Gradient Investments, LLC

Gradient Investments, LLC is an SEC‑registered, fee‑only investment manager that provides discretionary portfolio management to institutional accounts, pooled vehicles, pension and profit‑sharing plans, trusts, corporations, charitable organizations and individual investors. The firm also acts as a sub‑advisor to an ETF and offers ERISA 3(38) fiduciary services to retirement plans.

Gradient offers a broad suite of strategies—Strategic, Tactical (proprietary quantitative), Allocation, Defined Outcome (including structured notes), Preservation, and a Private Wealth Series that accesses private equity and private credit—primarily implemented through ETFs, no‑load mutual funds and individual equities. Portfolios are usually managed on a discretionary basis, client objectives and risk tolerances are documented via a Risk Tolerance Analysis and Investment Proposal, and the firm may engage sub‑advisors for portions of mandates.

What distinguishes the firm is its scale and corporate structure: as of 11/30/2025 it reported approximately $8.07 billion in discretionary AUM and 26,595 clients supported by 15 advisors (an unusually high client‑per‑advisor ratio). Gradient also maintains several corporate affiliations—an affiliated dually registered broker‑dealer, insurance marketing organizations and a private‑equity owner—serves as an ETF sub‑advisor, and discloses referral/AUM incentive arrangements and recent brochure updates clarifying conflicts; these relationships and arrangements are disclosed in its Form ADV and governed by the firm’s policies.