Overview
- Headquarters
- Tampa, FL
- Total Firm Assets
- $196 million
- Average High-Net-Worth Client Portfolio Size
- $2.2 million
Fee Structure
Primary Fee Schedule (PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $250,000 | 2.00% |
| $250,001 | $500,000 | 1.62% |
| $500,001 | $1,000,000 | 1.50% |
| $1,000,001 | $2,000,000 | 1.25% |
| $2,000,001 | $5,000,000 | 1.00% |
| $5,000,001 | and above | 0.75% |
Minimum Annual Fee: $1,500
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $16,562 | 1.66% |
| $5 million | $59,062 | 1.18% |
| $10 million | $96,562 | 0.97% |
| $50 million | $396,562 | 0.79% |
| $100 million | $771,562 | 0.77% |
Clients
- High-Net-Worth Share of Firm Assets
- 82.44%
- Number of High-Net-Worth Clients
- 72
- Total Client Accounts
- 343
- Discretionary Accounts
- 258
- Non-Discretionary Accounts
- 85
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients
Regulatory Filings
- SEC CRD Number
- 172537
Primary Brochure: PART 2A (2026-04-28)
View Document Text
Form ADV Part 2A
Item 1
Brochure Cover Page
Grand Central Investment Group, LLC
324 S. Hyde Park Ave., Suite 390
Tampa, FL 33606
Phone: (813) 251-4200
www.grandcentralgroup.com
April 28, 2026
This brochure provides information about the qualifications and business practices of Grand
Central Investment Group, LLC. If you have any questions about the contents of this brochure,
please contact us at (813) 251-4200. 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. Registration does not imply a certain level of skill or training.
Additional information about Grand Central Investment Group, LLC is also available on the
SEC’s website at www.adviserinfo.sec.gov.
Item 2
Material Changes
Grand Central Investment Group, LLC (“Advisor”) has made the following material changes to its
Form ADV, Part 2A (“Brochure”) since it published its Brochure on March 13, 2025.
Item 4
Advisory Business
Second paragraph – previous version (03/13/2025)
The Firm was established in July 2014. Frank E. Cooper, III became the Advisor’s Chief Executive
Officer (“CEO”) in August 2014. The Advisor is solely owned by Frank E. Cooper, III.
Second paragraph – new version (11/05/2025)
The Firm was established in July 2014. The Advisor is solely owned by Charles E. Poe, the Advisor’s
Chief Investment Officer, who joined the Firm in November 2014.
Page 2
ADV 2A- 04/2026
Item 3
Table of Contents
Item 2
Material Changes ..................................................................................................................... 2
Item 3
Table of Contents ..................................................................................................................... 3
Item 4
Advisory Business ..................................................................................................................... 4
Item 5
Fees and Compensation ........................................................................................................... 6
Item 6
Performance-Based Fees and Side by Side Management ...................................................... 10
Item 7
Types of Clients ...................................................................................................................... 10
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss ................................................ 11
Item 9
Disciplinary Information ......................................................................................................... 13
Item 10
Other Financial Industry Activities and Affiliations ................................................................ 13
Item 11
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........... 13
Item 12
Brokerage Practices ................................................................................................................ 14
Item 13
Review of Accounts ................................................................................................................ 16
Item 14
Client Referrals and Other Compensation .............................................................................. 16
Item 15
Custody .................................................................................................................................. 17
Item 16
Investment Discretion ............................................................................................................ 17
Item 17
Voting Client Securities .......................................................................................................... 17
Item 18
Financial Information ............................................................................................................. 18
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ADV 2A- 04/2026
Item 4
Advisory Business
Grand Central Investment Group, LLC (the “Firm” or “Advisor”) is a limited liability corporation
formed under Florida law. The Advisor became a registered investment advisor in January 2015.1
The Firm was established in July 2014. The Advisor is solely owned by Charles E. Poe, the
Advisor’s Chief Executive Officer, who joined the Firm in November 2014.
Advisory services include separate account portfolio management, financial planning, and
consulting services. This Brochure provides information about the Advisor and its advisory
services.
limited partnerships, structured products, alternative
The Advisor provides advisory services for the following types of investments: equity securities,
warrants, options, debt securities, municipal bonds, real estate investment trusts (“REIT”),
mutual funds, closed end funds, exchange traded products (“ETP”), unit investment trusts,
private placements,
investments,
certificates of deposit (“CD”), and master limited partnerships (“MLP”). Advisory services are
tailored to an individual client’s needs.
The Advisor provides information in a separate disclosure brochure for its services offered
through the Grand Central Investment Group Wrap Program. The Grand Central Investment
Group Wrap Program services are similar to the portfolio management services described in this
Brochure, in that the Advisor provides customized investment advice and management to the
client. Under the Grand Central Investment Group Wrap Program, the Advisor exercises
discretion over the client’s account and the corresponding broker-dealer custodian’s execution
and transaction charges are included in the advisory fee the Advisor charges for its services. If a
client would like more information on the Grand Central Investment Group Wrap Program, the
client should contact their investment advisor representative (“IAR”) for a copy of the Grand
Central Investment Group Wrap Program Wrap Brochure that describes the program or go to
www.adviserinfo.sec.gov.
As of December 31, 2025, the Advisor managed approximately $165,924,407 in client assets on
a discretionary basis, and $30,314,492 on a non-discretionary basis.
1. Separate Account Portfolio Management
The Advisor provides ongoing investment advice and management of customized client
portfolios on a discretionary or non-discretionary basis according to each client’s investment
objective and financial situation.
1 Registration does not imply a certain level of skill or training.
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ADV 2A- 04/2026
At our initial meeting with a prospective client, we discuss the client’s concerns, which then
leads to what they would like to accomplish, and finally the resources that they have to work
with through current liquid assets along with their ability to save annually.
From there, we begin to help the client better understand asset allocation and the resulting
potential volatility of the financial markets for each of our investment models. This helps us
identify where the client is the most comfortable on a risk scale to help accomplish the client’s
financial goals.
Portfolios typically include, but are not limited to, a variety of stock positions, ETPs, mutual funds,
and individual corporate or municipal bonds (based on the Advisor’s assessment of a client’s
personal finances and tax bracket). A client may impose restrictions by indicating any restrictions
in the Investment Advisory Agreement. A client may impose restrictions on specific industries or
securities that the client prefers not to invest. The Advisor will exercise its best efforts to adhere
to the client’s investment restrictions. Imposing restrictions may affect a client’s overall portfolio
performance in relation to other portfolios the Advisor may manage without such restrictions.
2. Financial Planning
The Advisor offers financial planning services. Financial planning services include areas such as
general cash flow planning, retirement planning, and insurance analysis.
The client retains the sole responsibility for determining whether to
implement any
recommendation made by the Advisor and for placing any resulting transaction. The Advisor
does not provide ongoing financial planning services and does not have discretionary
authority with respect to the client’s assets unless the client enters into a portfolio
management investment advisory agreement with the Advisor.
A conflict of interest may exist between the Advisor and the interests of the client if a
Financial Plan includes recommendations for products or services the Advisor provides. A client
is under no obligation to act upon the Advisor’s recommendation. If a client elects to act
on any of the Advisor’s recommendations, the client is under no obligation to effect the
transaction through the Advisor.
3. Consulting Services
The Advisor provides consulting services. The Firm’s advice takes into account information
collected from the client such as financial status, investment objectives, and tax status. The
Advisor will deliver to the client a written analysis or report as part of its services if requested in
the Investment Advisory Consulting Agreement. The Advisor tailors the consulting services to the
individual needs of the client based on the client’s investment objectives.
The Advisor does not have any discretionary investment authority when offering consulting
services. The Advisor will make recommendations as to general types of investment products or
securities that may be appropriate for a client to consider and may also provide
recommendations regarding specific investments or securities.
Page 5
ADV 2A- 04/2026
For consulting services associated with retirement plans, the Advisor’s recommendations will be
limited to the investment options available within the client’s retirement plan. These investment
options may include brokerage windows or other similar plan arrangements that enable
participants to select investments beyond those designated by the client’s retirement plan (e.g.
investment trusts, pooled separate
mutual funds, exchange traded funds, collective
accounts, allocations among annuity sub-accounts, publicly traded employer stock (“company
stock”)). The Advisor does not provide any advice or recommendations regarding any
participant loans from a client’s retirement plan assets.
The client retains the sole responsibility for determining whether to
implement any
recommendations made by the Advisor and for authorizing any resulting transactions. The
Advisor does not have discretionary authority with respect to the client’s assets.
A conflict of interest may exist between the Advisor and the interests of the client if Consulting
Services include recommendations for products or services the Advisor provides. A client is under
no obligation to act upon the Advisor’s recommendation. If a client elects to act on any of the
Advisor’s recommendations, the client is under no obligation to effect the transaction through
the Advisor.
Item 5
Fees and Compensation
1. Separate Account Portfolio Management
Investment Advisory Fees
Investment advisory fees for portfolio management services are based on the value of assets
managed by the Advisor, calculated as a percentage of assets under management. This fee is
compensation for advisory services and portfolio management rendered by the Advisor.
Fees may be negotiated on a client-by-client basis depending on the client’s specific
financial needs as well as the size, complexity and nature of the portfolio managed and will be
set forth in the investment advisory agreement. Because the Advisor’s fees may be negotiated,
not all clients will pay the same fees.
A client may pay higher or lower fees depending on considerations such as the size of the client’s
account, the amount of time the client has maintained an account with the Advisor (or its
affiliated IAR), and/or the combined market value of related portfolios. While the Advisor believes
that its investment advisory fees are competitive, clients may find lower or higher fees for
comparable services from other sources.
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ADV 2A- 04/2026
Maximum annual investment advisory fees for portfolio management are based on the
following tiered schedule that is based on asset levels:
Assets Under Management
First $250,000
Next $250,000
Next $500,000
Next $1,000,000
Next $3,000,000
Over $5,000,000
Maximum Annual Fee
2.00%
1.625%
1.50%
1.25%
1.00%
.75%
There is no minimum investment; however, the Advisor charges a minimum investment advisory
fee of $1,500 annually. If the account value falls below the minimum investment or is waived, the
client’s account will be subject to the minimum annual account fee, which will result in a higher
percentage fee than set forth in the advisory fee schedule above.
The amount of the investment advisory fee is set forth in the Investment Advisory Agreement
executed by the client at the time the relationship is established.
Investment advisory fees are charged quarterly in advance as a percentage of the portfolio value
on the last business day of the previous quarter or the last value provided by the custodian (if not
valued quarterly). These asset-based fees are assessed on all billable assets under management,
including securities, cash, and money market funds. The initial investment advisory fee will
be prorated based upon the number of days from the first day the Client’s assets are
in which the assets were
transferred to Custodian through the end of the quarter
transferred. Subsequently, investment advisory fees are charged and debited from a client’s
account within the first week of each calendar quarter.
The Advisor may make amendments to the investment advisory fee outlined in the Investment
Advisory Agreement at any time with at least 30 days written notice to the client.
Automatic Debiting of Investment Advisory Fees
Upon establishing an account with the Advisor, the client will authorize and direct the
client’s custodian broker-dealer to debit the client’s account for the investment advisory fee
payable from the account, which will result in the client’s custodian broker-dealer sending
the investment advisory fee payable directly to the Advisor.
At the beginning of the quarter, the Advisor will direct the client’s custodian broker-dealer to
debit the client’s designated account(s) the amount of the investment advisory fee.
Page 7
ADV 2A- 04/2026
If the client’s account does not maintain a sufficient cash or money market balance to cover the
investment advisory fees or is restricted from automatic debiting of fees, the client may deposit
additional funds (subject to certain restrictions for IRA accounts and Qualified Retirement Plans)
or make payment in an alternative manner acceptable to the Advisor. If such funds are not
deposited, certain securities in the client’s account may be liquidated in an amount sufficient to
cover such debits.
Other Charges and Information
The Advisor’s investment advisory fees are separate from charges assessed by third parties, such
as broker-dealers, custodians, or mutual fund companies.
A client incurs brokerage and other transaction costs charged by broker-dealer(s) executing the
transactions and the custodians maintaining the client’s assets. These costs include, but are not
limited to, brokerage transaction and money movement costs, commissions, ticket charges, fed
fund wire fees, custodial fees, and margin interest. These costs are in addition to the Advisor’s
investment advisory fees and are not shared with the Advisor. For additional information, see
“Brokerage Practices” below.
Mutual funds charge an investment management fee, which is in addition to the investment
advisory fee a client pays to the Advisor. Generally, funds also assess administrative fees and
12b-1 fees. The Advisor does not receive any portion of these fees. These fees are in addition
to the investment advisory fees the Advisor charges. The client does not pay these fees directly;
rather, they are deducted from the mutual funds’ assets and will affect the performance
of the investments. These funds’ advisory, administrative, and 12b-1 fees are described in the
funds’ prospectuses. Mutual fund share prices and execution costs differ based on share
class. The Advisor will review the cost of a fund’s share classes in conjunction with execution
costs to assure that it meets its fiduciary duty to obtain best execution.
When investing in an ETP, e.g., exchange traded fund or exchange traded note, a client will bear
the ETP’s proportionate share of fees and expenses as an investor in the ETP. The client does not
pay these fees directly; rather they are deducted from the ETP’s assets and will affect the
performance of the investment.
The Advisor recommends that clients establish brokerage accounts with Trade-PMR, Inc., a FINRA-
registered broker-dealer, member SIPC, to maintain custody of their assets and to effect trades
for their accounts.
Choosing an alternate broker-dealer may result in additional expenses, fees, and lack of efficiency
in reporting account information because the Advisor has established a relationship with
this broker-dealer to facilitate certain additional services, which are outlined in the section
“Brokerage Practices” below. However, if the client does not use Trade-PMR, Inc., the Advisor
will reserve the right not to accept the account. For information about the factors the
Advisor considers
in selecting and/or recommending brokerage firms, see “Brokerage
Practices” below.
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The Advisory may assume the cost of expenses incurred from engaging an outside tax
preparation service on behalf of the client. This service is negotiable and will be set out in
the Investment Advisory Agreement. The Advisor does not pay for tax preparation services for all
clients.
Termination
A client has the right to terminate the Investment Advisory Agreement for investment advisory
services without penalty within five (5) business days after entering into an Investment
Advisory Agreement. Thereafter, the Investment Advisory Agreement will terminate upon the
Advisor’s receipt of the client’s verbal or written notice. The Advisor may cease providing
investment advisory services upon its written notice of termination of the Investment Advisory
Agreement to the client or upon the occurrence of certain events as described in the
Investment Advisory Agreement.
Upon the effective date of termination, the client will be refunded fees on a prorated share
based on the remaining days of the quarter that have been prepaid.
2. Financial Planning Fees
is no minimum asset requirement
The Advisor charges hourly or flat rate fees for its financial planning services. The hourly
charge for financial planning services is a maximum of $450 per hour and the flat rate fee is the
greater of $1,000 or .25% of assets advised on. Fees are negotiated on a client-by-client basis
depending on the size, complexity, and nature of the client’s portfolio and will be set forth in
the Financial Planning Agreement. There
for a
financial planning engagement. The Advisor will request the client to pay 50% of the
financial planning fee upon engagement. Upon presentation of a completed financial plan
to the client, the Advisor will present an invoice reflecting the remaining fees owed for
services.
Termination
A client has the right to terminate a Financial Planning Agreement without penalty within five (5)
business days after entering into the Agreement. Thereafter, the Agreement will terminate
upon the Advisor’s receipt of the client’s written notice. The Advisor may terminate
providing investment advisory services upon written notice of termination to the client or
upon the occurrence of certain events as described in the Financial Planning Agreement.
The Financial Planning Agreement automatically terminates, unless otherwise agreed in
writing, upon delivery of the financial plan. The Advisor will present the client with an
invoice for any services provided up to termination.
3. Consulting Fees
The Advisor charges a flat rate fee for its consulting services. The maximum fee for
consulting services is 1.00% of assets advised on.
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ADV 2A- 04/2026
Fees are negotiated on a client-by-client basis depending on the size, complexity, and nature of
the client’s portfolio and will be set forth in the Consulting Agreement. There is no minimum asset
requirement for a consulting engagement. For consulting services, the client is required to pay at
the time of consultation with the Advisor.
Upon establishing an account with the Advisor, the client will authorize and direct the client’s
custodian broker-dealer to debit the client’s account for the consulting fee payable from the
account, which will result in the client’s custodian broker-dealer sending the investment advisory
fee payable directly to the Advisor. The fee for consulting services will be deducted from the
client’s brokerage account held with the custodian and will be reflected on the client’s custodian
statement.
Termination
A client has the right to terminate a Consulting Agreement without penalty within five (5) business
days after entering into the Agreement. Thereafter, the Agreement will terminate upon
the Advisor’s receipt of the client’s written notice. The Advisor may terminate providing
investment advisory services upon written notice of termination to the client or upon the
occurrence of certain events as described in the Consulting Agreement.
The Consulting Agreement automatically terminates, unless otherwise agreed in writing, upon
client’s termination of the agreement. The Advisor will deduct any fee due from the client’s
brokerage account for any services provided up to termination.
Item 6
Performance-Based Fees and Side by Side Management
Performance-Based Fees
The Advisor does not accept performance-based fees, which are fees based on a share of
capital gains or appreciation of the client’s assets.
Side-By-Side Management
Side-by-side management refers to the practice of managing accounts for which an advisor
charges performance-based fees while at the same time managing accounts that are not charged
performance-based fees.
The Advisor does not participate in side-by-side management.
Item 7
Types of Clients
The Advisor generally offers advisory services to individuals, high net worth individuals, pension
and profit-sharing plans, charitable organizations, and corporations or other businesses.
There is no minimum investment for Separate Account Portfolio Management; however, the
Advisor charges a minimum investment advisory fee of $1,500 annually.
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ADV 2A- 04/2026
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
Generally, the Advisor is a “top-down manager” and will first determine the U.S. and Global asset
allocation between stocks, bonds, and cash. The Advisor uses a wide variety of investment
research and industry publications to assist in its analysis, which may include, but is not limited
to:
Jeff Cooper’s Hit & Run Trading
• Valueline Pro
•
• The Forest for the Trees
• Trading with Cody
• Wall Street Journal
• MarketSmith
• The Aden Forecast
Investech
• Barron’s
• Briefing.com
• Dorsey Wright
• Elliott Wave
• Fleckenstein Capital
• High Tech Strategist
•
• Momentum Structural Analysis (MSA)
• MoneyGuide Pro
Once the Advisor determines these allocations, we place in the client’s portfolio a foundation of
dividend paying equities (stocks) separated into two groups. One portion contains a basket of
stocks that the Advisor expects to continue to pay above-average dividends and the other portion
is comprised of a wide selection of the stock from companies that are historically increasing their
dividend payouts at a faster rate than an average sample of companies. The Advisor uses data
provided by Standard & Poor’s to analyze potential investments.
History shows that annual paid dividends remain a significant part of the total returns over
decades for investing in the equity markets, and the Advisor’s investment analysis is based on its
belief that this trend will continue. The Advisor follows the investment theory of James P.
O’Shaughnessy, who over many years has done extensive quantitative analysis dating back to the
1950’s. The Advisor believes that his findings are factual and unbiased on what investing
strategies actually have worked in the equity markets over the past five decades and are helpful
in our stock allocations.3
The Advisor’s initial method of analysis is fundamental analysis and includes a number of factors
based on Mr. O’Shaughnessy findings of potential indicators of significantly enhanced potential
returns. These include, but are not limited to, the following:
•
financial strength ratios;
• price to earnings ratios;
3 Mr. O’Shaughnessy is not affiliated with the Advisor.
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ADV 2A- 04/2026
• price to sales ratios;
• price to cash flow rates;
• dividend growth history;
• dividend yields; and
• growth rate to price earnings ratios.
On the fundamental front, the Advisor also uses a service that screens for stocks that are owned
by more than one of a list of fifteen value managers (hedge fund managers and mutual
fund managers) that historically have above-average track records and low turnover of stocks
in their funds’ portfolios. We think it makes sense not to always have to reinvent the wheel and
to follow the smart money when looking for stock ideas.
The Advisor also believes that while fundamental analysis is important, the Advisor should not
ignore technical analysis both on individual stock positions, sectors and on the various domestic
and international indexes to help determine the overall health of the financial markets.
The Advisor believes there is a seasonal pattern in the equity markets which makes the Advisor
more wary from May through October because market drawdowns and corrections tend to occur
during this timeframe. In addition, the Advisor tends to use U.S. and global index-based
investments to populate this portion of clients’ portfolios on an annual basis.
The Advisor tends to be a stock picker but has come to appreciate the use of fixed income to
help cushion and mitigate the volatility inherit in the financial markets.
The Advisor may also use alternative investments in a client’s portfolio allocation to enhance
diversification. This includes investing in individual stocks, ETPs, closed end funds or institutional
mutual funds to gain exposure to companies that invest in real assets like precious metals, natural
resources, and real estate. We may also include institutional mutual funds or closed end funds
that use hedge fund strategies like long-short equity, long-short debt, covered call strategies,
and macro strategies.
The Advisor prefers to invest in companies that it believes can grow top line revenue,
are dominant in their field, have strong cash flows and balance sheets, and create high
barriers to their competitors for entry. The Advisor considers these types of companies ‘growth
stocks’ and, where appropriate, looks to add a portion of these companies to each client’s
portfolio to round out its custom allocations.
Because investment styles move in and out of favor over time, we strive to maintain a flexible
approach that uses multiple strategies. We like the idea of having more than one horse pulling
our investment portfolio wagon.
Clients are advised and should understand that:
Investing in securities involves risk of loss that clients should be prepared to bear.
•
• Asset allocation does not ensure a profit or protect against a loss.
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• Past performance is not a guarantee of future results.
• Market conditions, interest rates, and other investment-related risks may cause losses in
their portfolio.
• Risk parameters established for their portfolio are guidelines only – the selected risk
parameters may be exceeded, and index comparisons may outperform their portfolio.
• Portfolio values are subject to a variety of factors, such as liquidity and volatility of the
securities markets.
• There may be a higher level of risk with leveraged and inverse ETPs because, to accomplish
their objectives, they may pursue a range of investment strategies through the use of
swaps, futures contracts, and other derivative instruments in order to provide a return
that is a multiple of an underlying index or benchmark’s return. Most leveraged and
inverse ETFs “reset” daily, meaning that they are designed to achieve their stated
objectives on a daily basis. Their performance over longer periods of time can differ
significantly from the performance (or inverse of the performance) of their underlying
index or benchmark during the same period of time. This effect can be magnified in
volatile markets.
investments
including
limited
• Risks related to alternative investments may be greater than risks associated with
liquidity, tax considerations, potentially
traditional
speculative investment strategies, illiquidity, and potential for substantial losses including
entire investment.
Item 9
Disciplinary Information
Registered investment advisors are required to disclose specific information related to certain
legal or regulatory events that may be material to choosing an advisor. The Advisor has not been
the subject of any material legal or disciplinary proceedings. Please see Form ADV Part 2B
regarding disciplinary events involving the Advisor’s Covered Persons.
Item 10
Other Financial Industry Activities and Affiliations
None.
Item 11
Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
The Advisor has adopted a Code of Ethics (“Code”) pursuant to industry standards. The Code is
predicated upon serving the best interest of our clients. All persons covered under the Code
(“Covered Persons”) must at all times reflect the professional standards expected of those
engaged in the investment advisory business and shall act within the spirit and the letter of the
federal, state, and local laws and regulations pertaining to investment advisors and the general
conduct of business. These standards require all personnel to be judicious, accurate, objective,
and reasonable in dealing with both clients and other parties so that their personal integrity is
unquestionable.
The Code is certified annually with Covered Persons of the Firm. For a copy of the Code, a written
request should be sent to Grand Central Investment Group, Attention: T. Gregory Reymann II,
Chief Compliance Officer, 780 94th Avenue N., Suite 110, St. Petersburg, FL 33702.
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On occasion, the Advisor may buy or sell securities that it recommends to clients or
may recommend securities transactions in which the Advisor or its Covered Persons has some
financial interest. This practice would create a conflict of interest if the transactions were
structured to trade on the market causing an impact on recommendations made to the
Advisor’s clients. The Advisor addresses this conflict by prohibiting the execution of a personal
transaction in a security for which a client has a pending buy or sell order, until such client order
is executed or withdrawn.
The Chief Financial Officer will review a Covered Person’s personal transactions quarterly. The
Code requires pre-approval of personal transactions in some cases. The Advisor believes that
it has adopted sufficient controls so that personal transactions are consistent with advice given
to clients.
Item 12
Brokerage Practices
The Advisor does not provide brokerage services.
The Advisor recommends that clients establish brokerage accounts with Trade-PMR, Inc., a
FINRA-registered broker-dealer, member SIPC, to maintain custody of clients’ assets and to
effect trades for their accounts. Although the Advisor may recommend that clients establish
accounts at Trade-PMR, Inc., it is a client’s decision to custody assets with Trade-PMR, Inc. or
another custodian. The Advisor is independently owned and operated and is not affiliated with
or supervised by Trade-PMR, Inc.
Clients may utilize the broker-dealer of their choice and have no obligation to purchase or
sell securities through Trade-PMR, Inc. However, if the client does not use Trade-PMR,
Inc., the Advisor will reserve the right not to accept the account.
Trade-PMR, Inc. provides the Advisor with access to its trading and custody services, which
are typically not available to retail investors. These services generally are available to
independent investment advisors on an unsolicited basis.
These services are not contingent upon the Advisor committing to Trade-PMR, Inc. any
specific amount of business (assets
in custody or trading commissions). Trade-PMR’s
brokerage services include the execution of securities transactions, custody, research, and
access to mutual funds and other investments.
for custody services but
is compensated by account holders
For the Client’s accounts maintained by Trade-PMR, Inc., it generally does not charge
separately
through
commissions and other transaction-related or asset-based fees for securities trades that are
executed through Trade- PMR, Inc. or that settle into Trade-PMR, Inc. brokerage accounts.
Research & Other Soft Dollar Benefits
By recommending Trade-PMR, Inc., the Advisor receives soft-dollar benefits which may
include access to Trade-PMR, Inc.’s products and services that assist the Advisor
in
managing and administering clients’ accounts including software and other technology that:
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ADV 2A- 04/2026
(i)
(ii)
provide access to client account data (such as trade confirmations and account
statements);
facilitate trade execution and allocate aggregated trade orders for multiple client
accounts;
provide research, pricing and other market data;
facilitate payment of the Advisor’s fees from its clients’ accounts; and
assist with back-office functions, recordkeeping, and client reporting.
(iii)
(iv)
(v)
Best Execution
In recommending broker-dealers, the Advisor considers “best execution.” Best execution means
in recommending a broker-dealer, the Advisor will comply with its fiduciary duty to obtain best
execution and as defined by the Securities Exchange Act of 1934 and will take into account such
relevant factors as:
(i)
(ii)
(iii)
(iv)
price;
the broker-dealer’s facilities, reliability, and financial responsibility;
the ability of the broker-dealer to effect transactions, particularly with regard to
such aspects as timing, order size, and execution of order;
the research and related brokerage services provided by such broker-dealer to the
Advisor, notwithstanding that a client’s account may not be the direct or exclusive
beneficiary of such services; and
any other factors the Advisor considers to be relevant.
(v)
Aggregation of Orders
When the Advisor buys or sells the same security for more than one client, it may place
concurrent orders with the brokerage firm to be executed together as a single “block” in order
to facilitate orderly and efficient execution. Where orders are aggregated, each client’s account
will be charged or credited with the average price per unit. The Advisor receives no additional
compensation or remuneration from aggregating transactions.
Directed Brokerage
If a client directs the Advisor to use a specific firm for brokerage or custodial services, the client
should be aware that there may be brokerage and execution services available elsewhere at lower
cost. Clients should consider whether directing brokerage to a particular broker-dealer firm may
result in certain costs or disadvantages, such as higher commissions, less favorable executions,
or being limited in investment options.
If a client’s account is invested in mutual funds, these directed brokerage arrangements might
limit the investment options for the Advisor’s use in managing the client’s account. The reasons
for a brokerage firm to limit these options are many, such as the brokerage firm offers only its
proprietary investment products or is paid a higher commission when the volume of a particular
product attains a certain level.
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ADV 2A- 04/2026
In addition, with directed brokerage arrangements, the client is responsible for negotiating the
brokerage firm’s commission rates and other fees.
Trading Errors
If a trading error results in a profit, the Advisor may retain the profit for the Advisor’s account to
offset any losses that occur from future trade errors or allocate it to a charity.
Item 13
Review of Accounts
The client’s IAR reviews client account activity no less than quarterly. The level of review
is determined by the complexity of the portfolio at the discretion of the IAR. Other factors that
may trigger review are changes in economic or market conditions, and individual client
situations.
The custodian will deliver account statements at least quarterly that include a summary of
the client’s activity. In addition, written portfolio performance summaries that provide
historical information regarding a client’s investments are provided annually or upon the client’s
request. Performance summaries should not be relied upon as predictive of future performance.
The custodian, broker-dealer, or other investment vendor will value the securities held in a
client’s portfolio. The values of some investments, such as alternative investments or private
placements, are provided by the investment’s manager, which may be monthly, quarterly,
but not less than annually; often, these values are estimates made by the alternative
investment’s manager and may not be the liquidation value.
Item 14
Client Referrals and Other Compensation
Any compensation that the Advisor may receive from non-clients is described in “Other Financial
Industry Activities and Affiliations” and “Brokerage Practices.”
The Advisor enters into solicitation arrangements with third parties (“Promoters”) to offer the
Advisor’s advisory services or programs. The Advisor enters into agreements with Promoters
pursuant to Rule 206(4)-1 of the Investment Advisers Act of 1940. The Advisor will compensate
the Promoter directly if a client enters into a relationship with the Advisor. This compensation is
ongoing and made up of a portion of the investment advisory fee the Advisor charges the client,
which may be up to 25% of the Advisory Fee. A Promoter will provide the client with a statement
disclosing the terms of the Promoter’s arrangement with the Advisor. The Advisor assures that
Promoters are properly licensed or registered in accordance with state securities laws.
The Advisor endeavors at all times to put the interests of its clients first. Clients should be aware,
however, that the receipt of economic benefits by the Advisor or its related persons in and of itself
creates a potential conflict of interest.
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ADV 2A- 04/2026
Item 15
Custody
The Advisor has custody of clients’ funds to the extent that it has the ability to deduct fees from
clients’ accounts. The custodian will send quarterly account statements to clients. Neither the
Advisor nor its associated persons will accept delivery of a client’s securities or funds in the name
of the Advisor or its associated person.
Executing broker-dealers, custodians, or other investment vendors provide account statements
and confirmations. The Advisor urges clients to compare statements received from custodians
with any reports the Advisor may provide. If there are any differences, please contact the Advisor
immediately for resolution.
An unaffiliated, qualified custodian, such as a bank, broker/dealer (e.g., Trade-PMR, Inc.), mutual
fund company or transfer agent, will maintain client assets. The Advisor or any associated person
of the Advisor does not hold client assets. If a client chooses Trade-PMR, Inc. as custodian for their
brokerage account, Trade-PMR, Inc. acts as an introducing broker clearing on a fully disclosed
basis through Wells Fargo Clearing Services, LLC for the Advisor’s clients.
Item 16
Investment Discretion
Clients who have entered into a discretionary Investment Advisory Agreement with the Advisor
grant the Advisor power of attorney to exercise discretion over the selection of the investments,
timing of placing the trade, and amount of securities to be bought or sold. This investment
authority may be subject to specified investment objectives and guidelines and/or conditions
imposed by the client in writing, as described above in “Advisory Business.”
Clients who do not choose a discretionary arrangement retain the responsibility for the final
decision on all actions taken with respect to their portfolios and the Advisor must contact them
prior to the execution of any recommended trade. This may result in a delay in executing trades,
which could adversely affect the performance of a client’s portfolio. Non-discretionary trades may
not participate in block trading and as a result, may incur higher fees. For additional information
regarding block trading, see “Brokerage Practices” above.
Item 17
Voting Client Securities
The Advisor does not vote proxies on behalf of client owned securities. A client maintains
exclusive responsibility for: (i) directing the manner in which proxies solicited by issuers of
securities they beneficially own will be voted, and (ii) making all elections relative to mergers,
acquisitions, tender offers, bankruptcy proceedings or other types of events pertaining to the
client’s investments.
The Advisor does not render advice to or take any actions on behalf of clients with respect to any
legal proceedings, including bankruptcies, and shareholder litigation, to which any securities or
other investments held in client accounts, or the issuers thereof, become subject, and does not
initiate or pursue legal proceedings, including without limitation shareholder litigation, on behalf
of clients with respect to transactions, securities or other investments held in client accounts. The
Page 17
ADV 2A- 04/2026
right to take any actions with respect to legal proceedings, including shareholder litigation, with
respect to transactions, securities or other investments held in a client account is expressly
reserved to the client.
Item 18
Financial Information
The Advisor has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to its clients nor has it been the subject of a bankruptcy proceeding.
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ADV 2A- 04/2026
Additional Brochure: WRAP BROCHURE (2026-04-28)
View Document Text
Form ADV Part 2A Appendix 1
Item 1
Wrap Fee Program Brochure Cover Page
Grand Central Investment Group Wrap Program
Grand Central Investment Group, LLC
324 S. Hyde Park Ave., Suite 390
Tampa, FL 33606
Phone: (813) 251-4200
www.grandcentralgroup.com
April 28, 2026
This wrap fee program brochure provides information about the qualifications and business practices
of Grand Central Investment Group, LLC. If you have any questions about the contents of this
brochure, please contact us. 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.
Registration does not imply a certain level of skill or training.
Additional information about Grand Central Investment Group, LLC is also available on the SEC’s
website at www.adviserinfo.sec.gov.
Item 2
Material Changes
Grand Central Investment Group, LLC (“Advisor”) has made the following material changes to its Form
ADV, Part 2A, Appendix 1 (“Wrap Fee Program Brochure”) since it published its Wrap Brochure dated
March 13, 2025.
Item 4
Advisory Business
Second paragraph – previous version (03/13/2025)
The Firm was established in July 2014. Frank E. Cooper, III became the Advisor’s Chief Executive Officer
(“CEO”) in August 2014. The Advisor is solely owned by Frank E. Cooper, III.
Second paragraph – new version (11/05/2025)
The Firm was established in July 2014. The Advisor is solely owned by Charles E. Poe, the Advisor’s Chief
Investment Officer, who joined the Firm in November 2014.
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ADV 2A APP1-04/2026
Item 3
Table of Contents
Item 2 Material Changes ........................................................................................................................... 2
Item 3
Table of Contents ........................................................................................................................... 3
Item 4
Services, Fees and Compensation .................................................................................................. 4
Item 5
Account Requirements and Types of Clients ................................................................................. 8
Item 6
Portfolio Manager Selection and Evaluation .................................................................................. 8
Item 7
Client Information Provided to Portfolio Managers ..................................................................... 12
Item 8
Client Contact with Portfolio Managers ....................................................................................... 12
Item 9
Additional Information ................................................................................................................. 12
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ADV 2A APP1-04/2026
Item 4
Services, Fees and Compensation
Grand Central Investment Group, LLC (the “Firm” or “Advisor”) is a limited liability corporation formed
under Florida law. The Advisor became a registered investment advisor in January 2015.1
The Firm was established in July 2014. The Advisor is solely owned by Charles E. Poe, the Advisor’s
Chief Executive Officer, who joined the Firm in November 2014.
Advisory services include separate account portfolio management, financial planning, and consulting
services. This Wrap Brochure provides information about the Advisor and its advisory services under its
wrap program. Other investment advisory services offered by the Advisor are described in detail in the
Advisor’s ADV Part 2A Brochure.
Through its wrap program, the Grand Central Investment Group Wrap Program, the Advisor provides
ongoing investment advice and management for assets in the client’s account. The Advisor provides
advisory services for the following types of investments: equity securities, warrants, options, debt
securities, municipal bonds, real estate investment trusts (“REIT”), mutual funds, closed end funds,
exchange traded products (“ETP”), unit investment trusts, private placements, limited partnerships,
structured products, alternative investments, certificates of deposit (“CD”), and master limited
partnerships (“MLP”). Advisory services are tailored to an individual client’s needs.
As of December 31, 2025, the Advisor managed approximately $165,924,407 in client assets on a
discretionary basis, and $30,314,492 on a non-discretionary basis.
Services
At our initial meeting with a prospective client, we discuss the client’s concerns, which then leads to
what they would like to accomplish, and finally the resources that they have to work with through
current liquid assets along with their ability to save annually.
From there, we begin to help the client better understand asset allocation and the resulting potential
volatility of the financial markets for each of our investment models. This helps us identify where the
client is the most comfortable on a risk scale to help accomplish the client’s financial goals.
Portfolios typically include, but are not limited to, a variety of stock positions, ETPs, mutual funds, and
individual corporate or municipal bonds (based on the Advisor’s assessment of a client’s personal finances
and tax bracket).
1Registration does not imply a certain level of skill or training.
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ADV 2A APP1-04/2026
A client may impose restrictions by indicating any restrictions in the Investment Advisory Agreement. A
client may impose restrictions on specific industries or securities that the client prefers not to invest.
The Advisor will exercise its best efforts to adhere to the client’s investment restrictions. Imposing
restrictions may affect a client’s overall portfolio performance in relation to other portfolios the Advisor
may manage without such restrictions.
Trade-PMR, Inc. (“Custodian”) acts as the custodian for clients’ accounts and provides brokerage and
execution services as the broker-dealer on account transactions and delivers quarterly statements to
clients.
Fees and Compensation
The client pays the Advisor a single wrap fee (“Advisory Fee”) for advisory, brokerage and trade execution
services.
The Advisory Fee is based on the value of assets managed by the Advisor, calculated as a percentage of
assets under management. This fee is compensation for advisory services and portfolio management fees
rendered by the Advisor, as well as charges for execution and transaction services provided by the
Custodian. The Advisory Fee is negotiable between the client and the Advisor and is set out in the
Investment Advisory Agreement.
Fees may be negotiated on a client-by-client basis depending on the client’s specific financial needs as
well as the size, complexity and nature of the portfolio managed and will be set forth in the Investment
Advisory Agreement. Because the Advisory Fee may be negotiated, not all clients will pay the same fees.
A client may pay higher or lower Advisory Fees depending on considerations such as the size of the client’s
account, the amount of time the client has maintained an account with the Advisor (or its affiliated IAR),
and/or the combined market value of related portfolios. While the Advisor believes that its Advisory
Fees are competitive, clients may find lower or higher fees for comparable services from other sources.
The maximum Advisory Fee schedule is as follows:
Assets Under Management
First $250,000
Next $250,000
Next $500,000
Next $1,000,000
Next $3,000,000
Over $5,000,000
Maximum Annual Fee
2.25%
1.75%
1.50%
1.25%
1.00%
.75%
The amount of the Advisory Fee is set forth in the Investment Advisory Agreement executed by the client
at the time the relationship is established.
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ADV 2A APP1-04/2026
Advisory Fees are charged quarterly in advance as a percentage of the portfolio value on the last business
day of the previous quarter or the last value provided by the custodian (if not valued quarterly). These
asset-based fees are assessed on all billable assets under management, including securities, cash, and
money market funds. The initial investment advisory fee will be prorated based upon the number of days
from the first day the Client’s assets are transferred to Custodian through the end of the quarter in which
the assets were transferred. Subsequently, investment advisory fees are charged and debited from a
client’s account within the first week of each calendar quarter.
Although the client does not directly pay charges for execution and transactions, clients should be aware
that from the Advisory Fee paid to the Advisor, the Advisor pays the Custodian for its charges
associated with the client’s account. The Advisor retains the remaining portion as compensation for
its advisory services and portfolio management. These transaction charges paid by the Advisor to the
Custodian vary based on the type of transaction. Because the Advisor pays the execution and
transaction charges, clients should understand that the cost of transaction charges is a factor to the
Advisor when making decisions regarding transactions in the client’s account.
The Advisor instructs the Custodian to debit the client’s designated account(s) the amount of the Advisory
Fee. If the client’s account does not maintain a sufficient cash or money market balance to cover the
Advisory Fee or is restricted from automatic debiting of fees, the client may deposit additional funds
(subject to certain restrictions for IRA accounts and Qualified Retirement Plans) or make payment in an
alternative manner acceptable to the Advisor. If such funds are not deposited, certain securities in the
client’s account may be liquidated in an amount sufficient to cover such debits.
A client has the right to terminate the Investment Advisory Agreement for investment advisory services
without penalty within five (5) business days after entering into an Investment Advisory Agreement.
Thereafter, the Investment Advisory Agreement will terminate upon the Advisor’s receipt of the client’s
verbal or written notice. The Advisor may cease providing investment advisory services upon its written
notice of termination of the Investment Advisory Agreement to the client or upon the occurrence
of certain events as described in the Investment Advisory Agreement.
Upon the effective date of termination, the client will be refunded fees on a prorated share based on
the remaining days of the quarter that have been prepaid.
After the termination date, the Advisor has no responsibility to provide ongoing investment advice to
the client.
Other Types of Fees and Expenses
In addition to the Advisory Fee, which includes the Custodian’s execution and transaction costs, the
Custodian may charge additional costs directly to the client. The Custodian notifies clients of these
charges at account opening and makes available a list of these charges directly to the client.
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ADV 2A APP1-04/2026
The Advisor may assume the cost of expenses incurred from engaging an outside tax preparation
service on behalf of the client. This service is negotiable and will be set out in the Investment Advisory
Agreement. The Advisor does not pay for tax preparation services for all clients.
Fees Charged by Third Parties
There are other fees and charges that are imposed by parties other than the Advisor (third parties) that
apply to investments in Grand Central Investment Group Wrap Program accounts.
If a client’s assets are invested in mutual funds, ETPs, or other pooled investment products, the client
should be aware that there will be two layers of fees and expenses for those assets. The client will
pay an investment management fee to the fund manager and other expenses as a shareholder of the
fund. In the case of mutual funds that are fund-of-funds, there could be an additional layer of fees,
including performance fees that vary depending on the performance of the fund. The client will also pay
the Advisor the Advisory Fee with respect to those assets. Most of the mutual funds available
to the Grand Central Investment Group Wrap Program can be purchased directly. Therefore, a client
could generally avoid the second layer of fees by not using the advisory services of the Advisor and
by making their own decisions regarding the investment.
If a client transfers a previously purchased mutual fund into a Grand Central Investment Group Wrap
Program account, and there is an applicable contingent deferred sales charge on the fund, the client will
pay that charge when the mutual fund is sold. 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).
Although the Custodian makes available no-load and load-waived mutual funds to Grand Central
Investment Group Wrap Program accounts, the Custodian receives asset-based sales charges or service
fees (e.g., 12b-1 fees) from certain mutual funds. The Custodian retains these fees and they are not
shared with the Advisor.
If a client holds a REIT as part of a Grand Central Investment Group Wrap Program account, there are
dealer management fees and other organizational, offering and pricing expenses imposed by the REIT. If
a client holds a UIT in the Grand Central Investment Group Wrap Program account, UIT sponsors
charge creation and development fees or similar fees. Further information regarding fees assessed by a
product sponsor is available in the appropriate prospectus or offering document, which is available
upon request from the Advisor or from the product sponsor directly.
Important Things to Consider About Fees on a Grand Central Investment Group Wrap Program Account
The Advisory Fee is an ongoing wrap fee for investment advisory services, which includes the cost of the
execution of transactions and other administrative and custodial services. The Advisory Fee may cost
the client more than purchasing the services separately, for example, paying an advisory fee plus
commissions for each transaction in the account. In as much as the Advisor pays the Custodian the
transaction and execution costs associated with client accounts, this may create a disincentive for
the Advisor to trade securities in accounts.
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ADV 2A APP1-04/2026
Factors that bear upon the cost of the Grand Central Investment Group Wrap Program account in
relation to the cost of the same services purchased separately include the:
type and size of the account;
•
• historical and/or expected size or number of trades for the account; and
• number and range of supplementary advisory and client-related services provided to the client.
The Advisor receives compensation as a result of the client’s participation in the program, which may
be more than what the client would pay to another investment advisory firm.
The Advisor may make amendments to the fee schedule, including negotiated fees, at any time with at
least 30 days written notice to the client.
Item 5
Account Requirements and Types of Clients
There is no minimum investment; however, the Advisor charges a minimum investment advisory fee of
$1,500 annually. If the account value falls below the minimum investment or is waived, the client’s
account will be subject to the minimum annual account fee, which will result in a higher percentage fee
than set forth in the advisory fee schedule in Item 4 of this Wrap Brochure.
The Grand Central Investment Group Wrap Program account is available for individuals, high net worth
individuals, pension and profit-sharing plans, charitable organizations, and corporations or other
businesses.
Item 6
Portfolio Manager Selection and Evaluation
The Advisor provides the client investment advice and management in the Grand Central Investment
Group Wrap Program account. The Advisor does not select outside portfolio managers to manage the
Grand Central Investment Group Wrap Program.
The Custodian calculates the performance for the Grand Central Investment Group Wrap Program
account and delivers to clients’ individual annual performance reports in addition to quarterly account
statements. The Custodian’s performance reports and statements are intended to inform clients as to
how their investments have performed over a period of time, both on an absolute basis and compared
to leading investment indices. The Advisor periodically reviews the Custodian’s performance reports for
accuracy.
The Advisor offers other types of advisory programs, including portfolio management, financial planning,
and consulting advisory services. The Advisor offers portfolio management advisory services through its
Separately Managed Account program, which is similar to the services it provides in the Grand
Central Investment Group Wrap Program in that the Advisor provides the investment advice and
portfolio management to the client. However, under the Separately Managed Account program, the
client pays transaction charges directly to the broker-dealer custodian rather than the
Advisor. Other investment advisory services offered by the Advisor are described in detail in the
Advisor’s ADV Part 2A Brochure.
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ADV 2A APP1-04/2026
The Advisor has an incentive to recommend that a client use it, rather than another portfolio manager
because it will retain the Advisory Fee, therefore, it may receive higher compensation than if it
recommended a non-affiliated portfolio manager. The Advisor manages this conflict by providing
investment advisory services that are in its clients’ best interests.
Investment Discretion
The Advisor provides advisory services on a discretionary basis for the purchase and sale of securities in
the Grand Central Investment Group Wrap Program account. The client authorizes the Advisor to have
discretion through the Investment Advisory Agreement.
Methods of Analysis, Investment Strategies and Risk of Loss
Generally, the Advisor is a “top-down manager” and will first determine the U.S. and Global
asset allocation between stocks, bonds, and cash. The Advisor uses a wide variety of investment
research and industry publications to assist in its analysis, which may include, but is not limited to:
• The Aden Forecast
• Barron’s
• Briefing.com
• Dorsey Wright
• Elliott Wave
• Fleckenstein Capital
• The Forest for the Trees
• High Tech Strategist
•
Investech
• MarketSmith
• Momentum Structural Analysis
(MSA)
Jeff Cooper’s Hit & Run Trading
• MoneyGuide Pro
•
• Trading with Cody
• Wall Street Journal
• Valueline Pro
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ADV 2A APP1-04/2026
Once the Advisor determines these allocations, we place the client’s portfolio a foundation of dividend
paying equities (stocks) separated into two groups. One portion contains a basket of stocks that the
Advisor expects to continue to pay above-average dividends and the other portion is comprised of a wide
selection of the stock from companies that are historically increasing their dividend pay outs at a
faster rate than an average sample of companies. The Advisor uses data provided by Standard &
Poor’s to analyze potential investments.
History shows that annual paid dividends remain a significant part of the total returns over decades for
investing in the equity markets, and the Advisor’s investment analysis is based on its belief that this
trend will continue. The Advisor follows the investment theory of James P. O’Shaughnessy, who over
many years has done extensive quantitative analysis dating back to the 1950’s. The Advisor believes
that his findings are factual and unbiased on what investing strategies actually have worked in the
equity markets over the past five decades and are helpful in our stock allocations.3
The Advisor’s initial method of analysis is fundamental analysis and includes a number of factors based
on Mr. O’Shaughnessy findings of potential indicators of significantly enhanced potential returns.
These include, but are not limited to, the following:
•
financial strength ratios;
• price to earnings ratios;
• price to sales ratios;
• price to cash flow rates;
• dividend growth history;
• dividend yields; and
• growth rate to price earnings ratios.
On the fundamental front, the Advisor also uses a service that screens for stocks that are owned by more
than one of a list of fifteen value managers (hedge fund managers and mutual fund managers) that
historically have above-average track records and low turnover of stocks in their funds’ portfolios. We
think it makes sense to not always have to reinvent the wheel and to follow the smart money when
looking for stock ideas.
The Advisor also believes that while fundamental analysis is important, the Advisor should not ignore
technical analysis both on individual stock positions, sectors and the various domestic and international
indexes to help determine the overall health of the financial markets.
The Advisor believes there is a seasonal pattern in the equity markets which makes the Advisor more
wary from May through October because market drawdowns and corrections tend to occur during this
timeframe. In addition, the Advisor tends to use U.S. and global index-based investments to populate this
portion of clients’ portfolios on an annual basis.
The Advisor tends to be a stock picker, but has come to appreciate the use of fixed income to help
cushion and mitigate the volatility inherit in the financial markets.
The Advisor may also use alternative investments in a client’s portfolio allocation to enhance
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ADV 2A APP1-04/2026
diversification. This includes investing in individual stocks, ETPs, closed end funds or institutional mutual
funds to gain exposure to companies that invest in real assets like precious metals, natural resources,
and real estate. We may also include institutional mutual funds or closed end funds that use hedge fund
strategies like long-short equity, long-short debt, covered call strategies, and macro strategies.
The Advisor prefers to invest in companies that it believes can grow top line revenue, are dominant
in their field, have strong cash flows and balance sheets, and create high barriers to their competitors for
entry. The Advisor considers these type of companies ‘growth stocks’ and, where appropriate, looks to
add a portion of these companies to each client’s portfolio to round out its custom allocations.
Because investment styles move in and out of favor over time, we strive to maintain a flexible approach
that uses multiple strategies. We like the idea of having more than one horse pulling our investment
portfolio wagon.
Clients are advised and should understand that:
Investing in securities involves risk of loss that clients should be prepared to bear.
•
• Asset allocation does not ensure a profit or protect against a loss.
• Past performance is not a guarantee of future results.
• Market conditions, interest rates, and other investment related risks may cause losses in their
portfolio.
• Risk parameters established for their portfolio are guidelines only – the selected risk parameters
may be exceeded and index comparisons may outperform their portfolio.
• Portfolio values are subject to a variety of factors, such as liquidity and volatility of the
securities markets.
• There may be a higher level of risk with leveraged and inverse ETPs because, to accomplish their
objectives, they may pursue a range of investment strategies through the use of swaps,
futures contracts, and other derivative instruments in order to provide a return that is a
multiple of an underlying index or benchmark’s return. Most leveraged and inverse ETFs “reset”
daily, meaning that they are designed to achieve their stated objectives on a daily basis. Their
performance over longer periods of time can differ significantly from the performance
(or inverse of the performance) of their underlying index or benchmark during the same
period of time. This effect can be magnified in volatile markets.
• Risks related to alternative investments may be greater than those associated with
traditional investments including limited liquidity, tax considerations, potentially speculative
investment strategies, illiquidity, and potential for substantial losses including entire investment.
Side-By-Side Management
Side-by-side management refers to the practice of managing accounts that are charged performance-
based fees while at the same time managing accounts that are not charged performance-based fees.
3 Mr. O’Shaughnessy is not affiliated with the Advisor.
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ADV 2A APP1-04/2026
The Advisor does not participate in side-by-side management.
Voting Client Securities
The Advisor does not vote proxies on behalf of client owned securities. A client maintains exclusive
responsibility for: (i) directing the manner in which proxies solicited by issuers of securities
they beneficially own will be voted, and (ii) making all elections relative to mergers, acquisitions, tender
offers, bankruptcy proceedings or other types of events pertaining to the client’s investments.
The Advisor does not render advice to or take any actions on behalf of clients with respect to any legal
proceedings, including bankruptcies, and shareholder litigation, to which any securities or other
investments held in client accounts, or the issuers thereof, become subject, and does not initiate or
pursue legal proceedings, including without limitation shareholder litigation, on behalf of clients with
respect to transactions, securities or other investments held in client accounts. The right to take any
actions with respect to legal proceedings, including shareholder litigation, with respect to transactions,
securities or other investments held in a client account is expressly reserved to the client.
Item 7
Client Information Provided to Portfolio Managers
The Advisor obtains the client’s financial information, risk tolerance and investment objectives to
determine the investments in the client’s Grand Central Investment Group Wrap Program account. The
Advisor will contact the client periodically to review the client’s Grand Central Investment Group Wrap
Program account and determine whether there have been any changes to the client’s situation. Client
should contact the Advisor in the interim if they have had any changes to their situation.
Item 8
Client Contact with Portfolio Managers
No restrictions are placed on a client’s ability to contact and consult with the Advisor regarding the
Grand Central Investment Group Wrap Program.
Item 9
Additional Information
Disciplinary Information
Registered investment advisors are required to disclose specific information related to certain legal or
regulatory events that may be material to choosing an advisor. The Advisor has not been the subject of
any material legal or disciplinary proceedings. Please see Form ADV Part 2B regarding disciplinary events
involving the Advisor’s Covered Persons.
Other Financial Industry Activities and Affiliations
None.
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ADV 2A APP1-04/2026
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
The Advisor has adopted a Code of Ethics (“Code”) pursuant to industry standards. The Code is predicated
upon serving the best interest of our clients. All persons covered under the Code (“Covered Persons”)
must at all times reflect the professional standards expected of those engaged in the investment advisory
business and shall act within the spirit and the letter of the federal, state, and local laws and regulations
pertaining to investment advisors and the general conduct of business. These standards require all
personnel to be judicious, accurate, objective, and reasonable in dealing with both clients and other
parties so that their personal integrity is unquestionable.
The Code is certified annually with Covered Persons of the Firm. For a copy of the Code, a written request
should be sent to Grand Central Investment Group, LLC, Attention: T. Gregory Reymann II, Chief
Compliance Officer, 780 94th Avenue N., Suite 110, St. Petersburg, FL 33702.
On occasion, the Advisor may buy or sell securities that it recommends to clients or may recommend
securities transactions in which the Advisor or its Covered Persons has some financial interest. This
practice would create a conflict of interest if the transactions were structured to trade on the market
causing an impact on recommendations made to the Advisor’s clients. The Chief Financial Officer reviews
Covered Persons’ personal transactions quarterly. The Code requires pre-approval of personal
transactions in some cases. The Advisor believes that it has adopted sufficient controls so that personal
transactions are consistent with advice given to clients.
Review of Accounts
The client’s IAR reviews client account activity no less than quarterly. The level of review is determined
by the complexity of the portfolio at the discretion of the Advisor’s Chief Compliance Officer. Other
factors that may trigger review are changes in economic or market conditions, and individual client
situations.
The Custodian will deliver account statements at least quarterly that include a summary of the client’s
account activity. In addition, the written portfolio performance summaries that provide historical
information regarding a client’s investments are provided annually or upon client request.
Performance summaries should not be relied upon as predictive of future performance.
The value of securities held in a client’s portfolio will be valued by the custodian, broker-dealer, or other
investment vendor. The values of some investments, such as alternative investments or private
placements, are provided by the investment’s manager, which may be monthly, quarterly, but not less
than annually; often, these values are estimates made by the alternative investment’s manager and may
not be the liquidation value.
Client Referrals and Other Compensation
The Advisor may enter into solicitation arrangements with third parties (“Promoters”) to offer the
Advisor’s advisory services or programs. The Advisor enters into agreements with Promoters pursuant to
Rule 206(4)-1 of the Investment Advisers Act of 1940. The Advisor will compensate the Promoter directly
if a client enters into a relationship with the Advisor.
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This compensation is ongoing and made up of a portion of the investment advisory fee the Advisor
charges the client, which may be up to 25% of the Advisory Fee. A Promoter will provide the client with
a statement disclosing the terms of the Promoter’s arrangement with the Advisor.
The Advisor endeavors at all times to put the interests of its clients first. Clients should be aware,
however, that the receipt of economic benefits by the Advisor or its related persons in and of itself
creates a potential conflict of interest.
Research & Other Soft Dollar Benefits
By recommending Trade-PMR, Inc. for custodial and brokerage services, the Advisor receives
soft-dollar benefits which may include access to Trade-PMR, Inc.’s products and services that assist the
Advisor in managing and administering clients’ accounts including software and other technology that:
provide access to client account data (such as trade confirmations and account statements);
facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
provide research, pricing and other market data;
facilitate payment of the Advisor’s fees from its clients’ accounts; and
assist with back-office functions, recordkeeping, and client reporting.
(i)
(ii)
(iii)
(iv)
(v)
In evaluating whether to recommend that clients’ custody their assets at Trade-PMR, Inc., the Advisor
takes into account the availability of some of the foregoing products, services, and other arrangements
as part of the total mix of factors it considers and not solely the nature, cost, or quality of custody and
brokerage services provided by the client’s broker-dealer, which may create a potential conflict of
interest.
The Advisor addresses this conflict by conducting quarterly reviews of a sampling of execution quality
and annual reviews of commission rates, trade error rates, quality of client reporting, block
trading, reputation, and financial strength of the broker-dealer. The quarterly and annual reviews
include a comparison to other industry participants offering the same or similar services.
Custody
The Advisor has custody of clients’ funds to the extent that it has the ability to deduct fees from clients’
accounts. The custodian will send account statements to clients at least quarterly. Neither the Advisor
nor its associated persons will accept delivery of a client’s securities or funds in the name of the Advisor
or its associated person.
Executing broker-dealers, custodians, or other investment vendors provide account statements and
confirmations. The Advisor urges clients to compare statements received from custodians with any
reports the Advisor may provide. If there are any differences, please contact the Advisor immediately for
resolution.
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Client assets will be maintained by an unaffiliated, qualified custodian, such as a bank, broker/dealer
(e.g., Trade-PMR, Inc.), mutual fund company or transfer agent. Client assets are not held by the Advisor
or any associated person of the Advisor. Trade-PMR, Inc. acts as an introducing broker clearing on a fully
disclosed basis through Wells Fargo Clearing Services, LLC for the Advisor’s clients.
Financial Information
The Advisor has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to its clients, nor has it been the subject of a bankruptcy proceeding.
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