A. Introduction
Gobe Wealth Management, LLC (“Gobe” or the “Firm”), a Delaware limited liability company, is
registered as an investment adviser with the SEC with its principal place of business in New York, NY.
Gobe is a wholly-owned subsidiary of Krane Fund Advisors, LLC (“KFA”), which is also registered as an
investment adviser with the SEC (CRD # 157103).
Gobe was founded in 2017 under the name Krane Portfolio Advisors LLC and subsequently operated
under the name CICC Wealth Management (USA), LLC.
B. Advisory Services Offered by Gobe
Gobe offers an array of investment advisory services ranging from financial planning to portfolio
management services. Gobe’s primary business is to manage assets for institutional clients, high net
worth clients and retail investors by providing discretionary asset allocation services through
separately managed accounts. Such services may include providing discretionary advisory service to
individual retirement accounts (IRAs). Gobe may also from time to time provide non-discretionary
services to clients.
Prior to Gobe rendering any of the foregoing services, Gobe will enter into one or more written
agreements with a prospective client setting forth the relevant terms and conditions of the
advisory relationship (each an “Investment Management Agreement”). Each investment company,
institutional client, high net worth client or retail client that enters into an Investment Management
Agreement is referred to herein as a “Client”). In connection with entering into an Investment
Management Agreement, Gobe and each Client will establish investment guidelines and
restrictions to be adhered to in managing the Client’s portfolio.
C. Assets Under Management
As of December 31, 2023, Gobe managed $243,447 in client assets on a discretionary basis and
managed $0 on a non-discretionary basis.
Investment Management Services
Gobe primarily manages Client investment portfolios on a discretionary basis, but, depending on
client circumstances, such investment management can also be on a non-discretionary basis. Gobe
primarily allocates Client assets among ETFs and mutual funds. In addition, certain Client accounts
may invest either directly or through the use of Model Portfolios (as defined below), among (i) equity
securities, (ii) open-end or closed-end investment companies (including exchange traded funds,
“ETFs”) or other collective investment funds, registered or non-registered, affiliated or unaffiliated,
(iii) fixed income securities (and other debt instruments), (iv) restricted or privately placed securities,
and/or (v) foreign currency transactions, in accordance with the Client’s stated investment
objectives. Where appropriate, and as agreed in the applicable Investment Management Agreement,
Gobe may provide advice with respect to the management of legacy positions or other investments
that were held in Client portfolios prior to entering into the Investment Management Agreement.
In order to enable Gobe to provide Clients with an investment program that is consistent with their
individual investment objectives, risk tolerance, and financial parameters, at the outset of a Client
relationship, the Client is required to complete a Risk Tolerance Questionnaire (“RTQ”) or similar
document containing questions about the Client including age, financial resources, investment goals,
investment objectives, time horizon and risk tolerance. Clients may also indicate any special instructions
or constraints for their assets in the RTQ. Based on its analysis of the information provided by the Client
via the RTQ, Gobe will provide the Client with a recommended portfolio of investments based on
Gobe’s established model investment portfolios (each a “Model Portfolio”). In recommending a Model
Portfolio, Gobe will rely on the information provided in the RTQ and such other information it may have
about the Client; however, Gobe is under no obligation to capture any additional information not
covered in the RTQ in providing its investment advice.
Once Gobe recommends a Model Portfolio, the Client will be provided an opportunity to review and
discuss the recommendation with Gobe. Upon being presented with a recommended Model Portfolio,
the Client may: (i) approve and authorize Gobe to implement the Model Portfolio; (ii) request that Gobe
modify the recommendation to address any specific modifications or restrictions identified by the
Client; or (iii) reject the Model Portfolio. Clients are not required to implement the recommended model
investment portfolio. If so desired, Client may place investment restrictions on the management of their
Account(s), including with respect to specific mutual funds, ETFs, or other securities that can be
purchased for the Account(s), or modify existing investment restrictions, so long as Gobe deems such
investment restrictions reasonable. Client is required to provide any proposed investment restrictions
and/or modifications to Gobe in writing. Gobe will not accept any restrictions that it deems to be
unreasonable, including any that are overly burdensome to implement or that it deems to be
inconsistent with the Model Portfolio’s stated investment strategy or philosophy. Clients who choose to
implement a restriction on their Model Portfolio may experience performance that is different from
other Clients relying on the same Model Portfolio without (or with different) restrictions.
Based on monitoring a Client’s investments, risk/return forecasts for various asset classes and other
information it deems appropriate, Gobe may implement a change in a Client’s asset allocation, including
a change to allocations of a Model Portfolio. The specific percentages allocated to each asset class
through a Model Portfolio
may vary due to the nature of asset performance and/or the investment
strategy selected. It is Gobe’s intent to maintain a risk exposure for each Client’s portfolio that
is consistent with the Client’s investment objectives, risk tolerance, and financial parameters by using
various portfolio construction tools, including the Model Portfolios available under the strategy selected
by that Client.
The advisory services provided by Gobe may vary as each solution is tailored to meet the needs of each
individual Client. Gobe monitors Client portfolios to confirm that they are managed in a manner
consistent with the investment objectives, risk tolerance, and financial parameters of each Client,
including any applicable Model Portfolio. Gobe relationship managers (each a
“Relationship Manager”) consult with Clients on an initial and periodic basis to assess any change to the
information gathered in the RTQ, including any change in the Client’s investment objectives, risk
tolerance, and financial parameters relevant to the management of the Client’s portfolio. Clients are
advised to promptly notify Gobe if there are changes in their investment objectives, risk
tolerance, and financial parameters or if they wish to place any limitations on the management of their
portfolios.
From time to time, in addition to or in lieu of a Model Portfolio, and consistent with the applicable
Investment Management Agreement, Gobe may recommend that a Client maintain a designated
percentage of its portfolio in alternative assets outside of a Model Portfolio. In the event that a Client
agrees to such allocation, Gobe will manage such alternative investments.
Additionally, consistent with the applicable Investment Management Agreement, certain Clients may
choose to have a self-directed portion of their portfolio. In such cases, Gobe may provide advice on a
non-discretionary basis only, and execute transactions through intermediaries at the direction of the
Client.
Model Portfolios
As part of its investment advisory services, Gobe will from time to time recommend Model Portfolios
either developed and maintained by Gobe or made available by Gobe through arrangements with third-
party service providers.
Each Model Portfolio is an asset allocation model whose underlying allocations generally consist of
individual ETFs, mutual funds, equity securities, fixed income securities and/or other investment
products, including ETFs sponsored, advised or managed by one or more affiliates of Gobe
(“Affiliated ETFs”). Each Model Portfolio is built with a specific investment strategy and each is designed
consistent with a specific risk tolerance level. For example, certain investment strategies are intended
for investors who are seeking income generation, while others focus on market growth or the
incorporation of alternative investments into their portfolio. Each Model Portfolio is designed to achieve
specific investment strategies generally through allocations to ETFs, including Affiliated ETFs, in
accordance with the target allocations established for the Model Portfolio. The Model Portfolios will not
be limited to allocations to Affiliated ETFs; however, a Model Portfolio may be allocated up to 100% to
Affiliated ETFs.
Gobe or the applicable third-party provider may, from time to time, make updates to the allocations
among asset classes included in a Model Portfolio. In the event of such an update to a Model Portfolio,
Gobe will evaluate whether the Model Portfolio continues to be appropriate for each applicable Client
in light of their individual investment objectives, risk tolerance and financial parameters.
The Model Portfolios available as of the date of this brochure in Item 8.
Use of Third-Party Investment Managers
Gobe Relationship Managers are typically authorized to select and retain one or more third- party
investment managers and/or investment management programs (collectively referred to as
“Independent Managers”) to provide active discretionary asset management for all or part of a Client’s
portfolio. The Model Portfolio offerings provide access to third-party investment managers and third-
party funds. Gobe will only delegate management of all or a portion of the Client’s portfolio to an
Independent Manager when it determines such a delegation to be consistent with the Client’s
investment objectives, risk tolerance, and financial parameters. Such delegations may be made to
Independent Managers through established separately managed account programs maintained by the
Independent Manager or otherwise.
Once an Independent Manager has been selected and retained on behalf of the Client, Gobe shall have
no authority to place orders for the purchase or sale of any securities or other assets under the
discretion of such Independent Manager, or to select the broker-dealers or other counterparties with
which such transactions may be effected. Client acknowledges that the Independent Manager has such
authority and that Adviser will have no responsibility or obligation in that regard.
When delegating investment management discretion to an Independent Manager, the Adviser or Client
will enter into a separate agreement with the Independent Manager, which sets forth the terms and
conditions of the arrangement. Clients may incur additional fees for services provided by Independent
Managers.
Ancillary Services
Gobe may also provide additional ancillary services to Clients. These ancillary services may include Art
and Lifestyle Salons, US Real Estate Market Access, US Education Counseling, Elite Network
Development Opportunities, Tax and Accounting Expertise, Financial Planning and Investment Education
Seminars, Estate and Trust Planning, and Insurance services.