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ITEM 1 – COVER PAGE
BCGM WEALTH MANAGEMENT, LLC
Doing Business As
Gettings Busch Wealth Management
and
Aurora Financial Strategies
PART 2A – FIRM BROCHURE
FEBRUARY 19, 2026
BCGM WEALTH MANAGEMENT, LLC
672 MAIN STREET SUITE 300
LAFAYETTE, IN 47901
Office: 765-742-7366
This brochure provides information about the qualifications and business practices of BCGM Wealth
Management, LLC (“BCGM”). If the client has any questions about the contents of this brochure, please
contact us at 765-742-7366. 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. BCGM is a
Registered Investment Adviser. Registration as an Investment Adviser with the United States Securities and
Exchange Commission or any state securities authority does not imply a certain level of skill or training.
Additional information about BCGM is available on the SEC’s website at www.adviserinfo.sec.gov. The
client can search this site by a unique identifying number, known as an IARD number. The IARD number for
BCGM is 306757.
ITEM 2 – MATERIAL CHANGES
SUMMARY OF MATERIAL CHANGES
This section of the Brochure will address only those “material changes” that have been incorporated since
our
last delivery or posting of this document on the SEC’s public disclosure website (IAPD)
www.adviserinfo.sec.gov.
No material changes have been made to this brochure since its last filing in March 2025.
Currently, a free copy of our Brochure can be requested by contacting Scott C. Busch at 765-742-7366.
We encourage the client to read this document in its entirety.
BCGM WEALTH MANAGEMENT, LLC
FEBRUARY 2026 | PAGE 1
ITEM 3 – TABLE OF CONTENTS
ITEM 1 – COVER PAGE
0
ITEM 2 – MATERIAL CHANGES
1
ITEM 3 – TABLE OF CONTENTS
2
ITEM 4 – ADVISORY BUSINESS
3
ITEM 5 - FEES AND COMPENSATION
8
ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT
11
ITEM 7 - TYPES OF CLIENTS
11
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
11
ITEM 9 - DISCIPLINARY INFORMATION
16
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
16
ITEM 11 - CODE OF ETHICS
17
ITEM 12 - BROKERAGE PRACTICES
18
ITEM 13 - REVIEW OF ACCOUNTS
23
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
23
ITEM 15 – CUSTODY
24
ITEM 16 – INVESTMENT DISCRETION
25
ITEM 17 – VOTING CLIENT SECURITIES
25
ITEM 18 – FINANCIAL INFORMATION
26
BCGM WEALTH MANAGEMENT, LLC
FEBRUARY 2026 | PAGE 2
ITEM 4 – ADVISORY BUSINESS
This Disclosure document is being offered to the client by BCGM Wealth Management, LLC (“BCGM” or
“Firm”) about the investment advisory services we provide. It discloses information about our services and
the way those services are made available to the client.
We are an investment management firm located in Indiana. We specialize in investment advisory services
for individuals, high net worth individuals, foundations, employee sponsored retirement plans, charitable
organizations, trusts, and corporations. Our Firm became a registered investment adviser in January 2020
and is owned by William P. Gettings, Scott C. Busch, and William J. Cardwell. Andrew Armstrong is the Chief
Compliance Officer. BCGM is doing business as Gettings Busch Wealth Management located at 672 Main St
#300, Lafayette, IN 47901. In addition, BCGM is also doing business as Aurora Financial Strategies located
at 2705 S Berkley Rd #1b, Kokomo, IN 46902.
We are committed to helping clients build, manage and preserve their wealth, and to provide assistance
that helps clients to achieve their stated financial goals. We will offer an initial complimentary meeting upon
our discretion; however, investment advisory services are initiated only after the client and BCGM execute
an Investment Management Agreement.
INVESTMENT AND WEALTH MANAGEMENT AND SUPERVISION SERVICES
We manage advisory accounts on a discretionary and non-discretionary basis. For discretionary accounts,
once we have determined a profile and investment plan with a client, we will execute the day to day
transactions without seeking prior client consent. Account supervision is guided by the written profile and
investment plan of the client. We can accept accounts with certain restrictions, if circumstances warrant.
We primarily allocate client assets among various equities, Exchanged Traded Funds (“ETFs”), no-load or
load-waived mutual funds, or alternative investments in accordance with their stated investment
objectives.
During personal discussions with clients, we determine the client’s objectives, time horizons, risk tolerance,
and liquidity needs. As appropriate, we also review a client’s prior investment history, as well as family
composition and background. Based on client needs, we develop a client’s personal profile and investment
plan. We then create and manage the client’s investments based on that policy and plan. It is the client’s
obligation to notify us immediately if circumstances have changed with respect to their goals.
Once we have determined the types of investments to be included in the client’s portfolio and allocated
them, we will provide ongoing investment review and management services. This approach requires us to
periodically review the client’s portfolio.
With our discretionary relationship, we will make changes to the portfolio, as we deem appropriate, to
meet the client’s financial objectives. We trade these portfolios based on the combination of our market
views and the client’s objectives, using our investment process. We tailor our advisory services to meet the
needs of our clients and seek to ensure that the client’s portfolio is managed in a manner consistent with
those needs and objectives. The client will have the ability to leave standing instructions with us to refrain
from investing in particular industries or invest in limited amounts of securities.
If a non-discretionary relationship is in place, clients will be contacted for prior approval before action is
taken on the client’s behalf.
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In all cases, the client has a direct and beneficial interest in the client’s securities, rather than an undivided
interest in a pool of securities. We do have limited authority to direct the Custodian to deduct our
investment advisory fees from the client’s accounts, but only with the appropriate written authorization
from the client.
Where appropriate, we provide advice about any type of legacy position held in client portfolios. Typically,
these are assets that are ineligible to be custodied at our primary custodian. Clients will engage us to advise
on certain investment products that are not maintained at their primary custodian, such as variable life
insurance, annuity contracts, and assets held in employer sponsored retirement plans and qualified tuition
plans (i.e., 529 plans).
The client is advised and is expected to understand that our past performance is not a guarantee of future
results. Certain market and economic risks exist that adversely affect an account’s performance. This could
result in capital losses in the client’s account.
FINANCIAL INSTITUTION CONSULTING SERVICES
BCGM provides investment consulting services to certain broker dealer customers who provide a written
consent requesting to receive the firm’s consulting services. The broker dealer customers have entered
into a written advisory agreement with BCGM.
FINANCIAL PLANNING & CONSULTING
Through the financial planning process, our team strives to engage our clients in conversations around the
family’s goals, objectives, priorities, vision, and legacy – both for the near term as well as for future
generations. With the unique goals and circumstances of each family in mind, our team will offer financial
planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax,
charitable, cash flow, wealth transfer, and family legacy objectives. Our team partners with our client’s
other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure a coordinated
effort of all parties toward the client’s stated goals. Such services include various reports on specific goals
and objectives or general investment and/or planning recommendations, guidance to outside assets, and
periodic updates.
Our specific services in preparing the client’s plan could include:
▪ Review and clarification of the client’s financial goals
▪ Assessment of the client’s overall financial position including cash flow, balance sheet, investment
▪
strategy, risk management, and estate planning
Creation of a unique plan for each goal the client have including personal and business real estate,
education, retirement or financial independence, charitable giving, estate planning, business
succession, and other personal goals
▪ Development of a goal-oriented investment plan, with input from various advisors to our clients
around tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This
includes IRA and qualified plans, taxable, and trust accounts that require special attention
▪ Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and transfer,
▪
including liquidity as well as various insurance and possible company benefits; and
Crafting and implementation of, in conjunction with the client’s estate and/or corporate attorneys
as tax advisor, an estate plan to provide for the client and/or the client’s heirs in the event of an
incapacity or death
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If requested by the client, our Firm can consult on the selection and use of alternative investments in a
client portfolio. If suitable and appropriate to include in a client portfolio, our Firm will conduct the due
diligence, provide recommendations and offer on-going consulting for the use of such investments.
RETIREMENT PLAN SERVICES
For employer-sponsored retirement plans with participant-directed investments or cash balance plans, our
firm provides its advisory services as an investment advisor as defined under Section 3(21) or 3(38) of the
Employee Retirement Income Security Act of 1974, as amended (“ERISA”).
When serving as an ERISA 3(38) investment manager, the Plan Sponsor is relieved of all fiduciary
responsibility for the investment decisions made by Our Firm. Our Firm is a discretionary investment
manager in accordance with the terms of a separate ERISA 3(38) Plan Sponsor Investment Management
Agreement between Our Firm and the Plan Sponsor. Our Firm’s investment management is limited in that
it has the discretion solely to replace funds in plan fund lineups and initiate the transfer of existing balances
to the replacements without prior approval from the client.
Our Firm provides the following services to the plan sponsor:
•
Select the investments.
• Monitor the investments and replace investments when appropriate.
•
Provide a quarterly monitoring report.
• Assist the plan sponsor in developing an Investment Policy Statement (“IPS”).
•
Provide a comprehensive fiduciary investment review designed to meet Plan Sponsor fiduciary
responsibility and enhance the participant experience. This includes fiduciary education as
requested by the Department of Labor (DOL).
• Recommend QDIA alternatives
• Recommend non-discretionary model portfolios.
When serving as an ERISA 3(21) investment advisor, the Plan Sponsor and Our Firm share fiduciary
responsibility. The Plan Sponsor retains ultimate decision-making authority for the investments and can
accept or reject the recommendations in accordance with the terms of a separate ERISA 3(21) Plan Sponsor
Investment Management Agreement between our Firm and the Plan Sponsor. Under the 3(21) agreement,
Our Firm provides the following services to the Plan Sponsor:
•
Screen investments and make recommendations.
• Monitor the investments and suggests replacement investments when appropriate.
•
Provide a quarterly monitoring report.
• Assist the plan sponsor in developing an Investment Policy Statement (“IPS”).
• Recommend QDIA alternatives.
• Recommend non-discretionary model portfolios.
We can also be engaged to provide Plan Consulting Services. Plan Consulting Services include financial
education to Plan participants, benchmarking the Plan services, education to fiduciary committee members,
BCGM WEALTH MANAGEMENT, LLC
FEBRUARY 2026 | PAGE 5
and monitoring the service provider. The scope of education provided to participants will not constitute
“investment advice” within the meaning of ERISA and participant education will relate to general principles
for investing and information about the investment options currently in the Plan. We can also participate
in initial enrollment meetings and periodic workshops and enrollment meetings for new participants.
USE OF THIRD-PARTY MONEY MANAGERS
Our firm could determine that engaging the expertise of an independent third-party money manager is best
suited for the client’s account. If deemed appropriate for the client, our firm will recommend utilizing an
independent third-party investment adviser to aid in the implementation of investment strategies for the
client’s portfolio. In certain circumstances, we can allocate a portion of a portfolio to an independent third-
party investment adviser (“Manager”) for separate account management based upon the client’s individual
circumstances and objectives, including, but not limited to, your account size and tax circumstances. Upon
the recognition of such situations, in coordination with the client, the client will engage directly with the
Manager for the management of those assets. These Managers shall assist our Firm in managing the day‐
to‐day investment operations of the various allocations, shall determine the composition of the
investments comprising the allocation, shall determine what securities and other assets of the allocation
will be acquired, held, disposed of or loaned in conformity with the written investment objectives, policies
and restrictions and other statements of each client comprising the allocation, or as instructed by our Firm.
Managers selected for your investments need to meet several quantitative and qualitative criteria
established by us. Among the criteria that could be considered are the Manager’s experience, assets under
management, performance record, client retention, the level of client services provided, investment style,
buy and sell disciplines, capitalization level, and the general investment process.
The Client is advised and should understand that:
● A Manager’s past performance is no guarantee of future results;
● There is a certain market and/or interest rate risk which can adversely affect any Manager’s
objectives and strategies, and could cause a loss in a Client's account(s); and
● Client risk parameters or comparative index selections provided to our firm are guidelines only and
there is no guarantee that they will be met or not be exceeded.
Managers can take discretionary authority to determine the securities to be purchased and sold for the
client. Our firm will work with the Manager to communicate any trading restrictions or standing instructions
to refrain from a particular industry requested by the Client. In all cases, trading restrictions will depend
on the Manager and their ability to accommodate such restrictions.
All performance reporting will be the responsibility of the respective Manager. Such performance reports
will be provided directly to you and our firm. Disclosures will indicate which firm is providing the reporting.
Our Firm has entered into agreements with various independent Managers. All third-party Managers to
whom we will refer clients will be licensed as registered investment advisors by their resident state and any
applicable jurisdictions or registered investment advisors with the Securities and Exchange Commission. A
complete description of the Manager’s services, fee schedules and account minimums will be disclosed in
the Manager’s Form ADV or similar Disclosure Brochure.
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We review the performance of our Managers on at least a quarterly basis. More frequent reviews can be
triggered by changes in Manager’s management, performance or geopolitical and macroeconomic specific
events.
Our Firm only enters into only a select number of relationships with Managers. Our Firm will receive a
portion of the overall advisory fee charged to our clients directly from the Manager.
CO-BRANDED INVESTMENT ADVISOR REPRESENTATIVES
Our firm offers services through our network of
investment advisor representatives (“Advisor
Representatives” or “IARs”). IARs could have their own legal business entities whose trade names and logos
are used for marketing purposes and can appear on marketing materials or client statements. The Client
should understand that the businesses are legal entities of the IAR and not of our firm, BCGM . The IARs are
under the supervision of our firm and the advisory services of the IAR are provided through our firm. A
complete listing of the entities are listed on our ADV Part 1.
DISCLOSURE REGARDING ROLLOVER RECOMMENDATIONS
A client or prospect leaving an employer typically has four options regarding an existing retirement plan
(and could engage in a combination of these options): (i) leave the money in the former employer’s plan, if
permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted,
(iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could,
depending upon the client’s age, result in adverse tax consequences). Our Firm can recommend an investor
roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result, our
Firm and its representatives can earn an asset-based fee. In contrast, a recommendation that a client or
prospective client leave their plan assets with their previous employer or roll over the assets to a plan
sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has
an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which
presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm
will consider before recommending a rollover, including but not limited to: (i) the investment options
available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan
versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment
professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v)
required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any.
All rollover recommendations are reviewed by our Firm’s Chief Compliance Officer and remains available
to address any questions that a client or prospective client has regarding the oversight.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to
you regarding your retirement plan account or individual retirement account, we are also fiduciaries within
the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code,
as applicable, which are laws governing retirement accounts. We have to act in your best interest and not
put our interest ahead of yours. At the same time, the way we make money creates some conflicts with
your interests.
WRAP FEE PROGRAMS
We do not place any client assets into Wrap Fee Programs.
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FEBRUARY 2026 | PAGE 7
ASSETS
As of January 28, 2026, our Firm manages $541,469,419 in total regulatory assets under management.
Discretionary assets under our management total $516,175,038 and non-discretionary assets total
$25,294,381.
ITEM 5 - FEES AND COMPENSATION
INVESTMENT MANAGEMENT FEES AND COMPENSATION
Our Firm charges a fee as compensation for providing Investment Management services on the client’s
account. These services include advisory services, trade entry, investment supervision, and other account
maintenance activities. Our custodian charges transaction costs, custodial fees, redemption fees,
retirement plan and administrative fees or commissions. See Additional Fees and Expenses below for
details.
The fees for investment management are based on an annual percentage of assets under management and
are applied to the household asset value on a pro rata basis. Fees are billed monthly in arrears based on
the average daily balance of the account(s) during the previous month. Fees are assessed on all assets
under management, including securities, cash, and money market balances. Margin account balances are
not included in the fee billing.
Our maximum investment advisory fee is 1.15%. Investment advisory fees are negotiable. The specific
advisory fees are set forth in the client’s Investment Advisory Agreement. Fees can vary based on the size
of the account, complexity of the portfolio, extent of activity in the account, or other reasons agreed upon
by us and the client. In certain circumstances, our fees and the timing of the fee payments can be
negotiated. Our employees and their family related accounts are charged a reduced fee for our services.
Unless otherwise instructed by the Client, we will aggregate related client accounts for the purposes of
determining the account size and annualized fee. The common practice is often referred to as “house-
holding” portfolios for fee purposes and can result in lower fees than if fees were calculated on portfolios
separately. Our method of house-holding accounts for fee purposes looks at the overall family dynamic
and relationship. When applicable, and noted in Appendix of the Investment Management Agreement,
legacy positions will also be excluded from the fee calculation.
The independent and qualified custodian holding the client’s funds and securities will debit the client’s
account directly for the advisory fee and pay that fee to us. The client will provide written authorization
permitting the fees to be paid directly from the client’s account held by the qualified custodian. Further,
the qualified custodian agrees to deliver an account statement to the client on a monthly basis indicating
all the amounts deducted from the account including our advisory fees. In some cases, and as indicated in
the Investment Management Agreement, the advisory fee is billed directly to the client. The Firm will send
an invoice to the client for the monthly fee.
Either BCGM or the client can terminate the management agreement immediately upon written notice to
the other party. The management fee will be pro-rated to the date of termination, for the month in which
the cancellation notice was given and the unearned fee will be billed to the client’s account.
Upon termination, the client is responsible for monitoring the securities in the client’s account, and we will
have no further obligation to act or advise with respect to those assets. In the event of client’s death or
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FEBRUARY 2026 | PAGE 8
disability, BCGM will continue management of the account until we are notified of client’s death or disability
and given alternative instructions by an authorized party.
FINANCIAL PLANNING & CONSULTING FEES
For stand-alone financial planning or consulting arrangements, BCGM will negotiate the planning fees with
the client using either a fixed fee or an hourly rate. Fees can vary based on the extent and complexity of
the client’s individual or family circumstances and the amount of the client’s assets under our management.
BCGM will determine the client’s fee for the designated financial advisory services based on a fixed fee
arrangement described below.
Under our fixed fee arrangement, any fee will be agreed in advance of services being performed. The fee
will be determined based on factors including the complexity of the client’s financial situation, agreed upon
deliverables, and whether or not the client intends to implement any recommendations through BCGM.
Fixed fees for financial plans range from $250 to $5,000. In certain situations, when the Firm offers ongoing
due diligence and recommendations for alternative investments, consulting fees can be charged as a
monthly, on-going fixed fee.
For financial plans, we typically complete a plan within a month and will present it to the client within 90
days of the contract date, provided that the client has provided us all information needed to prepare the
financial plan. Fees are billed with one hundred percent (100%) payable at the time the financial plan is
delivered. Financial planning fees can be deducted from client’s brokerage accounts at their discretion.
Written authorization will be required by the client, the client. The client can terminate the financial
planning agreement by providing us with written notice. Upon termination, fees will be prorated to the
date of termination and any unearned portion of the fee will be refunded to the client based on an hourly
rate of $250.00. Services provided up to date of termination but not yet paid to BCGM will be billed to the
client based on the hourly rate of $250.00. We will not require prepayment of more than $1,200 in fees per
client, six (6) or more months in advance of providing any services.
In no case are BCGM fees based on, or related to, the performance of the client’s funds or investments.
When both investment management or plan implementation and wealth planning services are offered,
there is a conflict of interest since there is an incentive for us offering wealth planning services to
recommend products or services for which BCGM receives compensation. However, BCGM will make all
recommendations independent of such considerations and based solely on our obligations to consider the
client’s objectives and needs. As a wealth planning client, the client has the right not to act upon any of our
recommendations and not affect the transaction(s) through us if the client decides to follow the
recommendations.
RETIREMENT PLAN SERVICES
For Retirement Plan Advisory Services compensation, we charge an annual fee as negotiated with the client
and as disclosed in the Employer Sponsored Retirement Plans Consulting Agreement (“Plan Consulting
Agreement”). The compensation method is explained and agreed upon in advance before any services are
rendered and detailed in the Agreement.
Plan advisory services begin with the effective date of the Plan Consulting Agreement, which is the date the
client signs the Plan Consulting Agreement. For that calendar quarter, fees will be adjusted pro rata based
upon the number of calendar days in the calendar quarter that the Agreement was effective. Our fee is
billed in arrears on the last business day of the calendar quarter, as indicated on the Appendix of the Plan
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Consulting Agreement. For Plans where our fee is billed to the custodian, the fee is deducted directly from
the participant accounts. Written authorization permitting us to be paid directly from the custodial account
is outlined in the Plan Consulting Agreement.
Either party can terminate the Plan Consulting Agreement at any time upon immediate notice. The client is
responsible to pay for services rendered until the written termination of the agreement.
THIRD PARTY MONEY MANAGER FEES
As discussed in Item 4 above, there will be occasions where an independent Registered Investment Advisory
can be engaged to be a third party money manager on a portion of a client portfolio. In those circumstances,
the other investment adviser manages the assets based upon the parameters provided by our Firm. The
Manager collects the client advisory fee as described above (not to exceed 1.5%) and then pays out a
portion of advisory fee based on the assets under management for such services as outlined in the
Agreement between our Firm and the Manager.
FINANCIAL INSTITUTION CONSULTING SERVICES
BCGM receives a consulting fee based on a percentage of assets under management from those brokerage
customers who have provided written consent to the broker/dealer to receive the investment consulting
service from BCGM and have entered into a written advisory contract with BCGM. The consulting fee is
calculated from the assets under management as of the end of a calendar quarter period multiplied by the
annualized rate not to exceed 0.85%. The initial fee is paid only after the completion of one full calendar
quarter period following the date of the executed agreement with the broker/dealer.
ADMINISTRATIVE SERVICES PROVIDED BY ORION
We have contracted with Orion to utilize its technology platforms to support data reconciliation,
performance reporting, fee calculation, client relationship maintenance, quarterly performance
evaluations, and other functions related to the administrative tasks of managing client accounts. Due to
this arrangement, Orion will have access to client accounts, but Orion will not serve as an investment
advisor to our clients or bill the accounts. BCGM and Orion are non-affiliated companies. Orion charges our
Firm an annual fee for each account administered by its software. Please note that the fee charged to the
client will not increase due to the annual fee BCGM pays to Orion. The annual fee is paid from the portion
of the management fee retained by BCGM.
ADDITIONAL FEES AND EXPENSES:
In addition to the advisory fees paid to our Firm, clients will also incur certain charges imposed by other
third parties, such as broker-dealers, custodians, trust companies, banks, and other financial institutions
(collectively “Financial Institutions”). These additional charges will include custodial fees, fees charged by
the Independent Managers, charges imposed directly by a mutual fund or ETF in a client’s account, as
disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), 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. BCGM ’s brokerage practices are described at
length in Item 12, below. Neither our Firm nor its supervised persons accept compensation for the sale of
securities or other investment products. Further, our Firm does not share in any of these additional fees
and expenses outlined above.
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ITEM 6 - PERFORMANCE BASED FEES AND SIDE -BY-SIDE MANAGEMENT
We do not charge advisory fees on a share of the capital appreciation of the funds or securities in a client
account (so-called performance-based fees), nor engage side by side management.
ITEM 7 - TYPES OF CLIENTS
We provide investment advice to individuals, high-net worth individuals, employee sponsored retirement
plans, institutions, broker-dealers, charitable organizations, and trusts. We have a $100,000 minimum
dollar amount to open and maintain an advisory account. This minimum is negotiable.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
Our investment philosophy is to strike an appropriate balance between the following:
➢ Actively Managing our portfolio allocations
➢ Deep commitment to our research
➢ Patience - allowing time for investments in our model portfolios to perform through different
market cycles
➢ Discipline - when disruptions occur, focusing on asset allocation, diversification and our clients’
time horizons.
Our Firm provides proprietary investment strategies personalized to the needs and goals of each individual
client. Our strategies are developed and maintained in-house by our team and clients have direct access to
the individuals doing the research and making decisions regarding their accounts and the investments and
strategies in which they are involved. We create diversified portfolios designed to maximize return per unit
of risk assumed. We diversify portfolios by asset class, location, and sector and have a set of guidelines
defining maximum position size within a given portfolio. Our Firm utilizes Morningstar® Investment-
Professional software and other institutional research tools to review and compare data on funds. Our
team compares funds by peer categories and sectors, measuring performance over multiple periods and
against appropriate benchmarks. Emphasis is placed on fund expenses, upside/downside capture ratios,
consistency of performance, and comparative performance against peers and fund category benchmarks.
Fund categories include, Large-Cap, Mid-Cap, Small-Cap, International, and Emerging Market equities,
multiple Fixed Income categories, and alternative or non-correlated assets. Low cost Exchange Traded
Funds (ETFs), Index funds (ETF and Mutual Funds) and professionally managed mutual funds are included
in our model portfolios. Asset classes or fund categories contain multiple funds allowing each Investment
Adviser Representative limited flexibility to customize client portfolios.
Clients could hold or retain other types of assets as well, and our Firm may offer advice regarding those
various assets as part of its services. When combined with quality research and value-based fundamental
analysis, we feel that this is the best prescription for consistent client outcomes.
Additionally, our Firm offers individual stock portfolios for clients using our research and methodologies to
select and manage individual equity securities. Individual stocks, primarily allocated in US equities, are used
in place of mutual funds and ETFs. For this more actively managed stock portfolio, fees are agreed to and
outlined in the Investment Advisory Agreement and as negotiated by the client and firm.
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We use the following methods of analysis in formulating our investment advice and/or managing client
assets:
Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at economic and
financial factors (including the overall economy, industry conditions, and the financial condition and
management of the company) to determine if the security is underpriced (indicating that it could be a good
time to buy) or overpriced (indicating that it could be time to sell). Fundamental analysis does not attempt
to anticipate market movements. This presents a potential risk because the price of a security can move up
or down along with the overall market regardless of the economic and financial factors considered in
evaluating the security.
Asset Allocation: In addition to focusing on securities selection, we attempt to identify an appropriate ratio
of securities, fixed income, and cash suitable to the client’s investment goals and risk tolerance.
A risk of asset allocation is that the client might not participate in sharp increases in a particular security,
industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will change
over time due to stock and market movements and, if not corrected, will no longer be appropriate for the
client’s goals.
Periodically we could encounter economic conditions that warrant temporary adjustments to the asset
allocation of an investment strategy or portfolio. If we believe that these conditions present either an
increase in risk or opportunity for that particular asset class, we can alter the appropriate allocation to
reflect this conviction.
Mutual Fund and/or ETF Analysis: We look at the experience and track record of the manager of the mutual
fund or ETF in an attempt to determine if the manager has demonstrated an ability to invest over a period
of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF
in an attempt to determine if there is significant overlap in the underlying investments held in another
fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if they are
continuing to follow their stated investment strategy.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not
guarantee future results. A manager who has been successful might not be able to replicate that success in
the future. In addition, because we do not control the underlying investments in a fund or ETF, managers
of different funds held by the client could purchase the same security thereby increasing the risk to the
client if that security were to fall in value. There is also a risk that a manager could deviate from the stated
investment mandate or strategy of the fund or ETF which could make the holding(s) less suitable for the
client’s portfolio.
Our Firm can include mutual funds and exchange traded funds, (“ETFs”) in our investment strategies. Our
policy is to purchase institutional share classes of those mutual funds selected for the client’s portfolio. The
institutional share class generally has the lowest expense ratio. The expense ratio is the annual fee that all
mutual funds or ETFs charge their shareholders. It expresses the percentage of assets deducted each fiscal
year for funds expenses, including 12b-1 fees, management fees, administrative fees, operating costs, and
all other asset-based costs incurred by the fund. Some fund families offer different classes of the same fund
and one share class could have a lower expense ratio than another share class. These expenses come from
client assets which could impact the client’s account performance. Mutual fund expense ratios are in
addition to our fee, and we do not receive any portion of these charges. If an institutional share class is not
available for the mutual fund selected, the adviser will purchase the least expensive share class available
BCGM WEALTH MANAGEMENT, LLC
FEBRUARY 2026 | PAGE 12
for the mutual fund. As share classes with lower expense ratios become available, BCGM can use them in
the client’s portfolio, and/or convert the existing mutual fund position to the lower cost share class. Clients
who transfer mutual funds into their accounts with FIRM NAME would bear the expense of any contingent
or deferred sales loads incurred upon selling the product. If a mutual fund has a frequent trading policy, the
policy can limit a client’s transactions in shares of the fund (e.g., for rebalancing, liquidations, deposits or
tax harvesting). All mutual fund expenses and fees are disclosed in the respective mutual fund prospectus.
Non-Transaction Fee (NTF) Mutual Funds - When selecting investments for our clients’ portfolios we might
choose mutual funds on your account custodian’s Non-Transaction Fee (NTF) list. This means that your
account custodian will not charge a transaction fee or commission associated with the purchase or sale of
the mutual fund.
The mutual fund companies that choose to participate in your custodian’s NTF fund program pay a fee to
be included in the NTF program. The fee that a mutual fund company pays to participate in the program is
ultimately borne by the owners of the mutual fund including clients of our Firm. When we decide whether
to choose a fund from your custodian’s NTF list or not, we consider our expected holding period of the fund,
the position size and the expense ratio of the fund versus alternative funds. Depending on our analysis and
future events, NTF funds might not always be in your best interest.
Risks for all forms of analysis: Our securities analysis methods rely on the assumption that the companies
whose securities we purchase and sell, the rating agencies that review these securities, and other publicly-
available sources of information about these securities, are providing accurate and unbiased data. While
we are alert to indications that data could be incorrect, there is always a risk that our analysis might be
compromised by inaccurate or misleading information.
If deemed appropriate for the client’s portfolio, our Firm could recommend investments classified as
"alternative investments". Alternative investments can include a broad range of underlying assets
including, but not limited to, hedge funds, private equity, venture capital, and registered, publicly traded
securities. Alternative investments are speculative, not suitable for all clients and intended for only
experienced and sophisticated investors who are willing to bear the high risk of the investment, which can
include: loss of all or a substantial portion of the investment due to leveraging, short-selling, or other
speculative investment practices; lack of liquidity in that there might be no secondary market for the fund
and none expected to develop; volatility of returns; potential for restrictions on transferring interest in the
fund; potential lack of diversification and resulting higher risk due to concentration of trading authority with
a single advisor; absence of information regarding valuations and pricing; potential for delays in tax
reporting; less regulation and typically higher fees than other investment options such as mutual funds. The
SEC requires investors be accredited to invest in these more speculative alternative investments. Investing
in a fund that concentrates its investments in a few holdings can involve heightened risk and result in
greater price volatility.
RISK OF LOSS
Clients must understand that past performance is not indicative of future results. Therefore, current and
prospective clients should never assume that future performance of any specific investment or investment
strategy will be profitable. Investing in securities involves risk of loss. Further, depending on the different
types of investments, there will be varying degrees of risk. Clients and prospective clients should be
prepared to bear investment loss including loss of original principal.
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Because of the inherent risk of loss associated with investing, our Firm is unable to represent, guarantee,
or even imply that our services and methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate the client from losses due to market corrections or declines.
Investors should be aware that accounts are subject to the following risks:
▪ MARKET RISK - Even a long-term investment approach cannot guarantee a profit. Economic,
political, and issuer-specific events will cause the value of securities to rise or fall. Because the
value of investment portfolios will fluctuate, there is the risk that the client will lose money and
the client’s investment could be worth more or less upon liquidation.
▪
FOREIGN SECURITIES AND CURRENCY RISK - Investments in international and emerging-
market securities include exposure to risks such as currency fluctuations, foreign taxes and
regulations, and the potential for illiquid markets and political instability.
▪
CAPITALIZATION RISK - Small-cap and mid-cap companies could be hindered as a result of
limited resources or less diverse products or services their stocks have historically been more
volatile than the stocks of larger, more established companies.
▪
INTEREST RATE RISK - In a rising rate environment, the value of fixed-income securities generally
declines, and the value of equity securities could be adversely affected.
▪
CREDIT RISK - Credit risk is the risk that the issuer of a security might be unable to make interest
payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived
change in an issuer’s financial strength could affect a security’s value and thus, impact the fund’s
performance.
▪
SECURITIES LENDING RISK - Securities lending involves the risk that the fund loses money
because the borrower fails to return the securities in a timely manner or at all. The fund could also
lose money if the value of the collateral provided for loaned securities, or the value of the
investments made with the cash collateral, falls. These events could also trigger adverse tax
consequences for the fund.
▪
EXCHANGE-TRADED FUNDS - ETFs face market-trading risks, including the potential lack of an
active market for shares, losses from trading in the secondary markets, and disruption in the
creation/redemption process of the ETF. Any of these factors could lead to the fund’s shares
trading at either a premium or a discount to its “net asset value.”
▪
PERFORMANCE OF UNDERLYING MANAGERS - We select the mutual funds and ETFs in the
asset allocation portfolios. However, we depend on the manager of such funds to select individual
investments in accordance with their stated investment strategy.
▪ NON-LIQUID ALTERNATIVE INVESTMENTS - From time to time, our Firm will recommend
to certain qualifying clients that a portion of such clients’ assets be invested in private funds,
private fund-of-funds and/or other alternative investments (collectively, “Nonliquid Alternative
Investments”). Nonliquid Alternative Investments are not suitable for all of our Firm’s clients and
are offered only to those qualifying clients for whom our Firm believes such an investment is
suitable and in line with their overall investment strategy. Nonliquid Alternative Investments
typically are available to only a limited number of sophisticated investors who meet the definition
of “accredited investor” under Regulation D of the Securities Act of 1933, as amended (the
“Securities Act”), or “qualified client” under the Investment Advisers Act of 1940, or “qualified
BCGM WEALTH MANAGEMENT, LLC
FEBRUARY 2026 | PAGE 14
purchaser” under the Investment Company Act of 1940. Nonliquid Alternative Investments
present special risks for our Firm’s clients, including without limitation, limited liquidity, higher
fees and expenses, volatile performance, no assurance of investment returns, heightened risk of
loss, limited transparency, additional reliance on underlying management of the investment,
special tax considerations, subjective valuations, use of leverage and limited regulatory oversight.
When a Nonliquid Alternative Investment invests part or all of its assets in real estate properties,
there are additional risks that are unique to real estate investing, including but not limited to:
limitations of the appraisal value; the borrower’s financial conditions (if the underlying property
has been obtained by a loan), including the risk of foreclosures on the property; neighborhood
values; the supply of and demand for properties of like kind; and certain city, state and/or federal
regulations. Additionally, real estate investing is also subject to possible loss due to uninsured
losses from natural and man-made disasters. The above list is not exhaustive of all risks related to
an investment in Nonliquid Alternative Investments. A more comprehensive discussion of the risks
associated with a particular Nonliquid Investment is set forth in that fund’s offering documents,
which will be provided to each client subscribing to a Nonliquid Alternative Investment, for review
and consideration. It is important that each potential, qualified investor carefully read each
offering or private placement memorandum prior to investing.
▪
▪ OPTIONS AND OTHER DERIVATIVES Client portfolios can purchase or sell options, warrants,
equity-related swaps or other derivatives that trade on an exchange. Both the purchasing and
selling of call and put options entail risks. An investment in an option could be subject to greater
fluctuation than an investment in the underlying securities. The effectiveness of purchasing or
selling stock index options as a hedging technique depends upon the extent to which price
movements in the hedged portfolios correlate with price movements of the stock index selected.
Because the value of an index option depends upon movements in the level of the index rather
than the price of a particular security, whether a portfolio realizes a gain or loss will depend upon
movements in the level of security prices in securities markets generally rather than movements
in the price of a particular security.
CYBERSECURITY RISK - In addition to the Material Risks listed above, investing involves various
operational and “cybersecurity” risks. These risks include both intentional and unintentional
events at our Firm or one of its third-party counterparties or service providers, that could result in
a loss or corruption of data, result in the unauthorized release or other misuse of confidential
information, and generally compromise our Firm’s ability to conduct its business. A cybersecurity
breach could also result in a third-party obtaining unauthorized access to our clients’ information,
including social security numbers, home addresses, account numbers, account balances, and
account holdings. Our Firm has established business continuity plans and risk management
systems designed to reduce the risks associated with cybersecurity breaches. However, there are
inherent limitations in these plans and systems, including that certain risks might not have been
identified, in large part because different or unknown threats could emerge in the future. As such,
there is no guarantee that such efforts will succeed, especially because our Firm does not directly
control the cybersecurity systems of our third-party service providers. There is also a risk that
cybersecurity breaches might not be detected.
▪ ALTERNATIVE INVESTMENTS - Our Firm’s use of alternative assets is limited to the
investments approved on our recommended Custodian(s) Alternative Investments platform in
addition to publicly traded ETFs or ‘40 Act’ funds with specific exposure in commodities, long/short
strategies, real estate, and covered call writing. Investments classified as "alternative investments"
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FEBRUARY 2026 | PAGE 15
could include a broad range of underlying assets including, but not limited to, hedge funds, private
equity, venture capital, and registered, publicly traded securities. Alternative investments are
speculative, not suitable for all clients and intended for only experienced and sophisticated
investors who are willing to bear the high risk of the investment, which can include: loss of all or a
substantial portion of the investment due to leveraging, short-selling, or other speculative
investment practices; lack of liquidity in that there may be no secondary market for the fund and
none expected to develop; volatility of returns; potential for restrictions on transferring interest in
the fund; potential lack of diversification and resulting higher risk due to concentration of trading
authority with a single advisor; absence of information regarding valuations and pricing; potential
for delays in tax reporting; less regulation and typically higher fees than other investment options
such as mutual funds. The SEC requires investors be accredited to invest in these more speculative
alternative investments. Investing in a fund that concentrates its investments in a few holdings
could involve heightened risk and result in greater price volatility.
ITEM 9 - DISCIPLINARY INFORMATION
We do not have any legal, financial or other “disciplinary” item to report.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
FINANCIAL INSTITUTION CONSULTING SERVICES
BCGM has an agreement with Mutual Securities, LLC to provide investment consulting services to certain
brokerage customers of Mutual Securities. Mutual Securities will pay compensation to BCGM for providing
investment consulting services to its brokerage customers. This consulting arrangement does not include
assuming discretionary authority over brokerage accounts or the monitoring of securities. These consulting
services offered to financial institution clients could include a general review of client investments holdings,
which may or may not result in a BCGM ’s investment adviser representative making specific securities
recommendations or offering general investment advice.
This relationship presents a conflict of interest. The conflict is mitigated by the brokerage customer(s)
consenting to receive investment consulting services from BCGM and the brokerage customer(s) executing
a written advisory agreement directly with BCGM. Further, no other additional compensation will be paid
by Mutual Securities to BCGM in connection with the investment consulting services. BCGM will not hold
itself out to the public as engaging in brokerage activities. Mutual Securities and BCGM are separate and
unrelated entities.
THIRD PARTY MONEY MANAGER RELATIONSHIPS
Please refer to Item 4 and Item 5 above for more information about the selection of Managers used with
our investment services. Our firm will receive a portion of the advisory fee from the Manager. A conflict of
interest for our firm in utilizing a Manager is receipt of discounts or services not available to us from other
similar Managers. In order to minimize this conflict our firm will make our recommendations and selections
of Managers in the best interest of our clients.
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INSURANCE
Investment Adviser Representatives (“IAR”) of BCGM can act as agents appointed with various life, disability
or other insurance companies. They receive commissions, trails, or other compensation from the respective
product sponsors and/or as a result of effecting insurance transactions for clients. Commissions generated
by insurance sales do not offset regular advisory fees. Our firm has an incentive to recommend insurance
products and this incentive creates a conflict of interest between the client’s interests and our Firm. We
mitigate this conflict by disclosing to clients they have the right to decide whether or not to engage the
services of our affiliated Insurance entity. Further, clients should note they have the right to decide whether
to act on the recommendations and the right to choose any professional to execute the advice for any
insurance products through any licensed insurance agent not affiliated with our Firm. We recognize the
fiduciary responsibility to place the client’s interests first and have established policies in this regard to
mitigate any conflicts of interest.
Clients should be aware that the ability to receive additional compensation by our Firm and its management
persons or employees creates conflicts of interest that impair the objectivity of the Firm and these
individuals when making advisory recommendations. Our Firm endeavors at all times to put the interest of
its clients first as part of our fiduciary duty as a registered investment adviser; we take the following steps,
among others to mitigate these conflicts:
• we disclose to clients the existence of all material conflicts of interest, including the potential for
the Firm and our employees to earn compensation from advisory clients in addition to the Firm's
advisory fees;
• we disclose to clients that they have the right to decide not to purchase recommended investment
products from our employees;
• we collect, maintain and document accurate, complete and relevant client background
•
information, including the client’s financial goals, objectives, and liquidity needs;
the Firm conducts regular reviews of each client advisory account to verify that all
recommendations made to a client are in the best interest of the client’s needs and circumstances;
• we require that our employees seek prior approval of any outside employment activity so that we
can ensure that any conflicts of interest in such activities are properly addressed;
• we periodically monitor these outside employment activities to verify that any conflicts of interest
continue to be properly addressed by the Firm; and
• we educate our employees regarding the responsibilities of a fiduciary, including the need for
having a reasonable and independent basis for the investment advice provided to clients.
Our Firm does not have an application pending to register, as a futures commission merchant, commodity
pool operator, commodity trading adviser, or an associated person of the foregoing entities.
Neither our firm nor any of its management persons are registered or have an application pending to
register as a broker-dealer or a registered representative of a broker-dealer.
ITEM 11 - CODE OF ETHICS
Our Firm and persons associated with us are allowed to invest for their own accounts, or to have a financial
investment in the same securities or other investments that we recommend or acquire for the client’s
account, and could engage in transactions that are the same as or different than transactions recommended
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FEBRUARY 2026 | PAGE 17
to or made for the client’s account. This creates a conflict of interest. We recognize the fiduciary
responsibility to act in the client’s best interest and have established polices to mitigate conflicts of interest.
We have developed and implemented a Code of Ethics that sets forth standards of conduct expected of our
advisory personnel to mitigate this conflict of interest. The Code of Ethics addresses, among other things,
personal trading, gifts, and the prohibition against the use of inside information.
The Code of Ethics is designed to protect our clients to detect and deter misconduct, educate personnel
regarding the Firm’s expectations and laws governing their conduct, remind personnel that they are in a
position of trust and must act with complete propriety at all times, protect the reputation of BCGM,
safeguard against the violation of the securities laws, and establish procedures for personnel to follow so
that we can determine whether their personnel are complying with the Firm’s ethical principles.
We have established the following restrictions in order to ensure our Firm’s fiduciary responsibilities:
▪ A director, officer, or employee of BCGM shall not buy or sell any securities for their personal
portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her
employment unless the information is also available to the investing public on reasonable inquiry
No supervised employee of BCGM shall prefer his or her own interest to that of the advisory client.
Trades for supervised employees are traded alongside client accounts
▪ We maintain a list of all securities holdings of anyone associated with this advisory practice with
access to advisory recommendations. These holdings are reviewed on a regular basis by an
appropriate officer/individual of BCGM
▪ We emphasize the unrestricted right of the client to decline implementation of any advice
rendered, except in situations where we are granted discretionary authority of the client’s account
▪ We require that all supervised employees must act in accordance with all applicable Federal and
State regulations governing registered investment advisory practices
▪ Any supervised employee not in observance of the above could be subject to termination
None of our associated persons can affect for himself/herself or for accounts in which he/she holds a
beneficial interest, any transactions in a security which is being actively recommended to any of our clients,
unless in accordance with the Firm’s procedures.
The client can request a complete copy of our Code by contacting us at the address, telephone, or email on
the cover page of this Part 2; ATTN: Scott C. Busch.
ITEM 12 - BROKERAGE PRACTICES
BCGM ("we"/"our") does not maintain custody of your assets that we manage/on which we advise,
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 generally recommend that our clients use Charles
Schwab & Co., Inc. (Schwab), a registered broker-dealer, member SIPC, as the qualified custodian.
We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets
in a brokerage account and buy and sell securities when we/you instruct them to. While we generally
recommend that you use Schwab as custodian/broker, you will decide whether to do so and will open your
account with Schwab by entering into an account agreement directly with them. Conflicts of interest
associated with this arrangement are described below as well as in Item 14 (Client referrals and other
compensation). You should consider these conflicts of interest when selecting your custodian.
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We do not open the account for you, although we may assist you in doing so. Even though your account is
maintained at Schwab, and we anticipate that most trades will be executed through Schwab, 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 recommend Schwab, a custodian/broker, to hold your assets and execute transactions. When
considering whether the terms that Schwab provides are, overall, most advantageous to you when
compared with other available providers and their services, we take into account a wide range of factors,
including:
•
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, security and stability
•
Prior service to us and our clients
•
Services delivered or paid for by Schwab
• Availability of other products and services that benefit us, as discussed below (see "Products
and services available to us from Schwab")
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a broker-
dealer’s services, including the value of research provided, execution capability, commission rates, and
responsiveness. Although our firm will seek competitive rates, to the benefit of all clients, our firm may not
necessarily obtain the lowest possible commission rates for specific client account transactions.
Your brokerage and custody costs
For our clients' accounts that Schwab maintains, Schwab generally does not charge you separately for
custody services but is compensated by charging you commissions (ticket charges) or other fees on trades
that it executes or that settle into your Schwab account. Certain trades (for example, mutual funds and
ETFs) do not incur Schwab commissions (ticket charges) or transaction fees. Schwab is also compensated
by earning interest on the uninvested cash in your account in Schwab's Cash Features Program. Schwab's
ticket charges applicable to our client accounts were negotiated based on the condition that our clients
collectively maintain a total of at least $ of their assets in accounts at Schwab. This commitment benefits
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you because the overall ticket call rates you pay are lower than they would be otherwise. In addition to
ticket charges, Schwab 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 account. These fees are in addition to the
commissions or other compensation you pay the executing broker-dealer. Because of this, in order to
minimize your trading costs, we have Schwab execute most trades for your account.
We are not required to select the broker or dealer that charges the lowest transaction cost, even if that
broker provides execution quality comparable to other brokers or dealers. Although we are not required to
execute all trades through Schwab, we have determined that having Schwab 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"). By using another broker or dealer you may pay lower transaction costs.
Products and services available to us from Schwab
Schwab Advisor ServicesTM is Schwab's business serving independent investment advisory firms like us.
They provide us and our clients with access to their institutional brokerage services (trading, custody,
reporting, and related services), many of which are not typically available to Schwab retail customers.
However, certain retail investors may be able to get institutional brokerage services from Schwab without
going through us. Schwab also makes 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. Schwab's
support services are generally available on an unsolicited basis (we don't have to request them) and at no
charge to us. Following is a more detailed description of Schwab'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.
Services that do not directly benefit you. Schwab also makes available to us other products and services
that benefit us but do not directly benefit you or your account. These products and services assist us in
managing and administering our clients' accounts and operating our firm. They include investment
research, both Schwab's own and that of third parties. We use this research to service all or a substantial
number of our clients' accounts, including accounts not maintained at Schwab. In addition to investment
research, Schwab also makes available software and other technology that:
•
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 also offers other services intended to help us manage and
further develop our business enterprise. These services include:
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FEBRUARY 2026 | PAGE 20
•
Educational conferences and events
•
Consulting on technology and business needs
•
Consulting on legal and compliance related needs
•
Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance providers
• Marketing consulting and support
Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to
provide the services to us. Schwab also discounts or waives its fees for some of these services or pays 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. If you did not maintain your account with Schwab, we would be required
to pay for those services from our own resources.
Our interest in Schwab's services
The availability of these services from Schwab benefits us because we do not have to produce or purchase
them. We don't have to pay for Schwab's services. Schwab has also agreed to pay for certain technology,
research, marketing, and compliance consulting products and services on our behalf once the value of our
clients' assets in accounts at Schwab reaches certain thresholds. These services are not contingent upon us
committing any specific amount of business to Schwab in trading commissions or assets in custody. The
fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab
rather than making such a decision based exclusively on your interest in receiving the best value in custody
services and the most favorable execution of your transactions. This is a conflict of interest. In some cases,
the services that Schwab pays for are provided by affiliate of ours or by another party that has some
pecuniary, financial or other interests in us. This creates an additional conflict of interest. We believe,
however, that taken in the aggregate our selection/recommendation of Schwab as custodian and broker is
in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of
Schwab's services (see "How we select brokers/ custodians") and not Schwab's services that benefit only
us.
We place trades for our clients' accounts subject to its duty to seek best execution and its other fiduciary
duties. Schwab's execution quality could be different than other broker-dealers.
We will aggregate trades for ourselves or our associated persons with the client’s trades, providing that the
following conditions are met:
▪ Our policy for the aggregation of transactions shall be fully-disclosed separately to our existing
clients (if any) and the broker/dealer(s) through which such transactions will be placed
▪ We will not aggregate transactions unless we believe that aggregation is consistent with our duty
to seek the best execution (which includes the duty to seek best price) for the client and is
consistent with the terms of our investment advisory agreement with the client for which trades
are being aggregated
▪ No advisory client will be favored over any other client; each client that participates in an
aggregated order will participate at the average share price for all our transactions in a given
security on a given business day, with transaction costs based on each client’s participation in the
transaction
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▪ We will prepare a written statement (“Allocation Statement”) specifying the participating client
▪
accounts and how to allocate the order among those clients
If the aggregated order is filled in its entirety, it will be allocated among clients in accordance with
the allocation statement; if the order is partially filled, the accounts that did not receive the
previous trade’s positions should be “first in line” to receive the next allocation
▪ Notwithstanding the foregoing, the order could be allocated on a basis different from that
specified in the Allocation Statement if all client accounts receive fair and equitable treatment and
the reason for difference of allocation is explained in writing and is reviewed by our compliance
officer. Our books and records will separately reflect, for each client account, the orders of which
aggregated, the securities held by, and bought for that account
▪ We will receive no additional compensation or remuneration of any kind as a result of the
▪
proposed aggregation; and
Individual advice and treatment will be accorded to each advisory client
BROKERAGE FOR CLIENT REFERRALS
Our Firm does not receive client referrals from any custodian or third party in exchange for using that
broker-dealer or third party.
AGGREGATION AND ALLOCATION OF TRANSACTIONS
We can aggregate transactions if we believe that aggregation is consistent with the duty to seek best
execution for our clients and is consistent with the disclosures made to clients and terms defined in the
client investment advisory agreement. No advisory client will be favored over any other client, and each
account that participates in an aggregated order will participate at the average share price (per custodian)
for all transactions in that security on a given business day.
If we do not receive a complete fill for an aggregated order, we will allocate the order on a pro rata basis.
If we determine that a pro rata allocation is not appropriate under the particular circumstances, we will
base the allocation on other relevant factors, which could include:
▪ When only a small percentage of the order is executed, with respect to purchase allocations,
allocations can be given to accounts high in cash.
▪ With respect to sale allocations, allocations can be given to accounts low in cash.
▪ We can allocate shares to the account with the smallest order, or to the smallest position, or to an
account that is out of line with respect to security or sector weightings, relative to other portfolios
with similar mandates.
▪
▪
▪ We can allocate to one account when that account has limitations in its investment guidelines
prohibiting it from purchasing other securities that we expect to produce similar investment
results and that can be purchased by other accounts in the block.
If an account reaches an investment guideline limit and cannot participate in an allocation, we can
reallocate shares to other accounts. For example, this could be due to unforeseen changes in an
account’s assets after an order is placed.
If a pro rata allocation of a potential execution would result in a de Minimis allocation in one or
more accounts, we could exclude the account(s) from the allocation.
▪ We will document the reasons for any deviation from a pro rata allocation.
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TRADE ERRORS
We have implemented procedures designed to prevent trade errors; however, trade errors in client
accounts cannot always be avoided. Consistent with our fiduciary duty, it is our policy to correct trade
errors in a manner that is in the best interest of the client. In cases where the client causes the trade error,
the client will be responsible for any loss resulting from the correction. Depending on the specific
circumstances of the trade error, the client might not be able to receive any gains generated as a result of
the error correction. In all situations where the client does not cause the trade error, the client will be made
whole and we will absorb any loss resulting from the trade error if the error was caused by the Firm. If the
error is caused by the Custodian, the Custodian will be responsible for covering all trade error costs. If an
investment gain results from the correcting trade, the gain will be donated to charity. We will never benefit
or profit from trade errors.
DIRECTED BROKERAGE
We do not routinely recommend, request, or require that the client directs us to execute transaction
through a specified broker dealer. Additionally, we typically do not permit the client to direct brokerage.
We place trades for the client’s account subject to our duty to seek best execution and other fiduciary
duties.
ITEM 13 - REVIEW OF ACCOUNTS
ACCOUNT REVIEWS AND REVIEWERS – INVESTMENT SUPERVISORY SERVICES
Our Investment Adviser Representatives will monitor client accounts on a regular basis and perform annual
reviews with each client. All accounts are reviewed for consistency with client investment strategy, asset
allocation, risk tolerance, and performance relative to the appropriate benchmark. More frequent reviews
could be triggered by changes in an account holder’s personal, tax, or financial status. Geopolitical and
macroeconomic specific events could also trigger reviews.
STATEMENTS AND REPORTS
The custodian for the individual client’s account will provide clients with an account statement at least
quarterly. Upon request, clients can receive BCGM prepared written report detailing their current positions,
asset allocation, and year‐to‐date performance. The client is urged to compare the reports and invoices
provided by our Firm against the account statements the client receives directly from the client’s account
custodian.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
We receive an economic benefit from Schwab in the form of the support products and services it makes
available to us and other independent investment advisors whose clients maintain their accounts at
Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we would
otherwise have to pay once the value of our clients' assets in accounts at Schwab reaches a certain size.
[In some cases, a recipient of such payments is an affiliate of ours or another party which has some
pecuniary, financial or other interests in us. You do not pay more for assets maintained at Schwab as a
result of these arrangements. However, we benefit from the arrangement because the cost of these
services would otherwise be borne directly by us. You should consider these conflicts of interest when
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FEBRUARY 2026 | PAGE 23
selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related
conflicts of interest are described above (see Item 12—Brokerage Practices).
BCGM seeks to enter into agreements with individuals and organizations, some of whom might be affiliated
or unaffiliated with BCGM for the referral of clients to us. All such agreements will be in writing and comply
with the applicable state and federal regulations. If a client is introduced to BCGM by a solicitor, BCGM will
pay that solicitor a fee in accordance with the applicable federal and state securities law requirements.
While the specific terms of each agreement could differ, generally, the compensation will be based upon
BCGM’s engagement of new clients and the retention of those clients and would be calculated using a
varying percentage of the fees paid to BCGM by such clients until the account is closed by written
authorization from the client. Any such fee shall be paid solely from BCGM’s fees, and shall not result in any
additional charge to the client.
Each prospective client who is referred to BCGM by a solicitor who is not affiliated with BCGM will receive
a written disclosure document disclosing whether the solicitor is or is not a current client of BCGM, the
compensation that will be paid by us to the third party, and a description of any material conflicts of interest
on the part of the solicitor in light of BCGM’s relationship with the solicitor. In any case, applicable state
laws could require these persons to become licensed either as representatives of BCGM or as an
independent investment adviser.
ITEM 15 – CUSTODY
We do not have physical custody, as it applies to investment advisors. Custody has been defined by
regulators as having access or control over client funds and/or securities.
DEDUCTION OF ADVISORY FEES
For all accounts, our Firm has the authority to have fees deducted directly from client accounts. Our Firm
has established procedures to ensure all client funds and securities are held at a qualified custodian in a
separate account for each client under that client’s name. Clients, or an independent representative of the
client, will direct, in writing, the establishment of all accounts and therefore are aware of the qualified
custodian’s name, address, and the manner in which the funds or securities are maintained. Finally, account
statements are delivered directly from the qualified custodian to each client, or the client’s independent
representative, at least quarterly. The client should carefully review those statements and are urged to
compare the statements against reports received from BCGM. When the client has questions about their
account statements, the client should contact BCGM or the qualified custodian preparing the statement.
Please refer to Item 5 for more information about the deduction of advisor fees.
THIRD PARTY MONEY MOVEMENT:
On February 21, 2017, the SEC issued a no‐action letter (“Letter”) with respect to Rule 206(4)‐2
(“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided
guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client
funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody. As
such, our firm has adopted the following safeguards in conjunction with our custodian:
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• The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
• The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or
from time to time.
• The client’s qualified custodian performs appropriate verification of the instruction, such as a
signature review or other method to verify the client’s authorization, and provides a transfer
of funds notice to the client promptly after each transfer.
• The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
• The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
• The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
• The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
ITEM 16 – INVESTMENT DISCRETION
For discretionary accounts, prior to engaging BCGM to provide investment advisory services, the client will
enter a written Agreement with us granting the Firm the authority to supervise and direct, on an on-going
basis, investments in accordance with the client’s investment objective and guidelines. In addition, the
client will need to execute additional documents required by the Custodian to authorize and enable BCGM,
in its sole discretion, without prior consultation with or ratification by the client, to purchase, sell, or
exchange securities in and for the client’s accounts. We are authorized, in our discretion and without prior
consultation with the client to: (1) buy, sell, exchange and trade any stocks, bonds or other securities or
assets and (2) determine the amount of securities to be bought or sold, and (3) place orders with the
custodian. Any limitations to such discretionary authority will be communicated to our Firm in writing by
the client.
The limitations on investment and brokerage discretion held by BCGM for the client is:
▪
For discretionary accounts, we require that we be provided with authority to determine which
securities and the amounts of securities to be bought or sold.
▪ Any limitations on this discretionary authority shall in writing as indicated on the investment
advisory Agreement, Appendix B. The client can change/amend these limitations as required.
In some instances, we will not have discretion. We will discuss all transactions with the client prior to
execution or the client will be required to make the trades if in an employer sponsored account.
ITEM 17 – VOTING CLIENT SECURITIES
We will not vote proxies on the client’s behalf. The client is welcome to vote proxies or designate an
independent third-party at the client’s own discretion. The client designates proxy voting authority in the
custodial account documents. The client must ensure that proxy materials are sent directly to the client or
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FEBRUARY 2026 | PAGE 25
the client’s assigned third party. We do not take action with respect to any securities or other investments
that become the subject of any legal proceedings, including bankruptcies. Clients can contact our office
with questions about a particular solicitation by phone at 765-742-7366.
ITEM 18 – FINANCIAL INFORMATION
This item is not applicable to this brochure. We do not require or solicit prepayment of more than $1,200
in fees per client, six months or more in advance. Therefore, we are not required to include a balance sheet
for our most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair
our ability to meet contractual commitments to clients. Finally, we have not been the subject of a
bankruptcy petition at any time.
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