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Form ADV Part 2A – January 2026
Galecki Financial Management, Inc.
7743 W. Jefferson Blvd.
Fort Wayne, IN 46804
Phone: (260) 436-8525
Fax: (260) 436-8825
www.galecki.com
Form ADV Part 2A
January 14, 2026
This brochure provides information about the
qualifications and business practices of
Galecki Financial Management, Inc.
If you have any questions about the contents
of this brochure, please contact us at 260-
436-8525 or brady@galecki.com. 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.
Information
the
SEC's
web
site
Additional
about Galecki
Financial Management, Inc. also is available
on
at
www.adviserinfo.sec.gov. You can search
the site by using a unique identifying number,
known as a CRD number. Our firm's CRD
number is 107218.
Galecki Financial Management, Inc. is a
Fee-Only Financial Planning Firm. We do
not accept commissions or sell any
products.
Galecki Financial Management, Inc.
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Form ADV Part 2A – January 2026
Material Changes
Advisory Business
Ownership of GFM
Greg Galecki retired in 2021 selling his
remaining 53% interest to the existing
shareholders.
Table of Contents
Galecki Financial Management Inc. (GFM)
is a Registered Investment Advisory firm
with the SEC. The principal location is in
Fort Wayne, Indiana. The firm began
operations in 1990.
Contents
Form ADV Part 2A .............................................. 1
Material Changes ............................................... 2
The primary owners of the firm are Albert
Kohout (20%), Brady McArdle (16%),
Melanie Colwell (16%), Kevin Chandler
(16%), Andrew Young (16%) and Chloe
Blythe (16%).
Table of Contents ............................................... 2
Types of Services offered by GFM
Advisory Business ............................................... 2
Initial Financial Overview (IFO)
Assets Under Management ............................... 7
Fees and Compensation ..................................... 7
Performance Based Fees .................................... 7
Types of Clients .................................................. 7
Method of Analysis ............................................ 8
The Initial Financial Overview (IFO) is
packaged as a two-hour review of the
Client’s current financial position. It is
designed to be an overview of their current
situations with projections based on certain
assumptions.
Disciplinary Information..................................... 9
Other Financial Industry Activities/Affiliations .. 9
Code of Ethics/Client Transactions/Personal
Trading ............................................................... 9
Review of Accounts .......................................... 11
The IFO may cover items such as retirement
cash flow analysis, education funding and
planning, tax planning, insurance analysis,
estate planning and investment allocation
and planning. The direction of the IFO
typically depends on the needs of the Client.
Client Referrals and Other Compensation ... 12
Charitable Contributions .............................. 12
Custody ............................................................ 12
Investment Discretion ...................................... 13
Voting Client Proxies ........................................ 13
Financial Information ....................................... 13
The IFO will come with reports outlining
the projections and a letter discussing the
assumptions, results and recommendations.
The fee for the IFO is $300. If a client
utilizes our Asset Management services
within 6 months of the IFO, the IFO fee is
typically reimbursed to the Client on their
first Asset Management invoice.
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Form ADV Part 2A – January 2026
Divorce Financial Overview
GFM manages client accounts on a
Discretionary Basis. This means that GFM
has the authority to buy and sell investments
without the prior approval of the Client for
individual transactions. This approval is
given during the account opening process.
Going through a divorce can be traumatic
both emotionally and financially. The
purpose of the Divorce Financial Overview
(DFO) is to provide the Client with a review
of their financial situation based on a
proposed divorce settlement. It is designed
to give the individual a better picture as to
what their financial future looks like after
this major life change.
Client accounts are managed by the GFM
Investment Committee. Portfolio strategy
changes are then communicated to the Client
during their meetings with their assigned
Certified Financial Planner™ Professional.
Trade confirmations and statements are
delivered to each client by their custodian
(Schwab or TD Ameritrade for example).
The DFO will focus on cash flow analysis
based on a proposed divorce settlement and
typically includes alternate asset distribution
scenarios. It is designed to be an overview
of the current situation with projections
based on certain assumptions.
Client accounts are rebalanced periodically
to keep the appropriate allocation. However,
often, we will attempt to keep rebalancing
and portfolio changes to a minimum to help
minimize transaction costs for Clients.
Investments used in our discretionary
portfolios typically include mutual funds,
and exchange traded funds (ETFs).
However, we might also use common
stocks, foreign ADRs, Individual Bonds,
CDs, Option contracts, Structured Notes,
and Separately Managed Accounts.
The DFO will include a customizable
Divorce Distribution Worksheet, reports
outlining the projections, and a letter
discussing the assumptions, results, and
recommendations. Two additional alternate
scenarios are included throughout the
divorce process. The fee for the DFO is
$500. If a client utilizes our Asset
Management services within 6 months of the
DFO, the DFO fee is typically reimbursed to
the Client on their first Asset Management
invoice.
Asset Management
We will not place new money into a variable
life insurance policy or a variable annuity.
However, if a Client comes to GFM with
such a policy in place, we can manage the
underlying investment options.
GFM’s Asset Management fees are billed on
a quarterly basis. The fees are calculated as
of the first day of every billing quarter. The
minimum fee for the service is $1,250 a
quarter or $5,000 a year. Here is the current
Fee Schedule Table:
GFM provides Discretionary Asset
Management Services to clients looking for
professional investment management.
During the IFO, GFM determines the
Client’s investment objectives, time horizon,
risk tolerance and liquidity needs. These
items are agreed upon in the Asset
Management Agreement. A client’s
portfolio is then managed based on the
allocation selected in the Agreement.
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Form ADV Part 2A – January 2026
Fee
1.00%
Assets Under
Management
On first $2 million
$20,000 + 0.75%
$35,000 + 0.40%
On amount above $2
million
On amount above $4
million
GFM does not take direct custody of Client
assets. GFM requests that clients use a
custodian such as Charles Schwab to
custody their assets. These custodians have
certain fees to serve as custodian. These
fees represent an additional layer of cost for
clients.
The minimum fee may be waived by GFM
in certain cases. Existing Asset Management
clients may be on a different fee schedule.
These clients have been grandfathered in
under their old Agreements. Paying a
minimum fee of $5,000 per year could be a
much higher percentage than the schedule
listed above.
All transaction fees from the custodians are
reported on confirmation statements. The
rate of return that GFM reports to clients is
after all GFM Managements fees, custodial
fees, and funds fees. Unless clients are
invoiced directly, then their rate of return
might not include the GFM fee. Otherwise,
clients see the true return, Net of Fees.
GFM is sensitive to fees for clients. We
have negotiated rates with Schwab which
are significantly lower than retail fees. In
addition, GFM has access to Institutional
Share classes with some fund companies
which contain lower annual fees than typical
retail share classes.
The Asset Management fee is withdrawn
from the Client’s accounts at their custodian.
Authorization for the fee deduction is given
during the account opening procedure. Fees
are deducted in the middle of the quarter. In
special circumstances, we might bill clients
directly or their corporation. In these cases,
fees can be billed in arrears.
Charitable and non-profit accounts are
managed at a flat 0.40% per year. The
minimum fee is $800.
Upon termination of our Asset Management
service, any pre-paid or unearned fee will be
refunded to the Client. To calculate the
reimbursement amount, we will pro-rate the
fee according to the number of days
remaining in the billing period. Clients may
terminate their Agreement at any time.
Mutual Funds and ETFs have “hidden fees”;
typically known as annual operating expense
ratios. The fund companies withdraw their
fees before reporting the total return. This is
how they pay their bills and earn their
revenue. Separately Managed Accounts
(SMAs) get billed directly from the SMA
Manager. GFM does not receive any portion
of those fees.
Rolling money from a qualified retirement
plan into a rollover IRA could potentially
increase annual expenses for the individual.
This creates a potential conflict of interest
for GFM. We believe that our services
warrant the higher fees, but clients should
understand the conflict and situation.
Financial Planning Services
Some funds and ETFs will have transaction
fees to purchase and sell them at the
custodian. GFM also does not receive any
portion of those fees. GFM does not receive
any commissions from any source.
Clients utilizing the GFM Asset
Management Service will continue to
receive Financial Planning services pursuant
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Form ADV Part 2A – January 2026
Client what their projected net worth and
investment balance is at any time in the
future.
to their individual needs. Reviews and
updates will be done for retirement cash
flow analysis, estate planning, tax planning,
and risk management. The reviews will
occur at the client’s request, or periodically
based on the complexity of the situation.
Through this cash flow planning process, we
can identify excess cash flow years and
deficit cash flow years. We can then make
recommendations designed to improve the
cash flow projections.
Typically, clients with larger investment
assets have more complex financial planning
needs and are therefore more routinely
updated. Clients with simpler planning
needs are updated less frequently. Updates
and reviews are determined by the client’s
assigned CFP® Professional.
Financial Planning Services (Stand Alone)
Once the cash flow baseline analysis has
been complete, we can then begin to build
the plan and focus on other areas. We will
begin to focus on tax planning, estate
planning, retirement planning and risk
management.
This type of Broad Based Planning is
designed to be built over a two year period.
However, it often becomes perpetual as our
clients’ situations and circumstances
typically change over time.
GFM will provide more Broad Based
Financial Plans for Individuals (Typically
High Net-Worth Individuals). This can be
described as a holistic evaluation of a
Client’s current and future financial state,
determined by using currently known
variables to predict future cash flows and net
worth projections.
GFM’s financial plans are cash flow
based…not modular based!
Some of the areas that we may focus on are:
family structure, income sources, expenses,
assets, liabilities, portfolio diversification,
401k and pension choices, education
planning, stock options, employee benefits,
life insurance, disability insurance, health
insurance, Medicare choices, tax planning,
estate planning and other various goals.
Modular planning focuses on answering
questions about individual areas of financial
planning without taking into consideration
the Client’s holistic picture. For example,
modular planning might tell a Client how
much life insurance they need using general
rules of thumb, such as 3 times current
salary. But this would not take into
consideration items such as education
planning, or cash flow needs.
GFM may recommend the services of other
professionals for implementation purposes
(attorneys or accountants). The Client is
under no obligation to engage the services of
these professionals. The Client is free to
accept or reject any recommendations made
by GFM.
The cash flow planning that GFM uses
analyzes income sources, then subtracts out
living expenses and other future goals.
Taxes are taken out each year and
projections can then be made accordingly.
Once this analysis is complete, we can tell a
The Stand Alone planning service fee
depends on the complexity of the actual
plan. A quote will be provided based on the
estimated number of hours to complete the
plan. An annual retainer will be used and
will generally range from $5,000 to $10,000.
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Form ADV Part 2A – January 2026
We only allow Clients to use our hourly
service on three occasions after the IFO.
Hourly Consulting fees are non-refundable.
All fees are agreed upon in a signed
Financial Planning Agreement. Fees are to
be paid quarterly via an invoice mailed to
the Client however; GFM will charge the
first six months in advance before planning
work will begin.
The hourly fee for all CFP® Professionals
on staff is $250.
Retirement Plan Services
GFM’s Retirement Plan Services are
customized to the particular needs of the
Retirement Plan Sponsor. GFM is hired by
the Trustees of the Plan, which is usually the
employer or Plan Sponsor.
GFM can offer the following services to
Plan Sponsors:
It is expected that the GFM staff will meet
with a Financial Planning Client four times
each year in meetings that might last two to
three hours. The Client may contact any of
the GFM staff at any time between meetings
to ask questions, update information, or
otherwise seek guidance. There is no extra
cost for calls, contacts, e-mails, or additional
meetings during the year; the annual retainer
puts GFM staff on call as the Client's needs
arise.
•
Investment Policy Statement
Development
• Portfolio Recommendations and
Monitoring
The fee for the Financial Plan may be offset
by Asset Management fees for those
utilizing that service. In many cases, the
Asset Management fee being earned by
GFM is enough to waive the entire Financial
Planning fee.
• Fund Performance and Evaluation
• Recommending Available Funds
• Meet with Employees
• Review Plan’s custodian and
provider
• Act as additional fiduciary to the
Plan
Financial Planning Services may be
terminated at any time by the Client.
However, Stand Alone Financial Planning
Fees (Those not using Asset Management
Services) are not refundable.
Hourly Consulting Fees
GFM can meet with Plan Trustees to
determine an appropriate investment
strategy and build an Investment Policy
Statement. GFM can also assist in selecting
specific investments for the Plan and will
make recommendations for any necessary
changes.
It is unusual for GFM to work with Clients
on an hourly basis. After a Client has been
through the IFO process, they typically
utilize our Asset Management Service which
comes with ongoing Financial Planning
Services. In some cases, Clients may not
engage our Asset Management Services, but
would like future updates and reviews of
their financial situation. We will charge our
hourly fee for these services.
GFM is deemed to be a fiduciary to the Plan
pursuant to the Employee Retirement
Income and Securities Act (ERISA). GFM
will charge an annual flat fee for our
services. The fee is dependent upon the
services rendered and is individually
negotiated and contracted with the Plan
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Form ADV Part 2A – January 2026
Performance Based Fees
Sponsors or Trustees. All fees are agreed to
and contracted before services begin.
GFM does not charge performance-based
fees.
Retirement Plan Service fees are typically
charged in advance on a quarterly basis.
Any part of the fee that has already been
paid is non-refundable.
Types of Clients
Assets Under Management
The types of clients that we work with were
listed in the Advisory Business section.
However, here is a summary of these clients:
As of January 14, 2026, GFM was actively
managing $920,887,862 for 539 clients.
IFO and DFO Clients
IFO Clients are typically moderate or high
net worth individuals.
Fees and Compensation
Asset Management Clients
All GFM Fees were identified in the
Advisory Business section. Here is a
summary of those fees.
Asset Management Clients are individuals,
Pension and Profit Sharing Plans, Charitable
Organizations, Corporations, Trustees,
Trusts and Foundations.
Financial Planning Clients (Stand
Alone)
Service
IFO
DFO
Fee
$300
$500
These are typically high net worth
individuals.
Asset Management Fee Schedule based
Hourly Fees
on AUM
Annual Retainer
Financial Planning
(Stand Alone)
Hourly Planning
Retirement Plan
Services
$250-$350 per hour
Annual Retainer or
Negotiated Cost
Hourly Fee Clients are individuals, Pension
and Profit-Sharing Plans, Charitable
Organizations, Corporations, Trustees,
Trusts and Foundations.
Retirement Plan Services
GFM only receives direct compensation
from our Clients. However, we do receive
certain indirect economic benefits from
other sources. This is outlined in the
Brokerage Practices section.
The primary Client for these services will be
Pensions, Profit-Sharing and 401(k) Plans,
where GFM does not directly manage the
underlying investments.
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Form ADV Part 2A – January 2026
Method of Analysis
different asset classes to provide sufficient
diversification within the portfolios. Asset
classes that could be utilized by GFM are as
follows:
GFM analyzes investments and portfolios
through their Investment Committee. The
Investment Committee is made up of the
following members.
Intermediate-term bonds
• Albert Kohout, CFP®, MBA
• Brady McArdle, CFP®
• Melanie Colwell, CFP®
• Andy Young, CFP®, CPA
• Kevin Chandler, CFP®
• Chloe Blythe, CFP®
The Investment Committee meets formally
on a monthly basis. The Committee also
communicates often with each other about
various market and economic data.
The Investment Committee is responsible
for reviewing:
• Client Portfolios
• Performance of the Investments
• Economic and Business News
• Asset Allocation Changes
• Client Feedback
The Committee follows and reviews
different economists and publications.
Decisions are made based upon current
market and economic indicators.
• Short-Term Bonds
•
• Long-term bonds
• Municipal bonds
• Treasury inflation protected bonds
• Convertible bonds
• High-yield bonds
• Global bonds
•
International bonds
• Emerging market bonds
• Market neutral funds
• Global or international real estate trusts
• Real estate investment trusts
• Preferred stock
• Bear funds
• Small cap value
• Small cap growth
• Mid cap value
• Mid cap growth
•
Large cap value
•
Large cap growth
•
International small cap value fund
•
International mid cap value fund
•
International large cap value fund
•
International emerging fund
• Country-specific ETF
Mutual Funds, ETFs, SMA Managers and
other investments are analyzed based upon
proprietary methods. The intent is to find
and retain fund managers who have
consistently outperformed their benchmark
indices based on risk, return and other
intangibles.
Any of the above asset classes could be used
within the GFM portfolios as initially
determined by the Client's overall risk and
return objective, and then further specified
by the Investment Committee's asset
allocation in each Client's portfolio.
All of the aforementioned investments come
with various risks. Past performance is not
GFM begins with a diversified asset
allocation strategy. This strategy has taken
many years to develop and implement.
Appropriate allocations are implemented to
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Form ADV Part 2A – January 2026
GFM has adopted a Code of Ethics which
sets high standards of business conduct, and
compliance. This code is agreed to and
attested annually. A copy of the GFM Code
of Ethics is available upon request.
guaranteed to continue. Although GFM
attempts to develop a diversified portfolio
intended to minimize the overall risk, it is
important for clients to understand that the
risk of loss of principal over a short-term
time horizon is existent. This risk is
typically discussed during the Agreement
signing process and during subsequent
meetings.
GFM employees must comply with
applicable federal and state security laws. In
accordance with section 204A of the
Investment Advisors Act of 1940, GFM
maintains and enforces written policies and
procedures that are designed to prevent the
misuse of material non-public information.
Client Transactions
Purchases are made in accounts with the
intent of holding them for many years, but at
the very least 12 months or more. As a
practical manner, we try to focus on long
term growth and performance. There may
be times when investments are held for less
than a year.
Neither GFM nor its employees may buy or
sell for client accounts any individual
security in which GFM or its employees
have a material financial interest. This does
not include open-ended mutual funds as
participation in these investments would not
materially impact client holdings.
GFM does study and follow technical
analysis. It is possible that GFM could
make portfolio moves based on technical
analysis if the Committee deems it would be
beneficial for clients.
Disciplinary Information
Personal Trading
GFM has not been involved in any
Disciplinary events or actions.
Other Financial Industry
Activities/Affiliations
GFM and our employees are not affiliated
with any other financial institution or
activity. All GFM employees are required
to get approval for any outside employment.
GFM has a personal security transaction
policy in place to monitor the personal
securities transactions and holdings of all
employees. All trades in individual
securities must be pre-approved by the Chief
Compliance Officer. This is done to prevent
any potential front running violations. Front
running is when an employee of a firm
would buy an individual security, then
purchase large amounts of the same security
in client accounts. This might force the
price higher, in which case, the employee
can then sell at a profit.
Code of Ethics/Client
Transactions/Personal Trading
Code of Ethics
The pre-cleared transaction policy does not
include open-ended mutual funds that are
typically purchased in 401k plans.
Purchases in these funds do not need to be
Galecki Financial Management, Inc.
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Form ADV Part 2A – January 2026
custodian and assist with any transfer of
assets/investments to the custodian.
pre-approved as they will not impact market
movement.
GFM encourages the Investment Committee
members to use portfolios similar to the
portfolios in which our Clients are invested.
In addition, GFM employees may have an
interest or position in a certain stock or
investment which may also be
recommended to a Client.
It is not mandatory for a Client to have an
account at Schwab. GFM does have many
clients with accounts at Fidelity, Lincoln
and various other financial institutions. If
these accounts are managed by GFM per
Client request, then GFM may maintain
client web login information. With this
information, GFM can download balances
and transactions and make trades on behalf
of the client. In these cases, GFM may be
deemed to have “custody” of these assets
per recent SEC regulations.
GFM also requires employees to submit an
annual holdings report identifying all
investment holdings. This is another
opportunity for GFM to monitor employee
transactions and identify any potential
conflicts of interest.
Brokerage Practices
GFM utilizes a separate custodian (Schwab)
to custody Client assets.
GFM must hire an accounting firm to do an
annual surprise examination of accounts in
which GFM maintains “custody”. GFM
hires GBQ Partners to conduct these
examinations. GBQ will verify balances
with these custodians and the clients
directly. GFM must pay the fee for these
annual examinations.
Research and Additional Benefits
The custodian may charge transaction fees
to Clients for purchasing funds, stocks,
ETFs or other securities. GFM does not
receive any part of the custodian’s
commissions or transaction fees.
In choosing a custodian for Client assets,
GFM looks for cost competitiveness, good
service, financial security, good technology,
accuracy and reliability, good trade
execution, and solid back-up procedures.
Schwab meets these criteria.
Galecki Financial Management, Inc.
considers a number of factors in selecting
brokers and custodians at which to locate (or
recommend location of) its client accounts,
including, but not limited to, execution
capability, experience and financial stability,
reputation and the quality of services
provided
Prior to engaging GFM to provide Asset
Management services, the Client will be
required to enter into a formal Asset
Management Agreement with GFM setting
forth the terms and conditions under which
GFM shall manage the Client's assets, and a
separate custodial agreement with each
designated custodian. GFM will assist the
Client with opening accounts at the
GFM also participates in training sessions
held by Schwab at various locations. These
sessions typically include updates on new
services and technologies at these firms, as
well as economic updates, Mutual Fund
management updates, and industry
continuing education. It is typical that GFM
will receive a reduced rate for hotel rooms,
or dining at a conference of this nature.
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Form ADV Part 2A – January 2026
However, the hotel room discounts are not
subsidized by Schwab as much as they are
simply block discounts as you would also
get if attending a wedding party.
GFM maintains a trade/error account at
Schwab.
material conflict of interest for GFM as the
receipt of such services from BlackRock
reduces GFM’s operating costs, which
creates an incentive for GFM to recommend
and utilize products sponsored or distributed
by BlackRock in the management of all
client accounts.
GFM may receive economic benefit from
Schwab in the form of reduced cost for
certain services. In addition, GFM clients
may receive reduced commissions and fees
with each custodian because GFM has
negotiated lower rates for all GFM clients.
Review of Accounts
GFM reviews portfolios with Clients who
are utilizing our Asset Management service
on an ongoing basis by the Investment
Committee and the assigned CFP®
Professional. Clients are advised that it is
their responsibility to notify GFM of any
material changes in their financial situation
or objectives. All Clients are encouraged to
review their financial situation, objectives,
and account performance with GFM at least
annually.
BlackRock Fund Advisors BlackRock Fund
Advisors (“BlackRock”, CRD No. 105247)
has granted GFM with access to its
Aladdin® Platform, a portfolio management
and risk analytics operating system, as well
as marketing support at no cost to GFM.
Investment models generated by the
Aladdin® Platform are used by GFM in the
development and maintenance of the Models
and their related series. BlackRock does not
provide and is not responsible for providing
investment advice to clients of GFM, does
not participate in or make any investment
decisions on behalf of GFM or clients of
GFM, does not endorse any investment
decision or recommendation made by GFM,
and has no obligation to continue to provide
GFM with its investment models and/or
access to the Aladdin® Platform. In addition
to investment research, models and/or
technology, BlackRock provides or may
provide discounted or free attendance to
conferences, meetings and other educational
or social events, which may include full
coverage of travel expenses to such events.
Clients should be aware that the receipt of
these benefits creates a conflict of interest
for GFM as it creates another incentive for
GFM to recommend the use of iShares ETFs
and/or other BlackRock products in the
investment management of client
accounts. GFM addresses these conflicts of
interest by (1) providing disclosure of the
relationship and the associated conflicts of
interest to clients in this Brochure and (2)
reminding clients that they have the ability
to impose reasonable restrictions on the
securities or types of securities to be held in
The development and maintenance of the
GFM Models, is materially supported by
BlackRock Fund Advisors and/or its
affiliates, including BlackRock Investments,
LLC (collectively, “BlackRock”), which
provides GFM with investment research,
model recommendations and marketing
support at no cost. Research and
recommendations provided by BlackRock to
GFM, however, predominantly favor the use
of iShares ETFs, which are distributed by
BlackRock. While GFM is under no
obligation to utilize iShares ETFs in the
management of the GFM Models, such
models will predominantly utilize iShares
ETFs in their construction. This creates a
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Form ADV Part 2A – January 2026
their portfolios, including a restriction on the
purchase and/or use of investment products
associated with BlackRock.
create a conflict of interest because these
donations could be interpreted as an attempt
to retain the advisory business of these
clients or that certain clients are favored
over other clients.
Clients are provided with monthly
statements from their custodian. GFM also
provides quarterly performance statements.
Most statements are provided in secure
Client Vaults to reduce our carbon print.
Client Referrals and Other
Compensation
It is GFM policy to not engage solicitors or
pay related or non-related persons for
referring potential clients to our firm.
Some of these charities include the Shruti
Foundation, Isaac Knapp Dental Society,
Jyothi Corporation, Center for Whitley
County Youth, Camp-Watcha-Wanna-Do
and the Fort Wayne Trails. This is not
intended to be an all-inclusive list and these
charities will change from year to year.
Although the conflict exists, GFM will
continue to contribute to these organizations
because the owners feel it is the right thing
to do to give back to the community.
Custody
It is GFM policy to not take physical
custody of Client assets. This is why we use
Schwab to custody client assets.
As discussed in the Brokerage Practices
section, GFM may receive indirect
economic benefit from Schwab. However, it
is our policy to not accept any other form of
compensation from a non-client in
conjunction with the advisory services that
we provide to our Clients.
GFM may reward employees with cash
bonuses for bringing on new business.
GFM gets written authority from Clients
during the account opening process to debit
Client fees directly from their investment
accounts. This alone does not mean that
GFM has custody of those Client assets.
GFM receives an economic benefit in the
form of support products and services it
makes available to us and other Advisors
that have their clients maintain their
accounts at Schwab. The availability and
economic benefit to GFM is not based on
giving particular investment advice, such as
buying particular securities.
Charitable Contributions
However, the SEC recently modified the
custody rule to include some situations in
which GFM is deemed to have “custody” of
Client assets. This can occur if the Client
has given GFM their web login credentials
for an outside account. Because GFM could
potentially change the address of record with
this information, GFM is deemed to have
“custody” of that account.
GFM has made contributions to charitable
organizations in the past and will likely
continue this support. GFM has clients that
are affiliated with these organizations. GFM
understands that these contributions could
As mentioned previously, GFM must hire an
accounting firm to conduct an annual
surprise examination to review the accounts
in which GFM has “custody”. GFM has
hired GBQ Partners to conduct these annual
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Form ADV Part 2A – January 2026
examinations. GFM must pay all fees
associated with these examinations.
bankruptcy proceedings or other type
events pertaining to the Client's
investment assets. Clients are
responsible for instructing each
custodian of their accounts to
forward to the Client copies of all
proxies and shareholder
communications relating to the
Client's investment assets.
All Clients receive statements and trade
confirmations from their custodians. Clients
are encouraged to review these statements
and trade confirmations to ensure accuracy.
Custodians do not calculate the GFM fee, so
it is important that Clients carefully review
their statements. Clients should contact
GFM directly if an error is identified.
Investment Discretion
Clients will receive their proxies directly
from their custodian. Clients may contact
GFM to inquire about the proxy. We do not
offer consulting assistance regarding proxy
votes.
Financial Information
GFM manages Asset Management accounts
on a discretionary basis. “Discretionary”
means that GFM’s Investment Committee
determines what, when and how much of
each investment to buy or sell without the
approval of the Client on each individual
transaction.
GFM does not have a financial condition to
report to Clients. GFM does not require
payment of fees more than 6 months in
advance of services rendered. Therefore, we
are not required to include a Financial
Statement with this Brochure.
GFM has not been the subject of a
bankruptcy petition.
Clients give GFM discretionary authority
when they sign our Asset Management
Agreement. The Client also gives GFM
discretion on the custodian application or
Limited Power of Appointment form.
Clients may amend or change these
discretionary instructions at any time by
contacting the custodian directly.
Voting Client Proxies
GFM does not vote proxies on behalf of
Clients. Clients maintain exclusive
responsibility for:
• Directing the manner in which
proxies elicited by issuers of
investments beneficially owned by
the Client shall be voted and
• Making all elections relative to
mergers, acquisitions, tender offers,
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