Firm Description
GCM was established in 1993. GCM is majority owned by Gallacher, LLC. Gallacher Equity
Management (“GEM”) is wholly owned by GCM.
As of March 12, 2024, GCM managed approximately $463,132,952; $417,618,633 of client
assets on a discretionary basis and $45,514,319 on a non-discretionary basis.
Investment Advisory and Management Services
Through its Investment Advisory Agreement (“IAA” or “Client Agreement”), GCM offers
Investment Advisory Services (“IAS”) as an integrated approach that includes, but is not
limited to, wealth management, investment management, financial planning and consulting.
GEM Investment Management Service is offered to clients of GCM as a separate investment
platform of proprietary strategies created or sourced by GCM, which may change from time
to time, and is independent from IAS mentioned above. More information regarding GEM
analysis is available in Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
within this Brochure.
GCM and GEM consider information collected from their clients, such as their financial status,
investment objectives, investment restrictions and tax status, among other data. The GEM
investment strategy options are described further below in Item 8 – Methods of Analysis,
Investment Strategies and Risk of Loss within this Brochure.
GCM does not serve as an attorney or accountant, and no portion of their services should be
construed as legal, tax or accounting services.
GCM may also provide client access to eMoney, an internet-based service which can
incorporate all the client’s investment assets, including those investment assets that are not
part of the assets that GCM manages (“Assets Held Away”). The client remains solely
responsible for the investment performance of the Assets Held Away.
Private Investment Funds
GCM may also provide investment advice regarding both affiliated and unaffiliated private
investment funds. GCM, on a non-discretionary basis, may recommend that certain qualified
clients consider an investment in private investment funds.
As of March 26, 2024, GCM is affiliated with three private investment funds: GEM Private
Equity Fund, L.P., GEM Private Equity Fund II, L.P., and GEM goHomePort Fund I, L.P.
(together “Affiliated Funds”).
The GEM Private Equity Fund, L.P. (“GEM Fund I”) and GEM Private Equity Fund II, L.P.
(“GEM Fund II”) are single purpose private equity funds organized to make a total investment
of $24 million via a debt offering which includes warrants in Folium BioSciences, a United
States (“U.S.”) based fully integrated whole hemp genetic, cultivation, extraction, production
and distribution company. The GEM goHomePort Fund I, L.P. (“GEM goHomePort Fund”) is a
private fund organized to invest in real estate and other related investments. As of March 26,
2024, the fund investment window is open with a total investment of $18.2 million.
If a client invests in a private investment fund, the assets invested are generally included in
calculating GCM’s fees. Since GCM and/or its affiliates can earn compensation from the
Affiliated Funds (i.e., management fees and/or incentive compensation) that may exceed the
fee that GCM and/or its affiliates would earn under its IAA referenced in Item 5 – Fees and
Compensation below, the recommendation that a client purchase an interest in any Affiliated
Fund presents a conflict of interest. No client is under any obligation to become an Affiliated
Fund investor. GCM’s CCO, Quentin Stoker, remains available to address any questions
regarding this conflict of interest.
Private investment funds do not provide daily liquidity or pricing. Each prospective client
investor will be required to complete a Subscription Agreement, pursuant to which the
investor client shall establish that he/she is qualified for investment in the fund and
acknowledges and accepts the various risk factors that are associated with such an
investment.
Retirement Plan Consulting Services
GCM may be engaged to provide discretionary and/or non-discretionary pension consulting
services, pursuant to which it assists sponsors of self-directed retirement plans with the
selection
and/or monitoring of investment alternatives, generally open-end mutual funds,
from which plan participants shall choose in self-directing the investments for their individual
plan retirement accounts. In addition, to the extent requested by the plan sponsor, GCM shall
also provide participant education designed to assist participants in identifying the appropriate
investment strategy for their retirement plan accounts. The terms and conditions of the
engagement shall generally be set forth in a Retirement Plan Services Agreement between
GCM and the plan sponsor.
Retirement Account Rollovers. A client or prospective client leaving an employer typically has
four options regarding an existing retirement plan (and may engage in a combination of these
options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the
assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll
over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which
could, depending upon the client’s age, result in adverse tax and penalty consequences). If a
client rolls over their retirement plan assets into an account to be managed by GCM, it could
create a conflict of interest if GCM will earn a new (or increase its current) advisory fee as a
result of the rollover. GCM and/or its affiliates do not recommend any one option as it relates
to client rollovers for new or existing clients, but rather, educates the client on their options
available to them. No client is under any obligation to rollover retirement plan assets to an
account managed by GCM.
ERISA/IRC Fiduciary Acknowledgment. When GCM provides investment advice to a client
regarding the client’s retirement plan account or individual retirement account, it does so as
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 GCM makes money creates some conflicts with client interests,
so GCM operates under a special rule that requires it to act in the client’s best interest and
not put its interests ahead of the client’s. Under this special rule's provisions, GCM must:
Meet a professional standard of care when making investment recommendations
(give prudent advice);
Never put its financial interests ahead of the client’s when making recommendations
(give loyal advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that GCM gives advice that is in
the best interest of the client;
Charge no more fees than are reasonable for GCM’s services; and
Give the client basic information about conflicts of interest.
Financial Planning and Consulting Services
GCM offers personal financial planning tailored to a client’s individual needs. This financial
planning may be included as part of IAS or through a separate Financial Planning Agreement.
GCM also offers consulting services with services specified in the consulting agreement.
Financial planning and consulting services may include, as selected by the client, information
and recommendations regarding tax planning, investment planning, retirement planning,
estate planning, business planning, education planning, life and disability insurance needs,
long-term care needs and cash flow/budget planning.
These services consider information collected from the client such as financial status,
investment objectives and tax status, among other data. The Investment Advisor
Representatives (“IAR”) may or may not deliver to the client a written analysis or report as
part of these services.
Client Obligations. As GCM performs these services, GCM shall not be required to verify any
information received from the client or from clients’ other professionals and is expressly
authorized to rely thereon. Moreover, each client is advised that it remains his/her/its
responsibility to promptly notify GCM if there is ever any change in his/her/its financial
situation or investment objectives for the purpose of reviewing, evaluating or revising GCM’s
previous recommendations and/or services.