GAM24, LLC dba Gulfstream Asset Management (“Gulfstream” and/or the “firm”) is a limited liability company formed in the State of Florida. Ramon Emilio Pielago is the principal owner of Gulfstream. Gulfstream has been offering investment advisory services since 2024. The following paragraphs describe our services and fees. You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to anyone from our firm who is an officer, employee, and all individuals providing investment advice on behalf of our firm. Where required, such persons are properly licensed or registered as investment adviser representatives. Financial Planning Services Gulfstream offers various financial planning related services, which assist clients in the management of their financial resources. Financial planning services are based upon an analysis of the client’s individual needs beginning with one or more information gathering consultations. Once the firm has collected and analysed all documentation gathered during these consultations, Gulfstream provides a written financial plan designed to achieve the client’s financial goals and objectives. Gulfstream then assists clients in developing a strategy for the successful management of income, assets, and liabilities. In general, financial planning services may include any one or all of the following:
• Cash Flow Analysis – Assessment of present financial situation by collecting information regarding net worth and cash flow statements, tax returns, insurance policies, investment portfolios, pension plans, employee benefit statements, etc. The firm advises on ways to reduce risk; and, to coordinate and organize records and estate information.
• Retirement Analysis – Identification of long-term financial and personal goals and objectives including advice for accumulating wealth for retirement income or appropriate distribution of assets following retirement. Tax consequences and implications are identified and evaluated.
• Insurance Analysis – Includes risk management associated with advisory recommendations based on a combination of insurance types to meet your needs, e.g., life, health, disability, and long-term care insurance. This will necessitate an analysis of cash needs of the client’s family at death, income needs of surviving dependents, and potential disability income needs.
• Portfolio Analysis/Investment Planning – Presentation of investment alternatives, including asset allocation and its effect on the client’s portfolio; evaluation of economic and tax characteristics of existing investments as well as their suitability for the client; and, identification and evaluation of tax consequences and their implications.
• Estate Analysis – Advising clients with respect to property ownership, distribution strategies, estate tax reduction, and tax payment techniques. The recommendations and solutions are designed to achieve the client’s desired goals, subject to periodic evaluation of the financial plan, which may require revision to meet changing circumstances. Financial plans are based on your financial situation based on the information provided to the firm. We should be notified promptly of any change to your financial situation, goals, objectives, or needs. Important Note: Information related to tax and legal consequences that is provided as part of the financial plan is for informative purposes only. Clients are instructed to contact their tax or legal advisers for personalized advice. Portfolio Management Services Gulfstream provides discretionary, and in limited cases, non-discretionary portfolio management services. Discretionary portfolio management means we will make investment decisions and place buy or sell orders in your account without contacting you. These decisions would be made based upon your stated investment objectives. If you wish, you may limit our discretionary authority by, for example, setting a limit on the type of securities that can be purchased for your account. Simply provide us with your restrictions or guidelines in writing. If you have engaged us for non-discretionary portfolio management services, Gulfstream will obtain your approval prior to executing any transactions in your account(s). Our investment advice is tailored to meet our clients’ needs and investment objectives. If you decide to hire our firm to manage your portfolio, we will meet with you to gather your financial information, determine your goals, and help you decide how much risk you should take in your investments.

The information we gather will help us implement an asset allocation strategy that will be specific to your goals, whether we are actively investing for you or simply providing you with advice. We should be notified promptly of any change to your situation, goals, objectives, or needs. Gulfstream does not specialize in specific types of securities. We can advise clients on all types of securities, such as exchange listed equities, over the counter equities, foreign issues, American depository receipts, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (including mutual funds and exchange traded funds), US Government securities, options contracts on securities and/or commodities, structured products, private placements, private equity instruments, and interests in partnership investing in real estate. Additionally, will provide advice on existing investments you may hold at the inception of the advisory relationship or on other types of investments for which you ask advice. We will monitor your portfolio’s performance on a continuous basis, and rebalance the portfolio whenever necessary, as changes occur in market conditions and/or your financial circumstances. Our asset allocation models are diversified among investment styles and/or asset classes and are developed and managed by us based on research conducted by our firm or obtained from third party sources. Once the client portfolio is constructed, Gulfstream provides continuous supervision of the portfolio as changes in the market conditions and client circumstances may require. Investments and allocations are determined based upon the clients’ predefined objectives, risk tolerance, time horizons, financial horizons, financial information, and other various suitability factors. Further restrictions and guidelines imposed by clients may affect the composition and performance of a client’s portfolio. As such, different clients of our firm may have significant differences in their asset allocation. For these reasons, performance of one client’s portfolio might not be identical with another client’s even if both clients have similar risk parameters. We review the clients’ financial circumstances and investment objectives on a regular basis and make adjustments to clients’ portfolios or allocation models as may be necessary in an effort to achieve the desired results. At all times, our firm requires each Associated Person to uphold their fiduciary duty by providing advice that in our judgement is in the client’s best interest. In addition, where requested by you, we will also provide you with recommendations regarding the investment of certain “held-away” assets (e.g., investments held in employer sponsored retirement accounts, qualified tuition plans, or variable annuity sub-accounts). For these accounts, we will typically be limited to advising you as to the allocation of your holdings among the various investment options made available by the product sponsor, issuer, or custodian. Such accounts will be subject to our customary billing rates listed in Item 5 below. However, you will make all final investment decisions and you will be responsible for the implementation and monitoring of all assets contained in your held-away accounts. Recommendation of sub-adviser As part of our overall portfolio management strategy, we may use one or more sub-advisers to manage all or a portion of your portfolio. All sub-adviser recommended by our firm must either be registered as investment advisors or exempt from registration requirements. These sub-advisers may specialize in traditional or alternative investments, such as private equity investments, private credit markets, or hedge funds. Factors that we take into consideration when making our recommendations include, but are not limited to, the following: the Independent Manager’s performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will periodically monitor the Independent Manager’s performance to ensure its management and investment style remains aligned with your investment goals and objectives. We retain the right to hire and fire sub-adviser and the right to reallocate client assets to other model portfolios at the same sub- adviser. Wrap Fee Programs We do not sponsor, manage, or participate in any wrap fee programs. Assets Under Management Since we are a newly formed investment adviser, we do not have any discretionary or non-discretionary assets under management.