Overview

Assets Under Management: $497 million
Headquarters: PLYMOUTH, MN
High-Net-Worth Clients: 3
Average Client Assets: $44 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (ADV PART 2A)

MinMaxMarginal Fee Rate
$0 $500,000 1.30%
$500,001 $1,500,000 0.85%
$1,500,001 $2,500,000 0.70%
$2,500,001 $3,500,000 0.60%
$3,500,001 $5,000,000 0.50%
$5,000,001 $7,500,000 0.40%
$7,500,001 $10,000,000 0.30%
$10,000,001 and above Negotiable
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,750 1.08%
$5 million $35,500 0.71%
$10 million $53,000 0.53%
$50 million Negotiable Negotiable
$100 million Negotiable Negotiable

Clients

Number of High-Net-Worth Clients: 3
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 26.39
Average High-Net-Worth Client Assets: $44 million
Total Client Accounts: 2,126
Discretionary Accounts: 2,079
Non-Discretionary Accounts: 47

Regulatory Filings

CRD Number: 110179
Filing ID: 2005465
Last Filing Date: 2025-07-23 16:22:00
Website: https://genfinancial.com

Form ADV Documents

Primary Brochure: ADV PART 2A (2025-04-04)

View Document Text
GEN Financial Management, Inc. 10810 Old County Road 15, Suite 200 Plymouth, MN 55441 952-513-1466 www.genfinancial.com April 4, 2025 This Brochure provides information about the qualifications and business practices of GEN Financial Management, Inc. If you have any questions about the contents of this Brochure, please contact us at 952-513-1466. 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. GEN Financial Management, Inc. is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The information provided to you by an Adviser will allow you to determine whether to hire or retain the Adviser. Additional information about GEN Financial Management, Inc. is available on the SEC’s web site at www.adviserinfo.sec.gov. i 2 – Material Changes This section describes the material changes to GEN Financial Management, Inc.’s Part 2A of Form ADV (“Firm Brochure”) since its last annual update amendment on February 21, 2024. This Firm Brochure, dated April 4, 2025, has been prepared according to the U.S. Securities and Exchange Commission’s (SEC) disclosure requirements. In lieu of providing clients with an updated Firm Brochure each year, we may provide our advisory clients with a Summary describing any material changes occurring since the last annual update of our Part 2A Firm Brochure. We will make this delivery to clients within 120 days of the close of our fiscal year (December 31). Clients wishing to receive a complete copy of the current Part 2A Firm Brochure may request a copy at no charge by contacting the firm at 952-513-1466. There are no material changes to the Brochure since the last annual amendment filing Dated February 21, 2024. ii 3 -Table of Contents 2 – Material Changes ............................................................................................................................................ ii 3 -Table of Contents .............................................................................................................................................. ii 4 – Advisory Business .......................................................................................................................................... 4 5 – Fees and Compensation ............................................................................................................................... 4 6 – Performance-Based Fees and Side-By-Side Management .............................................................. 5 7 – Types of Clients ............................................................................................................................................... 6 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................... 6 9 – Disciplinary Information ............................................................................................................................. 7 10 – Other Financial Industry Activities and Affiliations ....................................................................... 7 11 – Code of Ethics ................................................................................................................................................ 7 12 – Brokerage Practices .................................................................................................................................... 8 The Custodian and Brokers We Use ........................................................................................................... 8 How We Select Brokers/Custodians .......................................................................................................... 9 Your Brokerage and Custody Costs ............................................................................................................ 9 Products and Services Available to Us From Schwab and/or Fidelity....................................... 10 Our Interest in Schwab and Fidelity’s Services .................................................................................. 11 13 – Review of Accounts .................................................................................................................................. 12 14 – Client Referrals and Other Compensation ....................................................................................... 12 15 – Custody ......................................................................................................................................................... 13 16 – Investment Discretion............................................................................................................................. 13 17 – Voting Client Securities .......................................................................................................................... 14 18 – Financial Information.............................................................................................................................. 14 iii 4 – Advisory Business ® ® , President, Aaron A. Lindberg, CFA, CFP ® , Vice President. GEN was founded in 1998 by Eric Moleski. Eric GEN Financial Management, Inc. (GEN) is a fee-only investment advisory firm owned by , Chief Investment Officer, Eric C. Moleski, CFP and Bryan L. Vancura, CFP has over 30 years of experience in financial planning and investment management. On April 1, 2018, GEN Financial Management, Inc. merged with Lindberg Financial Corporation. We provide comprehensive financial planning, asset allocation, estate planning, investment management and retirement planning services. Our advisory services are tailored to the individual needs of each client. An initial consultation includes the collection of specific financial data to serve as the foundation upon which to build a financial plan. Once the client’s investment portfolio type is determined (from conservative to aggressive) an Investment Policy Statement will be prepared to describe how the client’s investments will be managed. Every client has the ability to impose restrictions on investing in certain securities or types of securities. As of December 31, 2024, we managed $466,830,200 in client assets on a discretionary basis and $29,696,870 in client assets on a non-discretionary basis. 5 – Fees and Compensation Client accounts are charged a percentage of the assets under management. The specific manner in which fees are charged by us is established in your written agreement with us. Fees are billed on a quarterly basis, in advance, and deducted from your assets at the custodian. Management fees will be prorated for each capital contribution and withdrawal made during the applicable calendar quarter. Accounts initiated or terminated during a calendar quarter will be charged a prorated fee. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. 4 Graduated Billing Schedule Annual Rate 1.30% 0.85% 0.70% 0.60% 0.50% 0.40% 0.30% Negotiated for for for for for for for for Asset Range $0 – $500,000 $500,000 – $1,500,000 $1,500,000 – $2,500,000 $2,500,000 – $3,500,000 $3,500,000 - $5,000,000 $5,000,000 - $7,500,000 $7,500,000 - $10,000,000 $10,000,000 and above For example, the annualized fee for an account of $1,000,000 would be $10,750: $500,000 x 1.3% ($6,500) plus $500,000 x .85% ($4,250) = $10,750. The quarterly fee would be $10,750 divided by 4, or $2,687.50. In addition, an annual fixed fee of $1,000 ($250 per quarter) will be applied to accounts with less than $500,000 in assets under management. Fixed fees may be charged for written financial plans, which range from $1,500 to $15,000, depending on the complexity of your financial situation. Our fees are exclusive of transaction fees and other related costs and expenses which are incurred by you. You may incur certain charges imposed by custodians, brokers, third party investment advisors and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. We do not receive any portion of these commissions, fees, or expenses charged by third parties. If client terminates the Agreement, all prepaid fees will be refunded on a prorated basis within 3 weeks of the cancellation of the Agreement. See also Item 12 – Brokerage Practices, which further describes the factors that we consider in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g. commissions). 6 – Performance-Based Fees and Side-By-Side Management We do not charge performance-based fees (fees based on a share of capital gains on or capital appreciation of your assets). 5 7 – Types of Clients We provide investment advisory services to a select group of executives, business owners, families and individuals, including high net worth individuals, and to company retirement plans. 8 – Methods of Analysis, Investment Strategies and Risk of Loss We believe that the most effective means of managing client portfolios is through the use of model portfolios that allow some flexibility for client personalization. Our Investment Committee will occasionally adjust portfolio allocations to take advantage of sectors of the investment universe that it considers to be offering superior returns. We therefore minimize the use of individual stock picking techniques. Your portfolio will be periodically rebalanced when investments significantly deviate from the prescribed target allocations. Market fluctuations may cause your portfolio to deviate for short periods beyond the preferred upper or lower limits around the model's target allocations. Longer-term deviations may be experienced due to your individual investment preferences or portfolio requirements. We will seek to manage your portfolio as the prescribed model but cannot be held responsible for these deviations. Investments will be replaced when they no longer meet the criteria of our Investment Committee. We seek consistent, long-term performance in utilizing selected independent money managers, mutual funds, exchange traded funds, individual equities and bonds. Within each category, the Investment Committee will seek to identify the best investment manager based on its selection criteria. Some of the criteria used include long-term risk-weighted return compared to peers and the relevant benchmark, management expenses, asset turnover, manager tenure and manager style and investment constraints. When no manager meets our criteria for a category, we will opt to invest in a suitable index fund. We consider the most prudent investment strategy to be holding investments for the long term. We do not engage in market-timing and view such tactics as introducing unnecessary risk. Nonetheless, investing in securities involves risk of loss that you should be prepared to bear. The target allocations are managed on a portfolio level such that certain accounts may only hold a few investments. The main factors in choosing the appropriate account location for an investment are liquidity needs and tax efficiency. We will seek to be tax efficient by minimizing ordinary income in taxable accounts and harvesting capital losses. However, in making investment decisions, tax maneuvers will not override optimal portfolio allocation. 6 Client portfolios may include any of the following: mutual funds, exchange-traded funds, individual equities and bonds, real estate investment trusts, and money market funds. Depending on their investing focus, mutual funds and exchange-traded funds may be comprised of equities, bonds, commodities, real estate, hard assets, foreign currency and other investment instruments used by the managers of these funds to hedge risk and/or enhance investment return. The risks involved with these investments vary depending on the specific investment. Risks inherent to all investing include, but are not limited to, the following: volatility of investment value, uncertainty of future investment return, and lack of liquidity. Past performance of any investment is not a guarantee of future results, and we cannot guarantee that investment objectives will be attained. 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. We have no information applicable to this Item. 10 – Other Financial Industry Activities and Affiliations Neither Flynn Financial, LLC nor its representatives are registered as or have pending applications to become a broker/dealer or as representatives of a broker/dealer. Neither Flynn Financial, LLC nor its representatives are registered as or have pending applications to become a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor. We may recommend the services of independent Investment Advisors. In such instances, we do not share the fees charged by the independent Investment Advisors. A “Compensation Disclosure Statement” and the Advisor’s Form ADV will be provided to you. You are under no obligation to use the services of independent Advisor(s) we recommend. Separate account managers are accessible via our relationships with Schwab Advisor Services and Fidelity Wealthscape. Full disclosure will be provided at the time of solicitation pursuant to Rule 206(4)-3 of the Investment Advisors Act of 1940. 11 – Code of Ethics We have adopted a Code of Ethics for all employees of the firm describing its high standard 7 of business conduct and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All employees must acknowledge the terms of the Code of Ethics annually, or as amended. We anticipate that, in appropriate circumstances, consistent with your investment objectives, we will recommend to you the purchase or sale of securities in which our employees and/or clients, directly or indirectly, have a position of interest. Our employees and persons associated with us are required to follow our Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees may purchase or sell securities in their own accounts that we recommend to and/or purchase for you. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. In addition, the Code requires pre- clearance of many transactions and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics to reasonably prevent conflicts of interest between us and our clients. You may request a copy of our Code of Ethics by contacting the firm at 952-513-1466. 12 – Brokerage Practices The Custodians and Brokers We Use We do not maintain custody of your assets that we manage, although we may be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see item 15 – Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member SIPC, or Fidelity Investments Institutional Services Company (Fidelity), also a registered broker- dealer, member SIPC, as the qualified custodian. We are independently owned and operated and not affiliated with Schwab or Fidelity. Schwab and/or Fidelity will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab or Fidelity as custodian/broker, you will decide whether to do so and will open your account with 8 Schwab or Fidelity by entering into an account agreement directly with them. We do not open the account for you, although we will assist you in doing so. Even though your account is maintained at Schwab or Fidelity, we can still use other brokers to execute trades for your account as described below (see “Your Brokerage and Custody Costs”). How We Select Brokers/Custodians We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange- traded funds [ETFs], etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices • Reputation, financial strength, and stability • Prior service to us and our clients • Availability of other products and services that benefit us, as discussed below (see “Products and Services Available to Us From Schwab and/or Fidelity”) Your Brokerage and Custody Costs Schwab and Fidelity generally do not charge clients separately for custody services but are compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab or Fidelity account. Schwab and Fidelity commission rates applicable to our client accounts were negotiated based on the condition that our clients collectively maintain a total of at least $10,000,000 of their assets in accounts at Schwab and Fidelity, respectively. This commitment benefits you because the overall commission 9 rates you pay are lower than they would be otherwise. In addition to commissions, Schwab or Fidelity charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab or Fidelity account. These fees are in addition to the commission or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab or Fidelity execute most trades for your account. We have determined that having Schwab or Fidelity execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How We Select Brokers/ Custodians”). TM (formerly called Schwab Institutional ) and Fidelity Products and Services Available to Us from Schwab and/or Fidelity ® Schwab Advisor Services Wealthscape® serve independent investment advisory firms like us. They provide us and our clients with access to their institutional brokerage services such as trading, custody, reporting, and related services – many of which are not typically available to Schwab or Fidelity retail customers. Schwab and Fidelity also make available various support services. Some of those services help us manage or administer our clients’ accounts; while others help us manage and grow our business. These support services generally are available on an unsolicited basis (we don’t have to request them) and at no charge to us as long as our clients collectively maintain a total of at least $10 million of their assets in accounts at each custodian. If our clients collectively have less than $10 million in assets at Schwab, Schwab may charge us quarterly service fees of $1,200. Following is a more detailed description of Schwab and Fidelity’s support services: Services That Benefit You. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Fidelity’s institutional brokerage services offers similar benefits. Services That May Not Directly Benefit You. Schwab and Fidelity also make available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include both Schwab and Fidelity’s investment research and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab or Fidelity. In addition to investment research, Schwab and Fidelity also make available software and other technology that: 10 • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients’ accounts • Assist with back-office functions, recordkeeping, and client reporting Services That Generally Benefit Only Us. Schwab and Fidelity also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology, compliance, legal, and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers Schwab or Fidelity may directly provide some of these services to us. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits, such as occasional business entertainment of our personnel. Our Interest in Schwab and Fidelity’s Services The availability of these services from Schwab and Fidelity benefits us because we do not have to produce or purchase them. We don’t have to pay for these services so long as our clients collectively keep a total of at least $10 million of their assets in accounts at each custodian. Beyond that, these services are not contingent upon us committing any specific amount of business to Schwab or Fidelity in trading commissions or assets in custody. The $10 million minimum may give us an incentive to recommend that you maintain your account with Schwab or Fidelity, based on our interest in receiving Schwab and Fidelity’s services that benefit our business, rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab or Fidelity as custodian and broker is in the best interests of our clients. Our selection is primarily 11 supported by the scope, quality, and price of Schwab’s and Fidelity’s services (see “How We Select Brokers/Custodians”) and not Schwab’s or Fidelity’s services that benefit only us. We have $387,649,000 in client assets under management, and we do not believe that recommending our clients to collectively maintain at least $10 million of those assets at Schwab or Fidelity to avoid paying quarterly service fees presents a material conflict of interest. 13 – Review of Accounts ® ® , and/or Taylor Karels, CFP review all client accounts on a Investment accounts are reviewed periodically and at least quarterly. Financial plans are ® , President, Aaron A. Lindberg, CFA, CFP , reviewed at least annually. Eric C. Moleski, CFP ® , Financial Advisor, Joshua M. Moklestad, Chief Investment Officer, Bryan L. Vancura, CFP ® Financial Advisor, CFP portfolio basis. We provide reports to you on a quarterly basis that include portfolio investment return and the asset allocation of your holdings. 14 – Client Referrals and Other Compensation We receive an economic benefit from Schwab and Fidelity in the form of the support products and services they make available to us and other independent investment advisors whose clients maintain their accounts at Schwab or Fidelity. These products and services, how they benefit us, and the related conflicts of interest are described above (see item 12 – Brokerage Practices). The availability to us of Schwab and Fidelity’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Our firm may engage in promoter arrangements for client referrals. The Firm pays a referral fee to the promoter based on a portion of the management fees charged by the Firm and memorialized in a written agreement (“Promoter Agreement”). All fees are paid by us pursuant to the written promoter’s agreement, to be retained by both the promoter and us. All applicable federal and state laws are observed. All clients referred to us by promoters are given full written disclosure describing the terms and fee arrangements between us and the promoter prior to or at the time of entering into the advisory agreement with us. 12 15 – Custody Under government regulations, we are deemed to have custody of your assets if, for example, you authorize us to instruct Schwab or Fidelity to deduct our advisory fees directly from your account, or if you grant us authority to move your money from your account to another account that does not have the same registration. Schwab or Fidelity maintains actual custody of your assets. Frequently we will provide a comprehensive financial plan that includes 401(k) plan or other retirement plan assets maintained directly with the plan sponsor or a custodian selected by the plan sponsor. To enable us to determine the details of the 401(k) or other retirement plan assets, monitor changes in market value and implement investment management strategies or rebalance the portfolio, clients may grant us with online access to the account. Under these circumstances, we are deemed to have custody of the assets and we have an obligation to contract with an approved public accounting firm to conduct an annual surprise audit to verify the assets in each account over which we have online access. You will receive account statements directly from Schwab, Fidelity, or your 401(k) or other retirement plan custodian, at least quarterly. The statements will be sent to the email or postal mailing address you provided to Schwab, Fidelity, or the retirement plan administrator. You should carefully review those statements promptly when you receive them. We also urge you to compare Schwab or Fidelity’s account statements to the quarterly statements you will receive from us. 16 – Investment Discretion We receive written discretionary authority from each client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. When selecting securities and determining amounts, we observe the investment policies, limitations and restrictions set by you. We believe that the most effective means of managing your portfolio is through the use of model portfolios that allow some flexibility for client personalization. Our Investment Committee will occasionally adjust portfolio allocations to take advantage of sectors of the investment universe that it considers to be offering superior returns. We therefore minimize the use of individual stock picking techniques. Investment guidelines and restrictions must be provided to us in writing. 13 17 – Voting Client Securities As a matter of firm policy and practice, we do not have any authority to and do not vote proxies on your behalf. You retain the responsibility for receiving and voting proxies for any and all securities maintained in your portfolio. If you request that we do so, we may provide advice regarding your voting of proxies. 18 – Financial Information Registered investment advisers are required to provide you with certain financial information or disclosures about our financial condition. We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to you and have never been the subject of a bankruptcy proceeding. GEN applied for and received a Paycheck Protection Program loan as a hedge against the then unknown effects of the global Covid-19 pandemic on the business. The loan was forgiven in 2020. The firm remains in a strong financial position. 14 ® ® ® Eric C. Moleski, CFP , AIF , CKA GEN Financial Management, Inc. 10810 Old County Road 15, Suite 200 Plymouth, MN 55441 952-513-1466 This Brochure Supplement provides information about Eric C. Moleski that April 4, 2025 supplements the GEN Financial Management, Inc. Brochure. You should have received a copy of that Brochure. Please contact the firm at 952-513-1466 if you did not receive GEN Financial Management, Inc.’s Brochure or if you have any questions about the contents of this supplement. 2 - Educational Background and Business Experience Eric was born in 1963. In 1988 he graduated from the University of Wisconsin-Stout with a BS degree in Business Administration. He also received a one-year diploma in International Business from University College of Wales Aberystwyth (now Aberystwyth University) in 1987. ® ® ), an Accredited Investment Fiduciary (AIF) and ® ). Eric is a Certified Financial Planner (CFP a Certified Kingdom Advisor (CKA ® ® ® , AIF and CKA designations: Following are the certification requirements for the CFP ® and federally registered CFP (with flame ® marks”) are professional certification marks granted The CERTIFIED FINANCIAL PLANNER™, CFP design) marks (collectively, the “CFP in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). ® ® certification is a voluntary certification; no federal or state law or regulation certification. It is recognized in the United ® certification in the United States. The CFP requires financial planners to hold the CFP States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 72,000 individuals have obtained CFP 15 ® marks, an individual must satisfactorily fulfill the To attain the right to use the CFP following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • ® • Examination – Pass the comprehensive CFP Certification Examination. The six hour examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Standards of Professional Conduct , a set of ® professionals. Ethics – Agree to be bound by CFP Board’s documents outlining the ethical and practice standards for CFP ® Individuals who become certified must complete the following ongoing education and marks: ethics requirements in order to maintain the right to continue to use the CFP • Code of Ethics Standards of Continuing Education – Complete 30 hours of continuing education hours every two Professional Conduct years, including two hours on the and other parts of the , to maintain competence and keep up with developments in the financial planning field; and • Standards of Professional Conduct . ® professionals provide financial ® professionals Ethics – Renew an agreement to be bound by the The Standards prominently require that CFP planning services at a fiduciary standard of care. This means CFP must provide financial planning services in the best interests of their clients. ® professionals who fail to comply with the above standards and requirements may be ® certification. CFP subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP ® , Accredited Investment Fiduciary designation is issued by Fiduciary360. The AIF There are no prerequisites required. 16 Educational Requirements: Those who earn the AIF mark successfully complete a specialized program on investment fiduciary standards of care and subsequently pass a comprehensive examination. AIF designees demonstrate a thorough understanding of fi360's Prudent Practices for investment advisors and stewards. Continuing Education/Experience Requirements: Six hours of continuing professional education annually. ® , Certified Kingdom Advisor designation is issued by Kingdom Advisors. Kingdom The CKA Advisors' began in 1997 with the formation of the Christian Financial Planning Institute (CFPI). In 2003, the organization would take the lead in reaching out to the Christian financial professional community. Originally known as the Christian Financial Professionals Network (CFPN), in 2007 it was re-named Kingdom Advisors. ® Kingdom Advisors is a growing community serving the public by promoting the integration of a biblical worldview into financial practices. It offers training, community, advocacy, and designation, distinction to financial professionals. Through the Certified Kingdom Advisor a principled class of biblically-wise financial advisors are certified to a marketplace that is longing for contentment and purpose in their financial dealings. Requirements for the Financial Planner Discipline: Type of Practice: Comprehensive Financial Planning Experience Requirement: 10 years full-time experience* OR one of the following professional designations: CFP®, ChFC®, CPA/PFS Definition: The process of determining whether and how an individual can meet life goals through the proper management of financial resources. Financial planning integrates the financial planning process with the financial planning subject areas outlined by the CFP® Board of Standards: 1. 2. 3. 4. 5. 6. 7. Financial statement preparation and analysis (including cash flow analysis/planning and budgeting) Insurance planning and risk management Employee benefits planning Investment planning Income tax planning Retirement planning Estate planning Requirements for the Investment Professional Discipline: Type of Practice: Investment Management Experience Requirement: 10 years full-time experience OR one of the following professional designations: CFP®, ChFC®, CPA/PFS, CFA®, CIMA, AAMS® Definition: An investment professional provides professional expertise to the management of investment assets held in retirement accounts, trusts, individual and joint accounts. This 17 type of advisor is registered with the SEC/CSA or State and “flat fee” paid for advice, or they are registered with a Broker Dealer and paid on a commission basis. Applicants must enroll in and complete the CKA® Educational Program and take the tests accompanying each session and complete the CKA® Educational Program within six months of registering for the course. ® ® , ChFC ® ® , AAMS, CLU , CPA, CPA/PFS, EA, , FIC, JD, or hold 10 years of experience in the discipline in which ® designation. These disciplines include After successfully completing the CKA® Educational Program, applicants are allowed to sit for the CKA® Program Proctored Exam. The exam is delivered online and monitored by live proctors. Applicants for the designation must receive an 80% passing grade on the proctored exam. Applicants complete the Certified Kingdom Advisor application. Applicants must either hold one of the following industry approved designations: CFP CFA, CIMA applying for the Certified Kingdom Advisor insurance, investments, accounting, law, and financial planning. ® and Certification holders must maintain active status as a Certified Kingdom Advisor maintain ongoing annual compliance requirements. Annual renewal requirements include completion of 10 hours continuing education with Kingdom Advisors, Inc. GEN Financial Management, Inc. was founded in 1998 by Eric C. Moleski, President and Chief Executive Officer. Eric continues to build the client base and increase assets under management. 3 - Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. 4 - Other Business Activities Registered investment advisers are required to disclose information regarding any other investment related business or occupation. No information is applicable to this Item. 5 - Additional Compensation No additional economic benefits are received from non-clients for providing advisory services. 6 - Supervision Weekly Investment Committee meetings and weekly reviews of all materials prepared for upcoming client meetings incorporate oversight of the financial planning and investment advice provided. Eric Moleski is the CCO of the firm and can be contacted at 952-513-1466. 18 ® ® Aaron A. Lindberg, CFA, CFP , CKA, CAP GEN Financial Management, Inc. 10810 Old County Road 15, Suite 200 Plymouth, MN 55441 952-513-1466 This Brochure Supplement provides information about Aaron A. Lindberg that April 4, 2025 supplements the GEN Financial Management, Inc. Brochure. You should have received a copy of that Brochure. Please contact the firm at 952-513-1466 if you did not receive GEN Financial Management, Inc.’s Brochure or if you have any questions about the contents of this supplement. 2 - Educational Background and Business Experience Aaron was born in 1974. In 1998 he graduated from the Carlson School of Management at the University of Minnesota with a BS degree in Finance. He also received a Master of Business Administration degree in Finance from the University of St. Thomas in 2001. ® ), a Chartered Financial Analyst (CFA) Aaron is a Certified Financial Planner (CFP charterholder and a Certified Kingdom Advisor (CKA). ® Following are the certification requirements for the CFP and CFA designations: ® and federally registered CFP (with flame ® marks”) are professional certification marks granted The CERTIFIED FINANCIAL PLANNER™, CFP design) marks (collectively, the “CFP in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). ® ® certification is a voluntary certification; no federal or state law or regulation certification. It is recognized in the United ® certification in the United States. The CFP requires financial planners to hold the CFP States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 72,000 individuals have obtained CFP 19 ® marks, an individual must satisfactorily fulfill the To attain the right to use the CFP following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • ® • Examination – Pass the comprehensive CFP Certification Examination. The six hour examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Standards of Professional Conduct , a set of ® professionals. Ethics – Agree to be bound by CFP Board’s documents outlining the ethical and practice standards for CFP ® Individuals who become certified must complete the following ongoing education and marks: ethics requirements in order to maintain the right to continue to use the CFP • Code of Ethics Standards of Continuing Education – Complete 30 hours of continuing education hours every two Professional Conduct years, including two hours on the and other parts of the , to maintain competence and keep up with developments in the financial planning field; and • Standards of Professional Conduct . ® professionals provide financial ® professionals Ethics – Renew an agreement to be bound by the The Standards prominently require that CFP planning services at a fiduciary standard of care. This means CFP must provide financial planning services in the best interests of their clients. ® professionals who fail to comply with the above standards and requirements may be ® certification. CFP subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP Following are the certification requirements for the CFA designation: The CFA, Chartered Financial Analyst designation is issued by the CFA Institute. The following Prerequisites are required for the designation: 20 Candidate must meet one of the following requirements: • Undergraduate degree and four years of professional experience involving investment decision-making, or • Four years qualified work experience (full time, but not necessarily investment related) Educational Requirements: Self study program (250 hours of study for each of the three levels) Examination Type: Three course exams Continuing Education/Experience Requirements: None ® , Certified Kingdom Advisor designation is issued by Kingdom Advisors. Kingdom The CKA Advisors' began in 1997 with the formation of the Christian Financial Planning Institute (CFPI). In 2003, the organization would take the lead in reaching out to the Christian financial professional community. Originally known as the Christian Financial Professionals Network (CFPN), in 2007 it was re-named Kingdom Advisors. ® Kingdom Advisors is a growing community serving the public by promoting the integration of a biblical worldview into financial practices. It offers training, community, advocacy, and designation, distinction to financial professionals. Through the Certified Kingdom Advisor a principled class of biblically-wise financial advisors are certified to a marketplace that is longing for contentment and purpose in their financial dealings. Requirements for the Financial Planner Discipline: Type of Practice: Comprehensive Financial Planning Experience Requirement: 10 years full-time experience* OR one of the following professional designations: CFP®, ChFC®, CPA/PFS Definition: The process of determining whether and how an individual can meet life goals through the proper management of financial resources. Financial planning integrates the financial planning process with the financial planning subject areas outlined by the CFP® Board of Standards: 1. 2. 3. 4. 5. 6. 7. Financial statement preparation and analysis (including cash flow analysis/planning and budgeting) Insurance planning and risk management Employee benefits planning Investment planning Income tax planning Retirement planning Estate planning 21 Requirements for the Investment Professional Discipline: Type of Practice: Investment Management Experience Requirement: 10 years full-time experience OR one of the following professional designations: CFP®, ChFC®, CPA/PFS, CFA®, CIMA, AAMS® Definition: An investment professional provides professional expertise to the management of investment assets held in retirement accounts, trusts, individual and joint accounts. This type of advisor is registered with the SEC/CSA or State and “flat fee” paid for advice, or they are registered with a Broker Dealer and paid on a commission basis. Applicants must enroll in and complete the CKA® Educational Program and take the tests accompanying each session and complete the CKA® Educational Program within six months of registering for the course. ® ® , ChFC ® ® , AAMS, CLU , CPA, CPA/PFS, EA, , FIC, JD, or hold 10 years of experience in the discipline in which ® designation. These disciplines include After successfully completing the CKA® Educational Program, applicants are allowed to sit for the CKA® Program Proctored Exam. The exam is delivered online and monitored by live proctors. Applicants for the designation must receive an 80% passing grade on the proctored exam. Applicants complete the Certified Kingdom Advisor application. Applicants must either hold one of the following industry approved designations: CFP CFA, CIMA applying for the Certified Kingdom Advisor insurance, investments, accounting, law, and financial planning. ® and Certification holders must maintain active status as a Certified Kingdom Advisor maintain ongoing annual compliance requirements. Annual renewal requirements include completion of 10 hours continuing education with Kingdom Advisors, Inc. A Chartered Advisor in Philanthropy is a trained expert in philanthropic giving who works with clients to help them give in ways that fit their larger financial or estate plan. The Chartered Advisor in Philanthropy (CAP) program is a year-long program offered to professional advisors that provides participants with the knowledge, resources, and tools necessary to help clients reach their charitable giving objectives, while also helping them meet their estate planning and wealth planning goals. The Chartered Advisor in Philanthropy (CAP®) program offers several benefits to professional advisors and their clients. Some of the benefits include: 1. Expertise in Philanthropic Giving: CAPs are trained experts in philanthropic giving who can help clients give in ways that align with their larger financial or estate plan. 2. Charitable Giving Objectives: CAPs assist clients in reaching their charitable giving objectives while also helping them meet their estate planning and wealth management goals. The Chartered Advisor in Philanthropy® (CAP®) designation, administered through The American College of Financial Services, demonstrates you have the knowledge and tools to help clients articulate and advance their highest aspirations for self, family and society. 22 The CAP® program consists of graduate-level courses which can be used for credit toward a Master of Science in Financial Services degree. The CAP® program is designed for self- study, leading to an objective exam in a local exam center. Upon earning the CAP® designation, these professionals are equipped to take their seat at 3 - Disciplinary Information the planning table where wealthy families plan their legacies. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. Aaron Lindberg incurred a tax lien for untimely income tax payments from 2013 to 2016. The lien was satisfied April 1, 2021. 4 - Other Business Activities Registered investment advisers are required to disclose information regarding any other investment related business or occupation. No information is applicable to this Item. 5 - Additional Compensation No additional economic benefits are received from non-clients for providing advisory services. 6 - Supervision Aaron Lindberg is supervised by Eric C. Moleski, President, 952-513-1466. 23 ® Bryan L. Vancura, CFP GEN Financial Management, Inc. 10810 Old County Road 15, Suite 200 Plymouth, MN 55441 952-513-1466 This Brochure Supplement provides information about Bryan L. Vancura that April 4, 2025 supplements the GEN Financial Management, Inc. Brochure. You should have received a copy of that Brochure. Please contact the firm at 952-513-1466 if you did not receive GEN Financial Management, Inc.’s Brochure or if you have any questions about the contents of this supplement. 2 - Educational Background and Business Experience Bryan was born in 1987. Bryan earned a BS in Finance – with an emphasis on personal financial planning and insurance – and minors in Economics and Business Administration from Minnesota State University, Mankato in 2010. Bryan obtained his CERTIFIED FINANCIAL PLANNER™ designation in 2016. ® Following are the certification requirements for the CFP designation: ® and federally registered CFP (with flame ® marks”) are professional certification marks granted The CERTIFIED FINANCIAL PLANNER™, CFP design) marks (collectively, the “CFP in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). ® ® certification is a voluntary certification; no federal or state law or regulation certification. It is recognized in the United ® certification in the United States. The CFP requires financial planners to hold the CFP States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 72,000 individuals have obtained CFP ® marks, an individual must satisfactorily fulfill the To attain the right to use the CFP following requirements: 24 • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • ® Examination – Pass the comprehensive CFP Certification Examination. The six hour examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Standards of Professional Conduct , a set of ® Ethics – Agree to be bound by CFP Board’s documents outlining the ethical and practice standards for CFP professionals. ® Individuals who become certified must complete the following ongoing education and marks: ethics requirements in order to maintain the right to continue to use the CFP • Code of Ethics Standards of Continuing Education – Complete 30 hours of continuing education hours every two Professional Conduct years, including two hours on the and other parts of the , to maintain competence and keep up with developments in the financial planning field; and • Standards of Professional Conduct . ® professionals provide financial ® professionals Ethics – Renew an agreement to be bound by the The Standards prominently require that CFP planning services at a fiduciary standard of care. This means CFP must provide financial planning services in the best interests of their clients. ® professionals who fail to comply with the above standards and requirements may be ® certification. CFP subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP Bryan was hired by GEN Financial Management, Inc. in May 2015 as a Financial Advisor to provide financial planning services to the client base. Bryan is also a member of the Investment Committee. Effective May 1, 2019, Bryan became a minor owner of GEN Financial. Bryan was a Junior Associate with Affiance Financial, LLC from 2012 to 2015. 25 3 - Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. 4 - Other Business Activities Registered investment advisers are required to disclose information regarding any other investment related business or occupation. No information is applicable to this Item. 5 - Additional Compensation No additional economic benefits are received from non-clients for providing advisory services. 6 - Supervision GEN Financial Management Inc. has an Investment Committee, of which Bryan is a member, that conducts weekly meetings to: 1) Assess market-related topics such as the economy, geopolitical concerns, and valuation; 2) Review all GEN Financial Management, Inc. model portfolio holdings as well as non-model portfolio holdings for GEN Financial Management Inc. clients; and 3) Address any trading and miscellaneous account matters. In addition to this weekly Investment Committee meeting, periodic meetings are held with Bryan to review all investment-related reports and materials prepared for clients. Bryan Vancura is supervised by Eric C. Moleski, President, 952-513-1466. 26 ® ® Joshua M. Moklestad, CFP CIMA GEN Financial Management, Inc. 10810 Old County Road 15, Suite 200 Plymouth, MN 55441 952-513-1466 This Brochure Supplement provides information about Joshua M. Moklestad that April 4, 2025 supplements the GEN Financial Management, Inc. Brochure. You should have received a copy of that Brochure. Please contact the firm at 952-513-1466 if you did not receive GEN Financial Management, Inc.’s Brochure or if you have any questions about the contents of this supplement. 2 - Educational Background and Business Experience Josh was born in 1989. Josh graduated summa cum laude from Grand View University in 2012 with dual majors in Business Administration, with concentrations in finance and management, and Accounting. He also obtained a M.A. in Theological Studies from Midwestern Baptist Theological Seminary in 2016. ® Josh completed the Financial Planning Certificate Program from Minnesota State University, Mankato in 2021. This fulfills the educational requirements to sit for the CFP exam. Josh obtained his CERTIFIED FINANCIAL PLANNER™ designation in July 2021. Josh has also obtained the CIMA® designation as a Certified Investment Management Analyst. ® designation: Following are the certification requirements for the CFP ® and federally registered CFP (with flame ® marks”) are professional certification marks granted The CERTIFIED FINANCIAL PLANNER™, CFP design) marks (collectively, the “CFP in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). ® ® certification is a voluntary certification; no federal or state law or regulation certification. It is recognized in the United ® certification in the United States. The CFP requires financial planners to hold the CFP States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 72,000 individuals have obtained CFP 27 ® marks, an individual must satisfactorily fulfill the To attain the right to use the CFP following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • ® • Examination – Pass the comprehensive CFP Certification Examination. The six hour examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Standards of Professional Conduct , a set of ® professionals. Ethics – Agree to be bound by CFP Board’s documents outlining the ethical and practice standards for CFP ® Individuals who become certified must complete the following ongoing education and marks: ethics requirements in order to maintain the right to continue to use the CFP • Code of Ethics Standards of Continuing Education – Complete 30 hours of continuing education hours every two Professional Conduct years, including two hours on the and other parts of the , to maintain competence and keep up with developments in the financial planning field; and • Standards of Professional Conduct . ® professionals provide financial ® professionals Ethics – Renew an agreement to be bound by the The Standards prominently require that CFP planning services at a fiduciary standard of care. This means CFP must provide financial planning services in the best interests of their clients. ® professionals who fail to comply with the above standards and requirements may be ® certification. CFP subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP designation: Following are the certification requirements for the CIMA® The CIMA® designation is centered on the application of advanced portfolio construction and investment management theory. It teaches professionals how to integrate a complex body of investment knowledge, ethically contributing to prudent investment decisions by 28 providing objective advice and guidance to individuals and institutional investors. This designation signifies that an individual has met initial and on-going experience, ethical, education and examination requirements. Prerequisites for the CIMA® certification are three years of financial services experience and an acceptable regulatory history. Candidates must pass an on-line qualification examination, successfully complete an in- classroom executive education program, and successful completion of a comprehensive final examination. CIMA® designees are required to adhere to the Investments and Wealth Institute Code of Professional Responsibility and Rules and Guidelines for Use of the Marks and must report 40 hours of continuing education credits, including two ethics hours, every two years to maintain the certification. The designation is administered through the Investments and Wealth Institute. For more details, please see: www.investmentsandwealth.org/certifications/welcome-to-cima/cima-faqs. Josh was hired by GEN Financial Management, Inc. in April 2019 as a Financial Planning Analyst to provide support to the Financial Advisors and clients and has since been beginning to also provide financial planning services to the client base. Josh is also a member of the Investment Committee. Josh was a Financial Advisor with Northwestern Mutual from 2018 to 2019. 3 - Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. 4 - Other Business Activities Registered investment advisers are required to disclose information regarding any other investment related business or occupation. No information is applicable to this Item. 5 - Additional Compensation No additional economic benefits are received from non-clients for providing advisory services. 6 - Supervision GEN Financial Management Inc. has an Investment Committee, of which Josh is a member, that conducts weekly meetings to: 1) Assess market-related topics such as the economy, geopolitical concerns, and valuation; 2) Review all GEN Financial Management, Inc. model portfolio holdings as well as non-model portfolio holdings for GEN Financial Management Inc. clients; and 3) Address any trading and miscellaneous account matters. In addition to this weekly Investment Committee meeting, periodic meetings are held with Josh to review all investment-related reports and materials prepared for clients. Joshua Moklestad is supervised by Eric C. Moleski, President, 952-513-1466.d 29