What changed in this filing

/stocks — the workspaceLOADING

Item 9A. Controls and Procedures

2025-02-19 compared with 2024-02-20 · 46 added, 30 removed, 454 unchanged (14% of the section changed)

24 unchanged sentences

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

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

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

Shannon Ghia, 48, has served as a Director of the Sponsor since March 2022 and became a principal of the Sponsor on April 18, 2022.

34 unchanged sentences

Landini is a certified financial planner.

Kimun Lee, 77, 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.

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.

The Sponsor has a code of ethics (the “Code of Ethics”) that applies to its executive officers, including its Chief Executive Officer, President, Chief Financial Officer and Treasurer, who perform certain functions with respect to the Trust that, if the Trust had executive officers would typically be performed by them.

1 unchanged sentence

The Sponsor’s Code of Ethics is intended to be a codification of the business and ethical principles that guide the Sponsor, and to deter wrongdoing, to 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.

28 unchanged sentences

333-156506 filed by the Registrant on December 30, 2008

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.

39 unchanged sentences

Net realized gain (loss) from:

Litigation proceeds (a)

Silver bullion sold to pay expenses

8 unchanged sentences

2,228,813,537 ( 75,421,049 ) 38,418,066

Net decrease in net assets resulting from operations

Net increase (decrease) in net assets resulting from operations

$ 2,165,540,895 $ ( 128,982,872 ) $ ( 18,017,230 )

Net decrease in net assets per Share (a)

Net increase (decrease) in net assets per Share (b)

$ 4.42 $ ( 0.26 ) $ ( 0.03 )

Represents a payment received from a class action settlement related to silver.

Net increase (decrease) in net assets per Share based on average shares outstanding during the year.

12 unchanged sentences

1,001,643,726 ( 361,918,369 ) 215,447,290

Net decrease in net assets resulting from operations

Net increase (decrease) in net assets resulting from operations

2,165,540,895 ( 128,982,872 ) ( 18,017,230 )

4 unchanged sentences

( 6,775,130,565 ) ( 4,222,040,407 ) ( 4,680,125,800 )

Net decrease in net assets from capital share transactions

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

846,540,334 ( 641,924,324 ) ( 1,071,132,022 )

Decrease in net assets

Increase (decrease) in net assets

3,012,081,229 ( 770,907,196 ) ( 1,089,149,252 )

6 unchanged sentences

( 261,600,000 ) ( 196,800,000 ) ( 243,150,000 )

Net decrease in Shares issued and outstanding

Net increase (decrease) in Shares issued and outstanding

31,950,000 ( 29,550,000 ) ( 67,250,000 )

14 unchanged sentences

Reconciliation of Net Increase (Decrease) in Net Assets Resulting from Operations to Net Cash Provided by (Used in) Operating Activities

Net decrease in net assets resulting from operations

Net increase (decrease) in net assets resulting from operations

$ 2,165,540,895 $ ( 128,982,872 ) $ ( 18,017,230 )

2 unchanged sentences

61,784,640 53,707,373 56,964,663

Litigation Proceeds (a)

( 138,783 ) — —

Net realized (gain) loss

11 unchanged sentences

$ ( 6,775,130,565 ) $ ( 4,222,040,407 ) $ ( 4,680,125,800 )

Represents a payment received from a class action settlement related to silver.

See notes to financial statements.

59 unchanged sentences

— — 1,227,031,028 —

Litigation Proceeds (a)

— — 138,783 —

Net change in unrealized appreciation/depreciation

2 unchanged sentences

463,837,932 $ 11,628,353,352 $ 13,407,235,411 $ 1,227,031,028

Includes a payment received from a class action settlement related to silver of $ 138,783 .

Year Ended December 31, 2023

7 unchanged sentences

( 2,285,669 ) ( 49,834,316 ) ( 53,707,373 ) 3,873,057

Net realized loss

Net realized gain

— — 286,497,320 —

12 unchanged sentences

( 2,637,967 ) ( 57,003,252 ) ( 56,964,663 ) ( 38,589 )

Net realized gain

Net realized loss

— — ( 177,029,224 ) —

20 unchanged sentences

( 261,600,000 ) ( 6,775,130,565 ) ( 196,800,000 ) ( 4,222,040,407 ) ( 243,150,000 ) ( 4,680,125,800 )

Net increase (decrease)

31,950,000 $ 846,540,334 ( 29,550,000 ) $ ( 641,924,324 ) ( 67,250,000 ) $ ( 1,071,132,022 )

3 unchanged sentences

The Sponsor has analyzed applicable tax laws and regulations and their application to the Trust as of December 31, 2024 and does not believe that there are any uncertain tax positions that require recognition of a tax liability.

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 - Trust Expenses

1 unchanged sentence

The Sponsor has agreed to assume the following administrative and marketing expenses incurred by the Trust:

the Trustee’s fee and reimbursement for its reasonable out‑of‑pocket expenses, the Custodian’s fee, NYSE Arca listing fees, SEC registration fees, printing and mailing costs, audit fees and expenses, and, effective January 31, 2022, up to $ 500,000 per annum in legal fees and expenses.

the Trustee’s fee and reimbursement for its reasonable out‑of‑pocket expenses, the Custodian’s fee, NYSE Arca listing fees, SEC registration fees, printing and mailing costs, audit fees and expenses, and up to $ 500,000 per annum in legal fees and expenses.

The Sponsor may determine in its sole discretion to assume legal fees and expenses of the Trust in excess of the amount required under the Trust Agreement.

7 unchanged sentences

The Trust has agreed that the Custodian will only be responsible for any loss or damage suffered by the Trust as a direct result of the Custodian’s negligence, fraud or willful default in the performance of its duties.

The Trust’s maximum exposure under these arrangements is unknown because it involves future potential claims against the Trust, which cannot be predicted with any certainty.

6 - Commitments and Contingent Liabilities

33 unchanged sentences

Based on average Shares outstanding during the year.

The amounts reported for a Share outstanding may not accord with the change in aggregate gains and losses on investment for the period due to the timing of Trust Share transactions in relation to the fluctuating fair values of the Trust’s underlying investment.

The amounts reported for a Share outstanding may not accord with the change in aggregate gains and losses on investment for the period due to the timing of Share transactions in relation to the fluctuating fair values of the Trust’s underlying investment.

Based on the change in net asset value of a Share during the year.

13 unchanged sentences

iShares Delaware Trust Sponsor LLC,

Sponsor of the iShares Silver Trust (registrant)

Sponsor of iShares Silver Trust (registrant)

/s/ Shannon Ghia

17 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