety or to contact us with questions about the changes. Since the last annual amendment filed on 03/22/2024, the following changes have been made: • are generally Item 7: Certain options strategies now require a $1,000,000 minimum and limited to taxable accounts due to regulatory and suitability considerations. • Item 14: The Adviser has entered into agreements with certain intermediaries (Solicitors) to refer Clients in exchange for compensation. These agreements do not result in additional fees or expenses for Clients. ADV Part 2A – Firm Brochure Page 2  Item 3: Table of Contents Item 1: Cover Page .................................................................................................................................... 1 Item 2: Material Changes ......................................................................................................................... 2 Item 3: Table of Contents ......................................................................................................................... 3 Item 4: Advisory Business ....................................................................................................................... 4 Item 5: Fees & Compensation ................................................................................................................. 7 Item 6: Performance-Based Fees & Side-By-Side Management ....................................................... 9 Item 7: Types of Clients & Account Requirements ............................................................................. 9 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................ 9 Item 9: Disciplinary Information ......................................................................................................... 15 Item 10: Other Financial Industry Activities & Affiliations ............................................................ 15 Item 11: Code of Ethics, Participation or Interest in ........................................................................ 16 Item 12: Brokerage Practices ............................................................................................................... 16 Item 13: Review of Accounts or Financial Plans ............................................................................... 21 Item 14: Client Referrals & Other Compensation ............................................................................. 21 Item 15: Custody ...................................................................................................................................... 22 Item 16: Investment Discretion............................................................................................................ 22 Item 17: Voting Client Securities .......................................................................................................... 22 Item 18: Financial Information ............................................................................................................ 24 ADV Part 2A – Firm Brochure Page 3  Item 4: Advisory Business Our firm provides individuals and other types of clients with a wide array of investment advisory services. Our firm is a limited liability company formed under the laws of the State of Utah in 1999 and has been in business as an investment adviser since that time. Our firm is owned by Brian W. Hunsaker, Brett M Pattison, Spencer Nelson, and Franz S. Amussen. The purpose of this Brochure is to disclose the conflicts of interest associated with the investment transactions, compensation and any other matters related to investment decisions made by our firm or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is accomplished in part by knowing our client. Our firm has established a service-oriented advisory practice with open lines of communication for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to understand their investment objectives while educating them about our process, facilitates the kind of working relationship we value. Types of Advisory Services Offered Asset Management: As part of our Asset Management service, a portfolio is created, consisting of individual stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all the previously mentioned securities. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. Comprehensive Portfolio Management: As part of our Comprehensive Portfolio Management service, clients receive both asset management and financial planning or consulting services. This service is designed to help clients work toward their financial goals through a structured financial plan or consultation. Our firm conducts client meetings to gain a thorough understanding of their current financial situation, available resources, financial goals, and risk tolerance. Based on this information, we develop and present a tailored investment strategy that may include individual stocks, bonds, ETFs, options, mutual funds, and other public or private securities and investments. Once an appropriate portfolio is established, we provide ongoing monitoring and management, making adjustments as needed to align with the client’s objectives, changing circumstances, and market conditions. Upon request, we also provide clients with a summary of observations and recommendations related to the financial planning or consulting aspects of this service. To support clients in achieving their financial goals, we have developed a range of model portfolios, each designed to align with different risk tolerances and investment objectives, which we assess through our consultation process. ADV Part 2A – Firm Brochure Page 4  • • growth-oriented portfolio growth-oriented portfolio consisting of equities with an overlay options strategy consisting of equities. • • balanced portfolio moderate portfolio Our standard models include: A A aimed at generating both income and capital appreciation. It's important to note that this strategy can introduce higher volatility to the portfolio. ($1,000,000.00 Account Minimum) Some option strategies are not available in retirement accounts. A A with a 70% allocation to equities and 30% to fixed income. with a 50/50 allocation between equities and fixed income. Some of our options strategies are not suitable or permissible for use in certain retirement-type accounts due to regulatory limitations and suitability considerations. While we may utilize some options strategies in retirement accounts, others, particularly those with higher complexity or risk, require a $1,000,000.00 account minimum and must be implemented in taxable accounts. Examples of retirement-type accounts where certain options strategies may not be used include IRAs, Roth IRAs, and 401(k)s. Furthermore, for clients drawing income from their portfolios, our general practice is to maintain approximately two years' worth of anticipated cash needs in reserve. Retirement Plan Consulting: Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising may include: • • • • • Establishing an Investment Policy Statement – Our firm will assist in the development of a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives. Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment options and make recommendations for appropriate changes. Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, financial situation and tolerance for risk. Investment Monitoring – Our firm will monitor the performance of the investments and notify the client in the event of over/underperformance and in times of market volatility. Participant Education – Our firm will provide opportunities to educate plan participants about their retirement plan offerings, different investment options, and general guidance on allocation strategies. In providing services for retirement plan consulting, our firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section ADV Part 2A – Firm Brochure Page 5  3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. Financial Planning & Consulting: Our firm provides financial planning and consultation services tailored to each client's needs. These services typically include general recommendations for a course of action or specific steps clients may take to work toward their financial goals. Implementation of any recommendations is at the sole discretion of the client. For financial planning engagements, our firm delivers clients a summary of their financial situation along with relevant observations and recommendations. Our financial planners use specialized financial planning software to develop and present client plans. Clients receive secure login credentials to access and review their comprehensive financial plan digitally at their convenience. In contrast, financial consultations are generally less formal and do not typically include a written summary, as they focus on addressing specific concerns or financial questions during the engagement. Assuming all required information and documents are provided promptly by the client, financial plans and consultations are typically completed within six months of the client signing an agreement with our firm. Tailoring of Advisory Services Our firm offers individualized investment advice to our Asset Management clients. General investment advice will be offered to our Financial Planning & Consulting clients. Each Asset Management client can place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Participation in Wrap Fee Programs Our firm does not offer or sponsor a wrap fee program. Regulatory Assets Under Management on a discretionary basis and $194,200,000 on a non-discretionary Our firm manages $844,480,318.53 basis as of March 25, 2025. ADV Part 2A – Firm Brochure Page 6  Item 5: Fees & Compensation Compensation for Our Advisory Services Asset Management: The maximum annual fee charged for this service will not exceed 1.75%. Clients may be subject to a tiered or flat fee as noted in their previously signed advisory agreement but will not exceed the 1.75% maximum fee. Fees to be assessed will be outlined in the advisory agreement to be signed by the Client. Annualized fees are billed on a pro-rata basis quarterly or monthly, in advance or arrears based on the value of the account(s) on the last day of the previous quarter or month. Fees are negotiable and will be deducted from client account(s). Adjustments will be made for deposits and withdrawals during the quarter. In rare cases, our firm will agree to directly invoice. Further, it is important to note that our firm assesses advisory fees on cash and cash equivalents held in client accounts. As part of this process, Clients understand the following: a) b) c) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our firm. Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian; and If our firm sends a copy of our invoice to the client, a legend urging the comparison of information provided in our statement with those from the qualified custodian will be included. Comprehensive Portfolio Management: The maximum annual fee charged for this service will not exceed 1.75%. Fees to be assessed will be outlined in the advisory agreement to be signed by the Client. Annualized fees are billed on a pro- rata basis monthly or quarterly in advance or in arrears based on the value of the account(s) on the last day of the previous month OR quarter. Fees are negotiable and will be deducted from client account(s). Adjustments will be made for deposits and withdrawals during the quarter. In rare cases, our firm will agree to directly invoice. Further, it is important to note that our firm assesses advisory fees on cash and cash equivalents held in client accounts. As part of this process, Clients understand the following: a) b) c) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our firm. Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian; and If our firm sends a copy of our invoice to the client, a legend urging the comparison of information provided in our statement with those from the qualified custodian will be included. Retirement Plan Consulting: Our Retirement Plan Consulting services are billed on an hourly or flat fee basis or a fee based on the percentage of Plan assets under management. The total estimated fee, as well as the ultimate fee ADV Part 2A – Firm Brochure Page 7  charged, is based on the scope and complexity of our engagement with the client. Fees based on a percentage of managed Plan assets will not exceed 1.00%. The fee-paying arrangements will be determined on a case-by-case basis and will be detailed in the signed consulting agreement. Financial Planning & Consulting: Our firm charges on a flat fee basis for financial planning and consulting services. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with the client. Flat fees will range from $1,000 to $5,000. The fee-paying arrangements will be determined on a case-by-case basis and will be detailed in the signed consulting agreement. Our firm will not require a retainer. Additionally, for our firm’s asset management clients, the fee will be considered paid in quarterly installments via their asset management fees. If a client decides to remove us from managing his/her assets, any remaining financial planning fee will become due at the time of separation. Other Types of Fees & Expenses Clients will incur transaction fees for trades executed by their chosen custodian based on individual transaction charges. These transaction fees are separate from our firm’s advisory fees and will be disclosed by the chosen custodian. However, it is important to note that Charles Schwab & Co., Inc. (“Schwab”) no longer charges commissions on domestic equity and exchange traded fund transactions. Furthermore, clients should be aware that Fidelity Brokerage Services (“Fidelity”) eliminated transaction fees for U.S. listed equities and exchange traded funds for clients who opt into electronic delivery of statements or maintain at least $1 million in assets at Fidelity. Clients who do not meet either criteria will be subject to transaction fees charged by Fidelity for U.S. listed equities and exchange traded funds. Clients may also pay holdings charges imposed by the chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees. Termination & Refunds Either party may terminate the advisory agreement signed with our firm for Asset Management and Comprehensive Portfolio Management services in writing at any time. Upon notice of termination our firm will process a pro-rata refund of the unearned portion of the advisory fees charged in advance. Financial Planning & Consulting clients may terminate their agreement at any time before the delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work performed by us up to the point of termination shall be calculated at the hourly fee currently in effect. Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our firm. Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing written notice to the other party. Full refunds will only be made in cases where cancellation occurs ADV Part 2A – Firm Brochure Page 8  within 5 business days of signing an agreement. After 5 business days from initial signing, either party must provide the other party 30 days written notice to terminate billing. Billing will terminate 30 days after receipt of termination notice. Clients will be charged on a pro-rata basis, which takes into account work completed by our firm on behalf of the client. Clients will incur charges for bona fide advisory services rendered up to the point of termination (determined as 30 days from receipt of said written notice) and such fees will be due and payable. Commissionable Securities Sales Our firm and representatives do not sell securities for a commission in advisory accounts. Item 6: Performance-Based Fees & Side-By-Side Management Our firm does not charge performance-based fees. Item 7: Types of Clients & Account Requirements Our firm has the following types of clients: • • • • Individuals and High Net Worth Individuals. Trusts, Estates or Charitable Organizations. Profit Sharing Plans. Corporations, Limited Liability Companies and/or Other Business Types 250 ,000 for our Comprehensive Our firm requires a minimum account balance of $ Portfolio Management Service. This minimum may be waived at managements sole discretion. Some of our options strategies are not suitable or permissible for use in certain retirement-type accounts due to regulatory limitations and suitability considerations. While we may utilize some options strategies in retirement accounts, others, particularly those with higher complexity or risk, require a $1,000,000.00 account minimum and must be implemented in taxable accounts. Examples of retirement-type accounts where certain options strategies may not be used include IRAs, Roth IRAs, and 401(k)s. Clients who opt into electronic delivery of statements or maintain at least $1 million in assets at Fidelity will not be charged transaction fees for U.S. listed equities and exchange traded funds. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Methods of Analysis We use the following methods of analysis in formulating our investment advice and/or managing client assets: ADV Part 2A – Firm Brochure Page 9  FUNDAMENTAL ANALYSIS Our firm employs fundamental analysis as one of the methods to evaluate securities and provide investment advice. Fundamental analysis involves a thorough examination of a company's financial health, profitability, and overall business prospects. This approach focuses on understanding the intrinsic value of a security by analyzing various factors, including: • Financial Statements: We review a company's balance sheet (assets, liabilities, and • Management and Governance: We consider the quality and experience of the company's • equity), income statement (revenues, expenses, and profits), and cash flow statement to assess its financial position and performance. Industry and Market Conditions: management team and its corporate governance practices. We analyze the industry in which the company operates, • Qualitative Factors: its competitive landscape, and broader economic factors that may influence its future performance. We may also consider non-financial aspects such as the company's brand reputation, product innovation, and regulatory environment. The goal of fundamental analysis is to determine if a security is undervalued or overvalued relative to its intrinsic worth. We believe that while market prices can fluctuate in the short term due to various factors, the underlying fundamentals of a company will ultimately drive its long-term value. By conducting fundamental analysis, we aim to make informed investment decisions that align with our clients' financial goals and risk tolerance. This approach helps us to identify companies with strong financial foundations and sustainable growth potential. Important Note: While fundamental analysis is a valuable tool, it is important to understand that market conditions and unforeseen events can impact security prices, and there is no guarantee that our analysis will always predict future market movements accurately. We may also utilize other forms of analysis in conjunction with fundamental analysis to develop well-rounded investment strategies. Investment Philosophy and Process Thinking and acting like business owners guides our investor mindset. Consequently, our investment process employs four key criteria when identifying potential business investments. • Understanding the Business: We prioritize investing in businesses we thoroughly • Durable Competitive Advantages: understand, allowing us to make informed decisions based on a deep knowledge of their operations and industry. We seek businesses with strong and sustainable • Management Assessment: competitive advantages that protect their market position and profitability over the long term. We carefully analyze management teams to determine their integrity, work ethic, and track record of creating shareholder value, as we view them as key partners in the businesses we own. ADV Part 2A – Firm Brochure Page 10  Intrinsic Value and Discount: • We calculate the intrinsic value of a business and aim to acquire it at a significant discount, providing a margin of safety and enhancing potential returns. This forms the core of our equity strategy. It's important to note that we "eat our own cooking" and often own the same businesses that our clients own, aligning our interests and demonstrating our conviction in our investment process. Option Philosophy and Process The firm employs an options overlay strategy with the primary objective of generating income within client portfolios. This strategy is guided by a focus on probabilities and the pursuit of high- probability income-generating outcomes through the strategic sale of both call and put options. Importantly, the implementation of this options strategy typically involves a relatively small portion of the overall portfolio, generally less than 10%. The primary allocation of client accounts is typically to equity securities, with options being overlaid on top. Specifically, we sell call options on stocks that have been thoroughly researched and are well- understood by our investment team. These sales are often executed when we believe there is a high probability that the stock price will remain below the strike price at expiration, allowing us to retain the premium received. This activity is conducted on a select portion of the equity holdings. We also sell put options on stocks that we would be willing to own at the specified strike price or a lower level. These sales are typically implemented when we assess a high probability that the stock price will remain above the strike price at expiration, again allowing us to collect the premium. This strategy may involve a small allocation of capital in anticipation of potential stock acquisition. This options overlay strategy, rooted in an analysis of probabilities and applied to a limited portion of the portfolio, is intended to enhance portfolio income by seeking out trades with a higher likelihood of success in generating premium. However, investors should be aware that the use of options inherently involves risks and may increase portfolio volatility compared to strategies that do not utilize options, even when applied to a smaller segment of the holdings. While we focus on high-probability outcomes, there is no guarantee that these outcomes will be realized. In addition to the income-generating overlay, the firm may, from time to time, engage in directional options trades. These may involve purchasing long call options, typically with longer-term expirations, on individual stocks or market indexes when market opportunities arise. Conversely, we also aim to execute high-probability options trades designed to capitalize on perceived market inefficiencies and opportunities, always considering the probabilities of success and potential returns, within the context of the overall portfolio allocation." Fixed Income Philosophy Our fixed income philosophy is primarily designed for clients in our balanced portfolio strategies, such as our 70/30 (70% equity, 30% fixed income) and 50/50 (50% equity, 50% fixed income) allocations. Within these balanced portfolios, our approach to fixed income centers on a conservative strategy aimed at providing income and reducing overall portfolio volatility. We are not speculative in our fixed income investing and prioritize high-quality, secure, and highly-rated fixed income investments. To implement our fixed income strategy efficiently and cost-effectively, ADV Part 2A – Firm Brochure Page 11  we often utilize low-cost Exchange Traded Funds (ETFs) that provide broad exposure to the desired asset classes. Our general practice is to restrict maturities to the short to intermediate-term duration, which we believe helps to manage interest rate risk within the context of a balanced asset allocation. Historically, our fixed income allocations, often implemented through low-cost ETFs, have included exposure to U.S. Government Treasury bonds, high-grade corporate bonds, and, from time to time, high-grade preferred stock. These selections are made with the objective of generating consistent income and providing a measure of stability within the overall balanced portfolio in a cost-efficient manner. From time to time, we may also consider investing in municipal securities within these balanced portfolios. These may be particularly attractive and potentially beneficial for clients who are in higher income tax brackets due to their potential for tax-exempt income. When appropriate, exposure to municipal securities may also be obtained through low-cost ETFs." Investment Strategies We Use We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Long-Term Purchases: Our firm may buy securities for your account and hold them for a relatively long time (more than a year) in anticipation that the security’s value will appreciate over a long horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that could have been profitable to your account, or it’s possible that the security’s value may decline sharply before our firm decides to sell. Short-Term Purchases: When utilizing this strategy, our firm may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). Our firm does this to take advantage of conditions that our firm believes will soon result in a price swing in the securities our firm purchased. Trading: Our firm purchases securities with the idea of selling them very quickly (typically within 30 days or less). Our firm may do this to take advantage of our predictions of brief price swings. Trading involves risk that may not be suitable for every investor and may involve a high volume of trading activity. Each trade generates a commission and the total daily commission on such a high volume of trading can be considerable. Active trading accounts should be considered speculative in nature with the objective being to generate short-term profits. This activity may result in the loss of more than 100% of an investment. Short Sales: A short sale is a transaction in which an investor sells borrowed securities in anticipation of a price decline and is required to return an equal number of shares at some point in the future. These transactions have several risks that make it highly unsuitable for the novice investor. This strategy has a slanted payoff ratio in that the maximum gain (which would occur if the shorted stock was to plunge to zero) is limited, but the maximum loss is theoretically infinite (since stocks can in theory go up infinitely in price). The following risks should be considered: (1) In addition to trading commissions, other costs with short selling include that of borrowing the security to short it, as well as interest payable on the margin account that holds the shorted security. (2) The ADV Part 2A – Firm Brochure Page 12  short seller is responsible for making dividend payments on the shorted stock to the entity from whom the stock has been borrowed. (3) Stocks with very high short interest may occasionally surge in price. This usually happens when there is a positive development in the stock, which forces short sellers to buy the shares back to close their short positions. Heavily shorted stocks are also susceptible to “buy-ins,” which occur when a broker closes out short positions in a difficult-to-borrow stock whose lenders are demanding it back. (4) Regulators may impose bans on short sales in a specific sector or even in the broad market to avoid panic and unwarranted selling pressure. Such actions can cause a spike in stock prices, forcing the short seller to cover short positions at huge losses. (5) Unlike the “buy-and-hold” investor who can afford to wait for an investment to work out, the short seller does not have the luxury of time because of the many costs and risks associated with short selling. Timing is everything when it comes to shorting. (5) Short selling should only be undertaken by experienced traders who have the discipline to cut a losing short position, rather than add to it hoping that it will eventually work out. Margin Transactions: Our firm may purchase stocks, mutual funds, and/or other securities for your portfolio with money borrowed from your brokerage account. This allows you to purchase more stock than you would be able to with your available cash and allows us to purchase stock without selling other holdings. Margin accounts and transactions are risky and not necessarily appropriate for every client. The potential risks associated with these transactions are (1) You can lose more funds than are deposited into the margin account; (2) the forced sale of securities or other assets in your account; (3) the sale of securities or other assets without contacting you; and (4) you may not be entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call. Options : An option is a financial derivative that represents a contract sold by one party (the option writer) to another party (the option holder, or option buyer). The contract offers the buyer the right, but not the obligation, to buy or sell a security or other financial asset at an agreed-upon price (the strike price) during a certain period of time or on a specific date (exercise date). Options are extremely versatile securities. Traders use options to speculate, which is a relatively risky practice, while hedgers use options to reduce the risk of holding an asset. In terms of speculation, option buyers and writers have conflicting views regarding the outlook on the performance of a: • Call Option : Call options give the option to buy at certain price, so the buyer would want the stock to go up. Conversely, the option writer needs to provide the underlying shares in the event that the stock's market price exceeds the strike due to the contractual obligation. An option writer who sells a call option believes that the underlying stock's price will drop relative to the option's strike price during the life of the option, as that is how he will reap maximum profit. This is exactly the opposite outlook of the option buyer. The buyer believes that the underlying stock will rise; if this happens, the buyer will be able to acquire the stock for a lower price and then sell it for a profit. However, if the underlying stock does not close above the strike price on the expiration date, the option buyer would lose the premium paid for the call option. • Put Option : Put options give the option to sell at a certain price, so the buyer would want the stock to go down. The opposite is true for put option writers. For example, a put option buyer is bearish on the underlying stock and believes its market price will fall below the specified strike price on or before a specified date. On the other hand, an option writer who sells a put option believes the underlying stock's price will increase about a specified price on or before the expiration date. If the underlying stock's price closes above the specified strike price on the expiration date, the put option writer's maximum profit is achieved. Conversely, a put ADV Part 2A – Firm Brochure Page 13  option holder would only benefit from a fall in the underlying stock's price below the strike price. If the underlying stock's price falls below the strike price, the put option writer is obligated to purchase shares of the underlying stock at the strike price. The potential risks associated with these transactions are that (1) all options expire. The closer the option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices can move very quickly. Depending on factors such as time until expiration and the relationship of the stock price to the option’s strike price, small movements in a stock can translate into big movements in the underlying options. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase, and the account(s) could enjoy a gain, it is also possible that the stock market may decrease, and the account(s) could suffer a loss. It is important that clients understand the risks associated with investing in the stock market, and that their assets are appropriately diversified in investments. Clients are encouraged to ask our firm any questions regarding their risk tolerance. Cash & Cash Equivalent Risk: Cash and cash equivalents generally refer to either United States dollars or highly liquid short-term debt instruments such as, but not limited to, treasury bills, bank CD’s and commercial papers. Generally, these assets are considered nonproductive and will be exposed to inflation risk and considerable opportunity cost risk. Investments in cash and cash equivalents will generally return less than the advisory fee charged by our firm. Capital Risk: Capital risk is one of the most basic, fundamental risks of investing; it is the risk that you may lose 100% of your money. All investments carry some form of risk, and the loss of capital is generally a risk for any investment instrument. Company Risk: When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. Credit Risk: Credit risk can be a factor in situations where an investment’s performance relies on a borrower’s repayment of borrowed funds. With credit risk, an investor can experience a loss or unfavorable performance if a borrower does not repay the borrowed funds as expected or required. Investment holdings that involve forms of indebtedness (i.e. borrowed funds) are subject to credit risk. Economic Risk: The prevailing economic environment is important to the health of all businesses. Some companies, however, are more sensitive to changes in the domestic or global economy than others. These types of companies are often referred to as cyclical businesses. Countries in which a large portion of businesses are in cyclical industries are thus also very economically sensitive and carry a higher amount of economic risk. If an investment is issued by a party located in a country that experiences wide swings from an economic standpoint or in situations where certain elements of an investment instrument are hinged on dealings in such countries, the investment instrument will generally be subject to a higher level of economic risk. ADV Part 2A – Firm Brochure Page 14  Equity (Stock) Market Risk: Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. ETF & Mutual Fund Risk : When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. Clients will also incur brokerage costs when purchasing ETFs. Interest Rate Risk: Certain investments involve the payment of a fixed or variable rate of interest to the investment holder. Once an investor has acquired or has acquired the rights to an investment that pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market will affect the value of the interest-paying investment(s) they hold. In general, changes in prevailing interest rates in the market will have an inverse relationship to the value of existing, interest paying investments. In other words, as interest rates move up, the value of an instrument paying a particular rate (fixed or variable) of interest will go down. The reverse is generally true as well. Description of Material, Significant or Unusual Risks Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our firm tries to achieve the highest return on client cash balances through relatively low-risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees for our services related to our Asset Management services, as applicable. Item 9: Disciplinary Information There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management. Item 10: Other Financial Industry Activities & Affiliations Representatives of our firm are licensed insurance agents. As a result of these transactions, they receive normal and customary commissions. A conflict of interest exists as these commissionable securities sales create an incentive to recommend products based on the compensation earned. To mitigate this potential conflict, our firm will act in the client’s best interest Franz Amussen is also a member of SLC Angels. SLC Angels is an association of accredited angel investors based in Salt Lake City. Franz does not solicit clients to invest in these businesses. Any investments in these startup companies are solely done with Franz's private money. No client money is invested in these companies. Iron Gate does not believe Franz’s involvement in these outside ADV Part 2A – Firm Brochure Page 15  businesses creates a conflict of interest because of the limited time he spends managing these businesses and no involvement by Iron Gate or its customers. Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to always act solely in the best interest of each of our clients. Our fiduciary duty is the underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities transaction and insider trading. Our firm requires all representatives to conduct business with the highest level of ethical standards and to always comply with all federal and state securities laws. Upon employment with our firm, and at least annually thereafter, all representatives of our firm will acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. Our firm recognizes that the personal investment transactions of our representatives demand the application of a Code of Ethics with high standards and requires that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, our firm also believes that if investment goals are similar for clients and for our representatives, it is logical, and even desirable, that there be common ownership of securities. To prevent conflicts of interest, our firm has established procedures for transactions effected by our 1 . To monitor compliance with our personal trading policy, representatives for their personal accounts our firm requires quarterly securities transaction reporting for our representatives. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. Likewise, related persons of our firm may buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. To minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Item 12: Brokerage Practices Selecting a Brokerage Firm Our firm does not maintain custody of client assets. Client assets must be maintained by a qualified custodian. Our firm seeks to recommend a custodian who will hold client assets and execute 1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect beneficial interest in. ADV Part 2A – Firm Brochure Page 16  transactions on terms that are overall most advantageous when compared to other available providers and their services. The factors considered, among others, are these: • • • • • • • • • • • • • Timeliness of execution Timeliness and accuracy of trade confirmations Research services provided Ability to provide investment ideas Execution facilitation services provided Record keeping services provided Custody services provided Frequency and correction of trading errors Ability to access a variety of market venues Expertise as it relates to specific securities Financial condition Business reputation Quality of services Our firm also has an arrangement with National Financial Services LLC and Fidelity Brokerage Services LLC (collectively, and together with all affiliates, "Fidelity") through which Fidelity provides our firm with "institutional platform services." Our firm is independently operated and owned and is not affiliated with Fidelity. The institutional platform services include, among others, brokerage, custody, and other related services. Fidelity's institutional platform services that assist us in managing and administering clients' accounts include software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of fees from its clients' accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Our firm also recommends that clients use the Schwab Advisor Services division of Charles Schwab & Co. Inc. (“Schwab”), a FINRA-registered broker-dealer, member SIPC, as the qualified custodian. Our firm is independently owned and operated, and not affiliated with Schwab. Schwab will hold client assets in a brokerage account and buy and sell securities when instructed. While our firm recommends that clients use Schwab as custodian/broker, clients will decide whether to do so and open an account with Schwab by entering into an account agreement directly with them. Our firm does not open the account. Even though the account is maintained at Schwab, our firm can still use other brokers to execute trades, as described in the next paragraph. Products & Services Available from Schwab Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like our firm. They provide our firm and clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help manage or administer our client accounts while others help manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (our firm does not have to request them) and at no charge to our firm. The availability of Schwab’s products and services is not based on the provision of particular investment advice, such as purchasing particular securities for clients. Here is a more detailed description of Schwab’s support services: Services that Benefit Clients ADV Part 2A – Firm Brochure Page 17  Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which our firm might not otherwise have access or that would require a significantly higher minimum initial investment by firm clients. Schwab’s services described in this paragraph generally benefit clients and their accounts. Services that May Not Directly Benefit Clients • Schwab also makes available other products and services that benefit our firm but may not directly benefit clients or their accounts. These products and services assist in managing and administering our client accounts. They include investment research, both Schwab’s and that of third parties. This research may be used to service all or some substantial number of client accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • • • • provides access to client account data (such as duplicate trade confirmations and account statements); facilitates trade execution and allocate aggregated trade orders for multiple client accounts; provides pricing and other market data. facilitates payment of our fees from our clients’ accounts; and assists with back-office functions, recordkeeping, and client reporting. Services that Generally Benefit Only Our Firm Schwab also offers other services intended to help manage and further develop our business enterprise. These services include: • • • • educational conferences and events technology, compliance, legal, and business consulting. publications and conferences on practice management and business succession; and access to employee benefits providers, human capital consultants and insurance providers. Schwab may provide some of these services itself. In other cases, Schwab will arrange for third-party vendors to provide the services to our firm. Schwab may also discount or waive fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide our firm with other benefits, such as occasional business entertainment for our personnel. Irrespective of direct or indirect benefits to our client through Schwab, our firm strives to enhance the client experience, help clients reach their goals and put client interests before that of our firm or associated persons. Our Interest in Schwab’s Services The availability of these services from Schwab benefits our firm because our firm does not have to produce or purchase them. Our firm does not have to pay for these services, and they are not contingent upon committing any specific amount of business to Schwab in trading commissions or assets in custody. Fidelity, and Schwab (collectively referred to as “The Custodians”) may make certain research and brokerage services available at no additional cost to our firm. Research products and services provided by the Custodians may include: research reports on recommendations or other information ADV Part 2A – Firm Brochure Page 18  about particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making; and other products or services that provide lawful and appropriate assistance by the Custodians to our firm in the performance of our investment decision-making responsibilities. The aforementioned research and brokerage services qualify for the safe harbor exemption defined in Section 28(e) of the Securities Exchange Act of 1934. The Custodians generally do not charge a separate fee for custody services but are compensated by charging commissions or other fees to clients on trades that are executed or that settle into the Custodian account. In addition to commissions, the Custodians may charge a flat dollar amount as a “prime broker” or “trade away” fee for each trade that our firm has executed by a different broker- dealer but where the securities bought or the funds from the securities sold are deposited (settled) into a Custodian account. These fees are in addition to the commissions or other compensation paid to the executing broker-dealer. Because of this, to minimize client trading costs, our firm has the Custodian the client account is held at execute most trades for the account. The Custodians do not make client brokerage commissions generated by client transactions available for our firm’s use. The research and brokerage services are used by our firm to manage accounts for which our firm has investment discretion. Without this arrangement, our firm might be compelled to purchase the same or similar services at our own expense. As part of our fiduciary duty to our clients, our firm will always endeavor to put the interests of our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm or our related persons creates a potential conflict of interest and may indirectly influence our firm’s choice of the Custodians as a custodial recommendation. Our firm examined this potential conflict of interest when our firm chose to recommend the Custodians and have determined that the recommendation is in the best interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best execution. Our clients may pay a transaction fee or commission to the Custodians that is higher than another qualified broker dealer might charge to affect the same transaction where our firm determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services provided to the client as a whole. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients, our firm may not necessarily obtain the lowest possible commission rates for specific client account transactions. Soft Dollars Our firm does not receive soft dollars more than what is allowed by Section 28(e) of the Securities Exchange Act of 1934. The safe harbor research products and services obtained by our firm will generally be used to service all our clients but not necessarily all at any one particular time. ADV Part 2A – Firm Brochure Page 19  Client Brokerage Commissions The Custodians does not make client brokerage commissions generated by client transactions available for our firm’s use. Client Transactions in Return for Soft Dollars Our firm does not direct client transactions to a particular broker-dealer in return for soft dollar benefits. Brokerage for Client Referrals Our firm does not receive brokerage for client referrals. Directed Brokerage Neither our firm nor any of our firm’s representatives have discretionary authority in making the determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are affected. Our firm routinely recommends that clients direct us to execute through a specified broker-dealer. Our firm recommends the use of The Custodians. Each client will be required to establish their account(s) with The Custodians if not already done. Please note that not all advisers have this requirement. Special Considerations for ERISA Clients A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific broker or dealer to obtain goods or services on behalf of the plan. Such direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will be for the exclusive benefit of the plan. Client-Directed Brokerage Our firm allows clients to direct brokerage outside our recommendation. Our firm may be unable to achieve the most favorable execution of client transactions. Client directed brokerage may cost clients more money. For example, in a directed brokerage account, clients may pay higher brokerage commissions because our firm may not be able to aggregate orders to reduce transaction costs, or clients may receive less favorable prices. Aggregation of Purchase or Sale Our firm provides investment management services for various clients. There are occasions on which portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served by our firm, which involve accounts with similar investment ADV Part 2A – Firm Brochure Page 20  objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more accounts, they are affected only when our firm believes that to do so will be in the best interest of the effected accounts. When such concurrent authorizations occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. In any given situation, our firm attempts to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, current asset allocation and availability of funds using price averaging, proration, and consistently non-arbitrary methods of allocation. Item 13: Review of Accounts or Financial Plans Our management personnel or financial advisors reviews accounts on at least an annual basis for our Asset Management and Comprehensive Portfolio Management clients. The nature of these reviews is to learn whether client accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Our firm does not provide written reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when our Asset Management clients are contacted. Our firm may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. Financial Planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. Our firm does not provide ongoing services to financial planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or verbal updated reports regarding their financial plans unless they separately engage our firm for a post-financial plan meeting or update to their initial written financial plan. Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the service. Our firm also provides ongoing services where clients are met with upon their request to discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients do not receive written or verbal updated reports regarding their plans unless they choose to engage our firm for ongoing services. Item 14: Client Referrals & Other Compensation Schwab, Fidelity (see Item 12 – Brokerage Practices) . The availability Our firm receives economic benefit from Schwab in the form of the support products and services made available to our firm and other independent investment advisors that have their clients maintain accounts at Schwab. These products and services, how they benefit our firm, and the related conflicts of interest are described above of Schwab’s products and services is not based on our firm giving particular investment advice, such as buying particular securities for our clients. ADV Part 2A – Firm Brochure Page 21  Referral Fees The Adviser has entered into agreements with Intermediaries, whereby the Adviser compensates an Intermediary for referring Clients to the Adviser. A Solicitor Agreement may create an incentive for an Intermediary to refer a prospective Client to the Adviser, even if an Intermediary would not otherwise make the referral. There is no differential in the management fees charged to a Client and the Adviser will not charge Clients any additional fees or expenses as a result of Solicitor Agreements. A referral by an Intermediary should not be viewed by a Client as an endorsement of the Adviser’s services. Solicitors may be compensated in the form of both cash and non-cash compensation. This is disclosed to Clients alongside any presentation of products, prior to or at the time of signing any advisory agreement. Solicitors have received training regarding how to interact with Adviser’s Clients and will provide this Brochure to all Clients and prospective Clients at or before investment agreement signing. Item 15: Custody Representatives of our firm act as a trustee to client accounts. As such, our firm is deemed to have custody. The client funds and securities of which our firm has custody are verified by actual examination at least once during each calendar year by an independent public accountant (“IPA”) registered with the Public Company Accounting Oversight Board (“PCAOB”), at a time that is chosen by the accountant without prior notice or announcement to our firm and that is irregular from year to year. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. Item 16: Investment Discretion Clients have the option of providing our firm with investment discretion on their behalf, pursuant to an executed investment advisory client agreement. By granting investment discretion, our firm is authorized to execute securities transactions, determine which securities are bought and sold, and the total amount to be bought and sold. Should clients grant our firm non-discretionary authority, our firm would be required to obtain the client’s permission prior to effecting securities transactions. Limitations may be imposed by the client in the form of specific constraints on any of these areas of discretion with our firm’s written acknowledgement. Item 17: Voting Client Securities SEC Rule 206(4)-6 requires investment advisers who have voting authority with respect to securities held in their clients’ accounts to monitor corporate actions and vote proxies in their clients’ interests. Our firm is required by the SEC to adopt written policies and procedures, make those ADV Part 2A – Firm Brochure Page 22  policies and procedures available to clients, and retain certain records with respect to proxy votes cast. Our firm considers proxy voting an important right of our clients as shareholders and believe that reasonable care and diligence must be taken to ensure that such rights are properly and timely exercised. When our firm has discretion to vote the proxies of our clients, our firm will vote those proxies in the client’s best interests and in accordance with these policies and procedures. Clients may request a copy of our written policies and procedures regarding proxy voting and/or information on how particular proxies were voted by contacting our Chief Compliance Officer, Brian Hunsaker, by phone at (801) 575-6427 or email at brian@igga.com. Policy for Voting Proxies All proxies received by our firm will be given to our Chief Compliance Officer or designated person for processing. Based on our proxy voting guidelines outlined below, a determination of how our firm votes will be made. Proxies will generally be voted online unless custodian requires mailed forms. In the absence of standing voting guidelines from the client, our firm will vote proxies in the best interest of each client. Our firm seeks to ensure compliance with the new Exchange Act Rule 14a-11. In accordance with the rule, our firm provides shareholders with the opportunity to nominate directors at a shareholder meeting under the applicable state or foreign law. Clients also can have their nominees included in the company proxy materials sent to all our shareholders. Furthermore, the clients as shareholders also can use the shareholder proposal process to establish procedures for the inclusion of shareholder director nominations in company proxy materials. Proxies Voting Guidelines Where voting authority exists, proxies are voted by our firm according to Board recommendations in categories listed below among others unless not deemed to be in the best interests of the client: • • • • • • • • • • • • • for directors and for management on routine matters. for a limit on or reduction of the number of directors, and for an increase in the number of directors on a case-by-case basis. against the creation of a tiered board. for the elimination of cumulative voting. for independence of auditors. for deferred compensation. for profit sharing plans. for stock option plans unless the plan could result in material dilution to shares outstanding or is excessive. for stock repurchases. for an increase in authorized shares unless the authorization effectively results in a blind investment pool for shareholders. for reductions in the par value of stock. for company name changes. for routine appointments of auditors. ADV Part 2A – Firm Brochure Page 23  Our firm abstains on motions to limit directors' liability. Material issues not sent to 960 North 400 East, North Salt Lake, Utah 84054 as listed above (e.g., mergers, poison pills, social investing, and miscellaneous shareholder proposals) are dealt with on a case-by-case basis. Our firm will defer to instruction from clients in all voting matters. Records of all issues and votes are maintained and reported to clients as requested. Our firm recognizes that under certain circumstances our firm may have a conflict of interest between us and our clients. Such circumstances may include, but are not limited to, situations where our firm or one or more of our affiliates, including officers, directors, and employees, has or is seeking a client relationship with the issuer of the security that is the subject of the proxy vote. Our firm shall periodically inform our employees that they are under an obligation to be aware of the potential for conflicts of interest on the part of our firm with respect to voting proxies on behalf of funds, both as a result of our employee’s personal relationships and due to circumstances that may arise during the conduct of our business, and to bring conflicts of interest of which they become aware to the attention of the proxy manager. Our firm shall not vote proxies relating to such issuers on behalf of client accounts until our firm has determined that the conflict of interest is not material or a method of resolving such conflict of interest has been agreed upon by our management team. A conflict of interest will be considered material to the extent that it is determined that such conflict has the potential to influence our decision-making in voting a proxy. Materiality determinations will be based upon an assessment of the particular facts and circumstances. If our firm determines that a conflict of interest is not material, our firm may vote proxies notwithstanding the existence of a conflict. If the conflict of interest is determined to be material, the conflict shall be disclosed to our management team and our firm shall follow the instructions of the management team. • Our Chief Compliance Officer will maintain files relating to our proxy voting procedures. Records will be maintained and preserved for 5 years from the end of the fiscal year during which the last entry was made on a record, with records for the last two years kept on our premises. Records of the following will be included in the files: • • • a copy of each proxy statement that our firm receives, provided however that our firm may rely on obtaining a copy of proxy statements from the SEC’s EDGAR system for those proxy statements that are available. a record of each vote that our firm casts. a copy of any document our firm created that was material to making a decision how to vote proxies, or that memorializes that decision. a copy of each written client request for information on how our firm voted such client’s proxies, and a copy of any written response to any client request for information on how our firm voted their proxies. Our written policies and procedures regarding proxy voting are disclosed here. Information on how particular proxies were voted may contact our Chief Compliance Officer, Brian Hunsaker, by phone at (801) 575-6427 or email at brian@igga.com. Our firm does not pay for proxy voting services with soft dollars. Also, our firm does not charge an additional fee to vote proxies. Item 18: Financial Information ADV Part 2A – Firm Brochure Page 24  Inclusion of a Balance Sheet Our firm does not require nor is prepayment of fees solicited. Therefore, our firm has not included a balance sheet for our most recent fiscal year. Disclosure of Financial Condition Our firm has nothing to disclose in this regard. Bankruptcy Petition Our firm has nothing to disclose in this regard. ADV Part 2A – Firm Brochure Page 25