GatePass, an Ohio limited liability company, founded in 2023, is principally located in
Independence, OH.
GatePass is wholly owned by GatePass Capital Holdings, LLC (“Holdings”) which is wholly owned
by Matthew Jenkins.
GatePass offers a variety of advisory services, which include financial planning, consulting, and
investment management services. Prior to GatePass rendering any of the foregoing advisory services,
clients are required to enter into one or more written agreements with GatePass setting forth the relevant
terms and conditions of the advisory relationship (the "Advisory Agreement").
GatePass does not participate in any wrap fee programs.
This Brochure has been prepared and submitted in connection with GatePass’ 120-day
provisional registration with the SEC. GatePass expects to have discretionary assets under management
in excess of $100,000,000 within 120 days of the SEC approving GatePass’ registration, and will amend
its Form ADV accordingly.
Investment and Wealth Management Services
GatePass expects to manage client investment portfolios on a discretionary basis. In addition,
GatePass will provide certain clients with wealth management services which include a broad range
of financial planning and consulting services.
GatePass primarily allocates client assets among various publicly-traded equity and fixed income
securities, exchange-traded funds and notes ("ETFs/ETNs"), mutual funds, and independent investment
managers through separately managed accounts or subadvisory relationships ("Independent
Managers") in accordance with their stated investment objectives.
GatePass tailors its advisory services to meet the needs of its individual clients and seeks to
ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those
needs and objectives. GatePass will consult with clients on an initial and ongoing basis to assess their
specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the
management of their portfolios. Clients are advised to promptly notify GatePass if there are changes in
their financial situation or if they wish to place any limitations on the management of their portfolios.
Clients can impose reasonable restrictions or mandates on the management of their accounts if
GatePass determines, in its sole discretion, the conditions would not materially impact the
performance of a management strategy or prove overly burdensome to the Firm's management
efforts.
Where appropriate, the Firm may also provide advice about any type of legacy position or other
investment held in client portfolios, but clients should not assume that these assets are being
continuously monitored or otherwise advised on by the Firm. Clients can engage GatePass to manage
and/or advise on certain investment products that are not maintained at their primary custodian, such
as variable life insurance and annuity contracts and assets
held in employer sponsored retirement plans
and qualified tuition plans (i.e., 529 plans). In these situations, GatePass would direct or recommend the
allocation of client assets among the various investment options available with the product. These
assets are generally maintained at the underwriting insurance company or the custodian designated by
the product's provider and clients may be responsible to implement the recommendations depending
on the authority the Firm is given by the product's provider.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited
Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following
acknowledgment to our clients and prospective clients.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule's provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
We benefit financially from the rollover of
your assets from a retirement account to an account that we manage or provide investment advice,
because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary,
we only recommend a rollover when we believe it is in your best interest.
Other Services
GatePass expects to offer its clients a broad range of financial planning and consulting services,
which include any or all of the following functions:
• Business Planning
• Cash Flow Forecasting
• Trust and Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Risk Management
• Charitable Giving
• Distribution Planning
• Tax Planning
• Education Planning
While each of these services is available on a stand-alone basis, certain of them can also be
rendered in conjunction with investment portfolio management as part of a comprehensive wealth
management engagement.