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| Gamma Asset Management LLC
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| CRD # | 300050 |
| SEC # | 801-129754 |
| CIK # | |
| AUM | 424.8 M (2026-02-24) |
| Employees | 13 (62% Investors, 46% Brokers) |
| Fees | |
| Minimum | |
| Phone | 787-957-3260 |
| Address | Edificio Ochoa 500 Calle de La Tanca San Juan, PR 00901-1969 |
| Source | [IAPD] [Website] [LinkedIn] |
| Total AUM ($M) |
|---|
| Fees and Compensation — Form ADV Part 2A (2/24/2026) [Brochure] |
|---|
Item 5 - Fees and Compensation
Basic fee schedule:
The specific manner in which fees are charged by the Adviser is established in each client’s written
agreement with Adviser. 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. All fees are negotiable. Adviser may enter flat fee arrangements from time to time, typically
for administrative services provided to clients.
Basic Management Fee Schedule
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%
Calculation and Deduction of Advisory Fees
With respect to accounts that Adviser manages on a discretionary basis, including the specialized
discretionary programs, clients are generally required to authorize Adviser to directly debit management
fees from client accounts on a quarterly basis. Fees for non-discretionary programs are billed to clients,
although frequently clients pre-authorize their custodians to automatically deduct the fees from the client’s
account and to make payment to Adviser. Management fees are deducted or billed, as applicable, on a
quarterly basis in arrears. The Adviser from time-to-time bill fees in advance as negotiated with each
individual client.
A client can pay more or less fees than similar clients depending on the circumstances of the client, size,
additional or differing levels of servicing or as otherwise agreed with specific clients. Clients that
negotiate fees, including a flat fee, can end up paying a higher fee than that set forth above as a result of
fluctuations in the client’s assets under management and portfolio performance.
In the event the Adviser bills fees in advance, refunds are given on a prorated basis, based on the number
of days remaining in a quarter at the point of termination. Fees that are collected in advance will be
refunded based on the prorated amount of work completed up to the day of termination within the quarter
terminated. The fee refunded will be the balance of the fees collected in advance minus the daily rate*
times the number of days in the quarter up to and including the day of termination. (*The daily rate is
calculated by dividing the quarterly AUM fee by the number of days in the termination quarter). Clients
can terminate their contracts without penalty, for full refund, within five (5) business days of signing the
advisory contract. Advisory fees are withdrawn directly from the client’s accounts with client written
authorization.
Additional Fee Information
Page|5
Clients can authorize the Adviser to directly debit management fees from client accounts on a quarterly
basis. In such instances, management fees are prorated for each capital contribution and withdrawal made
during the applicable calendar quarter. Accounts initiated or terminated during a calendar quarter will be
charged a prorated fee.
Alternatively, in some instances, clients can receive an invoice for fees, in which it can choose to pay
GAM directly for its billed fees for the relevant period.
Adviser’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and
expenses which shall be incurred directly by the client. Clients can incur certain charges imposed by
custodians, brokers, and other third parties such as fees charged by fund managers, custodial fees, deferred
sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic funds fees, and other fees
and taxes on brokerage account and securities transactions. Mutual funds and exchange traded funds also
charge internal management fees, which are disclosed in a fund’s prospectus. It is the Adviser’s policy
not to accept “kickbacks” or retrocession fees from any third non-affiliated party providing services to the
Adviser’s clients.
Termination of the Agreement
Although an Agreement between GAM and its clients are ongoing agreements and constant adjustments
are required, the length of service to the client is at the client’s discretion. The client or the investment
manager can terminate an Agreement by written notice to the other party with a (30) thirty – day advance
notice or as agreed upon otherwise between the client and the Adviser.
If an agreement is terminated during a period in which the client has already paid GAM its advisory fees
in advance, then the Adviser will reimburse, on a pro-rated basis, the remaining advisory fees collected
for any service not rendered; these fees will be sent to the client’s address of record, unless otherwise
directed by the client, within (30) days of termination of the agreement. |
| Account Minimums and Types of Clients — Form ADV Part 2A (2/24/2026) [Brochure] |
|---|
Item 7 - Types of Clients GAM provides asset and/or portfolio management services to high-net-worth individuals, corporations and institutions or other entities. The minimum dollar value for establishing an Account is generally $1,000,000.00. Initial investments of a lesser amount may be accepted at Adviser’s discretion. |
| AUM Breakdown | Accounts | AUM ($M) |
|---|---|---|
| By Client Type | ||
| (a) Individuals (other than high net worth individuals) | 51 | 18.6 |
| (b) Individuals (high net worth individuals) | 12 | 29.1 |
| (c) Banking or thrift institutions | 0 | 1.0 |
| (d) Investment companies | 0 | 0.0 |
| (e) Business development companies | 0 | 0.0 |
| (f) Pooled investment vehicles | 1 | 36.4 |
| (g) Pension and profit sharing plans | 0 | 0.0 |
| (h) Charitable organizations | 0 | 0.0 |
| (i) State or municipal government entities | 0 | 0.0 |
| (j) Other investment advisers | 0 | 0.0 |
| (k) Insurance companies | 0 | 0.0 |
| (l) Sovereign wealth funds and foreign official institutions | 0 | 0.0 |
| (m) Corporations or other businesses not listed above | 39 | 339.6 |
| (n) Other | 0 | 0.0 |
| Total | 108 | 424.8 |
| By Discretionary | ||
| Discretionary | 105 | 417.5 |
| Non-Discretionary | 3 | 7.3 |
| Total | 108 | 424.8 |
| By Non-United States Persons | ||
| Non-United States Persons | 385.9 | |
| United States Persons | 38.9 | |
| Total | 108 | 424.8 |
| Firm Profile (Form ADV) | |
|---|---|
| Discretionary AUM | $0.1B |
| Serves | Retail |
| LEI | 2549006X4C9NPW749B69 |
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✚
|
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|
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|
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|
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|
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|
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