Firm profile

Gap Asset Management, LLC

SOUTH BEND, INCRD 309925Registration Status: ApprovedEffective since July 25, 2025SEC # 801-133963Latest ADV May 5, 2026

Gap Asset Management, LLC is an SEC registered investment adviser organized as a limited liability company with a primary office location in South Bend, IN. Its latest Form ADV filing, dated May 5, 2026, reports $287M in regulatory assets under management, 14 employees, 3 offices, and 2 accounts.

Assets Under Management
$287M
Employees
14
Offices
3 offices
Total Clients
<5

Associated firm names

1 name listed
  • GAP ASSET MANAGEMENT, LLC

Leadership

2 roles identified
CCOLauren C. Carroll
CFOLauren C. Carroll

Advisory services offered

2 types reported
Other advisory services
Portfolio management for pooled investment vehicles

Fee models offered

3 types reported
Asset based fees
Other fee arrangements
Performance-based fees

Offices & Contact

Primary office

SOUTH BEND, Indiana, United States

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Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

Indiana

SOUTH BENDPrimary office

Florida

NAPLES

Illinois

CHICAGO

3 office records listed · 3 total offices reported. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links
Phone574-485-2146
WebsiteNot found
LinkedInNot found

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$287Mas of May 5, 2026
Discretionary100.0%
$287M
100% of total RAUM100.0%
Non-discretionary0.0%
$0
0% of total RAUM0.0%
All regulatory assets under management are discretionary.

Client Coverage Demographics

Top client segmentPooled Investment Vehicles represent 100.0% of total clients.
Top client categories% of clientsClients
1
Pooled Investment Vehicles
100.0%
2

Assets under management Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$287M
Total Accounts2
10Y AUM Change+$17M (+6.4%)

Private Funds

Private funds reported by Gap Asset Management, LLC

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Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees14
Clients per Employee0:1
10Y Employee Change+2 (+16.7%)

Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.


Ownership

Reported direct and indirect ownership ranges

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
GACP II, LLCDirect owner · Schedule AInterest in GAP ASSET MANAGEMENT, LLC
75%+
GRAHAM-ALLEN PARTNERS, LLCIndirect owner · Schedule BInterest in GACP II, LLC
75%+

Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Gap Asset Management, LLC.

Reported ownership and control details

Form ADV · Filing date 2026-05-05 · Schedules A and B

6 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1GACP II, LLCMEMBERDomestic entityGAP ASSET MANAGEMENT, LLC75% or moreCode EYesMEMBER04/2020Schedule APDF page 29
2TRACY DANIEL GRAHAMMANAGING PRINCIPALIndividualGAP ASSET MANAGEMENT, LLCLess than 5%Code NAYesMANAGING PRINCIPAL04/2020Schedule APDF page 29
3LAUREN CHRISTINE CARROLLCHIEF COMPLIANCE OFFICER, CHIEF FINANCIAL OFFICERIndividualGAP ASSET MANAGEMENT, LLCLess than 5%Code NAYesCHIEF COMPLIANCE OFFICER, CHIEF FINANCIAL OFFICER08/2022Schedule APDF page 29
4GRAHAM-ALLEN PARTNERS, LLCMEMBERDomestic entityGACP II, LLC75% or moreCode EYesMEMBER04/2020Schedule BPDF page 29
5TRACY D. GRAHAM 2008 REVOCABLE TRUSTMEMBERDomestic entityGRAHAM-ALLEN PARTNERS, LLCPercentage not specifiedCode FYesMEMBER08/2008Schedule BPDF page 29
6TRACY DANIEL GRAHAMTRUSTEE OF THE TRACEY D. GRAHAM 2008 REVOCABLE TRUSTIndividualTRACY D. GRAHAM 2008 REVOCABLE TRUSTPercentage not specifiedCode FYesTRUSTEE OF THE TRACEY D. GRAHAM 2008 REVOCABLE TRUST08/2008Schedule BPDF page 29

Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.

Compliance & Disclosures

Filing dated 5/5/2026 4:25:52 PM

Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.

RIA or supervised-person involvementThe RIA reported that none of the events below involve the firm or its supervised persons.RIA responseNo
AFelonies2 No

In the past ten years, have you or any advisory affiliate:

  • A1Been convicted of or pleaded guilty or no contest to a felony?No
  • A2Been charged with a felony?No
BMisdemeanors2 No

In the past ten years, have you or any advisory affiliate:

  • B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
  • B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions5 No

Has the SEC or CFTC ever:

  • C1Found you or an advisory affiliate made a false statement or omission?No
  • C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?No
  • C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • C4Entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?No
DOther regulatory actions5 No

Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:

  • D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
  • D2Found you or an advisory affiliate violated investment-related regulations or statutes?No
  • D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions4 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?No
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?No
  • E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
  • GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No

(1) Court actions

Has a domestic or foreign court:

  • H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
  • H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
  • H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No

(2) Pending civil proceedings

  • H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No

* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.