# Gamma Asset Management LLC

> Gamma Asset Management LLC is an SEC-registered investment advisory firm in San Juan, PR, registered since 2024, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated September 17, 2026.

- CRD: 300050
- Filed as: GAMMA ASSET MANAGEMENT LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: San Juan, PR
- Filing period: October 2026
- Form ADV filing dated: September 17, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/300050
- AdvisorCensus page: https://advisorcensus.com/firm/gamma-asset-management-llc-san-juan-pr-300050

## Quick answers

**How is Gamma Asset Management LLC compensated?**
On its Form ADV (Item 5.E, October 2026), Gamma Asset Management LLC reports these compensation arrangements: a percentage of assets under its management.

**How much does Gamma Asset Management LLC charge?**
Its Form ADV Part 2A brochure dated February 24, 2026 states: Up to $1,999,999.99: 1% a year; $2,000,000 to $9,999,999.99: 0.8% a year; $10,000,000 to $24,999,999.99: 0.7% a year; $25,000,000 to $49,999,999.99: 0.6% a year; Above $50,000,000: 0.5% a year. Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Where is Gamma Asset Management LLC located?**
Gamma Asset Management LLC's principal office is in San Juan, PR, according to its Form ADV; the October 2026 filing also lists 1 other office (Schedule D, Section 1.F).

**Is Gamma Asset Management LLC registered with the SEC or a state?**
Gamma Asset Management LLC is an SEC-registered investment advisory firm, registered since 2024. Status as filed: Approved. CRD 300050.

**How much does Gamma Asset Management LLC manage?**
Gamma Asset Management LLC reports $424,799,105 in regulatory assets under management in its Form ADV filing dated September 17, 2026 (98% discretionary).

**How have Gamma Asset Management LLC's assets and staff changed since 2024?**
In the Form ADV data for Gamma Asset Management LLC: Regulatory assets under management: $100,595,428 in the October 2024 data and $424,799,105 in the October 2026 data, up 322%. Total employees: 8 in October 2024 and 13 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Gamma Asset Management LLC serve?**
By number of clients on Form ADV Item 5.D: individuals (other than high net worth individuals) (51); corporations or other businesses not listed above (39); high net worth individuals (12).

**Which custodians does Gamma Asset Management LLC use?**
Gamma Asset Management LLC's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists AV Securities Inc., Interactive Brokers LLC, J.P. Morgan Securities LLC and Pershing LLC as custodians holding 10% or more of its separately managed account assets.

**Does Gamma Asset Management LLC report any disciplinary disclosures?**
Reports no disclosure items on Form ADV Item 11. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/300050

**What changed in Gamma Asset Management LLC's recent Form ADV filings?**
In the October 2026 filing data: Registered or notice-filed in CA.

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management

### Fees and minimums (Form ADV Part 2A brochure dated February 24, 2026)

- Up to $1,999,999.99: 1% a year
- $2,000,000 to $9,999,999.99: 0.8% a year
- $10,000,000 to $24,999,999.99: 0.7% a year
- $25,000,000 to $49,999,999.99: 0.6% a year
- Above $50,000,000: 0.5% a year

> Generally, and pursuant to contract, fees for the management of Accounts will be based upon a percentage of the total assets in the account (including margined assets). Advisers typically receive an annual management fee, between 0.50% and 1.00% of the net asset value of the Account.

> Account Value Range Fee Percentage $0.00-$1,999,999.99 1.00% $2,000,000-$9,999,999.99 0.80% $10,000,000.00 to $24,999,999.99 0.70% $25,000,000.00-$49,999,999.99 0.60% Over $50,000,000.00 0.50%

> All fees are negotiable.

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Custodians (Schedule D, Section 5.K(3))
- AV Securities Inc.
- Interactive Brokers LLC
- J.P. Morgan Securities LLC
- Pershing LLC

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

### Regulatory assets under management (Item 5.F)
- Total: $424,799,105
- Discretionary: $417,461,492
- Non-discretionary: $7,337,613

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 51 | $18,621,346 |
| High net worth individuals | 12 | $29,110,943 |
| Banking or thrift institutions | Fewer than 5 | $981,657 |
| Investment companies | 0 | Not reported |
| Business development companies | 0 | Not reported |
| Pooled investment vehicles (other than investment companies and business development companies) | 1 | $36,447,222 |
| Pension and profit sharing plans (but not the plan participants or government pension plans) | 0 | Not reported |
| Charitable organizations | 0 | Not reported |
| State or municipal government entities (including government pension plans) | 0 | Not reported |
| Other investment advisers | 0 | Not reported |
| Insurance companies | 0 | Not reported |
| Sovereign wealth funds and foreign official institutions | 0 | Not reported |
| Corporations or other businesses not listed above | 39 | $339,637,937 |

### Advisory services (Item 5.G)
- Portfolio management for individuals and/or small businesses

### Firm details
- Registered since: 2024 (2 years)
- Employees: 13 total, 8 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: CA, FL, NY, PA, PR
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Other offices (Schedule D, Section 1.F), as of the October 2026 filing
- Miami, FL

### Websites listed on Form ADV (Item 1.I)
- gammaam.com
- LinkedIn @gamma-international-bank-lnc

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2024 | $100,595,428 | 8 | May 1, 2024 |
| October 2025 | $269,236,959 | 10 | March 14, 2025 |
| October 2026 | $424,799,105 | 13 | September 17, 2026 |

Regulatory assets under management: $100,595,428 in the October 2024 data and $424,799,105 in the October 2026 data, up 322%.
Total employees: 8 in October 2024 and 13 in October 2026.

## Changes in the filing (last 12 months)

### October 2026
- Registered or notice-filed in CA.

### March 2026
- Employees performing advisory functions went from 7 to 8.
- Regulatory assets under management went from $269,236,959 to $424,799,105 (+58%).
- Added an office in Miami, FL.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Gamma Asset Management LLC (CRD 300050): Form ADV filing data as of October 2026.