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GKV Capital Management Co., Inc.
February 18, 2026
ADV Part 2 Firm Brochure
This Brochure provides information about the qualifications and business practices of GKV Capital
Management. If you have any questions about the contents of this Brochure, please contact us
at (805) 497-2616 or email us at greg@gkvcapital.com.
The information in this brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority.
Additional information about GKV Capital Management also is available at
www.GKVcapital.com and on the SEC’s website at www.adviserinfo.sec.gov.
Item 1: Material Changes
On our last update dated February 18, 2026, we have amended Item 4 and Item 5 to reflect
our estate planning service addition.
Pursuant to SEC Rules, we will ensure that you receive a summary of any material changes to
this and subsequent Brochures within 120 days of the close of our business’ fiscal year. We may
further provide other ongoing disclosure information about material changes as necessary.
Currently, our brochure may be requested by contacting Greg Vogel, President at (805) 497-
2616 or greg@gkvcapital.com. This brochure is also available on our web site
www.gkvcapital.com, free of charge.
Additional information about GKV Capital Management is also available via the SEC’s web site
www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons
affiliated with GKV Capital who are registered, or are required to be registered, as investment
adviser representatives of GKV.
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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 ................................................................................................... 4
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................... 5
Item 7 – Types of Clients ................................................................................................................. 5
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss.......................................... 5
Item 9 – Disciplinary Information ................................................................................................... 7
Item 10 – Other Financial Industry Activities and Affiliations ........................................................ 7
tem 11 – Code of Ethics .................................................................................................................. 7
Item 12 – Brokerage Practices ....................................................................................................... 8
Item 13 – Review of Accounts ........................................................................................................ 9
Item 14 – Client Referrals and Other Compensation ..................................................................... 9
Item 15 – Custody ......................................................................................................................... 10
Item 16 – Investment Discretion .................................................................................................. 10
Item 17 – Voting Client Securities ................................................................................................. 10
Item 18 – Financial Information .................................................................................................... 10
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Item 4: Advisory Business
GKV Capital Management Co., Inc. was founded in 1975 for the purpose of providing
discretionary portfolio management services on behalf of clients. GKV manages individual
investment accounts for which the company charges a fee.
GKV Capital Management was founded by Peter W. Vogel. Greg Vogel is the President and CEO
and is the principal owner of the company.
GKV exclusively provides investment supervisory services to its clients. The firm makes
investment decisions on behalf of its clients. Investment portfolios include, but are not limited
to investments in common stocks, bonds, trust deed loans, real estate and options for both
individuals and institutions.
GKV manages separate accounts for its clients. This enables each client account to be managed
specifically to the requirements of that client. The investment objective and portfolio structure
of each account is individually designed according to the goals of each respective client.
Restrictions, such as investment in certain types of securities or individual securities can be
made at the request of the client. Client accounts are managed as discretionary accounts,
meaning GKV makes investment decisions on behalf of its clients. As of December 31, 2025,
total discretionary assets under management were $ 357,188,821.
Estate Planning Services
Through our partnership with an independent third-party technology company, Wealth, Inc.
("Wealth”), we can facilitate the preparation of various estate planning documents for
clients. Such services are generally separate from any investment management and/or
financial planning services that we may render to a client, and the exact scope of such
estate planning services will depend on the nature of a client’s specific estate planning
needs. As a condition of utilizing Wealth, you must agree to the terms and conditions,
available at wealth.com. We may pay for your access to Wealth. For the avoidance of doubt,
neither Advisor or Wealth renders legal advice or services. Wealth offers the ability to consult
with licensed attorneys in various jurisdictions at an additional charge, and subject to additional
terms and conditions.
EXECUTIVE OFFICERS AND INVESTMENT PROFESSIONALS
Gregory P. Vogel. Mr. Vogel joined GKV Capital in 2003 and is the firm’s principal owner. Prior
to that, he was a Managing Director and Equity Research Analyst in the technology group at
Bank of America Securities covering the software industry. His coverage included Microsoft,
Adobe Systems, Oracle, BEA Systems, and Macromedia. Mr. Vogel started at Montgomery
Securities in 1994. In 1999 the firm was acquired by NationsBank and became Bank of America
Securities after the subsequent acquisition of Bank of America.
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Mr. Vogel has been a regular guest on financial television including CNBC and CNN and has
been frequently mentioned in the business press including The Wall Street Journal, Business
Week, Forbes and other national financial publications. In 2000, Mr. Vogel was ranked in The
Wall Street Journal’s "Best on the Street" analyst survey for his coverage of the software
industry.
Mr. Vogel received a BA in philosophy from the University of California at Santa Barbara.
Supervision: Each of GKV Capital’s Investment Professionals is supervised by Greg Vogel,
President and Chief Compliance Officer. The location is the Corporate Offices located at 1350
Treat Blvd., Suite 260, Walnut Creek, CA 94597, 925-627-8680. Investment recommendations
are supervised and monitored during their development and prior to the Investment Policy
Statement being signed by the client and Greg Vogel. Financial Planning recommendations are
presented, discussed and agreed upon based on the Investment Professional’s analysis and the
combined efforts of the individual and Greg Vogel. Finally, all trading in client accounts
originates from the Walnut Creek, California office and only Greg Vogel has trading authority on
client accounts with Pershing Advisor Solutions and Charles Schwab.
Held Away Accounts: We implement investment advice on behalf of certain clients in held-
away accounts that are maintained at independent third-party custodians. These held-away
accounts are often 401(k) accounts, 529 plans and other assets that are not held at our primary
custodian(s).
The order management system that we use for held-away accounts is provided by Pontera
Solutions, Inc. We review, monitor, and manage these held-away accounts in an integrated way
with client accounts held at our primary custodian(s). Further information about this service is
available in Item 5.
Item 5: Fees and Compensation
Advisory Fees
All fees are subject to negotiation. The maximum fee schedule calculated for various asset
classes is included below:
1.0% on the first $3,000,000
¾ of 1% on the next $2,000,000
½ of 1% on the next $1,000,000
The specific way fees are charged by GKV Capital is established in a client’s written agreement
with GKV Capital. Fees are invoiced on a quarterly basis. Clients are billed at the beginning of
each calendar quarter based upon the market value of each respective account at the end of
the previous quarter. Clients may elect to be billed directly or to authorize GKV Capital to debit
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its fees from client accounts. Upon termination of any account, any prepaid, unearned fees will
be promptly refunded, and any earned, unpaid fees will be due and payable.
Some clients pay a fixed fee instead of a fee based on percentage of assets under management.
This fixed annual fee is negotiated individually with each applicable client.
Estate Planning Fees
Planning fees are billed at a flat rate up to $2,000 upon completion of the plan. Clients may pay
the fee via check.
GKV’s fees are exclusive of brokerage commissions, transaction fees, and other related costs
and expenses which shall be incurred by the client. Clients may incur certain charges imposed
by custodians, brokers, third party investment 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. Such charges, fees and
commissions are exclusive of and in addition to GKV Capital’s fee, and GKV Capital does not
receive any portion of these commissions, fees, and costs.
Neither GKV Capital, nor any of its employees receive commission compensation from an
outside 3rd party from the sale of an investment or recommendation of any investment vehicle
to clients.
For certain clients, GKV Capital Management charges an advisory fee for services provided to
the held-away accounts mentioned above in Item 4, just as it does with client accounts held at
its primary custodians(s). The specific fee schedule charged by GKV Capital is provided in the
client’s investment advisory agreement with us.
Termination of the Advisory Relationship: Either party may terminate the advisory agreement
signed with our firm in writing at any time. Clients who were billed in advance will receive a
pro-rata refund of the unearned portion of the advisory fees charged at the beginning of the
quarter.
Item 6: Performance-Based Fees and Side-by-Side Management
GKV does not charge any performance-based fees (fees based on a percentage share of a
client’s realized capital gains or capital appreciation from assets managed by GKV.
Item 7: Types of Clients
GKV provides portfolio management services to individuals, high net worth individuals,
corporate pension and profit-sharing plans, partnerships, charitable institutions, corporations,
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foundations, endowments, and other U.S. and international institutions. GKV usually requires
that clients maintain a minimum asset under management value of $500,000.
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear.
GKV works with each client individually to assess an investment risk profile and to develop a
guideline portfolio structure based on various asset classes. GKV manages all client accounts
separately and is therefore able to manage each client’s portfolio in a manner that is tailored to
the client’s needs, including consideration for risk appetite, taxes, political wishes, and any
other desires. Typically, a lower risk portfolio will include a greater proportion of fixed income
securities relative to historically more volatile equities. Clients with a significantly greater
tolerance for risk may request GKV to leverage their portfolio through the purchase or sale of
securities on margin. Additionally, the use of investment strategies that incorporate the use of
options or selling securities short may be used for clients requesting such strategies. GKV will
restrict the use of these strategies to appropriate portfolios where GKV believes the client
understands the risks involved in such investment practices.
GKV does not limit investments to particular asset classes but primarily focuses on equities
(stocks), fixed income (bonds) and real estate. Investment decisions are proposed and executed
by the investment committee comprised of two portfolio managers, Greg Vogel and Elaine
Kwei.
Each asset class has its own inherent risks of loss. Although fixed-income investments are
historically more stable than equities, companies and governments can and do default on loans
from time to time resulting in significant loss of principal and interest. Trading fixed-income
securities can also result in losses due to capital depreciation, generally as the result of rising
interest rates. Equities are not principal protected assets, and their value can fluctuate
substantially based generally on the financial outlook of a company. Unexpected events can
materially change a company’s prospects resulting in significant losses. Real-estate investments
also carry risks of significant capital losses and have the additional risk of illiquidity, or the
inability to quickly sell a security.
GKV takes a simultaneous top-down and bottom-up approach to the analysis of investments.
Managers analyze the macro-economic environment to identify asset classes and economic
sectors that are attractive for investment. In tandem, individual companies, municipalities, and
real-estate opportunities are analyzed using a fundamental earnings approach to identify
potential investment candidates. For example, an expected improving economic environment
will generally lead to an increase in the equity holdings of a portfolio and a reduction of cash
and/or fixed income. The individual equities purchased will be identified through a fundamental
analysis of that business and its prospects. When either the macro-economic environment
appears to worsen, or the fundamentals of that investment weaken, the security will be sold.
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GKV investments are generally long-term averaging approximately 12-months. However,
investment decisions are driven solely by the outlook and expected performance of the
investment resulting in holding periods both considerably longer and considerably shorter than
that average. Any material change in the outlook will result in a shift in strategy. This
investment technique is often referred to as market-timing. There is risk in this technique, in
that if the timing is wrong, investment performance can be worse than the major benchmarks
for that asset class. Additionally, frequent trading will incur transaction costs, such as brokerage
fees.
For the measure of equity performance, GKV generally suggests that clients compare the
performance of the S&P 500 index to our equity performance. For fixed income, or bonds, GKV
suggests comparison to the Barclays Aggregate U.S. Bond index. In all our quarterly
correspondence, we compare our results to the S&P 500, the U.S. Bond index as well as the
Dow Jones Industrial Average and the NASDAQ market for the same period.
Item 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 GKV or the integrity of GKV’s
management. GKV has no information applicable to this Item. GKV has never been subject to
any legal or disciplinary action and no legal or disciplinary events are pending.
Item 10: Other Financial Industry Activities and Affiliations
Neither GKV nor its officers are involved in other financial industry activities or affiliations
beyond the financial advisory business outlined above.
Item 11: Code of Ethics
GKV may periodically recommend to clients that they buy or sell securities or investment
products in which GKV, or a related person has some financial interest. GKV also buys or sells
for itself securities that it also recommends to clients.
GKV has adopted a Code of Ethics for all supervised persons of the firm describing its high
standard 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 supervised persons at GKV must acknowledge the terms of
the Code of Ethics annually, or as amended.
GKV anticipates that, in appropriate circumstances, consistent with clients’ investment
objectives, it will cause accounts over which GKV has management authority to effect and will
recommend to investment advisory clients or prospective clients, the purchase or sale of
securities in which GKV, its affiliates and/or clients, directly or indirectly, have a position of
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interest. GKV’s employees and persons associated with GKV are required to follow GKV’s Code
of Ethics. Subject to satisfying this policy and applicable laws, officers, directors, and employees
of GKV and its affiliates may trade for their own accounts in securities which are recommended
to and/or purchased for GKV’s clients. The Code of Ethics is designed to assure that the
personal securities transactions, activities, and interests of the employees of GKV 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.
Under the Code certain classes of securities have been designated as exempt transactions,
based upon a determination that these would materially not interfere with the best interest of
GKV’s clients. 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, and to
reasonably prevent conflicts of interest between GKV and its clients.
Certain affiliated accounts may trade in the same securities with client accounts on an
aggregated basis when consistent with GKV's obligation of best execution. In such
circumstances, the affiliated and client accounts will share commission costs equally and
receive securities at a total average price. GKV will retain records of the trade order (specifying
each participating account) and its allocation, which will be completed prior to the entry of the
aggregated order. Completed orders will be allocated as specified in the initial trade order.
Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on
the Order.
GKV’s clients or prospective clients may request a copy of the firm's Code of Ethics by
contacting Greg Vogel at 805-497-2616 or via email at greg@gkvcapital.com.
It is GKV’s policy that the firm will not affect any principal or agency cross securities
transactions for client accounts without written authorization from all parties. Principal
transactions are generally defined as transactions where an adviser, acting as principal for its
own account or the account of an affiliated broker-dealer, buys from or sells any security to any
advisory client. A principal transaction may also be deemed to have occurred if a security is
crossed between an affiliated hedge fund and another client account. An agency cross
transaction is defined as a transaction where a person acts as an investment adviser in relation
to a transaction in which the investment adviser, or any person controlled by or under common
control with the investment adviser, acts as broker for both the advisory client and for another
person on the other side of the transaction. Agency cross transactions may arise where an
adviser is dually registered as a broker-dealer or has an affiliated broker-dealer.
Item 12: Brokerage Practices
GKV Capital generally has full discretionary authority, without consulting with its client on a
transaction-by-transaction basis, to manage the client’s account, including the power to decide:
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(a) which securities or other investment products to buy, sell or hold for a client’s
account.
(b) the amounts of and prices at which such securities or other investments will be
bought, sold or held.
(c) the broker-dealer or other intermediary which will be used to effect transactions for
clients’ accounts, subject to the investment objectives and any restrictions or
directions specified by the client and accepted by GKV Capital in writing.
GKV Capital will always recommend an unaffiliated broker-dealer where clients may establish
accounts to be managed by GKV Capital and place custody of account assets. In recommending
these broker-dealers, GKV Capital takes into account the range and quality of services provided
by the broker-dealer to the client and to GKV Capital in its capacity as discretionary investment
manager for the client’s account, including, but not limited to, the broker-dealer’s computer
software and support systems that enable GKV Capital to access on-line account information,
generate account statements and reports and place orders to buy or sell securities for the
account. GKV Capital attempts to aggregate and route client trades through our Pershing
Advisor Solutions Average Price Account so that clients purchasing the same security at the
same time receive pricing that is similar. We reserve the right to trade accounts on an individual
basis if in our sole discretion we believe this will result in a better, more accurate outcome for
the client.
Item 13: Review of Accounts
All clients’ portfolios are reviewed internally by GKV on a continuous basis. GKV manages a
small number of portfolios which permits this intensive type of review. Formal investment
review statements are sent to each client at least quarterly, and more often if requested, and
all security transactions are almost immediately communicated to the appropriate client
whenever they are completed, generally in the form of brokerage firm confirms. Each client’s
portfolio, either partially or in its entirety, is reviewed with the client by GKV by telephone,
email and written correspondence. Each account is reviewed by GKV with each client in person
at least twice annually, if possible. All account reviews are done by Greg Vogel, President of
GKV. Contemplated changes in an account often trigger account reviews with each client. Greg
Vogel, Elaine Kwei, and Sarah Ellis are solely responsible for all investment decisions made by
GKV in clients’ portfolios.
Reports are furnished quarterly, or more frequently if requested, to clients. Reports contain a
summary of all assets in an account including their cost, market value, date acquired, estimated
annual income, current yield, yield to maturity, unrealized gain or loss, current unit market
value and percent weighting of each asset to the total portfolio. Separate schedules showing all
purchases and sales each quarter, realized capital gains and losses, dividend and interest
income, capital changes during the period and investment performance of the past quarter,
year to date and since inception of GKV’s management are also provided in each client’s
quarterly and annual investment report furnished by GKV.
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Item 14: Client Referrals and Other Compensation
GKV does not currently compensate any individuals or entities for making referrals to the firm.
This includes both employees of GKV as well as independent third parties.
Item 15: Custody
GKV does not retain physical possession of funds and/or securities owned by clients. GKV does
not serve as physical custodian for client assets. We employ independent, third-party custodians
(Pershing Advisor Solutions and Charles Schwab).
Clients should receive at least quarterly statements from the broker dealer, bank or other
qualified custodian that holds and maintains client’s investment assets. GKV urges you to
carefully review such statements and compare such official custodial records to the account
statements that we may provide to you. Our statements may vary from custodial statements
based on accounting procedures, reporting dates, or valuation methodologies of certain
securities. Variations in our statements and the statements of the custodian should be able to
be reconciled to the client’s satisfaction.
Item 16: Investment Discretion
GKV usually receives discretionary authority from the client at the outset of an advisory
relationship to select the identity and quantity 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, GKV observes the investment policies,
limitations, and restrictions of the clients for which it advises. For registered investment
companies, GKV’s authority to trade securities may also be limited by certain federal securities
and tax laws that require diversification of investments and favor the holding of investments
once made.
Investment guidelines and restrictions must be provided to GKV in writing.
Item 17: Voting Client Securities
As a matter of firm policy and practice, GKV does not have any authority to and does not vote
proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting
proxies for any and all securities maintained in client portfolios. GKV may provide advice to
clients if requested regarding the clients’ voting of proxies.
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Item 18: Financial Information
Registered investment advisers are required in this Item to provide you with certain financial
information or disclosures about GKV’s financial condition. GKV has no financial commitment
that impairs its ability to meet contractual and fiduciary commitments to clients and has not
been the subject of a bankruptcy proceeding.
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