A. Description of the Advisory Firm
GFS Wealth Management Advisors, Inc. dba Ganim Private Wealth (hereinafter “GFS”) is
a Corporation organized in the State of Connecticut. The firm was formed in September
2016, and is owned by Coastline Holdings Group, LLC.
B. Types of Advisory Services
Portfolio Management Services
GFS offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. GFS 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 to aid in the selection of a
portfolio that matches each client's specific situation. Portfolio management services
include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
GFS evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. GFS will request discretionary authority from clients in order to
select securities and execute transactions without permission from the client prior to each
transaction. Risk tolerance levels are documented in the Investment Policy Statement,
which is given to each client.
GFS seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of GFS’s economic, investment or
other financial interests. To meet its fiduciary obligations, GFS attempts to avoid, among
other things, investment or trading practices that systematically advantage or
disadvantage certain client portfolios, and accordingly, GFS’s policy is to seek fair and
equitable allocation of investment opportunities/transactions among its clients to avoid
favoring one client over another over time. It is GFS’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent, including
initial public offerings ("IPOs") and other investment opportunities that might have a
limited supply, among its clients on a fair and equitable basis over time.
Pension Consulting Services
GFS offers consulting services to pension or other employee benefit plans (including but
not limited to 401(k) plans). Pension consulting may include, but is not limited to:
• Identifying investment objectives and restrictions
• Providing guidance on various assets classes and investment options
• Recommending money managers to manage plan assets in ways designed
to achieve objectives
• Monitoring performance of money managers and investment options and
making recommendations for changes
• Recommending other service providers, such as custodians,
administrators and broker-dealers
• Creating a written pension consulting plan
These services are based on the goals, objectives, demographics, time horizon, and/or risk
tolerance of the plan and its participants.
Financial Planning
Financial plans and financial planning may include, but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning.
Services Limited to Specific
Types of Investments
GFS generally limits its investment advice to mutual funds, fixed income securities, real
estate funds (including REITs), insurance products including annuities, equities, ETFs
(including ETFs in the gold and precious metal sectors), treasury inflation
protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds
and private placements. GFS may use other securities as well to help diversify a portfolio
when applicable.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. The way we make money
creates some conflicts with your interests, so we operate under a special rule that requires
us to act in your best interest and not put our interest ahead of yours. Under this special
rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
C. Client Tailored Services and Client Imposed Restrictions
GFS will tailor a program for each individual client. This will include an interview session
to get to know the client’s specific needs and requirements as well as a plan that will be
executed by GFS on behalf of the client. GFS may use “model portfolios” together with a
specific set of recommendations for each client based on their personal 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
GFS from properly servicing the client account, or if the restrictions would require GFS to
deviate from its standard suite of services, GFS reserves the right to end the relationship.
D. Wrap Fee Programs
GFS acts as portfolio manager for and sponsor of a wrap fee program, which is an
investment program where the client pays one stated fee that includes management fees,
transaction costs, fund expenses, and other administrative fees. Clients utilizing GFS’s
wrap fee portfolio management should see the separate Wrap Fee Program Brochure. GFS
manages the investments in the wrap fee program, but does not manage those wrap fee
accounts any differently than it would manage non-wrap fee accounts. Fees paid under
the wrap fee program will be given to GFS as a management fee. Please also see Item 5
and Item 12 of this brochure.
E. Assets Under Management
GFS currently has $ 350,000,000.00 in assets under advisement.
GFS has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 131,543,639.00 $ 0.00 December 2023