Gemini Wealth

Gemini Wealth works primarily with plan sponsors and clients seeking financial planning and education, providing limited-scope ERISA 3(21) fiduciary services, standalone financial plans, and public seminars or workshops. Rather than exercising discretionary portfolio management itself, the firm introduces clients to a third‑party manager (Matson Money) to implement and trade model portfolios and does not maintain direct asset management over client accounts.

The firm’s recommendations draw on academic frameworks such as Modern Portfolio Theory and the Efficient Market Hypothesis and focus on selecting and monitoring third‑party model portfolios to ensure alignment with clients’ objectives; it documents client goals, conducts at least annual interviews, and performs periodic reviews of plan and manager performance. Gemini Wealth also provides education and non‑fiduciary participant support for retirement plans and prepares written financial plans on a fixed‑fee basis when requested.

Notable distinctions in the brochure include the firm’s co‑advisor relationship with Matson Money — including receiving co‑advisor fees remitted by that manager — and the firm’s use of performance materials, including past and hypothetical results, in its outreach and educational materials, which the brochure discloses alongside standard performance disclaimers. The brochure also discloses an outside business activity for one principal (event production) that consumes under 20% of their time, and it highlights that the firm does not manage individual portfolios directly, a model that differs from many peers.