Overview
- Headquarters
- Rosemont, IL
- Total Firm Assets
- $266 million
- Average High-Net-Worth Client Portfolio Size
- $0.5 million
- Stated Minimum Account Size
- $1,000,000
Fee Disclosure
BRENTVIEW INVESTMENT MANAGEMENT ADV PART 2 BROCHURE
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | $25,000,000 | 0.50% |
| $25,000,001 | $50,000,000 | 0.45% |
| $50,000,001 | $100,000,000 | 0.40% |
| $100,000,001 | $250,000,000 | 0.35% |
| $250,000,001 | and above | Negotiable |
Estimated Annual Fees (Based on ADV disclosures. Where a range is given, we use the upper rate)
| Portfolio Value | Estimated Annual Fee | Effective Fee Rate |
|---|---|---|
| $1 million | $5,000 | 0.50% |
| $5 million | $25,000 | 0.50% |
| $10 million | $50,000 | 0.50% |
| $50 million | $237,500 | 0.48% |
| $100 million | $437,500 | 0.44% |
Clients
- High-Net-Worth Share of Firm Assets
- 41.14%
- Number of High-Net-Worth Clients
- 211
- Total Client Accounts
- 315
- Discretionary Accounts
- 315
Services Offered
Services: Portfolio Management for Individuals, Portfolio Management for Institutional Clients
Regulatory Filings
- SEC CRD Number
- 300409
Primary Brochure: BRENTVIEW INVESTMENT MANAGEMENT ADV PART 2 BROCHURE (2026-09-23)
View Document Text
6400 Shafer Ct, Suite 360
Rosemont, IL 60018
www.brentviewim.com
Telephone: 312-283-4450
September 15, 2026
FORM ADV PART 2A
BROCHURE
This brochure provides information about the qualifications and business practices of Brentview
Investment Management, LLC.(“Brentview”, “us”, “we”, “our”). If clients (‘you”, “your”, “client”) have any
questions about the contents of this brochure, contact us at 312-283-4450. The information in this
brochure has not been approved or verified by the United States Securities and Exchange Commission
or by any state securities authority.
Additional information about Brentview Investment Management, LLC is available on the SEC's
website at www.adviserinfo.sec.gov. The searchable CRD number for Brentview Investment
Management, LLC is: 300409.
Brentview Investment Management, LLC is a registered investment adviser. Registration with the
United States Securities and Exchange Commission or any state securities authority does not imply a
certain level of skill or training.
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Item 2 Summary of Material Changes
The cover was updated to reflect the change in the firm’s main office address. Item 4 has been
updated for Assets Under Management and Uniform Managed Accounts assets and to remove
SMArtX Advisory Solutions, LLC from the list of TAMP Programs.
Item 3 Table of Contents
Item 2 Summary of Material Changes .......................................................................................... 2
Item 3 Table of Contents .............................................................................................................. 2
Item 4 Advisory Business ............................................................................................................. 3
Item 5 Fees and Compensation ................................................................................................... 6
Item 6 Performance-Based Fees and Side-By-Side Management ............................................... 7
Item 7 Types of Clients ................................................................................................................ 7
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ........................................... 8
Item 9 Disciplinary Information ................................................................................................... 11
Item 10 Other Financial Industry Activities and Affiliations ......................................................... 11
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ... 12
Item 12 Brokerage Practices ...................................................................................................... 13
Item 13 Review of Accounts ....................................................................................................... 14
Item 14 Client Referrals and Other Compensation ..................................................................... 14
Item 15 Custody ......................................................................................................................... 14
Item 16 Investment Discretion .................................................................................................... 15
Item 17 Voting Client Securities ................................................................................................. 15
Item 18 Financial Information ..................................................................................................... 15
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Item 4 Advisory Business
Description of Firm
Brentview Investment Management, LLC is registered as an Investment Adviser with the United States
Securities and Exchange Commission to provide investment advisory services described within this
document. We are organized as a limited liability company under the laws of the State of Illinois.
Brentview is employee owned by James R. Boothe (Bluestone Enterprises LLC), John A. Gomez
(Timberline Road, LLC), and Hai H. Vu. Brentview Investment Management, LLC is a Minority
Business Enterprise (MBE) certified with the National Minority Supplier Development Council
(NMSDC). Certifications are renewed annually.
The following paragraphs describe our services and fees. Refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual
needs.
Portfolio Management Services
We are a bottom-up fundamentally focused equity investment manager that provides separate account
investment advisory services utilizing a Dividend Growth philosophy. We offer three strategies:
Dividend Growth (US oriented), Select Dividend Growth (concentrated global dividend growth) and
International Dividend Growth focused solely on developed market dividend growth companies
domiciled outside the United States. We offer discretionary portfolio management services and our
investment advice is tailored to meet our clients' needs and investment objectives. Clients may impose
reasonable account restrictions and guidelines, which are subject to review. You may limit our
discretionary authority (for example, limiting the types of securities that can be purchased or sold for
your account) by providing our firm with your restrictions and guidelines in writing.
Our investment team consistently evaluates our strategy based on preferred weights, sector exposure,
and other guidelines. Investment guidelines that differ significantly from our preferred guidelines may
result in exclusions or variances in holdings from our standard portfolio which may take additional time
for the team to determine alternative holdings or weights for more restricted accounts. In such cases,
this may prevent a client from experiencing the same results as otherwise unrestricted portfolios that
are managed by our firm.
If you participate in our discretionary portfolio management services, we require you to grant our firm
discretionary authority to manage your account. Discretionary authorization will allow us to determine
the specific securities, and the amount of securities, to be purchased or sold for your account without
your approval prior to each transaction. Discretionary authority is typically granted by the investment
advisory agreement you sign with our firm and the appropriate trading authorization forms.
As part of our portfolio management services, in addition to other types of investments (see
disclosures below in this section), we may invest your assets according to our Dividend Growth
strategy.
In periods of market volatility, Brentview may be unable to invest new money contributed to an
account, or proceeds from the sale of securities, as quickly as it might have been able to do under
normal market conditions. Similarly, Brentview may be unable to sell securities to raise cash, or to
accommodate a terminating client’s request to sell securities, as quickly, or at favorable prices, as it
might have been able to do under normal market conditions. In such periods of market volatility, we
might deviate from our normal trading practices with respect to sequencing and allocation of
transactions. Market volatility may also cause Brentview to deviate from applicable account guidelines.
In such circumstances, we will use reasonable efforts to manage the account in a prudent manner
under the circumstances.
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Sub-Advisory Services to Registered Investment Advisers
We offer sub-advisory services to third-party money managers (the "Primary Investment Adviser"). As
part of these services, we will provide access to our dividend growth strategy, which the Primary
Investment Adviser implements for their clients. We will manage each client's account on the basis of
the client's financial situation and investment objectives provided by the Primary Investment Adviser,
and in accordance with any reasonable restrictions imposed by the client on the management of the
account.
Wrap Fee Programs
Brentview offers their strategies within wrap fee programs through other Registered Investment
Advisors. Brentview does not make direct recommendations to the investors within the wrap fee
programs. Each program offers a variety of managed investment strategies. Clients pay an asset-
based fee that covers investment management, execution and custody services. Before
recommending an appropriate program and investment strategy, the Investment Advisor supervising
the program will obtain certain information regarding your financial circumstances, investment goals
and objectives. They may use questionnaires or other methods to determine your risk tolerance. They
will also collect other pertinent information regarding your current investments, income, earnings,
assets, liabilities, retirement plans, tax circumstances, and insurance policies. This information is used
to make recommendations regarding your investment strategy and clients should notify their
Investment Advisor promptly of any changes in their financial situation, goals or objectives. Your
financial advisor will assist you in selecting an investment program and strategy that meets your
investment needs and risk tolerance.
Wrap Fee programs allow clients to consolidate all of their investment advisory and custodial services
within one managed account relationship. In a wrap fee program, your investment advisory fee
includes execution and custody services, and clients do not pay commissions or transaction-based
compensation for purchase or sale of securities in the account. Clients may receive comparable
services from other broker-dealers or investment advisers and pay fees that are higher or lower than
those charged in a wrap program. Fees in such a program may be more or less than if the client had
purchased investment management, custody and brokerage services separately outside of the wrap
program. Wrap fee programs are not intended for investors who seek to maintain control over trading
in their account. If you do not need continuous investment management, custodial and brokerage
services may be available at a lower aggregate cost through other firms or accounts. Ask your financial
advisor for additional information.
As of July 31, 2026, the Brentview Dividend Growth strategy is available in the following wrap
programs:
BNY-Lockwood Managed360 Program
LPL Financial Manager Select
LPL Financial Manager Access Select
LPL Model Wealth Portfolios
Morgan Stanley-Consulting and Evaluation Services
Morgan Stanley-Fiduciary Services
UBS Financial-Advisor Allocation Program
UBS Financial-Access
UBS Financial-Managed Account Consulting
UBS Financial-Strategic Wealth Portfolio
Pershing Advisor Solutions, LLC
Raymond James OSM Platform
Wells Fargo Private Advisor Network
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TAMP Platforms
A turnkey asset management platform (“TAMP”) provides asset management services to financial
advisors. TAMPs are technology platforms that provide financial advisors with access to investment
strategies. Through TAMPs, advisors can invest their client assets and access tools to assist with the
management of the account. Often financial advisors use TAMPS to have broader access to a variety
of investment strategies so they can research which strategies would be best for their clients. There
are usually additional costs associated with using these platforms. Brentview offers their strategies
through TAMP platforms to Registered Investment Advisors for their clients.
As of July 31, 2026, the Brentview Dividend Growth strategy is available on the following TAMP
platforms:
Advyzon
Adhesion Wealth Advisor Solutions
Ameriprise-Select Separate Account
BNY-Lockwood Managed360 Program
Envestnet Asset Management, LLC
Fidelity Managed Account Xchange
ICR Partners, LLC
Orion Portfolio Solutions, LLC
Types of Investments
General descriptions of Brentview’s investment strategy are included below. Additionally, from time to
time, Brentview may provide variations of the strategy listed below (for example) to accommodate
client requests.
Our Dividend Growth strategy primarily invests in both publicly traded dividend-paying common stocks
and real estate investment trusts that possess the fundamentals for future potential dividend growth.
The strategy seeks to provide an attractive total return comprised of both dividends and long-term
capital appreciation. Companies in certain economic sectors of the market historically have
demonstrated higher dividend yields than companies in other sectors and industries. As a result,
portfolios may, from time to time, have greater exposure to higher dividend-yield sectors and industries
than the broad equity market. The strategy may invest in a wide range of market capitalizations
including mid and large-cap companies. The Dividend Growth strategy generally emphasizes U.S.
companies, however investment in non-U.S. companies is permitted so long as those companies are
listed on an U.S. stock exchange.
These descriptions are not intended to serve as applicable account guidelines. Brentview’s Dividend
Growth strategy is not generally intended to provide a complete investment program for a client, and
clients are responsible for appropriately diversifying their assets.
From time to time, with Brentview’s consent, clients may include certain securities in accounts for
which we provide no investment advisory services (“unsupervised securities”). Unsupervised securities
are not subject to our services.
Assets Under Management
As of July 31, 2026, the combined firm assets under management (including Charles Fish Investments,
Inc.) are $2,115,716,263 and Brentview, individually, has $272,090,008 of discretionary assets
(including assets as sub-advisor), $0 of non-discretionary assets under management and
$1,495,314,943 in Unified Managed Account (UMA) programs.
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Item 5 Fees and Compensation
Portfolio Management Services
Advisory fees for separate accounts are determined based upon the following schedules. However,
fees for accounts that fall outside of the stated ranges are negotiated. We may impose minimum
annual fees for separate accounts as negotiated.
Separately Managed Accounts
Annual Fee Schedule for Dividend Growth
Assets Under Management
Annual Fee
First $25 million
0.50%
Next $25 Million
0.45%
Next $50 Million
0.40%
Next $150 Million
0.35%
Over $250 Million
Negotiated
Minimum Account Size
$1 million
Minimum account sizes can be waived at our discretion.
Annual Fee Schedule for Select Dividend Growth and International Dividend Growth
Assets Under Management
Annual Fee
First $25 million
0.70%
Next $25 Million
0.65%
Next $50 Million
0.60%
Over $100 Million
Negotiated
Minimum Account Size
$1 million
Minimum account sizes can be waived at our discretion.
Our Account Agreement for discretionary accounts includes the authorization to deduct advisory fees
directly from your account. Our annual portfolio management advisory fee is billed and payable,
quarterly in advance, based on the balance at end of billing period. If the portfolio management
agreement is executed at any time other than the first day of a calendar quarter, our advisory fees will
apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of
days in the quarter for which you are a client. Our advisory fee is negotiable, depending on individual
client circumstances.
At our discretion, we may combine the account values of family members living in the same household
to determine the applicable advisory fee. For example, we may combine account values for you and
your minor children, joint accounts with your spouse, and other types of related accounts. Combining
account values may increase the asset total, which may result in your paying a reduced advisory fee
based on the available breakpoints in our fee schedule stated above.
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We encourage you to reconcile our invoices with the statement(s) you receive from your qualified
custodian. If you find any inconsistent information between our invoice and the statement(s) you
receive from the qualified custodian call our main office number located on the cover page of this
brochure.
You may terminate the portfolio management agreement upon written notice. You will incur a pro rata
charge for services rendered prior to the termination of the portfolio management agreement, which
means you will incur advisory fees only in proportion to the number of days in the quarter for which you
are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated
refund of those fees. Employees have the option to invest in Brentview strategies as a client at no cost.
Our employee accounts are managed in a manner consistent with Brentview’s fiduciary duty to its
other clients. Employee accounts shall receive neither special advantages nor disadvantages.
Sub-Advisory Services for Registered Investment Advisers
Fees and payment arrangements are negotiable and will vary on a case-by-case basis.
Additional Fees and Expenses
Clients may incur brokerage, custody, and other transaction costs. These charges and fees are
typically imposed by the broker-dealer or custodian through whom your account transactions are
executed. We do not share in any portion of the brokerage fees/transaction charges imposed by the
broker-dealer or custodian. Neither our firm nor any of our supervised persons accepts compensation
for the sale of securities or other investment products, including asset-based sales charges or service
fees from the sale of mutual funds. To fully understand the total cost you will incur, you should review
all the fees charged by mutual funds, exchange traded funds, our firm, and others. For information on
our brokerage practices, refer to the Brokerage Practices section of this brochure.
Item 6 Performance-Based Fees and Side-By-Side Management
We do not accept performance-based fees or participate in side-by-side management. Performance-
based fees are fees that are based on a share of a capital gains or capital appreciation of a client's
account. Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged performance-
based fees. Our fees are calculated as described in the Fees and Compensation section above and
are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in
your advisory account.
Item 7 Types of Clients
We offer investment advisory services to a wide variety of clients including but not limited to
individuals, corporations, endowments, foundations, partnerships, trusts, and other investment
advisers. Prior to investing, an investor should review the relevant information concerning the
objectives, policies, strategies, risks, fees, and other important information.
In general, we require a minimum dollar amount of $1 million to open and maintain an advisory
account. We reserve the right to terminate your account if it falls below a threshold which, in our sole
opinion, is too small to manage effectively.
We may also combine account values for you and your minor children, joint accounts with your
spouse, and other types of related accounts to meet the stated minimum.
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Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Our Methods of Analysis and Investment Strategies
Brentview is a fundamentally focused investment firm. While several aspects are taken into
consideration, our primary objective is to understand the business facets of each prospective
company. First, we qualitatively evaluate a company's business model and its competitive position
versus its respective industry peer group. Next, we compare company specific fundamentals versus its
peer group and the broader sector overall. Finally, we assess a company's historical commitment to
issuing dividends and make a determination whether we believe the fundamentals will support future
dividend growth. Ultimately, Brentview seeks companies with strong fundamentals and a clear
commitment to growing their dividend.
We may use one or more of the following methods of analysis or investment strategies when providing
investment advice to you:
Fundamental Analysis: involves analyzing individual companies and their industry groups, such as a
company's financial statements, details regarding the company's product line, the experience and
expertise of the company's management, and the outlook for the company and its industry. The
resulting data is used to measure the true value of the company's stock compared to the current
market value based upon our assumptions.
Risk: The risk of fundamental analysis is that information obtained may be incorrect and the analysis
may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If
securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in
favorable performance.
Long-Term Purchases: securities purchased with the expectation that the value of those securities
will grow over a relatively long period of time, generally greater than one year.
Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the
long-term which may not be the case. There is also the risk that the segment of the market that you are
invested in or perhaps just your particular investment will go down over time even if the overall
financial markets advance. Purchasing investments long-term may create an opportunity cost -
"locking-up" assets that may be better utilized in the short-term in other investments.
Our investment strategies and advice may vary depending upon each client's specific financial
situation. As such, we determine investments and allocations based upon your predefined objectives,
risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors.
Your restrictions and guidelines may affect the composition of your portfolio. It is important that you
notify us immediately with respect to any material changes to your financial circumstances,
including for example, a change in your current or expected income level, tax circumstances, or
employment status.
Tax Considerations
Our strategies and investments may have unique and significant tax implications. However, unless we
specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the
management of your assets. Regardless of your account size or any other factors, we strongly
recommend that you consult with a tax professional regarding the investing of your assets.
Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Your
custodian will default to the First-In First-Out ("FIFO") accounting method for calculating the cost basis
of your investments. You are responsible for contacting your tax advisor to determine if this accounting
method is the right choice for you. If your tax advisor believes another accounting method is more
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advantageous, provide written notice to our firm immediately and we will alert your account custodian
of your individually selected accounting method. Decisions about cost basis accounting methods will
need to be made before trades settle, as the cost basis method cannot be changed after settlement.
Risk of Loss
Our strategy invests in publicly traded equity securities which may include either dividend paying
common stocks or real estate investment trusts. Investing in our strategy involves risk of loss that you
should be prepared to bear. We do not represent or guarantee that our services or methods of analysis
can or will predict future results, successfully identify market tops or bottoms, or insulate clients from
losses due to market corrections or declines. We cannot offer any guarantees or promises that your
financial goals and objectives will be met. Past performance is in no way an indication of future returns.
When evaluating risk, financial loss may be viewed differently by each client and may depend on many
different risks, each of which may affect the probability and magnitude of any potential loses. The
following risks may not be all-inclusive, but they should be considered carefully by a prospective client
before retaining our services.
A description of the types of securities we may recommend to you and some of their inherent risks are
provided below.
Common Stock: There are numerous ways of measuring the risk of equity securities (also known
simply as "equities" or "stock"). In very broad terms, the value of a stock depends on the financial
health of the company issuing it. Although common stocks historically have generated higher average
returns than fixed income securities, common stocks also have experienced significantly more volatility
in those returns. An adverse event, such as an unfavorable earnings report, may depress the value of
a particular common stock held by a portfolio. Stock prices can be affected by many other factors
including, but not limited to the class of stock (for example, preferred or common); the health of the
market sector of the issuing company; and, the overall health of the economy. Also, prices of common
stocks are sensitive to general movements in the stock market and a drop in the stock market may
depress the prices of common stocks. In general, larger, better established companies ("large cap")
tend to be safer than smaller start-up companies ("small cap") are but the mere size of an issuer is not,
by itself, an indicator of the safety of the investment.
Real Estate Investment Trust: A real estate investment trust ("REIT") is a corporate entity which
invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate
income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock
exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually
pay dividends out of funds from operations, so cash flow has to be strong or the REIT must either dip
into reserves, borrow to pay dividends, or distribute them in stock (which causes dilution). After 2012,
the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts
periodically. The credit markets are no longer frozen, but banks are demanding, and getting, harsher
terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay
debt, which will lead to additional dilution of the stockholders. Fluctuations in the real estate market can
affect the REIT's value and dividends.
Dividend Growth Style Risk: Dividends are not guaranteed and will fluctuate over time. Dividend
yield is one component of performance and should not be the only consideration for investment.
Growth style investing may fall out of favor and underperform other styles of investing over any period
of time. Certain sectors may shift characteristics over a long market cycle and may not perform in line
with stated benchmarks.
Dividend-Paying Security Risk: A portfolio’s investment solely in dividend-paying stocks could cause
the portfolio to underperform similar portfolios that invest without the consideration of a company’s
track record of paying dividends and/or utilize other investment styles. Stocks of companies with a
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history of paying dividends may not participate to the same degree in a broad market advance as most
other stocks, and a sharp rise in interest rates or economic downturn could cause a company to
unexpectedly reduce or eliminate its dividend.
Large-Cap Stock Risk: Depending on the extent that a strategy invests in large capitalization stocks,
the strategy may underperform other strategies that invest primarily in stocks of smaller capitalization
companies during periods when the stocks of such companies are in favor. Large-capitalization
companies may be unable to respond as quickly as smaller capitalization companies to competitive
challenges or to changes in business, product, financial or other market conditions.
Mid-Cap Stock Risk: While stocks of mid-cap companies may be slightly less volatile than those of
small-cap companies, they still involve substantial risk. Mid-cap companies may have limited product
lines, markets or financial resources, and they may be dependent on a limited management group.
Stocks of mid-cap companies may be subject to more abrupt or erratic market movements than those
of larger, more established companies or the market averages in general.
Value Stock Risk: Value investing has gone in and out of favor during past market cycles and when
value investing is out of favor the securities of value companies may underperform the securities of
other companies. Ultimately the intrinsic value of a company’s stock that has value type characteristics
may be difficult to identify and may not be fully recognized by the market for a long period of time.
Growth Stock Risk: Growth stocks tend to be more volatile than certain other types of stocks and
their prices usually fluctuate more dramatically than the overall stock market. Growth stocks may be
more expensive relative to their earnings or assets compared to other types of equity securities.
Accordingly, a stock with growth characteristics can have sharp price declines due to decreases in
current or expected earnings and may have lower dividend yields overall. The lower yield may not
provide as much cushion against volatility in its share price as the higher yielding peer group might in a
declining market. In addition, growth stocks, at times, may not perform as well as value stocks or the
stock market in general, and may be out of favor with investors for varying periods of time.
Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to
high volatility or lack of active liquid markets. You may receive a lower price or it may not be possible
to sell the investment at all.
Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and
sovereign fixed income or bonds. A bond issuing entity can experience a credit event that could impair
or erase the value of an issuer’s securities held by a client.
Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to
changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and
may reduce the purchasing power of a client’s future interest payments and principal. Inflation also
generally leads to higher interest rates which may cause the value of many types of fixed income
investments to decline.
Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an
unforeseen event, for example, the loss of your job. This may force you to sell investments that you
were expecting to hold for the long term. If you must sell at a time that the markets are down, you may
lose money. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for
people who are retired or are nearing retirement.
Non-U.S. Markets Risk: Non-U.S. companies or U.S. companies with significant non-U.S. operations
may be subject to risks in addition to those of companies that principally operate in the United States
due to political, social and economic developments abroad, different regulatory environments and
laws, potential seizure by the government of company assets, higher taxation, withholding taxes on
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dividends and interest and limitations on the use or transfer of portfolio assets. ADRs may be more
thinly traded in the U.S. than the underlying shares traded in the country of origin, which may increase
volatility and affect purchase or sale prices. ADRs do not eliminate the currency and economic risks for
the underlying shares in another country.
The U.S. and non-U.S. equity markets often rise and fall at different times or by varying amounts due
to economic or other developments specific to a country or region. This phenomenon would tend to
lower the overall price volatility of a portfolio that included both U.S. and non-U.S. stocks as it is more
broadly diversified across geography and economic exposure. Sometimes, however, global trends will
cause the U.S. and non-U.S. markets to move in the same direction thereby reducing or eliminating the
diversification benefit of international investing. In addition, non-U.S. stock exchanges and investment
professionals are subject to less governmental regulation, and commissions may be higher than in the
United States. Also, non-U.S. stock exchange transactions may experience longer settlement times.
Investments in securities of non-U.S. issuers involve special risks not presented by investments in
securities of U.S. issuers, including the following: (i) less publicly available information about non-U.S.
issuers or markets due to less rigorous disclosure or accounting standards or regulatory practices; (ii)
many non-U.S. markets are smaller, less liquid and more volatile, meaning that in a changing market,
a portfolio may not be able to sell securities at times, in amounts and at prices it considers reasonable;
(iii) potential adverse effects of currency exchange rate fluctuations or controls on the value of a
portfolio’s investments; (iv) the economies of non-U.S. countries may grow at slower rates than
expected or may experience a downturn or recession; (v) the impact of economic, political, social or
diplomatic events; (vi) possible seizure, expropriation or nationalization of the company or its assets;
(vii) enforcing legal rights may be difficult, costly and slow in non-U.S. countries, and there may be
special problems enforcing claims against non-U.S. governments; (viii) non-U.S. markets may be less
liquid and more volatile than U.S. markets; (ix) certain non-U.S. countries may impose restrictions on
the ability of non U.S. issuers to make payments of principal and/or interest to investors located
outside the issuer’s country of domicile, due to blockage of foreign currency exchanges or otherwise;
and (x) withholding and other non-U.S. taxes may decrease a portfolio’s return. These risks are more
pronounced to the extent that a portfolio invests a significant amount of its assets in companies located
in one region.
Item 9 Disciplinary Information
We do not have any disciplinary events and do not have any required disclosures under this item.
Item 10 Other Financial Industry Activities and Affiliations
We are committed to putting the interests of our clients first and seek to act in a manner consistent with
our fiduciary and contractual obligations to clients and applicable law. We have not provided
information on other financial industry activities and affiliations because we do not have any
relationship or arrangement that is material to our advisory business or to our clients with any of the
types of entities listed below.
1.
2.
3.
4.
5.
6.
7.
8.
broker-dealer, municipal securities dealer, or government securities dealer or broker.
investment company or other pooled investment vehicle (including a mutual fund, closed-end
investment company, unit investment trust, private investment company or "hedge fund," and
offshore fund).
other investment adviser or financial planner.
futures commission merchant, commodity pool operator, or commodity trading advisor.
banking or thrift institution.
accountant or accounting firm.
lawyer or law firm.
insurance company or agency.
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pension consultant.
real estate broker or dealer.
9.
10.
11. sponsor or syndicator of limited partnerships.
Brentview has a 50% ownership interest in Charles Fish Investments, Inc.(“CFI”), an SEC registered
investment adviser. CFI will remain an independent business under common control and ownership
with Brentview. Additional information on CFI is available upon request or by reviewing their ADV on
the SEC website at https://adviserinfo.sec.gov/firm/summary/110445.
Certain non-investment support functions (e.g., operations, account administration, information
technology, legal, human resources, trading, and other corporate or administrative services) are
provided, or in some instances supplemented, by third party service providers.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code
of Ethics includes guidelines for professional standards of conduct for persons associated with our
firm. Brentview has adopted a Code of Ethics in compliance with 204A-1 in reference to its controls
over personal trading that sets forth the governing ethical standards and principles of Brentview. Our
goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties
of honesty, good faith, and fair dealing with you. All persons associated with our firm are expected to
adhere strictly to these guidelines. Persons associated with our firm are also required to report any
violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably
designed to prevent the misuse or dissemination of material, non-public information about you or your
account holdings by persons associated with our firm.
Our Ethics Rules (the “Rules”), are comprised of the Code of Ethics and Compliance Manual Policies
and Procedures. The Rules are designed to ensure that our personnel (i) observe applicable legal
(including compliance with applicable state and federal securities laws) and ethical standards in the
performance of their duties; (ii) at all times place the interests of our clients first; (iii) disclose all actual
or potential conflicts; (iv) adhere to the highest standards of loyalty and care in all matters relating to
our clients; (v) conduct all personal trading consistent with the Rules and in such a manner as to avoid
any actual, potential or perceived conflict of interest or any abuse of their position of trust and
responsibility; and (vi) not use any material non-public information in securities trading. The Rules also
establish policies regarding other matters such as outside employment, the giving or receiving of gifts,
and safeguarding portfolio holdings information.
Clients or prospective clients may obtain a copy of Brentview’s Code of Ethics by contacting us at the
telephone number on the cover page of this brochure.
Participation or Interest in Client Transactions
Neither our firm nor any persons associated with our firm has any material financial interest in client
transactions beyond the provision of investment advisory services as disclosed in this brochure.
Personal Trading Practices
Our firm or persons associated with our firm may buy or sell the same securities that we recommend to
you or securities in which you are already invested. A conflict of interest exists in such cases because
we have the ability to trade ahead of you and potentially receive more favorable prices than you will
receive. To mitigate this conflict of interest, it is our policy that neither our firm nor persons associated
with our firm shall have priority over your account in the purchase or sale of securities. Additionally,
securities held in the strategy may be purchased or sold within a personal brokerage account but must
follow a pre-clearance process to assure that clients are not impacted by the transaction.
12
Item 12 Brokerage Practices
We do not maintain direct relationships with broker-dealers. While you are free to choose any broker-
dealer or other service provider as your custodian, we recommend that you establish an account with a
brokerage firm that has an established platform for separately managed accounts which allows for
"open architecture"; in other words the investor is free to select the investment manager of their
choosing. This “open architecture” allows you to give us discretionary trading authority in your
accounts as described above. Otherwise, we would recommend that a client should select a broker-
dealer whom they believe provides quality execution services and at competitive prices. Price should
not be the sole factor when considering best execution. The quality of the brokerage services provided
by any broker-dealer, should also include the value of the firm's reputation, execution capabilities,
commission rates, and responsiveness to their clients. We do not recommend any specific
broker/dealers and/or custodians.
Research and Other Soft Dollar Benefits
We do not have any soft dollar arrangements.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation,
such as brokerage services or research.
Directed Brokerage
In limited circumstances, and at our discretion, some clients may instruct our firm to use one or more
particular brokers for the transactions in their accounts. If you choose to direct our firm to use a
particular broker, you should understand that this might prevent our firm from aggregating trades with
other client accounts or from effectively negotiating brokerage commissions on your behalf. This
practice may also prevent our firm from obtaining favorable net price and execution. Thus, when
directing brokerage business, you should consider whether the commission expenses, execution,
clearance, and settlement capabilities that you will obtain through your broker are adequately favorable
in comparison to those that we would otherwise obtain for you.
Block Trades
We combine multiple orders for shares of the same securities purchased for discretionary advisory
accounts we manage (this practice is commonly referred to as "block trading"). We will then distribute a
portion of the shares to participating accounts in a fair and equitable manner. Generally, participating
accounts will pay a fixed transaction cost regardless of the number of shares transacted. In certain
cases, each participating account pays an average price per share for all transactions and pays a
proportionate share of all transaction costs on any given day. In the event an order is only partially
filled, the shares will be allocated to participating accounts in a fair and equitable manner, typically in
proportion to the size of each client’s order. Accounts owned by our firm or persons associated with
our firm may participate in block trading with your accounts; however, they will not be given preferential
treatment.
Our firm or persons associated with our firm may buy or sell securities for you at the same time we or
persons associated with our firm buy or sell such securities for our own account. We may also combine
our orders to purchase securities with your orders to purchase securities ("block trading"). A potential
conflict of interest exists in such cases because we have the ability to trade ahead of you and
potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, it is
our policy that neither our firm nor persons associated with our firm shall have priority over your
account in the purchase or sale of securities.
Trade Rotation
Brentview has instituted a trade rotation policy to ensure fair and equitable trade implementation
13
across our client base. Our trade rotation utilizes a “top to bottom” trade order procedure (i.e. 1,2,3,4
then 2,3,4,1, etc.) across all of our accounts. Accounts are grouped according to their custodian.
Portfolio changes will be communicated, implemented, and then executed sequentially across each
custodial relationship, following the top to bottom process, through the trade rotation, until the trade
has been completed. Upon completion of the trade, the custodial group that went first would then be
moved to the last place of the queue for the next set of trades. Our trade rotation policies and
procedures ensure that each account routinely moves through the queue consistently and equitably
over time.
We review accounts regularly to determine if there are any irregularities in performance in a custodial
group that might indicate this process is not working in the manner intended.
Brentview’s outsourced investment operations provider, Archer, is responsible for executing trades and
communicating to custodians on behalf of Brentview and subject to Brentview’s direction and oversight
at all times. The trade rotation policy, as documented in Brentview’s compliance manual, will be
provided to clients upon request
Item 13 Review of Accounts
Brentview’s Investment and Client Service personnel will monitor your accounts on an ongoing basis
for adherence to our stated investment guidelines, which may also include client specific guidelines as
well. Our personnel will conduct account reviews at least quarterly or upon request, to ensure the
advisory services provided to you are consistent with your investment needs and objectives.
Additional reviews may be conducted based on various circumstances, including, but not limited to:
• contributions and withdrawals,
• year-end tax planning,
• market moving events,
• security specific events, and/or,
• changes in your risk/return objectives.
The individuals conducting reviews may vary from time to time depending on the nature of the account.
You will receive trade confirmations and monthly or quarterly statements from your account
custodian(s). At this time, we do not provide you with regular written reports.
Item 14 Client Referrals and Other Compensation
We do not receive any compensation from any third party in connection with providing investment
advice to you nor do we compensate any individual or firm for client referrals.
Refer to the Brokerage Practices section above for disclosures on research and other benefits we may
receive resulting from our relationship with your account custodian.
Item 15 Custody
We directly debit advisory fees from your account if you have provided us with the authority to do so.
We are considered to have custody over accounts of the Principals of the firm that trade the strategy,
but we do not exercise custody over client funds or securities. Your funds and securities will be held
with a bank, broker-dealer, or other qualified custodian. You will receive account statements from the
qualified custodian(s) holding your funds and securities. If you have a question regarding your account
statement or if you did not receive a statement from your custodian, contact your custodian directly.
14
Item 16 Investment Discretion
Before we can buy or sell securities on your behalf, you must first sign our discretionary management
agreement and the appropriate trading authorization forms.
You may grant our firm discretion over the selection and amount of securities to be purchased or sold
for your account(s) without obtaining your consent or approval prior to each transaction. You may
specify investment objectives, guidelines, and/or impose certain conditions or investment parameters
for your account(s). For example, you may specify that the investment in any particular stock or
industry should not exceed specified percentages of the value of the portfolio and/or restrictions or
prohibitions of transactions in the securities of a specific industry or security. Refer to the Advisory
Business section in this brochure for more information on our discretionary management services.
Item 17 Voting Client Securities
We will determine how to vote proxies based on our reasonable judgment of the vote most likely to
produce favorable financial results for you. Proxy votes generally will be cast in favor of proposals that
maintain or strengthen the shared interests of shareholders and management, increase shareholder
value, maintain or increase shareholder influence over the issuer's board of directors and
management, and maintain or increase the rights of shareholders. Generally, proxy votes will be cast
against proposals having the opposite effect. However, we will consider both sides of each proxy
issue. Unless we receive specific instructions from you, we will not base votes on social
considerations.
In the event you wish to direct our firm on voting a particular proxy, you should contact our main office
at the phone number on the cover page of this brochure with your instruction.
Conflicts of interest between you and our firm, or a principal of our firm, regarding certain proxy issues
could arise. If we determine that a material conflict of interest exists, we will take the necessary steps
to resolve the conflict before voting the proxies. For example, we may disclose the existence and
nature of the conflict to you, and seek direction from you as to how to vote on a particular issue; we
may abstain from voting, particularly if there are conflicting interests for you (for example, where your
account(s) hold different securities in a competitive merger situation); or, we will take other necessary
steps designed to ensure that a decision to vote is in your best interest and was not the product of the
conflict.
We keep certain records required by applicable law in connection with our proxy voting activities. You
may obtain information on how we voted proxies and/or obtain a full copy of our proxy voting policies
and procedures by making a written or oral request to our firm.
Item 18 Financial Information
Our firm does not have any financial condition or impairment that would prevent us from meeting our
contractual commitments to you. We do not take physical custody of client funds or securities, or serve
as trustee or signatory for client accounts, and, we do not require the prepayment of more than $500 in
fees six or more months in advance. Therefore, we are not required to include a financial statement
with this brochure.
We have not filed a bankruptcy petition at any time in the past ten years.
15
John A. Gomez
Brentview Investment Management, LLC
6400 Shafer Ct, Suite 360
Rosemont, IL 60018
Telephone: 312-283-4450
September 15, 2026
FORM ADV PART 2B
BROCHURE SUPPLEMENT
This brochure supplement provides information about John Gomez that supplements the Brentview
Investment Management, LLC brochure. You should have received a copy of that brochure. Contact us
at 312-283-4450 if you did not receive Brentview Investment Management's brochure or if you have
any questions about the contents of this supplement.
Additional information about John Gomez (CRD # 2275694) is available on the SEC's website at
www.adviserinfo.sec.gov
Last reviewed: September 15, 2026
Item 2 Educational Background and Business Experience
John Gomez
Year of Birth: 1970
Formal Education After High School:
• Loyola University Chicago, BA, Finance, 8/1988 - 6/1992
• Loyola University Chicago, MBA, Finance with Focus on Financial Derivatives, 6/1995 - 6/1997
Business Background:
• Brentview Investment Management, LLC, Principal/President, 5/2019 - Present
• Santa Barbara Asset Management, President, 3/2015 - 4/2018
• Nuveen Securities, LLC, Business Development, 5/2006 - 4/2018
• Santa Barbara Asset Management, MD, Head of Business Development/Client Service, 3/2013
- 3/2015
• Santa Barbara Asset Management, Managing Director, Client Portfolio Manager, 6/2006 -
3/2013
Item 3 Disciplinary Information
Mr. Gomez does not have any reportable legal or disciplinary events.
Item 4 Other Business Activities
Mr. Gomez is not actively engaged in any investment related business or occupation (investment-
related or otherwise) beyond his capacity as President of Brentview Investment Management, LLC.
Item 5 Additional Compensation
John Gomez does not receive any additional compensation beyond that received as President of
Brentview Investment Management, LLC.
Item 6 Supervision
Brentview Investment Management, LLC supervises Mr. Gomez and monitors the advisor services
provided to clients according to their code of ethics and Compliance Manual. Questions regarding any
of Mr. Gomez’s activities can be addressed to the Chief Compliance Officer of Brentview Investment
Management at 312-283-4450.
James R. Boothe, CFA
Brentview Investment Management, LLC
6400 Shafer Ct, Suite 360
Rosemont, IL 60018
Telephone: 312-283-4450
September 15, 2026
FORM ADV PART 2B
BROCHURE SUPPLEMENT
This brochure supplement provides information about James Boothe that supplements the Brentview
Investment Management, LLC brochure. You should have received a copy of that brochure. Contact us
at 312-283-4450 if you did not receive Brentview Investment Management's brochure or if you have
any questions about the contents of this supplement.
Last reviewed: September 15, 2026
Item 2 Educational Background and Business Experience
James Boothe, CFA
Year of Birth: 1955
Formal Education After High School:
• Kent State University, BBA, 1977
• Loyola Marymount University, MBA, Finance, 1984
Business Background:
• Brentview Investment Management, LLC, Principal/Chief Investment Officer, 6/2019 - Present
• Santa Barbara Asset Management, Chief Investment Officer/Portfolio Manager, 2002-2019
• USAA Investment Management, Portfolio Manager/Analyst, 1993-2001
• San Juan Asset Management, Institutional Equity Research Analyst, 1988-1993
• Farmers Insurance Group, Equities Analyst, 1978-1981
Mr. Boothe holds the Chartered Financial Analyst Designation.
The CFA Designation is a professional certification offered by the CFA Institute to financial analysts
who pass each of three six-hour exams, possess a bachelor’s degree or equivalent, and have 48
months of qualified professional work experience.
Item 3 Disciplinary Information
Mr. Boothe does not have any reportable legal or disciplinary events.
Item 4 Other Business Activities
Mr. Boothe is not actively engaged in any investment related business or occupation (investment-
related or otherwise) beyond his capacity as Chief Investment Officer of Brentview Investment
Management, LLC.
Item 5 Additional Compensation
Mr. Boothe does not receive any additional compensation beyond that received as Chief Investment
Officer and Portfolio Manager of Brentview Investment Management, LLC.
Item 6 Supervision
Brentview Investment Management, LLC supervises Mr. Boothe and monitors the advisor services
provided to clients according to their code of ethics and Compliance Manual. Questions regarding any
of Mr. Boothe’s activities can be addressed to the Chief Compliance Officer of Brentview Investment
Management at Cynthia.Aragon@brentviewim.com.
Hai H. Vu, CFA
Brentview Investment Management, LLC
6400 Shafer Ct, Suite 360
Rosemont, IL 60018
Telephone: 312-283-4450
September 15, 2026
FORM ADV PART 2B
BROCHURE SUPPLEMENT
This brochure supplement provides information about Hai Vu that supplements the Brentview
Investment Management, LLC brochure. You should have received a copy of that brochure. Contact us
at 312-283-4450 if you did not receive Brentview Investment Management's brochure or if you have
any questions about the contents of this supplement.
Last reviewed: September 15, 2026
Item 2 Educational Background and Business Experience
Hai H. Vu, CFA
Year of Birth: 1967
Formal Education After High School:
• California State University, East Bay, BS
• University of California Los Angeles, PhD in Applied Mathematics
Business Background:
• Brentview Investment Management, LLC, Director of Research/Portfolio Manager, 7/2019 -
Present
• Santa Barbara Asset Management, Senior Vice President and Director or Research, 2015-2019
• Santa Barbara Asset Management, Vice President and Research Analyst, 2007-2015
• Jeffries & Co, Vice President/Research Analyst, 2001-2005
• Western Asset, Analyst, 2000
• Transamerica Asset Management, Vice President/Analyst, 1998-2000
• Ahmanson & Co, Vice President/Analyst, 1995-1998
• Pacific Income Advisers, Analyst, 1993-1995
Mr. Vu holds the Chartered Financial Analyst Designation.
The CFA Designation is a professional certification offered by the CFA Institute to financial analysts
who pass each of three six-hour exams, possess a bachelor’s degree or equivalent, and have 48
months of qualified professional work experience.
Item 3 Disciplinary Information
Mr. Vu does not have any reportable legal or disciplinary events.
Item 4 Other Business Activities
Mr. Vu is not actively engaged in any investment related business or occupation (investment-related or
otherwise) beyond his capacity as Director or Research and Portfolio Manager of Brentview
Investment Management, LLC.
Item 5 Additional Compensation
Mr. Vu does not receive any additional compensation beyond that received as Director of Research
and Portfolio Manager of Brentview Investment Management, LLC.
Item 6 Supervision
Brentview Investment Management, LLC supervises Mr. Vu and monitors the advisor services
provided to clients according to their code of ethics and Compliance Manual. Questions regarding any
of Mr. Vu’s activities can be addressed to the Chief Compliance Officer of Brentview Investment
Management at 312-283-4450.