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PRINCETON GLOBAL ASSET MANAGEMENT, LLC
17 Hulfish Street, Suite 240
Princeton, NJ 08542
A SEC Registered Advisory Firm1
FIRM BROCHURE, MAY 2025
This brochure provides information about the qualifications and business practices of
Princeton Global Asset Management, LLC (“PGAM”). If you have any questions
about the content of this brochure, please contact us at (609) 945-1781 and/or
www.princetonglobal.com. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any state
securities authority.
Additional information about PGAM is available on the SEC’s website at
www.adviserinfo.sec.gov
1 SEC or State registration does not and should not imply any certain level of skill or training.
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Item 2. Material Changes
In 2024, PGAM has added an estate planning service provider. Please refer to Item 4 for additional
information. There have not been any other material changes to PGAM’s advisory business or
personnel since the filing of its 2024 Annual ADV Disclosure Brochure.
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Item 3. Table of Contents
Item 4. Advisory Business ......................................................................................................... 4
Item 5. Fees and Compensation ................................................................................................ 6
Item 6. Performance Based Fees and Side by Side Management ............................................ 7
Item 7. Types of Clients ............................................................................................................ 7
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss..................................... 8
Item 9. Disciplinary Information .............................................................................................. 8
Item 10. Other Financial Industry Activities and Affiliations ................................................... 8
Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ...................................................................................................................................... 9
Item 12. Brokerage Practices ................................................................................................... 10
Item 13. Review of Accounts .................................................................................................... 11
Item 14. Client Referrals and Other Compensation ................................................................. 11
Item 15. Custody ...................................................................................................................... 12
Item 16. Investment Discretion ............................................................................................... 12
Item 17. Voting Client Securities ............................................................................................. 12
Item 18. Financial Information ................................................................................................ 12
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Item 4: Advisory Business
PGAM was founded on January 31, 2008. PGAM is principally owned and managed by Paul J. Gerard
and Brett M. Shaver.
PAUL GERARD, Chairman of PGAM, has over 40 years of investment experience. Paul earned a
B.S. from the University of California, Berkeley, and an M.B.A. from New York University Graduate
School of Business Administration. Paul is a CFA® Charterholder and is a member of the New
York Society of Security Analysts (NYSSA).Prior to forming PGAM, Paul was a Managing Director
and Senior Portfolio Manager for BlackRock/Merrill Lynch Investment Managers from 1986 to 2007.
(Merrill Lynch Investment Managers (MLIM) combined with BlackRock in 2006.) Paul was a
member of the domestic Investment Policy and Strategy Committee and served as Chairman of the
International Policy and Strategy Committee. Before joining MLIM in 1986, Paul was associated
with Equitable Investment Management Corporation in New York for 13 years.
BRETT M. SHAVER is President and Portfolio Manager of PGAM. As a leader of the Investment
Team, Brett focuses on providing customized investment advice to PGAM’s clients. Prior to joining
PGAM in 2016 as a Partner, Brett was a Senior Research Analyst for BlackRock and managed the
fundamental investment analysis within the Technology, Consumer and Energy sectors for large cap
equity strategies. Before joining BlackRock via the combination with Merrill Investment Managers in
2006, Brett served as a generalist fundamental analyst on a team led by President and Chief Investment
Officer of MLIM and served as an analyst for equity and balanced separately managed accounts. Brett
earned a BSBA degree from Bucknell University in 2002 where he majored in Management and
minored in Economics. Brett is a CFA® Charterholder and is a member of the CFA Society New
York. In 2015 he completed the Columbia University Graduate School of Business Executive
Education program in Financial Analysis and Valuation.
ERICA S BULLINGER is Chief Operating Officer of PGAM, primarily responsible for the day-to-
day operations of the firm. Prior to joining PGAM in 2025, Erica was a Managing Director and
Product Strategist for BlackRock, responsible for product management for the Global Allocation
Platform across retail and institutional clients globally. Erica joined BlackRock as part of the 2007
analyst class, and held different roles within the product strategy group during her 18 years with the
firm. Erica earned a BS degree from Villanova University in 2007 where she majored in Finance and
Economics. She is a CFA® Charterholder and is a member of the CFA Society New York.
Investment Management Services:
PGAM furnishes “investment supervisory services,” defined as giving continuous advice to Clients
on the investment of their funds based on their individual needs. We provide US, International and
Global investment strategies that are customized to our Clients’ investment objectives and needs
through equity, fixed income and balanced accounts. Our customization considers risk tolerance, time
horizon, liquidity needs, tax considerations, and Client directed restrictions such as, but not limited to,
social concerns, and all other pertinent issues of our Clients.
We provide investment advice based on information Clients provide us about personal, financial and
tax statuses, and investment objectives and policies, as well as any updates or changes to their
information. We impose no restrictions on the ability of Clients to contact and consult with us.
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Use of Independent Managers: In certain situations, PGAM may allocate a portion of their clients’ assets
by and/or among certain independent investment managers (“Independent Managers”), based upon
the stated investment objectives of the client. Currently, PGAM uses certain managers for municipal
bond management and income enhancement and option overlay strategies. Thes Independent
Managers are accessible through Schwab’s Managed Account Marketplace. The terms and conditions
under which the client engages the Independent Managers are set forth in a separate written agreement
between PGAM, the client and the designated Independent Managers. PGAM monitors and reviews
the account performance and investments to ensure they align with the client’s investment objectives.
PGAM Clients also receive each Independent Manager’s ADV Brochure.
Pension/Endowment/Foundation Consulting Services
PGAM also provides investment planning, implementation advice, and portfolio management
recommendations to primarily an institutional client base. Typical clients include corporate and public
retirement plans; foundations and endowments. As part of its services, PGAM works with its clients
to develop Investment Policy Statements, asset allocation models and investment manager
recommendations which are tailored to the individual needs of clients. PGAM delivers comprehensive
written reports for review and discussion, on a monthly and quarterly basis, which include
performance evaluations of each investment manager, and each portfolio; comparative performance
for established benchmarks, and for peer institutions; assessment of asset allocation and need, if any,
for rebalancing.
PGAM does not participate in wrap fee programs.
AUM/AUA
As of December 31, 2024, PGAM maintained approximately $782 million in clients’ assets under
management (AUM) primarily on a discretionary basis. In addition, PGAM provides consulting
advisory services to more than $58 Millon, on an asset under advisement basis (AUA). Collectively
PGAM provides advisory services to more than $840 million in client assets.
Investment Management Services for “Held Away” Accounts
We offer an additional investment management service for “Held Away accounts,” such as 401(k),
403(b) plan accounts. We use a third-party platform, Pontera, to leverage an Order Management
System to implement asset allocation and opportunistic rebalancing strategies on behalf of clients. We
regularly review the available investment options in these accounts, monitor them, and rebalance and
implement our strategies in the same way we do other accounts, though using different tools, as
necessary.
A link will be provided to Clients allowing them to connect account(s) to the platform. Once a client’s
account is connected to the platform, we will review the current account allocations. When deemed
necessary, we will rebalance the account considering the Client’s investment goals and risk tolerance,
and any change in allocations will consider current economic and market trends. The goal is to
improve account performance over time, minimize loss during difficult markets, and manage internal
fees that harm account performance. Client account(s) will be reviewed and allocation changes will be
made as deemed necessary. The Pontera’s platform allows us to avoid having custody of Clients’ funds
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since we do not have direct access to Client log-in credentials. We are not affiliated with Pontera and
receive no compensation from Pontera for using their platform.
Financial Planning Services:
PGAM provides its clients with financial planning and consultation services (e.g., review of goals and
objectives, analysis and recommendations for cash flow planning, asset allocation/investment
planning, income tax planning, insurance planning, estate planning, retirement planning, education
planning, real estate/mortgage planning, etc.).
Estate Planning Services:
Through our partnership with an independent third-party technology company, Wealth, Inc.
("Wealth”), PGAM can facilitate the preparation of various estate planning documents for clients.
Such services are generally separate from any investment management and/or financial planning
services that we may render to a client, and the exact scope of such estate planning services will depend
on the nature of a client’s specific estate planning needs. As a condition of utilizing Wealth, you must
agree to the terms and conditions available at wealth.com. PGAM may pay for your access to Wealth.
For the avoidance of doubt, neither PGAM nor Wealth render legal advice or services. Wealth offers
the ability to consult with licensed attorneys in various jurisdictions at an additional charge, and subject
to additional terms
Item 5: Fees and Compensation
PGAM’s fees are generally charged in arrears on a quarterly basis as a percentage of assets under
management. However, upon agreement between a Client and PGAM, fees may also be charged in
advance, on a schedule other than quarterly, or at a fixed rate. When charged as a percentage of assets
under management, fees are calculated based on the quarter end’s market value as determined by the
Client’s custodian. This market value is multiplied by the agreed upon annual fee percentage. One
quarter (¼) of this annual fee will then be charged. Fees are usually deducted from the Client's account
by the custodian with the Client’s prior authorization upon receipt of an invoice from PGAM and
transferred to PGAM. However, other methods of payment, such as payment from another account,
are possible.
Clients may incur brokerage commissions, other trade-related fees, custodian fees, and fees associated
with any investment company securities (e.g., closed- or open-end mutual funds and ETFs) their
accounts may contain. Clients also have the option to purchase investment products that PGAM
recommends through other brokers or agents that are not affiliated with PGAM. Further details about
our brokerage practices can be found in Item 12: Brokerage Practices.
Independent Manager utilized by PGAM assess an advisory fee in addition to PGAM’s advisory fee.
Such fee is debited separately and paid directly to the Independent Manager. The terms and
conditions of these fees are set forth in the agreement between the client and the Independent
Manager.
PGAM’s advisory fees are generally negotiated based on a number of factors including, but not limited
to, the size and type of account, securities held, strategies implemented, and the number and types of
Client restrictions applied. However, PGAM will not assess any advisory fee in excess of 1.50%.
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Clients can terminate their Discretionary Management Agreement with PGAM at any time. In the
event an Agreement includes a fee paid in advance and is terminated before a fee period’s end, any
unearned fee will be returned to the Client by a mutually agreed upon method.
Financial Planning Fees:
PGAM’s financial planning and consulting fees are negotiable, but generally are $300 on an hourly
rate basis, and from $1,000 to $25,000 on a fixed fee basis, depending upon the level and scope of the
service(s) required and the professional(s) rendering the service(s). Prior to engaging PGAM to
provide financial planning or consulting services, clients will be required to enter into a Financial
Planning Agreement with PGAM setting forth the terms and conditions of the engagement, describing
the scope of the services to be provided, and the portion of the fee that is due from the client prior
to PGAM commencing services.
Item 6: Performance Based Fees and Side-By-Side Management
PGAM does not charge performance-based fees.
Item 7: Types of Clients
PGAM serves individual, high net worth individuals, pension, retirement and profit-sharing plans
partnerships, estates, trusts and corporations. PGAM generally maintains a minimum account value
of $1 million, however it reserves the right to negotiate this and other conditions for starting or
maintaining an account. We also reserve the right not to provide investment advisory services to a
Client when it is not in the Client’s or our best interests.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
PGAM’s primary method of analysis is fundamental analysis. We also consider global market
conditions, country and regional fiscal and monetary policies, macro-economic developments,
currency trends, and geo-political environments. Our main sources of information include financial
newspapers and magazines, inspections of corporate activities, research materials provided by others,
corporate rating services, and companies’ press releases, annual reports, prospectuses, and filings with
the Securities and Exchange Commission. We also utilize local and global general news sources,
internet-based services, academic, governmental, and international organizations’ research and
reports.
The types of investments and investment strategies utilized by PGAM vary depending on the
particular investment objectives and restrictions selected by our Clients. We provide US, International
and Global investment strategies that are customized to our Clients’ investment objectives through
diversified equity, fixed income and balanced separately managed accounts. We consider a US
investment strategy to invest primarily in US domiciled entities. We consider an International
investment strategy to invest primarily in non-US domiciled entities, and a Global investment strategy
to invest in a mix of both US and non-US domiciled entities.
To execute these strategies, we may purchase exchange-listed securities, including American
Depository Receipts (“ADRs”) and Exchange Traded Funds (“ETFs”), securities traded over-the-
counter, securities issued by foreign issuers, warrants, corporate debt securities, certificates of deposits,
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municipal securities, mutual fund shares, United States government securities, and foreign bonds
issued or guaranteed by foreign governments and international organizations.
International and Global investment strategies contain special risks and circumstances involved in
investing in foreign securities, including but not limited to currency fluctuations, political and
economic instability, and expropriation, confiscatory or withholding taxation practices of foreign
governments. There may also be reduced availability of public information about issuers, including
but not limited to less accounting and financial reporting. Foreign financial markets may be less liquid
and more volatile and may be subject to less regulation than US markets. Investing in foreign markets
may also involve settlement delays and higher commission and transaction costs.
An International Equity or Balanced Investment Strategy, and the non-US securities component of a
Global Equity or Balanced Investment Strategy, are invested primarily in ADRs. The number of ADRs
available with respect to a given country or region may not be representative of that country or region’s
proportionate share of the world securities market. Direct investments in some non-US securities may
be prevented or made impractical by factors including federal, state or local country law or regulation.
In addition, these strategies may not be diversified across industry sectors.
Trading in Client accounts may be long-term or short-term. Depending on the investment objective
selected, and the level of customization involved, annual account turnover of an account may be
minimal or substantial. PGAM does not guarantee the future performance of any investment strategy
or any specific level of performance, the success of any investment recommendation or strategy, or
the success of PGAM’s overall management of a strategy. PGAM’s investment recommendations are
subject to various markets, currency, economic, political and business risks. Past performance is not a
guarantee of future results and our investment decisions and strategies will not always be profitable.
Item 9: Disciplinary Information
There are no disclosable legal or disciplinary events associated with PGAM or its supervised personnel.
Item 10: Other Financial Industry Activities and Affiliations
Receipt of Insurance Commission
Certain of PGAM’s Supervised Persons, in their individual capacities, are also licensed insurance agents
with various insurance companies, and in such capacity, may recommend, on a fully- disclosed
commission basis, the purchase of certain insurance products. While PGAM does not sell such
insurance products to its investment advisory clients, PGAM does permit its Supervised Persons, in their
individual capacities as licensed insurance agents, to sell insurance products to its investment advisory
clients. A conflict of interest exists when PGAM’s Supervised Persons recommends insurance
products and receives compensation. Any such contemplated transaction is fully disclosed to the
client, including all compensation terms.
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Pontera Platform
PGAM is not affiliated with Pontera in any way and receives no compensation from Pontera in
connection with our use of the Pontera Platform. Clients are advised that our management of accounts
via the Pontera Platform is subject to the limitations and restrictions imposed by the underlying
sponsor, issuer, and/or custodian of the client’s held-away assets. For example, our instructions to
rebalance holdings within your held-away account through the Pontera Platform may not be
implemented by the account sponsor, issuer, or custodian for up to one (1) business day or more
following entry. We may also not be able to view real-time account value and holdings data over the
Pontera Platform. Clients understand that our investment of the assets held within such accounts is
limited to allocation of the client’s assets among the various investment options made available by the
account sponsor, issuer, or custodian.
Upon entering into an agreement for advisory services with us, clients authorize us to use unrelated
third-party service providers (including Pontera) to service their account(s). We require unrelated
third-party service providers to execute a confidentiality agreement and not share client information
with any unauthorized person or entity. The use of unrelated third-party service providers will not
cause the client to incur any additional fees. We pay unrelated third-party service providers (including
Pontera) for services out of the total advisory fee charged to the client.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
PGAM enforces Compliance Policies and Procedures which include Insider Trading and Personal
Trading Policies. These policies require pre-clearance procedures, and transaction, holdings and
account monitoring that are designed to prevent potential conflicts of interest and the infringement
of statutory and other rules relating to trading and similar activities. Each employee who makes
investment recommendations or decisions for Clients, who participates in the determination of such
recommendations or decisions, or who, in connection with their duties, obtains information
concerning which securities are being purchased or sold or recommended for such action, must
comply with the applicable requirements and restrictions of our Compliance Manual of Policies and
Procedures.
Among other restrictions, our employees' personal trading may not be executed on the basis of
information that is not generally available to the investing public. In addition, our employees are
prohibited from trading securities which are under consideration for purchase or sale by PGAM’s
Investment Committee before the Committee’s decision to purchase or sell the securities is made.
These and other restrictions are designed and enforced in order to established and maintain the
primacy of our Clients’ interests above all else.
PGAM’s Code of Ethics is intended to reflect fiduciary principals that govern the conduct of PGAM
Employees in general and in those situations where PGAM provides investment advice to Clients in
particular. Our Compliance Manual consists of policies and procedures regarding several key areas:
standards of conduct and compliance with laws, rules and regulations, safeguarding Client and PGAM
information and privacy, insider trading, personal securities trading, and our Code of Ethics.
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PGAM maintains and enforces a Privacy Policy. PGAM respects our Clients’ right to keep their
personal information confidential and understands their desire to avoid unwanted solicitations. Unless
compelled by a validly issued and enforceable subpoena or summons, PGAM will not disclose
personal information about our Clients or former Clients to anyone without their authorization. We
also restrict access to non-public personal information about our Clients to employees of our firm and
other parties who must use that information to provide services to our Clients.
Item 12: Brokerage Practices
PGAM may select brokers which provide us with research or other transaction-related services.
However, PGAM does not participate in “soft-dollar” arrangements with any broker. That is, PGAM
does not accumulate soft dollar credits with any broker, and any benefits PGAM may receive from
any broker, such as obtaining research or any other goods or services, is not contingent upon any level
of commission generation or trading activity.
PGAM recommends custodians and/or brokers that we reasonably believe will provide the best
execution of services, including trading. PGAM generally will seek competitive commission rates but
will not necessarily attempt to obtain the lowest possible commission for transactions. In selecting
brokers for a particular transaction, PGAM may consider all relevant factors, including the execution
capabilities required by the transaction, the importance of speed, efficiency or confidentiality,
familiarity with sources from whom or to whom particular securities might be purchased or sold, as
well as any other relevant matter.
Consistent with obtaining best execution, transactions for a Client’s account are directed to brokers
that furnish PGAM with research or other services regardless of the amount of commissions and trade
activity generated by the relationship between PGAM and the broker. Such research or other services
benefit all of PGAM’s Clients and brokerage commissions paid by a particular Client for a particular
transaction do not benefit that particular Client but all of PGAM’s Clients. PGAM may, in its
discretion, cause a Client to pay brokers a commission greater than another qualified broker might
charge to effect the same transaction where PGAM determines in good faith that the commission is
reasonable in relation to the value of the brokerage services received.
It is also usual for custodians to provide certain products and services to investment advisers in order
to facilitate business between them. For example, custodians may provide PGAM with software for
downloading information into our account management and accounting systems and submitting client
trades. They may also provide us with services such as practice management and compliance assistance
depending on the total value of Client assets held with the custodian. PGAM may also utilize any
custodian's research products and services.
PGAM does not accept Client referrals from brokers or custodians in consideration for selecting
brokers or custodians for services. PGAM may recommend custodians and/or brokers to Clients and
Clients may designate their own if PGAM agrees.
It is usually anticipated that all or a significant amount of brokerage transactions for a Client’s account
will be placed through the custodian of the Client’s account if the custodian is also the broker and the
account is a retail brokerage account. In the event a Client directs PGAM to use a particular custodian
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and/or broker, it is made clear to the Client in writing that PGAM may not have the authority to
negotiate commissions, obtain volume discounts, aggregate that Client’s orders or ensure best
execution, and that there may be a disparity in commission charges with other Clients.
Transactions for each Client generally will be effected independently on a rotational allocation basis.
To the extent permitted by law, PGAM shall also be permitted to, but is not obligated to, combine
trade orders to obtain best execution, to negotiate more favorable commission rates, or to allocate
equitably among PGAM’s Clients. Clients may experience differences in prices and commissions or
other transaction costs that might have been obtained had such orders been placed independently.
Under this procedure, transaction prices and costs are shared equally on a pro-rata basis between all
accounts in any such combined trade order.
Item 13: Review of Accounts
Under the direction of the Chief Investment Officer, members of the PGAM Investment Committee
review select accounts on a daily basis for cash flows, security additions or withdrawals, trade
settlement, corporate action processes, trading to model, and other account-appropriate operational
processes. Selection of accounts is based on several factors such as its status of bringing the account
to model or restrictions, account specific circumstances such as expected inflows or outflows of
securities and/or cash, or any other circumstances unique to the account. All accounts are reviewed
on a monthly basis for cash flows, security additions or withdrawals, trade settlement, corporate action
processes, and trading to model.
They are reviewed on a quarterly basis for adherence to investment objective, asset allocation, stage
of implementation of investment strategy, and other account-appropriate management requirements.
The Chief Operating Officer is also responsible for monitoring accounts for cash flows, security
additions or withdrawals, trade settlement, corporate action processes, and other account-appropriate
operational processes. Unscheduled reviews are triggered by changes to a holding's fundamentals, or
a Client's circumstances such health, employment, family, etc.
At a minimum, each PGAM Client receives on a quarterly basis a written report of account holdings,
market value and advisory fees. Clients may also receive interpretive comments on investment
positions and the general investment environment. Such reports and commentaries are always
provided to Clients upon request. Clients may also receive transaction confirmations and monthly, or
on another frequency, statements from brokers and their custodians.
Item 14: Client Referrals and Other Compensation
PGAM is required to disclose any relationship or arrangement where it receives an economic benefit
from a third party (non-client) for providing advisory services. PGAM may receive economic benefits
from non-clients for providing advice or other advisory services to clients. This type of relationship
poses a conflict of interest and any such relationship is disclosed in response to Item 12, Brokerage
Practice, see above.
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Item 15: Custody
PGAM primarily does not maintain physical custody of client assets. All client assets are custodied
with nationally recognized, SEC registered and FINRA member broker-dealer/custodians. Clients are
provided with transaction confirmation notices and regular summary account statements directly from
the broker-dealer/custodian of the client accounts. PGAM provides a report summarizing account
activity, positions and performance. Clients are advised that the custodian statement is the official
record of their account(s) and PGAM’s reporting is for informational purposes only.
PGAM is deemed to have custody of client funds solely because it has the ability to authorize the
custodians to debit its Advisory Fee but otherwise PGAM has no ability to access client funds.
Item 16: Investment Discretion
Clients usually grant PGAM discretionary trading authorization and appoint PGAM as agent and
limited attorney-in-fact with respect to their accounts. However, Clients may impose investment
restrictions or other special instructions as described in Item 4: Advisory Business. When necessary
and appropriate, Clients agree to sign a “Limited Powers of Attorney” or “Trading Authorization” as
may be required by their custodian and/or broker. Pursuant to such agreement(s), PGAM is
authorized to purchase, sell, exchange and otherwise trade in the securities and other investments in
the Client’s account(s) and act on behalf of the Client in all other matters necessary or incidental to
the handling of the Client’s account.
Item 17: Voting Client Securities
Generally, PGAM will not vote proxies of securities in Client accounts. If PGAM agrees to a Client’s
request for PGAM to vote proxies, PGAM will vote proxies in accordance with our Proxy Policy and
Procedures. In general, PGAM will act prudently, taking into consideration those factors that may
affect the value of the security, and will vote such proxies in a manner that, in our opinion, is in the
best interest of the Client. Information about how PGAM voted proxies will be available to the Client
upon request. PGAM will provide a copy of our Proxy Policy and Procedures upon request.
Item 18: Financial Information
PGAM is not required to provide a balance sheet for our most recent fiscal year as we do not require
or solicit prepayment of more than $1,200 in fees per Client six months or more in advance.