Overview
Garrison Point Capital, LLC ("Registrant", "GPC", or the "Firm") is operated by Garrett J. Smith,
Principal, Chief Executive Officer ("CEO"), Portfolio Manager; and Julie T. Meissner, Chief Compliance
Officer ("CCO"). As of July 1, 2018, Registrant is owned by Garrison Point Holdings, LP ("GPH"). GPH
is principally owned by Messr. Smith. As of December 31, 2023, Registrant's advisory assets under
management were approximately $485,189,913 in discretionary managed assets and $0 in non-
discretionary managed assets. Registrant had approximately 36 discretionary clients and 0 non-
discretionary clients. Registrant was formed and registered under the Investment Advisers Act of 1940
("Advisers Act") in 2012.
The Registrant primarily provides investment advice regarding fixed income securities with a specialty
towards non-agency residential mortgage-backed securities (RMBS). See Item 8 for more information.
Registrant provides investment advice and management to individually managed accounts that is
tailored to the needs of individual clients, mostly on a discretionary basis. For discretionary clients,
Registrant has complete discretion over the selection and amount of securities to be bought or sold
without obtaining specific client consent. Clients may impose restrictions on their investments upon
request. These restrictions may include prohibitions or limits on individual securities, security types,
asset classes, allocation, liquidity, credit quality and income. For non-discretionary accounts,
Registrant generally does not have discretion to buy or sell securities without specific client consent.
The firm also serves as sub-advisor to a registered investment company. The firm's management of
fund assets is governed by the investment objective of the fund, including certain restrictions and
limitations imposed on the management of the fund's assets by its board of directors. Such strategies
and/or restrictions are described in the prospectus of each investment company. GPC does not
provide tailored investment advisory services to the individual investors in an investment company.
GPC may recommend investments in the registered
investment company for which it provides sub-
advisor services. This presents a conflict of interest as GPC receives compensation from
the registered investment company. To mitigate this conflict of interest GPC does not charge additional
investment management fees, other than the fees received from the investment company, when
recommending clients invest in the investment management company.
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 you. 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.
4
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.