Item 5 – Additional Compensation ........................................................................................................... 29
Item 6 – Supervision ................................................................................................................................. 29
Appendix: Summary of Material Changes (One-Page Format) ................................................................................ 33
Summary of Material Changes (since December 2022) ..................................................................... 33
Gould Asset Management LLC (“Gould”) was founded in 1999 and is majority-owned by Donald P.
Gould. The other owners are Paul M. Goldensohn (consultant) and senior portfolio managers
Thomas K. Carr Jr., CFP®, John J. DeBiase III, CFA, and Scott B. Smith, CFA.
Gould provides investment management services, primarily through individually managed
accounts for individuals and institutions. Gould does not hold itself out as a provider of financial
planning services. To the extent specifically requested by a client, Gould provides limited
consultation services to its investment management clients on investment and non-investment
related matters that are generally ancillary to the investment management process, for example,
preparing retirement income projections. Any such consultation services are rendered exclusively
on an unsolicited basis.
Gould’s general investment philosophy is to seek good risk-adjusted return while maintaining a
long-term perspective. Most Gould investment strategies offer a broadly diversified portfolio of
securities, with periodic adjustments consistent with a disciplined investment process. Gould does
not generally engage in market timing. Careful attention is paid to managing the costs of
investing, both explicit (for example, trading commissions and mutual fund expense ratios) and
implicit (for example, tax implications and liquidity constraints). Gould offers a broad suite of
strategies, suitable for investors ranging from conservative to growth oriented.
In recommending one or more investment strategies to a client, Gould considers client objectives,
risk tolerance, tax and/or legal situation, and other individual factors. While Gould offers
customized and personal investment management, accounts managed according to similar
strategies may be similar in composition. Gould seeks to treat all clients fairly over time with
Gould Asset Management LLC 5 Dated March 31, 2023
respect to investment allocations, but not all accounts in a particular strategy will purchase or sell
the same securities at the same times. This may be due to differences in client risk tolerances,
objectives, cash balances, account tax status, or other reasons. Clients may impose reasonable
restrictions on the way any account is managed.
Gould’s management agreement with the client generally provides Gould with authority to act on
a discretionary basis with client assets, with exceptions noted below. Client assets are held in a
third-party custodial account (typically with a brokerage firm), registered in the name of the client.
Gould may enter into sub-advisory agreements with unaffiliated investment advisors whereby (i)
Gould, as sub-advisor, provides discretionary investment management services to clients of such
advisors for a fee, or, (ii) Gould retains and pays a sub-advisor to manage all or a portion of a
client’s assets under Gould’s management.
Gould may also enter into agreements with unaffiliated investment advisors whereby such
advisors provide discretionary investment management services to Gould clients, acting in the
capacity of a sub-advisor. In such instances, Gould will pay the sub-advisor’s fee out of its own
resources.
Gould may use a third-party platform to facilitate its management of certain defined contribution
plan assets such as client 401(k) and 403(b) accounts that are not held on the custodial platforms
generally used by Gould clients. Platform procedures are designed such that Gould does not have
custody of client assets managed through the platform. Gould is not affiliated with the platform
provider and receives no compensation from the platform provider. Any fees charged by the
platform provider are paid by Gould out of its own resources. Client management fees with
respect to assets managed through the platform are generally paid from client accounts other
than those
managed through the platform.
In selected circumstances, Gould may make available to certain clients opportunities to invest
directly in real estate through investment in special purpose limited liability companies (“RE
LLCs”). RE LLCs are managed by one or more third-party companies that specialize in such
investments. Clients generally must be “accredited investors” (as defined in Regulation D under
the Securities Act of 1933) and “qualified clients” (as defined under Rule 205-3 of the Investment
Advisers Act of 1940) and meet other requirements, as determined by Gould in its discretion,
taking into account such factors as the client’s net worth, investment objectives, risk tolerance,
and liquidity needs, among others. Investments in RE LLCs generally are made by clients on a non-
discretionary basis. Gould may charge clients an advisory fee consisting of a fixed percentage of
the estimated market value of the client’s investment and/or a performance fee based on the
client’s realized investment return in relation to a specified preferred return. RE LLCs are non-
publicly traded, illiquid securities, and therefore, investors in RE LLCs may not have access to their
capital from the time of their initial investment until the underlying property is sold and the RE LLC
is dissolved, typically a period of several years and potentially exceeding ten years. Client
ownership of the RE LLC interest is evidenced by documentation provided by the manager of the
RE LLC.
In selected circumstances, Gould may make available to certain clients opportunities to invest in
private equity through investment in private commingled funds (“PE Funds”). PE Funds are
Gould Asset Management LLC 6 Dated March 31, 2023
managed by one or more third-party companies that specialize in private equity investments. PE
Funds typically are “funds-of-funds;” that is, a single PE Fund typically invests in one or more other
private funds, each managed by a manager independent of the PE Fund manager and each making
multiple private equity investments over time. The fund-of-funds structure may provide its
investors greater diversification of private equity investments and may also provide access to
private equity managers (and the funds they manage) that would not otherwise be available. The
PE Funds’ fund-of-funds structure generally entails higher overall management fees to its investors
than would direct investments in the PE Funds’ underlying funds, given the additional layer of
management.
Clients who invest in PE Funds generally must be “qualified purchasers” (as defined in Section
2(a)(51) of the Investment Company Act of 1940) and meet other requirements, as determined by
Gould in its discretion, taking into account such factors as the client’s net worth, investment
objectives, risk tolerance, and liquidity needs, among others. Investments in PE Funds generally
are made by clients on a non-discretionary basis. Gould may charge clients an advisory fee
consisting of a fixed percentage of the estimated market value of the client’s investment. PE
Funds are non-publicly traded, illiquid securities, and therefore, investors in PE Funds may not
have access to their capital from the time of their initial investment until such time as the PE Funds
make cash distributions and/or wind up, a period of at least several years, sometimes exceeding
ten years. Client ownership of the PE Fund interest is evidenced by documentation provided by the
manager of the PE Fund.
Gould does not sponsor or participate in any wrap fee programs.
In addition, when Gould provides 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.
Gould’s discretionary client assets under management as of December 31, 2022 totaled $627.7
million. Non-discretionary assets under management on the same date were $73.4 million.
Gould Asset Management LLC 7 Dated March 31, 2023