# Gap Asset Management, LLC

> Gap Asset Management, LLC is an SEC-registered investment advisory firm in South Bend, IN, registered since 2025, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated May 5, 2026.

- CRD: 309925
- Filed as: GAP ASSET MANAGEMENT, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Location: South Bend, IN
- Filing period: October 2026
- Form ADV filing dated: May 5, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/309925
- AdvisorCensus page: https://advisorcensus.com/firm/gap-asset-management-llc-south-bend-in-309925

## Quick answers

**How is Gap Asset Management, LLC compensated?**
On its Form ADV (Item 5.E, October 2026), Gap Asset Management, LLC reports these compensation arrangements: a percentage of assets under its management; performance-based fees; other. The amounts are in Item 5 of its Form ADV Part 2A brochure.

**Where is Gap Asset Management, LLC located?**
Gap Asset Management, LLC's principal office is in South Bend, IN, according to its Form ADV; the June 2026 filing also lists 2 other offices (Schedule D, Section 1.F).

**Is Gap Asset Management, LLC registered with the SEC or a state?**
Gap Asset Management, LLC is an SEC-registered investment advisory firm, registered since 2025. Status as filed: Approved. CRD 309925.

**How much does Gap Asset Management, LLC manage?**
Gap Asset Management, LLC reports $286,973,918 in regulatory assets under management in its Form ADV filing dated May 5, 2026 (100% discretionary).

**How have Gap Asset Management, LLC's assets and staff changed since 2021?**
In the Form ADV data for Gap Asset Management, LLC: Regulatory assets under management: $269,615,898 in the October 2025 data and $286,973,918 in the October 2026 data, up 6%. Total employees: 12 in October 2025 and 14 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Gap Asset Management, LLC serve?**
By number of clients on Form ADV Item 5.D: pooled investment vehicles (other than investment companies and business development companies) (2).

**Does Gap 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/309925

**What changed in Gap Asset Management, LLC's recent Form ADV filings?**
In the April 2026 filing data: Employees performing advisory functions went from 11 to 13. Added an office in Naples, FL. Registered or notice-filed in FL.

## From the Form ADV filing

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

### Regulatory assets under management (Item 5.F)
- Total: $286,973,918
- Discretionary: $286,973,918
- Non-discretionary: $0

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Pooled investment vehicles (other than investment companies and business development companies) | 2 | $286,973,918 |

### Advisory services (Item 5.G)
- Portfolio management for pooled investment vehicles (other than investment companies)
- Other

### Firm details
- Registered since: 2025 (1 year)
- Employees: 14 total, 13 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: FL, IL, IN
- Disclosures (Item 11): Reports no disclosure items on Form ADV Item 11.

### Other offices (Schedule D, Section 1.F), as of the June 2026 filing
- Chicago, IL
- Naples, FL

### Websites listed on Form ADV (Item 1.I)
- graham-allen.com
- LinkedIn @graham-allen-partners

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2021 | Not reported | Not reported | March 31, 2021 |
| October 2022 | Not reported | Not reported | March 30, 2022 |
| October 2023 | Not reported | Not reported | March 31, 2023 |
| October 2024 | Not reported | Not reported | April 25, 2024 |
| October 2025 | $269,615,898 | 12 | June 25, 2025 |
| October 2026 | $286,973,918 | 14 | May 5, 2026 |

Regulatory assets under management: $269,615,898 in the October 2025 data and $286,973,918 in the October 2026 data, up 6%.
Total employees: 12 in October 2025 and 14 in October 2026.

## Changes in the filing (last 12 months)

### April 2026
- Employees performing advisory functions went from 11 to 13.
- Added an office in Naples, FL.
- Registered or notice-filed in FL.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Gap Asset Management, LLC (CRD 309925): Form ADV filing data as of October 2026.