A Our Firm. Gates Pass Advisors, LLC is a California limited liability company and independent registered investment advisory firm located in Los Altos, California. We were granted registration as an investment advisor with the SEC effective April 11, 2022. Previously, our firm had been registered as an investment advisor with the State of California since its founding in 2015. Our principal owner is K. Esther Szabo, CFP®. The information contained in this brochure describes our investment advisory services, practices, and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our services to the needs of our clients. As used throughout this brochure, the words “Gates Pass,” “firm,” “we,” “our,” and “us” refer to Gates Pass Advisors, LLC and its associated financial professionals, and the words “you,” “your,” and “client” refer to you as either a client or prospective client of our firm. Prior to forming an investment advisor-client relationship with you, we may offer a complimentary general consultation to discuss the nature of our service offerings and to determine the possibility of a potential advisory relationship. Investment advisory services begin only after the client and Gates Pass formalize their relationship by the execution of a written investment advisory agreement. B-C Our Services. Gates Pass offers broad-based, comprehensive financial planning and ongoing wealth management services to clients. Our investment advice is always tailored to the stated investment objectives and needs of our clients. A description of each of our service offerings is as follows: Financial Planning Services: Most clients relationships begin with the client engaging us for broad- based financial planning services before moving into on ongoing wealth management relationship where we implement our financial planning recommendations and monitor the client’s designated investment accounts on an ongoing basis. However, we also offer financial planning as a stand- alone service. When we are engaged for financial planning services we will provide you with advice covering some or all of the following financial topics, depending on your specific financial circumstances, needs, goals, and concerns: ➢ budgeting, and cash flow planning; ➢ goal funding; ➢ income tax planning; ➢ education planning; ➢ transition consulting/planning; ➢ disability planning and income protection ➢ debt management; ➢ estate planning; ➢ retirement planning; and ➢ investment planning/specific investment recommendations.
We will provide you with a series of periodic consultations, as agreed, to discuss your unique financial circumstances, investment objectives and needs, tolerance for risk, time horizon for investments, and/or any particular issues of financial concern. We will review pertinent financial documents and information provided by you and then provide you with our investment and financial recommendations in the form of a written financial plan. Our written financial plans typically include a summary of the client’s financial situation, our general observations regarding the same, and a series of recommendations for a course of activity to be undertaken by the client to achieve their financial objectives and goals. For example, recommendations may be made that the client begin or revise certain investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education savings or charitable giving programs. We will also recommend third-party providers to you who can assist with implementation of specific aspects of the written plan as necessary, including attorneys, certified public accountants, insurance professionals, and others. Unless you engage us for ongoing wealth management services following the completion and delivery of your written financial plan, we will not provide you with any subsequent review or updates of the financial plan and the engagement is considered concluded upon delivery. You always maintain the sole and absolute discretion to accept or reject any of our financial planning recommendations, in whole or in part, and shall be responsible for the selection of service providers for investment implementation and monitoring. While you are not obligated to do so, if you decide to engage us for ongoing wealth management services following the preparation and delivery of your written financial plan, we will implement our investment recommendations in your designated investment accounts and monitor such investments on an ongoing basis. Where you elect to engage us for these combined services, we may elect to reduce or offset all or a portion of the agreed upon financial planning fees against the advisory fees charged for ongoing wealth management services. Please see the description of our wealth management services below. Wealth Management

Services: When you engage us for these services, we will provide ongoing management and monitoring of your designated investment account(s) in accordance with your unique financial circumstances, goals, and needs, and your written financial plan. You will deposit your assets to an account (or accounts) held in your name at an independent qualified custodian (“Custodian”) and be required to execute a limited power of attorney granting our firm the authority to direct the execution investment transactions within your account. Typically, you will be required to grant us discretionary authority to directly implement investments within your account(s) without having to obtain your prior approval of each specific transaction. In limited circumstances, we may agree to a non-discretionary arrangement, under which we will recommend investments to you and only implement them within your account(s) after receiving your approval. You may impose reasonable restrictions on our management of your account(s), including instructing us not to purchase certain specific securities, industry sectors, and/or asset classes. Please see Item 16 of this brochure for more information on our investment discretion policy. We will consult with you at the inception of our relationship and thereafter, as necessary, to gain a thorough understanding of your financial circumstances, investment objectives and limitations, tolerance for investment risk, and time horizon for investments. Based on this information, we will implement the desired portfolio of investments within your account(s), monitor your investments on an ongoing basis, and adjust your holdings as needed or appropriate, acting as your trusted fiduciary. Client portfolios are typically constructed using a diversified mix of some or all of the following investments: individual stocks, corporate and government issued bonds, mutual funds, exchange traded funds (“ETFs”), cash and cash equivalents. As part of these services, we may also recommend the use of certain third-party money managers (“Independent Managers”) to manage all or a portion of your account(s). The Independent Managers we select to assist in the management of your account may require you to execute a separate written trading authorization, advisory agreement, platform agreement, and/or other account opening documentation. You will be provided with the Form ADV Part 2A (or equivalent disclosures) for any recommended Independent Manager(s) at or prior to the time they begin to manage your account. We will monitor the performance of your assets managed by Independent Managers on an ongoing basis, reallocate assets among Independent Managers, and engage or terminate Independent Manager relationships as necessary, and in your best interests. We will also be responsible as your primary fiduciary advisor to ensure that the investment programs and performance of the selected Independent Managers remains suitable and well aligned with your investment goals and needs. At your specific request or as outlined in your written financial plan, we may also provide you with advice and recommendations with respect to the investment of certain “held-away” investment accounts (e.g., employer sponsored retirement accounts, qualified tuition plans, variable annuity sub-accounts). For these accounts, we are 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. You will make all final investment decisions and be responsible for the implementation and monitoring of all investments contained in your held-away accounts. If a written financial plan has not been provided already, wealth management clients may elect to have Gates Pass provide a customized wealth management plan – additional fees may apply. When you engage us for these additional services, we will provide you with a suite of financial planning advice, including, without limitation, recommendations regarding cash flow and budgeting, review of insurance and employee benefits, financial goal setting services, advice and planning regarding specific life events (career decisions, purchase of a new home, college funding, and retirement), estate plan review, and a review of potential tax minimization strategies, as applicable. As part of our rendering of ongoing wealth management services, we will update you written financial plan periodically, as agreed with the client. While we do not provide legal, tax, or insurance related services of any kind, we advise clients to discuss such matters with their independent trusted, legal, tax, and insurance professionals. Where possible, we will attempt to coordinate our services with these outside providers. D Wrap Fee Programs. Gates Pass does not participate in or sponsor any wrap fee programs. E Assets Under Management. As of December 31, 2023, we managed approximately $149,294,838 of client assets on a discretionary basis and $1,990,269 of client assets on a non-discretionary basis.