{"url":"https://nivawealth.com/firms/gap-asset-management-309925","iapdUrl":"https://adviserinfo.sec.gov/firm/summary/309925","regulatoryAum":286973918,"crd":"309925","history":[{"filedOn":"2025-06-25","regulatoryAum":269615898,"clients":2,"employees":12,"offices":2},{"filedOn":"2026-05-05","regulatoryAum":286973918,"clients":2,"employees":14,"offices":3}],"secFileNumber":"801-133963","legalName":"Gap Asset Management, LLC","displayName":"Gap Asset Management","slug":"gap-asset-management-309925","website":"https://graham-allen.com/","classification":{"segment":"private_funds","segmentLabel":"Private funds","type":"private_fund_manager","typeLabel":null,"feeDisclosure":"payment_only"},"founded":null,"organization":"Indiana limited liability company","fiscalYearEnd":"December","headquarters":{"street":"100 E. Wayne Street, Suite 450","city":"South Bend","state":"IN","stateName":"Indiana","country":"United States","postalCode":"46601"},"tradeNames":[],"registration":{"secApproved":"25 July 2025","noticeFilings":null,"latestNoticeFiling":null},"wealthAumPerClient":null,"staff":{"employees":14,"advisory":13,"brokerDealerReps":0,"insuranceAgents":0,"promoters":0},"aum":{"regulatory":286973918,"discretionary":286973918,"discretionaryAccounts":2,"nonDiscretionary":0,"nonDiscretionaryAccounts":0,"wrapProgram":null,"nonUsClientsPct":0,"nonAumClients":0},"clientTypes":[{"label":"Pooled investment vehicles","clients":2,"regulatoryAum":286973918}],"feePrograms":[],"brochureCoverage":{"scope":"known_documents","status":"not_processed","checkedAt":null,"documents":[]},"custodians":[],"custodyNote":"Gap Asset Management has custody of $192M in client assets for 1 client.","leadership":[{"name":"Lauren Carroll","title":"Chief Compliance Officer, Chief Financial Officer","crd":"5875646"},{"name":"Tracy Graham","title":"Managing Principal","crd":"7271339"}],"ownership":[{"label":"Gacp II, LLC","detail":"Member in the 75% or more ownership band and a control person, since April 2020."},{"label":"Graham-Allen Partners, LLC","detail":"Indirect owner: a member of Gacp II, LLC in the 75% or more band and a control person, since April 2020.","parent":"Gacp II, LLC"},{"label":"Tracy D. Graham 2008 Revocable Trust","detail":"Indirect owner: member of Graham-Allen Partners, LLC and a control person, since August 2008.","parent":"Graham-Allen Partners, LLC"},{"label":"Tracy Graham","detail":"Indirect owner: trustee of the tracey d. graham 2008 revocable trust of Tracy D. Graham 2008 Revocable Trust and a control person, since August 2008.","parent":"Tracy D. Graham 2008 Revocable Trust"}],"filedOffices":{"otherThanPrincipal":2,"privateResidences":0},"listedOfficeAddresses":3,"foreignOffices":[],"officesByState":[{"state":"Florida","offices":1,"addresses":[{"street":"4850 Tamiami Trail N","city":"Naples"}]},{"state":"Illinois","offices":1,"addresses":[{"street":"303 West Madison","city":"Chicago"}]},{"state":"Indiana","offices":1,"addresses":[{"street":"100 E. Wayne Street, Suite 450","city":"South Bend","headquarters":true}]}],"advFacts":{"source":{"file":"ia100226.zip","asOf":"2 October 2026"},"telephone":"574-485-2146","stateRegisteredReps":0,"otherAdviserReps":0,"compensation":["A percentage of assets under management","Performance-based fees","Other"],"activities":["Portfolio management for pooled investment vehicles (other than investment companies)","Other"],"financialPlanningClients":null,"assetMix":[],"privateFunds":2},"sources":{"adv1FilingDate":"5 May 2026","adv1Url":"https://reports.adviserinfo.sec.gov/reports/ADV/309925/PDF/309925.pdf","brochureDate":null,"brochureUrl":null,"iapdCompiledDate":null,"retrievedDate":"15 October 2026","retrievedOn":"2026-10-15","updatedOn":"2026-10-21","holdingsUpdatedOn":"2026-10-21","adv1Pages":{},"brochurePages":{}},"otherBusiness":[],"faq":[{"question":"How many clients does Gap Asset Management have?","answer":"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","sourceRef":{"doc":"adv1","section":"employees"}},{"question":"What services does Gap Asset Management offer?","answer":"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","sourceRef":{"doc":"adv1","section":"employees"}},{"question":"How many financial advisors does Gap Asset Management have?","answer":"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","sourceRef":{"doc":"adv1","section":"employees"}},{"question":"Who owns Gap Asset Management?","answer":"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","sourceRef":{"doc":"adv1","section":"scheduleA"}},{"question":"How does Gap Asset Management get paid?","answer":"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","sourceRef":{"doc":"adv1","section":"employees"}},{"question":"Is Gap Asset Management registered with the SEC?","answer":"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","sourceRef":{"doc":"adv1","section":"identity"}},{"question":"How do I contact Gap Asset Management?","answer":"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.","source":"Form ADV Part 1A, Item 1.F, filed 5 May 2026","sourceRef":{"doc":"adv1","section":"offices"}}],"holdings":null,"notice":"Compiled from public SEC Form ADV filings on the dates in `sources`. Facts as filed; not a rating, ranking, or recommendation. Niva is not affiliated with this firm. Disciplinary history is deliberately not included here or on the page; the SEC publishes the complete record at the `iapdUrl` above."}