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Greenfield Seitz Capital Management, LLC
Firm Brochure
This brochure provides information about the qualifications and business practices of Greenfield Seitz Capital
Management, LLC. If you have any questions about the contents of this brochure, please do not hesitate to contact
us at (214) 367-6170 or by email at: eric@gscapital.net. 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 Greenfield Seitz Capital Management, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov. Greenfield Seitz Capital Management, LLC’s CRD number is: 150434.
1722 Routh St., Suite 760
Dallas, TX 75201
Main: (214) 367-6170
Fax: (214) 367-6180
eric@gscapital.net
www.gscapital.net
Registration does not imply a certain level of skill or training.
Version Date: 1/30/2026
Item 2: Material Changes
The following material changes were made to the Greenfield Seitz Capital Management, LLC firm
brochure since the last annual update filing on January 31, 2025. Material changes relate to Greenfield
Seitz Capital Management, LLC’s policies, practices or conflicts of interests only.
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Item 4 – GSCM added the section – Retirement Plan Rollover Recommendations – as a conflict
of interest to disclose that when GSCM provides investment advice about your retirement plan
account or individual retirement account (“IRA”), we acknowledge that GSCM is a
“fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act
(“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing
retirement accounts. The way GSCM makes money creates conflicts with clients’ interests so
GSCM operates under a special rule that requires GSCM to act in your best interest and not
put our interest ahead of you.
•
•
Item 12 – GSCM pays a monthly fee to Raymond James & Associates for certain soft dollar
benefits.
Item 15 – GSCM is deemed to have custody of client funds and securities whenever GSCM is
given the authority to have fees deducted directly from client accounts.
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Item 3: Table of Contents
Table of Contents
Item 2: Material Changes .......................................................................................................................................................................................................... i
Item 3: Table of Contents .........................................................................................................................................................................................................ii
Item 4: Advisory Business ....................................................................................................................................................................................................... 1
A. Description of the Advisory Firm ................................................................................................................................................................................ 1
B. Types of Advisory Services ........................................................................................................................................................................................... 1
Investment Supervisory Services ................................................................................................................................................................................. 1
Services Limited to Specific Types of Investments .................................................................................................................................................... 1
C. Client Tailored Services and Client Imposed Restrictions ........................................................................................................................................ 1
D. Wrap Fee Programs ....................................................................................................................................................................................................... 2
E. Amounts Under Management ...................................................................................................................................................................................... 2
Item 5: Fees and Compensation .............................................................................................................................................................................................. 2
A. Fee Schedule ................................................................................................................................................................................................................... 2
Investment Supervisory Services Fees ........................................................................................................................................................................ 2
B. Payment of Fees .............................................................................................................................................................................................................. 2
Payment of Investment Supervisory Fees .................................................................................................................................................................. 2
C. Clients Are Responsible For Third Party Fees ............................................................................................................................................................ 3
D. Prepayment of Fees ....................................................................................................................................................................................................... 3
E. Outside Compensation For the Sale of Securities to Clients ..................................................................................................................................... 3
Item 6: Performance-Based Fees and Side-By-Side Management ...................................................................................................................................... 3
Item 7: Types of Clients ........................................................................................................................................................................................................... 4
Minimum Account Size ................................................................................................................................................................................................ 4
Item 8: Methods of Analysis, Investment Strategies and Risk, of Investment Loss ......................................................................................................... 4
A.
Methods of Analysis and Investment Strategies ............................................................................................................................................... 4
Fundamental analysis ................................................................................................................................................................................................... 4
B.
Material Risks Involved ....................................................................................................................................................................................... 4
C.
Risks of Specific Securities Utilized .................................................................................................................................................................... 4
Item 9: Disciplinary Information ............................................................................................................................................................................................ 5
Item 10: Other Financial Industry Activities and Affiliations ............................................................................................................................................. 5
A.
Registration as a Broker/Dealer or Broker/Dealer Representative ............................................................................................................... 5
B.
Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor ................................ 5
C.
Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ........................................................... 5
D.
Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections ................................................. 5
Item 11: Code of Ethics, Participation in Transactions, Personal Trading ......................................................................................................................... 6
A.
Code of Ethics ....................................................................................................................................................................................................... 6
B.
Recommendations Involving Material Financial Interests .............................................................................................................................. 6
C.
Investing Personal Money in the Same Securities as Clients........................................................................................................................... 6
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D.
Trading Securities At/Around the Same Time as Clients’ Securities ............................................................................................................ 6
Item 12: Brokerage Practices ................................................................................................................................................................................................... 6
A.
Factors Used to Select Custodians and/or Broker/Dealers ............................................................................................................................ 6
1.
Research and Other Soft-Dollar Benefits ...................................................................................................................................................... 6
2.
Brokerage for Client Referrals ........................................................................................................................................................................ 7
3.
Clients Directing Which Broker/Dealer/Custodian to Use ....................................................................................................................... 7
B.
Aggregating (Block) Trading for Multiple Client Accounts ............................................................................................................................ 7
Item 13: Reviews of Accounts ................................................................................................................................................................................................. 7
A.
Frequency and Nature of Periodic Reviews and Who Makes Those Reviews .............................................................................................. 7
B.
Factors That Will Trigger a Non-Periodic Review of Client Accounts .......................................................................................................... 7
C.
Content and Frequency of Regular Reports Provided to Clients.................................................................................................................... 7
Item 14: Client Referrals and Other Compensation ............................................................................................................................................................. 8
A.
Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ...................... 8
B.
Compensation to Non –Advisory Personnel for Client Referrals ................................................................................................................... 8
Item 15: Custody ...................................................................................................................................................................................................................... 8
Item 16: Investment Discretion ............................................................................................................................................................................................... 8
Item 17: Voting Client Securities (Proxy Voting).................................................................................................................................................................. 8
Item 18: Financial Information ................................................................................................................................................................................................ 8
A.
Balance Sheet ......................................................................................................................................................................................................... 8
B.
Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients .............................................. 9
C.
Bankruptcy Petitions in Previous Ten Years ..................................................................................................................................................... 9
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Item 4: Advisory Business
A. Description of the Advisory Firm
This firm has been in business since 06/26/2009, and the principal owners are Stuart
Edwards Greenfield and Yancey Tighe Seitz.
B. Types of Advisory Services
Greenfield Seitz Capital Management, LLC (hereinafter “GSCM”) offers the following
services to advisory clients:
Investment Supervisory Services
GSCM offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. GSCM creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels) and then constructs a plan (the Investment Policy
Statement) to aid in the selection of a portfolio that matches each client’s specific
situation. Investment Supervisory Services include, but are not limited to, the following:
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•
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Investment strategy •
•
Asset allocation
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Risk tolerance
Personal investment policy
Asset selection
Regular portfolio monitoring
GSCM evaluates the current investments of each client with respect to their risk
tolerance levels and time horizon. Risk tolerance levels are documented in the
Investment Policy Statement, which is given to each client.
Services Limited to Specific Types of Investments
GSCM limits its investment advice and/or money management to exchange-listed
securities, securities traded over the counter, foreign issuers, Corporate debt securities,
Certificates of deposit, Municipal Securities, United States Government Securities, and
Options contracts on securities. GSCM can use other securities as well to help diversify a
portfolio when applicable.
Retirement Plan Rollover Recommendations
When GSCM provides investment advice about your retirement plan account or
individual retirement account (“IRA”) including whether to maintain investments
and/or proceeds in the retirement plan account, roll over such investment/proceeds
from the retirement plan account to a IRA or make a distribution from the retirement
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plan account, we acknowledge that GSCM is a “fiduciary” within the meaning of Title
I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal
Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts.
The way GSCM makes money creates conflicts with your interests so GSCM operates
under a special rule that requires GSCM to act in your best interest and not put our
interest ahead of you.
Under this special rule’s provisions, GSCM must act as a fiduciary to a retirement plan
account or IRA under ERISA/IRC:
•
standard of
care when making
investment
•
•
•
•
•
Meet a professional
recommendations (e.g., give prudent advice);
Never put the financial interests of GSCM ahead of you when making
recommendations (e.g., give loyal advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that GSCM gives advice that
is in your best interest;
Charge no more than is reasonable for the services of GSCM; and
Give Client basic information about conflicts of interest.
To the extent we recommend you roll over your account from a current retirement plan
account to an individual retirement account managed by GSCM, please know that
GSCM and our investment adviser representatives have a conflict of interest.
We can earn increased investment advisory fees by recommending that you roll over
your account at the retirement plan to an IRA managed by GSCM. We will earn fewer
investment advisory fees if you do not roll over the funds in the retirement plan to an
IRA managed by GSCM.
Thus, our investment adviser representatives have an economic incentive to
recommend a rollover of funds from a retirement plan to an IRA which is a conflict of
interest because our recommendation that you open an IRA account to be managed by
our firm can be based on our economic incentive and not based exclusively on whether
or not moving the IRA to our management program is in your overall best interest.
We have taken steps to manage this conflict of interest. We have adopted an impartial
conduct standard whereby our investment adviser representatives will (i) provide
investment advice to a retirement plan participant regarding a rollover of funds from
the retirement plan in accordance with the fiduciary status described below, (ii) not
recommend investments which result in GSCM receiving unreasonable compensation
related to the rollover of funds from the retirement plan to an IRA, and (iii) fully
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disclose compensation received by GSCM and our supervised persons and any
material conflicts of interest related to recommending the rollover of funds from the
retirement plan to an IRA and refrain from making any materially misleading
statements regarding such rollover.
When providing advice to you regarding a retirement plan account or IRA, our
investment advisor representatives will act with the care, skill, prudence, and diligence
under the circumstances then prevailing that a prudent person acting in a like capacity
and familiar with such matters would use in the conduct of an enterprise of a like
character and with like aims, based on the investment objectives, risk, tolerance,
financial circumstances, and a client’s needs, without regard to the financial or other
interests of GSCM or our affiliated personnel.
C. Client Tailored Services and Client Imposed Restrictions
GSCM offers the same suite of services to all of its clients. However, specific client
financial plans and their implementation are dependent upon the client Investment
Policy Statement which outlines each client’s current situation (income, tax levels, and
risk tolerance levels) and is used to construct a client specific plan to aid in the selection
of a portfolio that matches restrictions, needs, and targets.
Clients may impose restrictions in investing in certain securities or types of securities in
accordance with their values or beliefs. However, if the restrictions prevent GSCM from
properly servicing the client account, or if the restrictions would require GSCM to
deviate from its standard suite of services, GSCM reserves the right to end the
relationship.
D. Wrap Fee Programs
GSCM does not participate in any wrap fee programs.
E. Amounts Under Management
GSCM has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$363,362,682
$0.00
1/2/2026
Item 5: Fees and Compensation
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A. Fee Schedule
Investment Supervisory Services Fees
Total Assets Under Management
Annual Fee
$1 - $5,000,000
1.00%
Above $5,000,000
Negotiable
These fees are negotiable, and the final fee schedule is attached as Exhibit II of the
Investment Advisory Contract. Fees are paid quarterly in advance, and clients may
terminate their contracts with written notice. Refunds are given on a prorated basis,
based on the number of days remaining in a quarter at the point of termination. Clients
may terminate their contracts without penalty, for full refund, within 5 business days of
signing the advisory contract. Advisory fees are withdrawn directly from the client’s
accounts with client written authorization.
It should be noted that lower fees for comparable service may be available from other
sources. The exact fees and other terms will be outlined in the agreement between you
and GSCM.
B. Payment of Fees
Payment of Investment Supervisory Fees
Advisory fees are withdrawn directly from the client’s accounts with client written
authorization. Fees are paid quarterly in advance.
C. Clients Are Responsible For Third Party Fees
Clients are responsible for the payment of all third-party fees (i.e. custodian fees, mutual
fund fees, transaction fee etc.). Those fees are separate and distinct from the fees and
expenses charged by GSCM.
Please see Item 12 of this brochure regarding
broker/custodian. Raymond James charges the following transaction fees to clients:
Trade Types
Transaction Fees
Equity Transaction fees
$0.00
ETFs
$0.00
Bonds
$14.95
M/fs, UITs, Closed-end Funds
$19.95
Options
$0.00 + $0.65 per contract
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Trade Types
Transaction Fees
Prime Brokerage
$25.00
D. Prepayment of Fees
GSCM collects fees in advance. Fees that are collected in advance will be refunded based
on the prorated amount of work completed at the point of termination and the total days
during the billing period. Fees will be returned within fourteen days to the client
Account.
E. Outside Compensation For the Sale of Securities to Clients
Neither GSCM nor its supervised persons accept any compensation for the sale of
securities or other investment products, including asset-based sales charges or services
fees from the sale of mutual funds.
Item 6: Performance-Based Fees and Side-By-Side Management
GSCM does not accept performance-based fees or other fees based on a share of capital gains on
or capital appreciation of the assets of a client.
Item 7: Types of Clients
GSCM generally provides investment advice to the following Types of Clients:
Individuals
High-Net-Worth Individuals
Pension and Profit-Sharing Plans
Government Entities
Minimum Account Size
There is an account minimum, $1,000,000 which can be waived by the investment
advisor, based on the needs of the client and the complexity of the situation.
Item 8: Methods of Analysis, Investment Strategies and Risk, of
Investment Loss
A. Methods of Analysis and Investment Strategies
GSCM uses fundamental analysis.
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Fundamental analysis involves the analysis of financial statements, the general financial
health of companies, and/or the analysis of management or competitive advantages.
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
B. Material Risks Involved
GSCM uses Long Term and Short-Term Trading, Short Sales, Margin Transactions, and
Options Writing including covered options, uncovered options, or spreading strategies.
GSCM utilizes investment strategies that are designed to capture market rates of both
return and risk. Frequent trading, when done, can affect investment performance,
particularly through increased brokerage and other transaction costs and taxes.
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
C. Risks of Specific Securities Utilized
GSCM generally seeks investment strategies that do not involve significant or unusual
risk beyond that of the general domestic and/or international equity markets.
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to a client’s or prospective client’s
evaluation of this advisory business or the integrity of our management.
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
Neither GSCM nor its representatives are registered as a broker/dealer or as
representatives of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity Pool
Operator, or a Commodity Trading Advisor
Neither GSCM nor its representatives are registered as a FCM, CPO, or CTA.
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C. Registration Relationships Material to this Advisory Business and
Possible Conflicts of Interests
GSCM is not and does not have a related person that is a broker/dealer, municipal
securities dealer, government securities dealer or broker, an investment company or
other pooled investment vehicle (including a mutual fund, closed-end investment
company, unit investment trust, private investment company or "hedge fund," and
offshore fund), another investment adviser or financial planner, a futures commission
merchant, commodity pool operator, or commodity trading advisor, a banking or thrift
institution, an accountant or accounting firm, a lawyer or law firm, a pension consultant,
a real estate broker or dealer, and a sponsor or syndicator of limited partnerships.
We are an independent registered investment adviser and only provide investment
advisory services. We are not engaged in any other business activities and offer no other
services except those described in this Disclosure Brochure.
D. Selection of Other Advisors or Managers and How This Adviser is
Compensated for Those Selections
GSCM does not utilize nor select other advisors or third-party managers. All assets are
managed by GSCM management.
Item 11: Code of Ethics, Participation in Transactions, Personal
Trading
A. Code of Ethics
We have a written Code of Ethics that covers the following areas: Prohibited Purchases
and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions,
Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality,
Service on a Board of Directors, Compliance Procedures, Compliance with Laws and
Regulations, Procedures and Reporting, Certification of Compliance, Reporting
Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual
Review, and Sanctions. Clients may request a copy of our Code of Ethics from
management.
B. Recommendations Involving Material Financial Interests
GSCM does not recommend that clients buy or sell any security in which a related
person to GSCM has a financial interest.
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C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of GSCM can buy or sell securities for themselves
that they also recommend to clients. GSCM will always document any transactions that
could be construed as conflicts of interest and will always transact client business before
their own when similar securities are being bought or sold and a block trade is not
affected.
D. Trading Securities At/Around the Same Time as Clients’ Securities
From time to time, representatives of GSCM can buy or sell securities for themselves at
or around the same time as clients.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
The Custodian, Raymond James & Associates, Inc. (RJA), a FINRA member, was
chosen based on their relatively low transaction fees and strong balance sheet.
GSCM will never charge a premium or commission on transactions, beyond the
actual cost imposed by Custodian.
1. Research and Other Soft-Dollar Benefits
Potential Soft Dollar Arrangements: Services provided by RJA to advisory firms
include research, brokerage, and custody. In addition, RJA makes available
technologies that provide access to client (trade confirmations and account
statements), facilitate trade execution, provide research, market data services,
facilitate payment of fees, performance reporting, and back-office support. RJA also
provides access to financial planning software, practice management support, best
execution assistance, conferences, marketing/educational materials, technology
support, and corporate discounts. GSCM pays a monthly fee to RJA for these
benefits.
2. Brokerage for Client Referrals
GSCM receives no referrals from a broker-dealer or third-party in exchange for using
that broker-dealer or third-party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
GSCM allows clients to direct brokerage. GSCM may be unable to achieve most
favorable execution of client transactions if clients choose to direct brokerage. This
may cost clients money because without the ability to direct brokerage GSCM may
not be able to aggregate orders to reduce transactions costs resulting in higher
brokerage commissions and less favorable prices.
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B. Aggregating (Block) Trading for Multiple Client Accounts
We may elect to purchase or sell the same securities for several clients at approximately
the same time. This process is referred to as aggregating orders, batch trading or block
trading and is used by our firm when GSCM believes such action may prove
advantageous to clients. If and when we aggregate client orders, allocating securities
among client accounts is done on a fair and equitable basis. Typically, the process of
aggregating client orders is done in order to achieve better execution, to negotiate more
favorable commission rates or to allocate orders among clients on a more equitable basis
in order to avoid differences in prices and transaction fees or other transaction costs that
might be obtained when orders are placed independently.
GSCM uses the average price allocation method for transaction allocation.
Under this procedure GSCM will calculate the average price and transaction charges for
each transaction included in a block order and assign the average price and transaction
charge to each allocated transaction executed for the client’s account.
If and when we determine to aggregate client orders for the purchase or sale of
securities, including securities in which GSCM or our associated persons may invest, we
will do so in accordance with the parameters set forth in the SEC No-Action Letter, SMC
Capital, Inc. Neither we nor our associated persons receive any additional compensation
as a result of block trades.
Item 13: Reviews of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes Those
Reviews
Client accounts are reviewed at least quarterly by GSCM staff.
B. Factors That Will Trigger a Non-Periodic Review of Client
Accounts
Reviews may be triggered by material market, economic or political events, or by
changes in client's financial situations (such as retirement, termination of employment,
physical move, or inheritance).
C. Content and Frequency of Regular Reports Provided to Clients
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Each client will receive at least quarterly a written report detailing the clients account
performance, which may come from the custodian.
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice Rendered
to Clients (Includes Sales Awards or Other Prizes)
GSCM does not receive any economic benefit, directly or indirectly from any third-party
for advice rendered to GSCM clients.
B. Compensation to Non –Advisory Personnel for Client Referrals
GSCM does not directly or indirectly compensate any person for client referrals.
Item 15: Custody
Custody, as it applies to investment advisors, has been defined by regulators as having access
or control over client funds and/or securities. In other words, custody is not limited to
physically holding client funds and securities. If an investment adviser has the ability to access
or control client funds or securities, the investment adviser is deemed to have custody and
must ensure proper procedures are implemented.
GSCM is deemed to have custody of client funds and securities whenever GSCM is given the
authority to have fees deducted directly from client accounts.
For accounts in which GSCM is deemed to have custody, we have established procedures to
ensure all client funds and securities are held at a qualified custodian in a separate account for
each client under that client’s name. Clients or an independent representative of the client will
direct, in writing, the establishment of all accounts and therefore are aware of the qualified
custodian’s name, address and the manner in which the funds or securities are maintained.
Finally, account statements are delivered directly from the qualified custodian to each client,
or the client’s independent representative, at least quarterly. Clients should carefully review
those statements and are urged to compare the statements against reports received from
GSCM. When clients have questions about their account statements, they should contact
GSCM or the qualified custodian preparing the statement.
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Item 16: Investment Discretion
When providing asset management services, GSCM maintains trading authorization over your
account and will provide management services on a discretionary basis. When discretionary
authority is granted, we will have the authority to determine the type of securities, the amount
of securities that can be bought or sold, the broker or dealer to be used and the commission
rates paid for your portfolio without obtaining your consent for each transaction. However, it is
the policy of GSCM to consult with you prior to making significant changes in the account even
when discretionary trading authority is granted.
Item 17: Voting Client Securities (Proxy Voting)
GSCM will not ask for, nor accept voting authority for client securities. Clients will receive
proxies directly from the issuer of the security or the custodian. Clients should direct all proxy
questions to the issuer of the security.
Item 18: Financial Information
A. Balance Sheet
GSCM does not require nor solicit prepayment of more than $1,200 in fees per client, six
months or more in advance and therefore does not need to include a balance sheet with
this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet
Contractual Commitments to Clients
Neither GSCM nor its management have any financial conditions that are likely to
reasonably impair our ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
Neither GSCM nor its management have been the subject of a bankruptcy petition in the
last ten years.
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