What changed in this filing

/stocks — the workspaceLOADING

Item 9A. Controls and Procedures

2025-02-19 compared with 2024-02-20 · 87 added, 53 removed, 675 unchanged (17% of the section changed)

24 unchanged sentences

Shannon Ghia is the President and Chief Executive Officer of the Sponsor and Bryan Bowers is the Chief Financial Officer of the Sponsor.

The Sponsor is managed by the Board of Directors composed of Shannon Ghia, Bryan Bowers, Philip Jensen, Peter Landini and Kimun Lee.

The Sponsor is managed by the Board of Directors composed of Shannon Ghia, Bryan Bowers, Philip Jensen, Peter Landini and Lindsey Haswell.

Shannon Ghia , 48, has served as a Director of the Sponsor since March 2022 and became a principal of the Sponsor on May 19, 2023.

20 unchanged sentences

and iShares U.S.

From September 1, 2014 to October 3, 2021, Mr.

From September 1, 2014 to

October 3, 2021, Mr.

Bowers worked in Global Financial Reporting on the Business Operations & Technology team within BlackRock’s GAAPS function.

29 unchanged sentences

Castaneda earned a Bachelor of Science in Business Administration from San Jose State University, in 2005.

Matthew DeCicco , 36, became a principal of the Sponsor and jointly responsible for the trading decisions with respect to the Trust’s account as of January 21, 2025.

DeCicco is a Director of BlackRock, Inc.

and performs supervisory and managerial functions.

Since March 2024, he has managed the Derivatives ETF Portfolio Management Team within BlackRock’s Global Markets & Index Investments Group.

In that capacity, Mr.

DeCicco oversees product operations and the continued development of complex and derivatives-based products.

From May 2022 to March 2024, Mr.

DeCicco was Global Head of Commodities, Carbon Emissions, and Digital Assets Trading within BlackRock Global Markets.

In this role, he was responsible for overseeing BlackRock’s traditional commodity trading platform as well as building out trading capabilities and thought leadership in the emerging sectors of carbon emissions and digital assets trading.

From August 2010 to May 2022, Mr.

DeCicco was the Head of North American Rates Trading with oversight for all U.S.

Treasury, Treasury Inflation Protected Securities, agency mortgage-backed securities, derivatives and futures trading on behalf of BlackRock’s investment platform.

DeCicco earned his Bachelor of Science in finance from Babson College.

Ann Frechette , CPA, 56, became a principal of the Sponsor on April 13, 2020.

16 unchanged sentences

Frechette graduated with honors from Drexel University with a Bachelor of Science in accounting in 1991 and was initially licensed as a certified public accountant in 1993.

Lindsey Haswell , 46, is a member of the Sponsor’s audit committee.

Haswell is the Chief Legal and Administrative Officer of MoonPay, a web3 and crypto payments company that she joined in February 2023.

She served in the same capacity for crypto-asset firm Blockchain.com from May 2021 to February 2023.

Since July 2022, she also has served on the founding team of the Core blockchain network, a Bitcoin-powered layer-one blockchain.

Haswell was the Chief Legal and Administrative Officer of mobility company Lime from September 2018 to May 2021 and was a founding member of Uber’s Legal team, on which she served from January 2015 to November 2017.

In November 2017, she founded a venture-backed company in the autonomous vehicle space.

From August 2003 to January 2015, Ms.

Haswell worked at the law firm Gibson, Dunn & Crutcher LLP, where she focused on tech counseling and litigation.

Haswell earned a degree in Political Science and Journalism from the University of Southern California and a law degree from the University of Southern California.

Philip Jensen , 66, became a principal of the Sponsor in September 2009 and is Chairman of the Sponsor’s audit committee.

20 unchanged sentences

Landini is a certified financial planner and is a member of the Financial Planning Association.

Kimun Lee , 77, became a principal of the Sponsor in September 2009 and is a member of the Sponsor’s audit committee.

Lee is a California-registered investment adviser and has conducted his consulting business under the name Resources Consolidated since January 1980.

Since September 2010, Mr.

Lee has served as a member of the board of directors of Firsthand Technology Value Fund, Inc., a mutual fund company.

Since April 2013, Mr.

Lee has served as a member of the board of trustees of Firsthand Funds, a mutual fund company.

Since April 2014, Mr.

Lee has served as a member of the board of trustees of FundX Investment Trust, a mutual fund company.

Until January 2005, Mr.

Lee also served as a member of the board of directors of Fremont Mutual Funds, Inc., a mutual fund company.

Lee received his Bachelor of Arts from the University of the Pacific and an MBA from University of Nevada, Reno.

He also completed the executive education program on corporate governance at Stanford Graduate School of Business.

Orlando Montalvo , 57, became a principal of the Sponsor and jointly responsible for the trading decisions with respect to the Trust’s account as of January 21, 2025.

Since December 2009, Mr.

Montalvo has served as a Managing Director of BlackRock, Inc.

and performs supervisory and managerial functions.

Montalvo has managed the Digital Currency and Currency Overlay Portfolio Management Team within BlackRock’s Global Markets & Index Investments Group.

In that capacity, Mr.

Montalvo oversees portfolio management for the currency hedged, commodity and crypto exchange-traded products and for institutional hedged currency overlays.

His service with BlackRock or its affiliates dates to 1992, including his years with Barclays Global Investors.

Montalvo earned his Bachelor of Science in finance from San Francisco State University.

Charles Park , 57, became a principal of the Advisor in December 2012 and has served as Chief Compliance Officer for the Advisor since August 2006.

10 unchanged sentences

Park earned a Bachelor of Arts in economics from the University of Michigan in 1989 and a Juris Doctor from the University of Michigan in 1992.

Greg Savage , 52, became a principal and associated person of the Sponsor in July 2012 and performs supervisory and managerial functions.

Since March 2009, Mr.

Savage was a principal and associated person, performing supervisory and managerial functions, of BlackRock Asset Management International Inc., a former commodity pool operator that withdrew its commodity pool operator registration in February 2014.

Savage has served as a Senior Portfolio Manager and Team Leader for BlackRock Fund Advisors, an investment advisor registered with the SEC and a commodity trading advisor registered with the CFTC, since September 2007 and became a principal and associated person of that entity in March 2009.

Savage also served as a Portfolio Manager for BFA from March 2001 to September 2007.

Savage served as a Transition Services Manager for BlackRock Institutional Trust Company, N.A., a national banking association and commodity trading advisor registered with the CFTC, from June 1999 to March 2001 and became an associated person of that entity in June 2007.

Savage received his Bachelor of Science in accounting from the University of Colorado at Boulder and is a CFA charterholder.

He has the FINRA Series 7, 63 and 3 licenses.

Charles Pulsfort , 44, has served as Global Head of Financial Reporting for BlackRock, Inc.

since February 1, 2025.

In this role, Mr.

Pulsfort leads the design and enhancement of BlackRock’s financial and regulatory reporting operating environment across multiple jurisdictions.

Pulsfort has served as a Managing Director since March 2016.

From March 2016 to January 2025, Mr.

Pulsfort led the Americas Financial Reporting, Regulatory Financial and Disclosure Operations and Technical Accounting Center groups within BlackRock’s Global Accounting and Product Services.

In that capacity, Mr.

Pulsfort oversaw the production and delivery of financial statements and regulatory financial reports, and he led a centralized accounting and financial reporting consultation center that supports accounting policies and technical accounting conclusions for BlackRock-sponsored funds.

He is a Managing Director of BlackRock, Inc.

Pulsfort graduated with honors from Ursinus College with a bachelor’s degree in economics and business administration.

Philip Vasan , 64, became a principal of the Sponsor and the Advisor on August 24, 2022 and performs supervisory and managerial functions.

12 unchanged sentences

in Economics from Harvard University.

Paul Whitehead, 53, became a principal, an NFA associate member and an associated person of the Sponsor on August 23, 2022 and performs supervisory and managerial functions.

Whitehead became a principal of the Advisor, performing supervisory and managerial functions, on August 23, 2022 and has been an associated person since February 22, 2001 and an NFA associate member since January 26, 2001.

Whitehead has been a principal of BlackRock Institutional Trust Company, N.A., performing supervisory and managerial functions, since August 23, 2022, a swap associated person since December 14, 2012, and an associated person and an NFA associate member since September 22, 2003.

Whitehead is a Managing Director of BlackRock, Inc.

Since January 2022, Mr.

Whitehead has served as the Co-Head of Index Equity with responsibility for Global Portfolio Engineering, Index Asset Allocation, Investment Process and Platform, and Transition Management within BlackRock, Inc.'s ETF and Index Investments group (“EII”).

Whitehead previously was the Global Head of Equity Trading for EII from July 2015 to January 2022.

Whitehead earned his Bachelor of Science in economics from the University of Colorado at Boulder in 1993.

BlackRock Asset Management International Inc.

3 unchanged sentences

The Sponsor’s Code of Ethics is intended to be a codification of the business and ethical principles that guide the Sponsor, deter wrongdoing, and promote (1) honest and ethical conduct (including the ethical handling of actual or apparent conflicts of interest), (2) full, fair, accurate, timely and understandable disclosure in public reports, documents and communications, (3) compliance with applicable laws and governmental rules and regulations, (4) the prompt internal reporting of violations of the Code of Ethics and (5) accountability for adherence to the Code of Ethics.

BlackRock has adopted an insider trading policy governing the purchase, sale and other dispositions of BlackRock’s securities that applies to all employees of BlackRock and its subsidiaries, and BlackRock’s directors and officers, as well as BlackRock itself.

BlackRock believes that its insider trading policy is reasonably designed to promote compliance with insider trading laws, rules and regulations, as well as applicable listing standards.

A copy of BlackRock’s insider trading policy is filed as Exhibit 19.1 to this report.

Executive Compensation.

44 unchanged sentences

333‑193156 on April 2, 2014

Global Insider Trading Policy

Consent of PricewaterhouseCoopers LLP

5 unchanged sentences

Section 1350, as Adopted Pursuant to Section 906 of the Sarbanes‑Oxley Act of 2002

Executive Officer Incentive-Based Compensation Clawback Policy

Executive Officer Incentive-Based Compensation Clawback Policy is incorporated by reference to Exhibit 97.1 of the Annual Report on Form 10-K filed by the Registrant on February 20, 2024

Inline XBRL Instance Document - the instance document does not appear in the Interactive Data File because its XBRL tags are embedded within the Inline XBRL document.

38 unchanged sentences

A trust’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles.

(ii) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the trust are being made only in accordance with authorizations of the Sponsor’s management and the Sponsor of the trust;

and (iii) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the trust’s assets that could have a material effect on the financial statements.

A trust’s internal control over financial reporting includes those policies and procedures that (i) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the trust; (ii) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the trust are being made only in accordance with authorizations of the Sponsor’s management and the Sponsor of the trust; and (iii) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the trust’s assets that could have a material effect on the financial statements.

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements.

48 unchanged sentences

8,116,594 8,909,822 14,782,155

Net investment income (loss)

Net investment income

43,134,541 43,650,066 7,523,923

28 unchanged sentences

$ 968,051,679 $ 1,221,109,857 $ 1,431,810,115

Net investment income (loss)

Net investment income

43,134,541 43,650,066 7,523,923

10 unchanged sentences

( 307,190,380 ) ( 350,512,508 ) ( 1,078,742,396 )

Net increase (decrease) in net assets from capital share transactions

Net decrease in net assets from capital share transactions

( 70,493,171 ) ( 186,516,503 ) ( 601,508,880 )

Increase (decrease) in net assets

Decrease in net assets

( 502,149 ) ( 253,058,178 ) ( 210,700,258 )

6 unchanged sentences

( 14,650,000 ) ( 17,100,000 ) ( 49,100,000 )

Net increase (decrease) in Shares issued and outstanding

Net decrease in Shares issued and outstanding

( 3,700,000 ) ( 9,350,000 ) ( 26,200,000 )

37 unchanged sentences

( 70,493,171 ) ( 186,516,503 ) ( 601,508,880 )

Net increase (decrease) in cash and cash equivalents

Net decrease in cash and cash equivalents

( 932,804 ) ( 2,745,980 ) ( 36,444,510 )

44 unchanged sentences

25,000,000 24,835,859

4.46 % due 3/06/25

28,750,000 28,539,454

4.35 % due 3/13/25

50,000,000 49,593,634

4.34 % due 3/20/25

61,000,000 60,455,082

Treasury bills (Cost:

2 unchanged sentences

Other Assets, Less Liabilities – 0.41 %

( 4,061,770 )

Net Assets – 100.00 %

38 unchanged sentences

51,000,000 50,620,877

Treasury bills (Cost:

5.40 % due 2/27/24

42,000,000 41,654,885

5.35 % due 3/07/24

50,000,000 49,529,991

Total Investments – 98.46 %

5.37 % due 3/14/24

50,000,000 49,481,150

Treasury bills (Cost:

$ 971,687,389 )

Total Investments – 100.42 %

Other Assets, Less Liabilities – (0.42) %

( 4,061,770 )

Net Assets – 100.00 %

77 unchanged sentences

The Trust is under no obligation to make periodic distributions to shareholders.

Segment Reporting

The Trust adopted Financial Accounting Standards Board Update 2023 - 07, Segment Reporting (Topic 280 ) - Improvements to Reportable Segment Disclosures (“ASU 2023 - 07” ) during the period.

The Trust’s adoption of the new standard impacted financial statement disclosures only and did not affect the Trust’s financial position or results of operations.

The Chief Financial Officer of the Sponsor acts as the Trust’s Chief Operating Decision Maker (“CODM”) and is responsible for assessing performance and allocating resources with respect to the Trust.

The CODM has concluded that the Trust operates as a single operating segment since the Trust has a single investment strategy as disclosed in its prospectus, against which the CODM assesses performance.

The financial information provided to and reviewed by the CODM is presented within the Trust's financial statements.

3 - Offering of the Shares

32 unchanged sentences

$ 20.08 $ 21.22 $ 17.10

Net investment income (loss) (a)

Net investment income (a)

0.94 0.84 0.09

8 unchanged sentences

Ratio to average net assets:

Net investment income (loss)

Net investment income

4.39 % 4.07 % 0.42 %

11 unchanged sentences

Asset Derivatives

Liability Derivatives Fair Value

Fair Value Liability Derivatives Fair Value

December 31, 2024

15 unchanged sentences

December 31, 2023

Commodity contracts

Net realized gain (loss) from futures contracts $ 359,651,081 $ —

Net change in unrealized appreciation/depreciation on futures contracts

Commodity contracts Net realized gain (loss) from futures contracts $ ( 58,095,356 ) $ —

Net change in unrealized appreciation/depreciation on futures

— ( 52,150,846 )

1 unchanged sentence

Commodity contracts Net realized gain (loss) from futures contracts $ 359,651,081 $ —

Net change in unrealized appreciation/depreciation on futures contracts — ( 5,445,651 )

Net change in unrealized appreciation/depreciation on futures

10 - Investment Valuation

15 unchanged sentences

The following table summarizes the value of each of the Trust’s investments by the fair value hierarchy levels as of December 31, 2024 and December 31, 2023:

Level 1 Level 2 Level 3 Total

December 31, 2024

Futures contracts (a)

$ 32,609,106 $ — $ — $ 32,609,106

Treasury bills

— 963,610,158 — 963,610,158

December 31, 2023

5 unchanged sentences

iShares Delaware Trust Sponsor LLC,

Sponsor of the iShares S&P GSCI™ Commodity-Indexed Trust (registrant)

Sponsor of iShares S&P GSCI™ Commodity-Indexed Trust (registrant)

/s/ Shannon Ghia

12 unchanged sentences

February 18, 2025

/s/ Kimun Lee

/s/ Lindsey Haswell

Lindsey Haswell

February 18, 2025

1 unchanged sentence

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 9A. Controls and Procedures