Firm Information This Disclosure Brochure (“Form ADV Part 2”) provides information regarding the qualifications, business practices, and the advisory services provided by Gasaway Investment Advisors, Inc. (Gasaway or Acronym or “the Firm”, “we”, “us”, “ours”). We are a federally Registered Investment Adviser with the U.S. Securities and Exchange Commission (“SEC”). We were founded in 1990 and are owned and operated by Jim Gasaway. We provide investment advisory services to individuals, pension and profit-sharing plans, trusts, and estates. Our investment advisory services include investment management, financial planning, and Third-Party Administration / Recordkeeping services for qualified retirement plans. Investment Management We provide Investment Supervisory Services, defined as giving continuous advice to a client or making investments for a client based on the individual needs of the client. We generally manage advisory accounts on a discretionary basis, but we do allow for both non-discretionary accounts and for non-discretionary investments to be held in discretionary accounts. (An example of a non-discretionary investment held in a discretionary account would be an individual stock that the client has either asked us to purchase or has transferred into the account.) For individual clients, we generally invest in (but are not limited to) exchange traded funds “ETFs,” mutual funds, certificates of deposit, and individual US Treasuries. A mix of all of these investments is generally used in accounts over $50,000 in size while mutual funds are generally used for smaller accounts under $50,000. Our investment philosophy is to use investments that meet our screening criteria and invest for the long-term. We are independent of any fund, brokerage, or other investment company. Since we have no proprietary products to push or fund family minimums to meet, we can offer unbiased investment recommendations to meet your investment objectives. We screen the investments, looking for seasoned investment managers managing funds that meet our screening criteria. Then, we monitor the investments to make sure that they continue to perform well relative to their peers, replacing them when we believe it is necessary. We believe that active investment strategies, which change in response to market conditions, can provide for better long-term returns. Through this active investment strategy, we seek to reduce risk through diversification among different investment categories, but also by seeking to reduce the drag of weaker performers by selling them in a timely fashion. There are risks involved in this, as described later in Item 8. We manage most accounts through the use of assigning them to a target allocation and then managing the underlying investments and the overall asset allocations. Financial Planning We create financial plans for retirement plan participants, individual clients, and prospects. These projections are to help clients determine how much they need to save for retirement and how much they might be able to take in distributions throughout retirement. We can also calculate life insurance needs, education savings needs, etc. if requested by the client. Generally, we do not prepare any comprehensive financial plans (such as Estate Planning). Services for Retirement Plans- Third Party Administration We perform services for retirement plan trustees and sponsors which may include selection of a fund menu for participant directed plans, ongoing monitoring of plan investments, periodic trustee meetings, periodic employee meetings, and implementing Model portfolios in order to help participants

allocate and monitor the investments in their accounts. We monitor the allocations of the models on a quarterly basis during our regularly scheduled Investment Committee meetings and make changes as we deem appropriate. We may review the models and make changes at any time that the Investment Committee deems appropriate, which may be at times in addition to the quarterly reviews described above. At this time, we do not charge any additional fees (other than Investment Management Fees) for this service. In addition, we offer design, implementation, and administration of qualified retirement plans (*401(k)s, SIMPLEs, SEPs and Profit-Sharing Plans) tailored to the needs of the business. Tailored Relationships We tailor investment advisory services to the individual needs of the client. Our clients are allowed to impose restrictions on the investments in their account. All limitations and restrictions placed on accounts must be presented to us in writing. Wrap Fee Programs A “wrap-fee” program is one that provides the client with advisory and brokerage execution services for an all-inclusive fee. The client is not charged separate fees for the respective components of the total service. We do not sponsor, manage, or participate in a Wrap Fee Program. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Assets Under Management As of December 31, 2022, we managed $134,452,708 in client assets; $119,455,287 are managed on a discretionary basis and $14,997,421 on a non-discretionary basis.