Gap Asset Management provides portfolio management for pooled vehicles. The firm advises 2 private funds.
Gap Asset Management reports 2 pooled investment vehicles. These counts refer to investment vehicles, rather than the individual investors in them. Of its assets, 100.0% ($287M across 2 accounts) are managed with discretion.
| Client type | Clients | Assets |
|---|---|---|
| Pooled investment vehicles | 100% | 100% |
Client breakdown and activity details
| Client type | Clients | Regulatory AUM | AUM share | Avg. per client |
|---|---|---|---|---|
| Pooled investment vehicles | 2 | $287M | 100.0% | $143M |
| Total | 2 | $287M | 100% | $143M |
- Clients
- 2
- Regulatory AUM
- $287M
- AUM share
- 100.0%
- Avg. per client
- $143M
Total
- Clients
- 2
- Regulatory AUM
- $287M
- AUM share
- 100%
- Avg. per client
- $143M
- Clients outside the U.S.
- 0%
- Clients advised without assets under management last fiscal year
- 0
- Private funds advised
- 2
Gap Asset Management is paid through a percentage of assets under management, performance-based fees and other compensation; its fees and minimums are set out in its brochures on the SEC website.
Gacp II, LLC owns 75% or more of Gap Asset Management and is in turn owned by Graham-Allen Partners, LLC (75% or more). The leadership team of Gap Asset Management includes Chief Financial Officer Lauren Carroll. It has 14 employees, 13 of them in advisory roles.
Leadership
- Lauren CarrollChief Compliance Officer, Chief Financial Officer
- Tracy GrahamManaging Principal
Staff
- 14 employees
- 13 in advisory functions
- Owns 75% or more of Gap Asset Management, LLC
Gacp II, LLC
Control person · since April 2020
- Owns 75% or more of Gacp II, LLC
Graham-Allen Partners, LLC
Control person · since April 2020
Tracy D. Graham 2008 Revocable Trust
Member · Control person · since August 2008
Tracy Graham
Trustee of the tracey d. graham 2008 revocable trust · Control person · since August 2008
Gap Asset Management’s regulatory assets grew from $270M (June 2025) to $287M (May 2026); clients were 2 in both filings and employees rose from 12 to 14.
Figures from each annual filing
| Filed | Regulatory AUM | Clients | Employees | Offices |
|---|---|---|---|---|
| May 2026 | $287M | 2 | 14 | 3 |
| June 2025 | $270M | 2 | 12 | 2 |
Besides its headquarters, Gap Asset Management has 2 offices, with 3 listed addresses in Florida, Illinois and Indiana.
Florida · 1 listed address
- 4850 Tamiami Trail N, Naples
Illinois · 1 listed address
- 303 West Madison, Chicago
Indiana · 1 listed address
- 100 E. Wayne Street, Suite 450, South BendHQ
Contact and registration details
- Legal name
- Gap Asset Management, LLC
- Headquarters
- 100 E. Wayne Street, Suite 450, South Bend, IN 46601
- Website
- graham-allen.com
- Phone
- 574-485-2146
- SEC file
- 801-133963
- Structure
- Indiana LLC
- Fiscal year end
- December
Gap Asset Management has custody of $192M in client assets for 1 client.
How many clients does Gap Asset Management have?
Gap Asset Management has 2 clients and manages $287 million for them, as of May 2026. They include 2 pooled investment vehicles.
Source: Form ADV Part 1A, Items 5.D and 5.F, filed 5 May 2026
What services does Gap Asset Management offer?
Gap Asset Management provides portfolio management for pooled vehicles.
Source: Form ADV Part 1A, Item 5.G, from the SEC's 2 October 2026 data file
How many financial advisors does Gap Asset Management have?
Gap Asset Management has 0 investment adviser representatives registered with state securities authorities, out of 14 employees, and 13 perform investment advisory functions. None are registered representatives of a broker-dealer or licensed insurance agents.
Source: Form ADV Part 1A, Items 5.A and 5.B, from the SEC's 2 October 2026 data file
Who owns Gap Asset Management?
Gap Asset Management’s direct owner is Gacp II, LLC (75% or more).
Source: Form ADV Part 1A, Schedules A and B, filed 5 May 2026
How does Gap Asset Management get paid?
Gap Asset Management is paid through a percentage of assets under management, performance-based fees and other compensation. Its Form ADV lists no commissions among how it is paid.
Source: Form ADV Part 1A, Item 5.E, from the SEC's 2 October 2026 data file
Is Gap Asset Management registered with the SEC?
Yes, Gap Asset Management has been registered with the SEC as an investment adviser since 25 July 2025. Its CRD number is 309925 and its SEC file number is 801-133963.
Source: Form ADV Part 1A, Item 1, filed 5 May 2026; IAPD firm record
How do I contact Gap Asset Management?
Gap Asset Management’s main office is at 100 E. Wayne Street, Suite 450, South Bend, IN 46601. Its phone number is 574-485-2146. Its website is graham-allen.com.