• G.A. Repple & Company (“G.A. Repple”, GAR, the “Firm”, or “Advisor”), member FINRA and SIPC,
has been primarily engaged as a broker/dealer in the offer and sale of securities products since
1986. In addition to its broker/dealer activities, G.A. Repple has also been registered as an
Investment Advisor since 1983.
• The Advisor is owned 100% by its parent company, G.A. Repple Financial Group, Inc. (“Financial
Group”). The Glenn A. Repple Revocable Trust (Glenn A. Repple, Trustee) is the majority
stockholder of Financial Group. The remaining minority ownership in Financial Group is allocated
among a small number of other family members.
• GAR Advisory Representatives and GAR branch offices may use marketing names or other names
that are held out to the public. Such names are known as “doing business as or DBA” names. The
purpose of using a name other than G.A. Repple is for the Advisory Representative to create a
brand that is specific to the Advisory Representative and/or branch but separate from GAR. While
GAR allows its Advisory Representatives to use a name other than GAR, the Advisory
Representative must disclose on advertising and client correspondence that advisory services are
offered through G.A. Repple & Company.
• Some GAR Advisory Representatives may also provide securities advice as registered
representatives of G.A. Repple & Company, a broker/dealer. In that separate capacity as
registered representatives, GAR’ Advisory Representatives may charge commissions on a per-
transaction basis when implementing their advice on behalf of clients. As such, certain advisory
services may be provided under alternative names, which are listed in Section 1.B of Schedule D
of Form ADV Part 1.
• Investment strategies and philosophies differ among Financial Professionals who are responsible
for determining and implementing their own investment advice under the supervision and
compliance controls of G. A. Repple & Company. GAR does not consider itself as specializing in
any one form of advisory service.
• As of March 29, 2024, G.A. Repple manages approximately $612,758,337 in client assets.
Approximately $575,758,337 is managed on a discretionary basis, and approximately $37,110,857
is managed on a non-discretionary basis.
Types of Advisory Services
G.A. Repple provides various types of investment supervisory services for its clients. Descriptions of these
services are provided below in the section titled “Types of Agreements”. On more than an occasional basis,
the Firm furnishes advice to clients on matters not involving securities, such as financial planning matters,
taxation issues, and trust services that often include estate planning.
Tailored Relationships
The goals and objectives for each client are determined one on one by the Firm’s Investment Advisory
Representative’s (IARs). A personalized plan is typically created that reflects the stated goals and objectives
of each client. Each IAR may employ strategies and techniques as they see fit such as the following:
• Technical analysis
• Fundamental analysis
• Qualitative analysis
• Quantitative analysis
• Market timing
• Risk Management Analysis
• Cash Flow and Net Worth Analysis
• Portfolio Review and Evaluation
• Retirement Account Analysis
• Budgeting
• Planning for Family Member Special Needs
• Divorce Planning
• Developing a Comprehensive Documented Financial Plan
• Retirement Planning
• Education Funding Planning
• Review of Medical, Disability, and other insurance
• Estate Analysis and Planning
• Financial Planning and Education Seminars
• Technical analysis
• Fundamental analysis
• Qualitative analysis
• Quantitative analysis, Market timing
With certain advisory offerings clients can impose restrictions on investing in certain securities or types of
securities.
GAR Advisory Representatives also provide financial planning services to business entities and groups
requesting educational services and financial planning seminars or individual consulting and planning
services to be provided to employees, members or entity. Each participating employee or member will be
required to execute a separate agreement with GAR when individual planning or consulting services will
be provided depending on the services being provided.
GAR Advisory Representatives are permitted to provide financial planning seminars. Such services are
provided as general in nature and do not focus on individual needs of seminar participants. Financial
Professionals charge a fee for participation in seminars. When fees charged are equal to or in excess of
$500/per attendee, each attendee of the seminar will be provided a copy of this Disclosure Brochure and
are signing an acknowledgement.
For all programs, account recommendations are ultimately determined based upon your risk tolerance,
financial situation, and stated investment objectives (i.e. preservation of capital, income, growth and
income, growth and speculation, etc.).
GAR does not mandate a specific timeframe for review but does encourage our Financial Representatives
to contact all of their clients at least annually, or at you the client’s request, to discuss your investment
portfolio and to update your financial information should any changes have occurred. It is necessary for
you to inform your GAR Advisory Representatives promptly regarding any changes in your financial
circumstances or as it relates to your investment goals, objectives and time horizon. Failure to notify GAR
of any such changes could result in investment recommendations not meeting your needs.
Types of Agreements
The following highlights the Firm’s client relationships and types of advisory services offered:
Advisor Asset Management Services
G.A. Repple offers Advisor Asset Management Services to its advisory clients. In an advisor asset managed
account, the Firm’s IAR will act on your behalf in executing the investment strategy. These accounts can
be established as discretionary or non-discretionary.
Non-Discretionary: The IAR will recommend the purchase or sale of securities for review by their clients.
The IARs will only purchase or sell securities which have been approved by clients in advance.
Discretionary: The IAR acts as portfolio managers for these accounts. The purchase and sale of securities
does not require advance client approval.
Our IARs work with their clients to identify their investment goals and objectives, as well as risk tolerance,
in order to create an initial portfolio allocation designed to complement the client’s financial situation and
personal circumstances. The investment strategies utilized and portfolios constructed and managed
depend on the individual client’s investment objectives and goals as provided to the IAR. Model portfolios,
sub-advisers, options, and/or margin can also be used as a part of this strategy.
Investment recommendations are not limited to any specific product or service offered through a
broker/dealer or insurance company. Your portfolio holdings can include but are not limited to, securities
listed on the stock market exchanges, corporate and municipal bonds, mutual funds, Unit Investment
Trusts (“UITs”), Variable Annuities (“VAs”) and/or the sub-accounts within a VA, alternative products
including Real Estate Investment Trusts (REITs”), Direct Participation Programs (“DPPs”) or Business
Development Companies (“BDCs”), United States government and government agency securities,
certificates of deposit, warrants, and commercial paper. Some investment products, such as REITs, DPPs
and BDCs and certain VAs are not eligible to be purchased and held in an Advisor Asset Managed Account.
Advisor asset managed accounts allow clients the opportunity to place reasonable restrictions on the type
of investments to be held in the portfolio, subject to the IARs acceptance of these restrictions.
You maintain full and complete ownership of all assets held in your Advisor Asset Managed Account. This
means you retain the right to add or withdraw securities or cash, pledge securities, and vote securities.
We will not pool your Advisor Managed Account assets with assets in other accounts. You will receive
periodic statements directly from the account custodian.
Third Party Asset Managers (“TPAM”)
The Firm also provides access to Third Party Asset Managers (“TPAMs”). The Advisor’s IARs will assist their
clients in the selection of a suitable TPAM. TPAM provides the IAR with a number of tools such as asset
allocation, portfolio optimization, investment policy development, manager selection and proposal
development, and periodic client reporting. Through the TPAM, the IAR also has access to various top
quality money managers.
Factors considered in the selection of a TPAM include but may not be limited to: i) the client’s risk
tolerance, goals and objectives, as well as investment experience; ii) the amount of client assets available
for investment, and iii) the client’s or the individual IAR’s preference for a particular Third Party Advisory
Service. In order to assist clients in the selection of a TPAM, the IAR will typically gather information from
the client about the client’s financial situation, investment objectives, and any reasonable restrictions the
client wants imposed on the management of the account.
As specified in its (separate) management agreement and disclosures, TPAMs exercise discretion in the
management of client accounts.
The Firm IARs review the reports provided by the TPAM to the client. Review frequencies for clients
invested in a TPAM strategy will be set at least annually, or more often as agreed upon with each client,
and should serve to assist the client in understanding and continued evaluation of the services provided
by the TPAM.
Retirement Plan Advisory Services
GAR provides investment advisory services to employer sponsored retirement plans, including but not
limited to 401(k), 457(b), 403(b), and pension and profit-sharing plans. For all services provided, the plan’s
named fiduciary retains decision-making authority and responsibility for the plan’s investment policy
statement, selecting and maintaining investment alternatives available under the plan and implementing
any plan, advice or strategy provided by your IAR.
Financial Planning & Consulting Services
G. A. Repple & Company IARs may offer Financial Planning & Consulting Services consisting of a
comprehensive written financial plan designed to help evaluate current and future financial states in order
to help achieve financial goals. The preparation of such a plan will necessitate that the client provide the
Advisor with personal data such as family records, budgeting, personal liability, estate information and
additional financial goals.
Financial planning and/or consulting services do not involve the active management of client accounts.
The role of a financial planner is to find ways to help the client understand his/her overall financial
situation and help the client set financial objectives. Financial planning may include any or all of the
following as requested and/or directed by the client: asset protection, tax planning, risk planning, business
succession, strategies for exercising stock options, cash flow, education planning, estate planning and
wealth transfer, charitable giving, long-term care and disability planning, retirement planning, insurance
planning, asset allocation comparisons, and risk management.
Financial planning recommendations are made based on your individual needs that are made based on
the data and information provided.
Financial planning
services can include, but are not limited to, one or more of the
following:
• Comprehensive Financial Plan Creation
• Net Worth and Cash Flow Analysis
• Portfolio Review and Evaluation
• Retirement Account Analysis
• Retirement Planning
• Estate Analysis and Planning
• Business planning and evaluation
• Risk Management Analysis
• Budgeting
• Planning for Family Member Special Needs
• Divorce Planning
• Education Planning and Funding
• Review of Medical, Disability, and other insurance
• Financial Planning and Education Seminars
• Other
Consulting services can be narrow in scope and not take into consideration all areas of a client’s financial
situation. Consulting services include consulting clients in the management of their money, investment
options and asset reallocation.
When choosing financial planning services, the implementation of transactions on your behalf is not part
of the financial planning service. To the extent you would like your GAR Financial Professional to
implement transactions on your behalf, you will need to contract with your GAR Financial Professional for
one or more of the management services described in this Disclosure Brochure or you can work with your
GAR Financial Professional in his/her separate capacity as a G. A. Repple & Company Registered
Representative to establish a brokerage account and implement transactions through a non-fee,
commission-based brokerage account. If you choose to utilize any of these services a conflict of interest
will exist between those of GAR, your Financial Professional and you. Firm IAR’s are often both RRs of the
broker/dealer and IARs of the Advisor and as such can earn commissions on products in addition to
advisory fees, or financial planning fees if implemented through the Firm. Clients are under no obligation
to utilize the services of the IAR in the execution of the financial plan and may execute their plan wherever
they please.
Financial Professionals may also provide investment consulting services on accounts not managed or
maintained by GAR. Only accounts for which a Financial Professional is not the Registered Representative
of record or does not have trading authorization on the account are eligible for this service. Such accounts
include, but are not limited to, 401(k) accounts and pension plan accounts not held at NFS which our
Broker Dealer uses as our clearing firm. You will be responsible for all trade implementation under this
service. Financial Professionals will not have access to your funds, securities, or account(s) and therefore
will not have authority to rebalance, reallocate or trade in the account(s). If you decide to sign up for this
service, your selected accounts will be reviewed based upon your specific needs and desires for future
financial goals and/or objectives. General or specific recommendations will be provided by your Financial
Professional. Fees can be paid in a variety of options determined between yourself and your Financial
Professional. Please see the Financial Planning and Consulting Information within the Fees and
Compensation section of this Disclosure Brochure for additional fee information.
IRA Rollover Considerations
Investment Advisory Representatives can make recommendations to plan participants regarding the
rollover of employer sponsored retirement plan assets. In the case where an IAR recommends a
retirement plan rollover into an advisory account program, the IAR will earn a portion of the advisory fee.
This presents a conflict of interest because IARs have an economic incentive to recommend you to rollover
your retirement plan into a GAR advisory program account. Plan participants are under no obligation to
rollover your retirement plan assets to an IRA with GAR and should carefully consider all relevant factors,
such as penalty-free withdrawals, whether loans are permitted, legal protections, required minimum
distributions, fees and expenses, service levels, available investment options, employer stock
considerations and state taxes.
Annuities
GAR offers investment management services for various approved annuities. Financial Professionals can
manage the subaccounts of those annuities either on a discretionary or non-discretionary basis. Your
Financial Professional will provide ongoing investment advice based on your investment objectives, risk
tolerance, options available under the annuity contract, and any other benefits and features under the
annuity contract. A conflict of interest is present as your Financial Professional receives a fee for the advice
provided to you, however, not all annuity products are approved for investment management services.
There could be other annuity products suitable for you that are more or less costly.
Wrap Fee Programs
The Firm offers portfolio management services via a wrap fee program, which differs from non-wrap
programs in the costs and execution strategy. The Firm receives a portion of wrap fees assessed.
Wrap Fee Program versus Non-Wrap Fee Program Financial
Professionals provide asset management services through both wrap fee programs and non-wrap fee
programs. Under non-wrap fee programs, there are two separate types of fees. An investment advisory
fee is charged for our advisory services, and another fee (“ticket charge”) is charged for each transaction
(i.e., buy/sell/exchange) by our affiliated introducing broker-dealer, G. A. Repple & Company, for accounts
held at National Financial Services (NFS) the clearing firm. This creates a conflict of interest for GAR
because there is an incentive to have Financial Professionals trade more due to the receipt of transaction-
based ticket charge revenue by GAR. Your Financial Professional determines whether or not the
transaction ticket fees charged by GAR, NFS are charged to you. If your Financial Professional chooses to
absorb the ticket charges a conflict of interest is created in that your Financial Professional could choose
to trade less often in order to reduce their expenses. Under a wrap fee program, advisory services and
transaction services are provided for one fee to the client, however, certain other non-transaction related
fees can be assessed to a wrap fee account. For additional details about GAR’s wrap fee programs, please
see the corresponding Wrap Brochures for the programs we offer. From a management perspective, there
is not a fundamental difference in the way our Financial Professionals manage a wrap fee account(s)
versus a traditional management account(s). The significant difference is the way in which transaction
services are paid. For information on additional fees regarding ticket charges, please refer to the Fees and
Compensation section of this Brochure.
Conflicts of Interest Regarding Certain Compensation, Services and Platform Decisions
GAR Advisory Representatives, if properly registered and licensed, can potentially be acting in multiple-
capacities when soliciting, offering, buying, selling and exchanging investment products, investment
advisory services and/or insurance products. When acting in these capacities, GAR Advisory
Representatives are acting as a registered representative of a securities broker (also known as an RR), an
investment adviser representative of a registered investment adviser (also known as an IAR), and an agent
of an insurance company (also known as an “insurance agent”). A conflict of interest can occur when IARs
solicit, offer and sell securities and insurance products for which you would pay a commission, while also
soliciting, offering and selling investment advisory services and managing assets that are in your accounts
and charging a separate investment advisory fee. In these circumstances additional care must be
considered in relation to the client and their objectives.
G.A. Repple & Company requires the Investment Advisory Representative acting in the capacity of RR to
disclose to you at the time a brokerage account is opened through G.A. Repple & Company his or her role
as an G.A. Repple & Company RR and any compensation including commissions that are paid by you
and/or received by the IAR as well as the nature of the transaction or relationship. Moreover, it is the
general policy of GAR to refrain from a charging a commission on accounts where the IAR is charging an
investment advisory fee for the same period of time.
In situations where clients want comprehensive financial planning , or ongoing advice covering securities
originally sold in brokerage transactions, GAR's policy, unless reviewed and approved by GAR Supervision,
prohibits charging an investment advisory fee for assets sold in a brokerage transactions, unless (i) a
period of time passes until the investment advisory fee that would have been charged exceeds the
commission actually charged, and there is a sound basis to commence the investment
advice/management of such assets at that time (ii) such products are not available on an advisory platform
on an commission-free, advisory share class basis, are better for the client's investment objectives and in
the client's best interest, are liquid and the client also seeks continuous and regular investment
advice/management.
Wherever possible, in situations where assets purchased in brokerage transaction for a commission
through GAR, such assets should either be excluded from investment advisory billing or the investment
advisory fee should be reduced to offset any commission that was otherwise unavoidable for the
particular security. You are under no obligation to (i) engage the services of any IAR or other individual
investment professional recommended by GAR, (ii) engage the services of any 3rd party investment
adviser/manager recommended by GAR or (iii) accept the advice to buy, sell or exchange of any particular
product and implementation decisions in situations where the IAR/GAR only has non-discretionary
authority over the account. You may vest discretionary authority for trading decisions with your IAR or
retain such authority yourself. If you retain discretion over implementation decisions, you will be the one
to accept or reject recommendation from GAR or its IAR. In situations where you have provided the
IAR/GAR with discretionary investment management authority, you may revoke that authority at any
time, but unless or until revoked, your IAR retains the authority to make trading decisions in your account
without discussing them with you beforehand.
The reference to comprehensive financial planning may involve ongoing account monitoring services or
may simply refer to a discrete, single plan, or a revisitation of a plan periodically (e.g., annually). If ongoing
account monitoring services are provided in conjunction with a comprehensive financial plan, then such
services should be priced based upon a % of assets under management/AUM, for which ongoing
advisory/management services would be provided. Without a specification of ongoing account monitoring
services, financial planning services normally are priced based upon a flat fee and for which there would
not be ongoing advisory/management services covering the accounts.
Financial plans priced based upon a flat fee and for which there would not be continuous and regular
advisory/management services could provide such limited advisory services that cover securities (sold by
GAR’s broker dealer) without having to wait until a commissioned product sold by GAR "ages" for a period
of time such that the commission equates to the proposed advisory fee for the same time period, or
otherwise have to comply with considerations in point above concerning platform availability.