Materials that reference or identify Great Gray trusteed collective investment trusts (CITs) must clearly and prominently identify Great Gray Trust Company, LLC as trustee at the very first instance when the CIT is identified. In addition, the following disclosure must be included. This disclosure can be placed in a footnote on the same page or at the end of the document so long as there is initial mention that Great Gray Trust Company, LLC is the trustee for the CIT(s).
Please note that the second paragraph must be in bold text and as a stand-alone paragraph. Font size should be no smaller than 8 pt.
In addition, to the extent that other parties are identified in the piece, their roles should be clearly disclosed. For example, where there is a CIT sub-advisor, the second highlighted sentence should be added.
DISCLOSURE:
Great Gray Trust Company, LLC serves as Trustee for its bank collective investment trusts (“CITs” or “Funds”) and maintains ultimate fiduciary authority over the management of, and investments made in, the Funds. [Name of Sub-Advisor] has been hired by the Trustee to assist it in managing the Funds. The Funds are not mutual funds as the Funds and their units are exempt from registration under the Investment Company Act of 1940 and the Securities Act of 1933, respectively.
Investments in the Funds are not bank deposits or obligations of and are not insured or guaranteed by Great Gray Trust Company, LLC, any bank, the FDIC, the Federal Reserve, or any other governmental agency. The Funds are commingled investment vehicles, and as such, the values of the underlying investments will rise and fall according to market activity; it is possible to lose money by investing in the Funds.
Participation in Collective Investment Trusts (CITs) is limited primarily to qualified retirement plans and certain state or local government plans and is not available to IRAs, non-governmental health and welfare plans and, in certain cases, Keogh (H.R. 10) plans. CITs may be suitable investments for plan fiduciaries seeking to construct a well-diversified retirement savings program. Investors should consider the investment objectives, risks, charges, and expenses of any pooled investment fund carefully before investing. The Additional Fund Information and Principal Risk Definitions (PRD) contains this and other information about a CIT and is available at www.greatgray.com/principalriskdefinitions or ask for a free copy by contacting Great Gray Trust Company, LLC at(866) 427-6885.
Great Gray® and Great Gray Trust Company are service marks used in connection with various fiduciary and non-fiduciary services offered by Great Gray Trust Company, LLC.
©2025 Great Gray Trust Company, LLC. All rights reserved.
Materials that compare or contrast mutual funds and collective investment trusts (CITs) or otherwise identify them as strategy equivalents must include the following disclosure. This disclosure can be placed in a footnote on the page where the reference initially occurs or the page can have a footnote that cross-references the reader to this disclosure that is placed at the end of the document. The font size should be no smaller than 8pt.
DISCLOSURE:
Key Comparisons between CITs and Mutual Funds. CITs are tax-qualified investments primarily restricted to the retirement market so investors tend to have a longer-term horizon and the trustee can make investment decisions without tax considerations. Mutual funds are not subject to these investor limits or investment horizons, and must distribute substantially all of their taxable net gains and income to investors. CIT expense structures can be customized to investor channels. Mutual funds generally have less fee flexibility. CITs tend to have lower administrative, marketing and distribution costs than mutual funds due to the differences in how they can be sold and to whom. CITs are maintained by a bank as trustee and are subject to federal or state banking regulation and ERISA fiduciary standards. Mutual funds are managed by registered investment advisers and are subject to extensive SEC regulation and public disclosure and reporting requirements. Both CITs and mutual funds are generally priced and traded daily, subject to annual financial audits, and benefit from their pooled structure that aggregates investor funds and can provide greater diversification than individual accounts.
Materials that include Morningstar proprietary data elements, such as the Morningstar category, Investment Style Box, Morningstar rating, Morningstar return ranking or Morningstar risk evaluation must include the following disclosure. This disclosure can be placed at the end of the document. The font size should be no smaller than 8pt.
DISCLOSURE:
© 2025 Morningstar. All Rights Reserved. The information contained herein: (1) is proprietary to Morningstar and/or its content providers; (2) may not be copied or distributed; and (3) is not warranted to be accurate, complete, or timely. Neither Morningstar nor its content providers are responsible for any damages or losses arising from any use of this information. Past performance is no guarantee of future results.
Materials that reference RPAG ratings of any investment vehicles, whether a Great Gray CIT or another party’s investment mutual fund or CIT, must include the following disclosure. The disclosure can be at the end of the document if such disclosure is cross-referenced in a footnote on the page where the initial ratings appear. The font size should be no smaller than 8pt.
Note: Version 1 is specific to Great Gray CITs that are sub-advised by flexPATH.
Version 1: Use if Great Gray CIT materials include CITs that flexPATH sub-advises
Retirement Plan Advisory Group, LLC (“RPAG”) provides technology, solutions and services for a fee to its customers, who are primarily retirement plan advisors and associated institutions. The services include ratings of various third-party investment vehicles based on RPAG’s proprietary quantitative and qualitative scoring methodology. The investment vehicles do not pay to be evaluated and scored; nor do the companies that provide services to the investment vehicles pay for them to be evaluated and scored, but those companies may have commercial relationships and affiliations with RPAG.
Great Gray Trust Company, LLC (“Great Gray”) serves as trustee and provides administrative services for collective investment trusts (“Great Gray CITs”) that are scored by RPAG, and flexPATH Strategies, LLC (“flexPATH”) sub-advises some of those Great Gray CITs. Great Gray and RPAG are wholly owned by Great Gray Group, LLC (“Great Gray Group”), which also has an indirect, non-controlling, minority equity investment in flexPATH, but Great Gray Group does not have the power, directly or indirectly, to direct flexPATH’s management or policies. Great Gray and flexPATH have commercial relationships with RPAG that do not involve the evaluation and scoring of Great Gray CITs.
Version 2: Use if Great Gray CIT materials DOES NOT include CITs that flexPATH sub-advises
Retirement Plan Advisory Group, LLC (“RPAG”) provides technology, solutions and services for a fee to its customers, who are primarily retirement plan advisors and associated institutions. The services include ratings of various third-party investment vehicles based on RPAG’s proprietary quantitative and qualitative scoring methodology. The investment vehicles do not pay to be evaluated and scored; nor do the companies that provide services to the investment vehicles pay for them to be evaluated and scored, but those companies may have commercial relationships and affiliations with RPAG.
Great Gray Trust Company, LLC (“Great Gray”) serves as trustee and provides administrative services for collective investment trusts (“Great Gray CITs”) that are scored by RPAG. Great Gray and RPAG are wholly owned by Great Gray Group, LLC (“Great Gray Group”). Great Gray has a commercial relationship with RPAG that does not involve the evaluation and scoring of Great Gray CITs.
Great Gray Trust Company, LLC serves as Trustee for Panorix Target Date Series, a set of bank collective investment trusts (“CITs” or “Funds”), and maintains ultimate fiduciary authority over the management of, and investments made in, the Funds. The Trustee has hired Wilshire Advisors LLC as sub-advisor to assist it in managing the Funds, and has hired BlackRock Financial Management, Inc. as Glidepath Manager to provide strategic asset allocation guidance for the Funds, and also is the manager for many of the underlying funds, including the private equity assets. The Funds will invest in a Great Gray CIT that invests in the BlackRock Private Investments Fund, and a private credit CIT trusteed by The Goldman Sachs Trust Company, N.A. and advised by Goldman Sachs Asset Management. The Funds are not mutual funds as the Funds and their units are exempt from registration under the Investment Company Act of 1940 and the Securities Act of 1933, respectively.
Investments in the Funds are not bank deposits or obligations of and are not insured or guaranteed by Great Gray Trust Company, LLC, any bank, the FDIC, the Federal Reserve, or any other governmental agency. The Funds are commingled investment vehicles, and as such, the values of the underlying investments will rise and fall according to market activity; it is possible to lose money by investing in the Funds.
Participation in Collective Investment Trusts (CITs) is limited primarily to qualified retirement plans and certain state or local government plans and is not available to IRAs, non-governmental health and welfare plans and, in certain cases, Keogh (H.R. 10) plans. CITs may be suitable investments for plan fiduciaries seeking to construct a well-diversified retirement savings program. Investors should consider the investment objectives, risks, charges, and expenses of any pooled investment fund carefully before investing. The Additional Fund Information and Principal Risk Definitions (PRD) contains this and other information about a CIT and is available at www.greatgray.com/principalriskdefinitions or ask for a free copy by contacting Great Gray Trust Company, LLC at (866) 427-6885.
Great Gray® and Great Gray Trust Company are service marks used in connection with various fiduciary and non-fiduciary services offered by Great Gray Trust Company, LLC.
©2025 Great Gray Trust Company, LLC. All rights reserved.
Risks Associated with the Underlying Private Company Investments of the Funds: Private companies are generally not subject to SEC reporting requirements, are not required to maintain their accounting records in accordance with generally accepted accounting principles and are not required to maintain effective internal controls over financial reporting. As a result, there may not be timely or accurate information about the business, financial condition and results of operations of the underlying private companies of the Funds. There is risk that the Funds may invest on the basis of incomplete or inaccurate information, which may adversely affect the Funds’ investment performance. Private companies held by the Funds may have limited financial resources, shorter operating histories, more asset concentration risk, narrower product lines and smaller market shares than larger businesses, which tend to render such private companies more vulnerable to competitors’ actions and market conditions, as well as general economic downturns. These companies generally have less predictable operating results, may from time to time be parties to litigation, may be engaged in rapidly changing businesses with products subject to a substantial risk of obsolescence, and may require substantial additional capital to support their operations, finance expansion or maintain their competitive position. These companies may have difficulty accessing the capital markets to meet future capital needs, which may limit their ability to grow or to repay their outstanding indebtedness upon maturity. In addition, these investments also may be structured as pay-in-kind securities with minimal or no cash interest or dividends until the company meets certain growth and liquidity objectives. Typically, investments in private companies are in restricted securities that are not traded in public markets and subject to substantial holding periods, so that it may not be possible to resell some of its holdings for extended periods, which may be several years. There can be no assurance that the value of private company investments can be realized in a timely manner.
BLACKROCK and LIFEPATH are trademarks of BlackRock, Inc. or its affiliates. Used under license. WILSHIRE is a registered trademark of Wilshire Advisors LLC. All other trademarks, service marks, and logos appearing herein are the property of their respective owners and used with permission where applicable.
This material does not constitute a recommendation by any party, or an offer to sell, or a solicitation of any offer to buy or sell any securities, product or service, in any jurisdiction to any person. The information is not intended to serve as or provide investment advice. None of the parties guarantee the suitability or potential value of any particular investment. This is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution would be unlawful under securities laws of such jurisdiction. Any distribution, by whatever means, of this information and related material to persons other than those referred to above is strictly prohibited.
The Goldman Sachs Collective Trust – Private Credit Fund (“GS Private Credit CIT”) is created by The Goldman Sachs Trust Company, N.A, (“GSTC”), and managed by Goldman Sachs Asset Management as the investment adviser. GSTC is a national bank limited to fiduciary activities, with the ability to serve as a fiduciary in all 50 states. GSTC is a full-service corporate fiduciary that leverages the global resources of Goldman Sachs to deliver integrated fiduciary administration and best-in-class investment management services. Goldman Sachs Asset Management, L.P. is a registered investment adviser and the primary investing area within Goldman Sachs, delivering investment and advisory services across public and private markets for the world’s leading institutions, financial advisors and individuals Goldman Sachs (NYSE: GS) is one of the largest investors in alternatives globally. The business invests in the full spectrum of alternatives, including private equity, growth equity, private credit, real estate, infrastructure, sustainability and hedge funds. The alternative investments platform is part of Goldman Sachs Asset Management. GS Private Credit CIT has not been launched yet. This information is delivered solely as reference material with respect to the GS Private Credit Fund, an investment product that Goldman Sachs may offer in the future. There is no guarantee objectives will be met.