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101 North Brand Boulevard Suite 1950
Glendale, California 91203
(800) 989‐6693
www.pacificglobal.us
March 31, 2025
Pacific Global Investment Management Company is a registered investment
adviser. Registration as an Investment Adviser does not, by itself, imply a
specific level of skill or training.
This brochure provides information about the qualifications and business
practices of Pacific Global Investment Management Company. If you have any
questions about the contents of this brochure, please contact us at
1‐800‐989‐6693. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission (“SEC”) or by
any state securities authority.
Additional information about Pacific Global Investment Management Company
also is available on the SEC’s website at www.adviserinfo.sec.gov. You can
search this site using a CRD, a unique identifying number; our firm’s CRD
number is 106962.
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Item 2 Material Changes
There have been no material changes to this brochure since the last version as of March 28, 2024.
We will ensure that clients receive a summary of any material changes to this and subsequent brochures
within 120 days of the close of our fiscal year on December 31st. Furthermore, we will provide clients with
other interim disclosure information about any material changes.
Clients or prospective clients may request a copy of our brochure, free of charge, by contacting Pacific Global
Client Services at (800) 404‐6693 or clientservices@pgimc.com. Our brochure is also available on our website
at www.pacificglobal.us.
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Table of Contents
Page
Item 1
Cover Page
i
Item 2 Material Changes
ii
Item 3
Table of Contents
iii
Item 4
Advisory Business
1
A. Ownership Structure
1
B. Advisory Services
1
1. Separately Managed Account Clients
1
2. Financial Planning Services
1
C. Assets Under Management
2
Item 5
Fees and Compensation
2
Item 6
Performance‐Based Fees and Side‐by‐Side Management
4
Item 7
Types of Clients
4
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
4
Item 9
Disciplinary Information
8
Item 10 Other Financial Industry Activities and Affiliations
8
A. Broker/Dealer Relationships
8
B. Other Registrations
9
C. Other Relationships
9
D. Conflicts of Interest
9
E. Business Continuity Plan and Cybersecurity Policy
9
Item 11
10
Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Item 12
Brokerage Practices
11
Item 13
Review of Accounts
14
A. Account Reviews
14
B. Account Reports
15
Item 14
Client Referrals and Other Compensation
15
Item 15
Custody
16
Item 16
Investment Discretion
16
Item 17
Voting Client Securities
16
Item 18
Financial Information
17
Privacy Policy
17
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Item 4 Advisory Business
Pacific Global Investment Management Company (“Pacific Global” or “we” or the “firm”), a privately held
California corporation established in 1991, provides investment management services to individuals,
institutions, retirement plans and others as Separately Managed Accounts (SMAs). The firm also provides
financial planning services related primarily to retirement, cash flow and investment planning. From 1993 to
early 2020, the firm also managed the Pacific Advisors family of mutual funds. Pacific Global is registered with
the SEC under the Investment Advisers Act of 1940 (Advisers Act). This registration does not imply a certain level
of skill or training.
A.
Ownership Structure
George A. Henning, Chairman and President of Pacific Global, is a principal owner of the firm.
B.
Advisory Services
Pacific Global provides investment advisory services to various types of SMA clients as described below and in
Item 7.
1.
SMA Clients
Pacific Global provides investment advisory services to high net worth individuals and institutional investors.
When providing such services, each client account is governed by a written Investment Management Agreement
(IMA) which reflects any circumstances specific to the account. In the IMA, the client selects one investment
management style for the account. Our management styles, all of which are offered exclusively on a
discretionary basis, include equity (value‐oriented or core, a combination of value and growth), fixed income and
balanced (fixed income and equity mix) options. For individuals, the client’s financial situation, risk tolerance
and needs are considered. The client makes the final determination as to which of the management styles is
appropriate and desired.
Subject to Pacific Global’s approval, the client may impose reasonable restrictions on investments or the
management style selected in the IMA. Restrictions are permissible provided that, in Pacific Global’s view, they
do not present a significant handicap to the management style. If we determine that the restrictions would
present a significant handicap, we would not accept the prospective client, or the IMA would be terminated.
Periodically, an officer or authorized representative of Pacific Global seeks to determine if any changes in a
client’s financial situation or needs might affect the client’s account or make continuation of management
services inappropriate.
2.
Financial Planning Services
We utilize currently known variables to assess future cash flows, asset values, and withdrawal plans in our
comprehensive evaluation of a client’s current and anticipated future financial state. Through the financial
planning process, we consider and analyze all information and variables which may impact, or be impacted by,
the entire financial and life situation of the client. Each client who enters into a Financial Planning Agreement
will receive a written report which provides a detailed financial plan designed to assist the client in achieving his
or her financial goals and objectives.
We offer financial planning in the following subject areas:
Retirement Planning: We analyze a client’s current strategies and investment plans to help assess future
asset values, cash flows and withdrawal plans. For retirees, we analyze the impact of varying income
and expenses, gifting, and risk tolerance with the objective of maintaining financial independence.
Cash Flow Planning & Income: We review a client’s family records, budgets, assets, liabilities, and cash
flow to create a clear picture of the current financial status to determine opportunities and priorities.
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Investment Planning: We analyze investment alternatives and the effects of each on a client’s portfolio.
Specific topics that may include current asset allocation; strategies for retirement income; potential
returns, withdrawal rates and tax ramifications of various investment strategies; portfolio optimization
and rebalancing; and education planning.
We gather required information through in‐depth personal interviews as well as client‐provided documents. In
preparing a written plan, we consider a client’s current financial status, tax circumstances, future goals,
investment objectives, and attitudes toward risk.
We initiate the Financial Planning process once a client signs the Financial Planning Engagement Agreement and
provides the necessary requested information and documents. The financial plan will be completed when a
client receives a written plan; typical financial planning engagements are completed within six (6) months of the
initiation date.
Should a client choose to implement the recommendations contained in the financial plan, Pacific Global
suggests that a client work closely with his or her attorney, accountant, insurance agent, financial adviser and/or
broker. Implementation of the recommendations contained in the financial plan and/or financial consulting
engagement is entirely at a client’s discretion.
A client may select on‐going reviews of the financial plan. The updates, which typically occur annually, review
the income, expense and other components of the plan. Absent the selection of this ongoing review option on
the Financial Planning Engagement Agreement, the plan will be complete with the delivery of the written plan.
We also provide a less formal financial consulting service. Consulting topics may include our observations and
recommendations on assets (such as 401(k) accounts) which are not managed by Pacific Global. Additional
topics available for consulting engagements are Education Planning, Gifting Strategies and Investment Analysis.
Separate fees, as agreed upon, may be charged for consulting services.
C.
Assets Under Management
As of December 31, 2024, Pacific Global had $98.9 million in client assets under management. All assets were
managed on a discretionary basis.
Item 5
Fees and Compensation
Advisory Fees ‐ SMAs
Pacific Global charges each SMA client an annual investment management fee based on the value of the client’s
assets under management in accordance with the following fee schedule:
Up to $1 million in net assets under management: 1.25%
Next $2.5 million: 1.00%
Next $2.5 million: 0.75%
Next $5.0 million: 0.65%
$11 million and above: 0.50%
As shown in the fee schedule above, Pacific Global provides for “breakpoints” at which the percentage is
reduced if assets under management exceed certain amounts.
The specific manner in which fees are charged and paid is established in each client’s IMA. In most cases, fees
are payable quarterly, in advance. For certain accounts with assets below the minimum account size, the
Adviser may charge a minimum quarterly fee. In no event, however, will fees be paid more than six months in
advance. Lower fees for comparable services may be available from other companies. The initial fee is based on
the account’s market value at the inception of Pacific Global’s management and is prorated for the number of
days in the period that the account is under Pacific Global’s management. Subsequent fees are based on the
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account’s market value as of the close of business on the last business day preceding the period for which the
fee is due.
The payment schedule and fees may be negotiated. As such, some existing clients pay fees that are different
from the fees shown above. As a result, one client’s fee may be higher or lower than another client’s fee for
similarly valued accounts. Fees may be negotiated (either up or down) based on a number of factors, including
(among others): (1) the number and type of services provided; (2) the investment strategy or style, types of
investment securities and number of portfolios or accounts for which services are provided; (3) the level of
reporting and administrative operations required to service the client’s account; (4) the terms of the IMA; and
(5) other circumstances concerning Pacific Global’s relationship with the client. Once Pacific Global enters into
an IMA with a client, Pacific Global will only modify its fee as permitted under the IMA and consistent with
applicable law.
Clients generally authorize Pacific Global to withdraw quarterly management fees directly from their accounts.
PG in its sole discretion may agree to allow a client to pay the quarterly management fee by check. If the client
pays the fee by check, we issue an invoice which is payable within 30 days of receipt. Even if we have agreed to
allow a client to pay the fee by check, the IMA provides that Pacific Global shall have the authority to withdraw
quarterly management fees (or any unpaid portion thereof) from the client’s account if the quarterly
management fee (or any portion thereof) is not paid within 30 days after the client receives an invoice from
Pacific Global.
If an IMA is terminated prior to the end of a management period, the client receives a pro‐rata refund of fees.
Clients are notified of the management fee refund calculation in writing. De minimis refunds of less than $10 are
only paid upon client request.
Advisory Fees ‐ Fund Companies and ETFs
Pacific Global may, for a variety of reasons, choose to invest in mutual funds and/or ETFs; when we do so, our
asset‐based fee for investment management services includes mutual funds and ETF investments. The
performance of each fund or ETF is net of the management fees charged by each fund’s investment manager;
these charges can be found in the applicable fund prospectus and SAI.
Other Fees and Expenses
Pacific Global’s fees are exclusive of transaction fees, and other related costs and expenses which shall be
incurred by the client. For example, clients may incur certain charges imposed by custodians, broker/dealers
and other third parties such as custodial fees, brokerage commissions, sales charges, wire transfer and electronic
fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and ETFs,
which may be held in a client account, may also charge internal management fees which are disclosed in each
fund’s prospectus.
Item 12 describes the factors we consider in selecting or recommending broker/dealers for client transactions
and in determining the reasonableness of their compensation (such as commission level).
Financial Planning & Consulting Fees
Pacific Global charges financial planning fees based upon the nature and complexity of the services provided. All
fees are agreed upon in writing prior to the initiation of financial planning or consulting services.
Our financial planning fees are calculated and charged on an hourly basis, with a minimum fee of $1,000 and
hourly fees ranging from $250 to $700. The length of time to complete the financial plan may vary depending on
a client’s circumstances. Prior to initiating the planning process, we provide an estimate of the total hours
anticipated for the financial planning engagement.
Up to 50% of the fee, or estimated fee, may be due upon signing the financial planning agreement with the
balance due upon completion of services.
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A client may choose to engage us to provide periodic, typically annual, updates to a plan. The fee, which is billed
quarterly in advance, may range from $1,000 to $2,500 per year. The initial fee is prorated for the number of
days remaining in the calendar quarter at initiation of the engagement. Either party may terminate the
engagement at any time by notifying the other in writing. Any unearned fees are promptly refunded; any fees
incurred but not yet paid are due and payable in full.
Pacific Global reserves the right to reduce or waive the hourly fee and/or the minimum fixed fee in certain
circumstances; for example, we may consider asset size, pre‐existing client relationships and aggregated assets
under management for a client’s family relationships. Certain clients may pay more or less than others for the
same services.
Financial consulting fees range from $250 to $700 per hour, with a minimum fee of $250. The fee is based upon
the scope and complexity of the financial consulting engagement.
Item 6
Performance‐Based Fees and Side‐By‐Side Management
Pacific Global does not charge any performance‐based fees (i.e., fees based on a share of the capital gains on a
client’s account or on the capital appreciation of the client’s assets). For more detailed information on how our
fees are calculated please refer to the IMA.
“Side‐by‐side management” refers to our simultaneous management of different types of client accounts. For
example, the firm manages SMAs for different clients at the same time. Our clients have different investment
objectives, policies, strategies, limitations and restrictions, and may pay fees that are higher or lower than those
paid by other clients.
Side‐by‐side management gives rise to a variety of potential and actual conflicts of interest for the firm, our
employees and supervised persons. We follow procedures that are reasonably designed to treat our clients
fairly and to prevent any client or group of clients from being systematically favored or disadvantaged and we
manage our accounts consistent with applicable law. Please see Item 11 for a discussion of such procedures.
Item 7
Types of Clients
Pacific Global generally provides advisory services to:
Individuals, including high net worth individuals;
Trusts, estates or charitable organizations; and
Pension and profit sharing plans;
Corporations or other business entities.
Account Requirements
We require clients to enter into an IMA which grants us authority to manage their assets. SMAs generally
require a minimum account size of $100,000 for new accounts that will be invested primarily in individual
securities. Accounts with assets below $100,000 are invested in one of a variety of guideline portfolios based on
account size; that is, each portfolio consists of an assortment of holdings which approximates the sector
diversification and allocation, and stock selection, of larger accounts of the same strategy.
Depending on the specific circumstances, exceptions to the account minimum may be negotiated at the sole
discretion of Pacific Global.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Pacific Global utilizes a variety of methods and strategies when formulating investment advice and managing
client assets. Pacific Global’s security research primarily relies on fundamental analysis that attempts to
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measure intrinsic value by examining related economic, financial and other qualitative and quantitative factors.
Specifically,
Potential equity investments are identified through a proprietary screening process that focuses on
factors including balance sheet strength, growth rates, returns on invested capital, and P/E ratios.
Investment candidates are also identified in consideration of factors such as company reorganizations,
new management teams, new product developments, economic and sector cycles, and analysts’
research. Pacific Global also evaluates the ownership structure of the company as well as the stock’s
daily trading volumes and price fluctuations over an extended period of time.
Potential fixed income investments are identified through a fundamental analysis of the underlying
company and in consideration of the current interest rate environment.
In evaluating investments, Pacific Global utilizes in‐house research efforts as well as third‐party analyst reports,
industry trade data, and other public sources of information. Additionally, Pacific Global’s portfolio managers
and analysts may converse with company management through phone interviews, conference call participation,
and/or on‐site visits. In consideration of each client’s situation, including account size, investment strategy, time
horizon, and other issues, client accounts may be invested in a variety of investments including equity securities,
corporate debt securities, municipal securities, U.S. government securities, mutual funds, certificates of deposit
and commercial paper.
Investment Strategies
Each SMA is managed individually, consistent with the investment objective and style specified in the client’s
IMA. Pacific Global utilizes the following strategies in the Investment Styles listed below:
Equities are managed using either a value‐oriented strategy or a core strategy. The firm’s value‐
oriented strategy seeks undervalued (or “on‐sale”) stocks of established companies with strong
fundamentals, experienced management teams, sound business strategies, and a catalyst for growth;
the core strategy seeks to identify high‐quality companies with relative earnings stability and strong
competitive positioning. Investment selection is based on analysis that evaluates a variety of factors
including a company’s industry, financial statements, management and business model. We generally
select investments with an anticipated holding period of 3 to 5 years.
Fixed Income Securities are managed for total return to protect principal, provide income and take
advantage of opportunities for capital appreciation. Maturities are actively managed to adapt to the
interest rate environment. Fixed income securities include investment grade taxable and tax‐free
bonds, mutual funds, preferred stocks, cash, high‐quality money market securities and/or money
market funds.
In allocating assets within selected industries (sectors) or sub‐industries, we generally restrict investments in
individual securities to no more than 5%, on a cost basis, of an account’s total net asset value; and to no more
than 25%, on a cost basis, of an account’s total net assets in any single industry or sub‐industry, with the
exception of securities issued or guaranteed by the U.S. Treasury or by an agency or instrumentality of the U.S.
Government including securities issued by U.S. Government Sponsored Enterprises (GSEs).
Investment Styles
Equity – Pacific Global’s equity styles seek capital appreciation through diversified equity investments.
Income is considered secondary in the selection of investments. Investments may be diversified in large
(i.e., companies with market capitalizations in the range of companies that comprise the S&P 500®
Index1) to small capitalization companies (i.e., companies with market capitalizations of up to the
1 As of February 28, 2025, the market cap range was between $4.61 billion and $3.65 trillion. The S&P 500® Index is an unmanaged,
market capitalization weighted index which measures the performance of the large cap segment of the U.S. equities market,
covering approximately 75% of the U.S. equities market. The Index includes 500 leading companies in leading industries of the U.S.
economy.
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largest market cap of companies in the Russell 2000® Index2) or focused primarily in companies of a
particular size.
Balanced – Pacific Global’s balanced style seeks capital appreciation and income. Balanced accounts
typically maintain a targeted minimum of 25% in fixed income securities and cash or cash equivalents.
Equity investments are typically diversified in large to small capitalization companies. Accounts are
rebalanced no less frequently than quarterly to the target allocation to maintain a minimum allocation
not less than 5% below the target.
Fixed Income – Pacific Global’s fixed income styles seek income and, secondarily, capital appreciation.
Fixed Income accounts typically maintain a targeted minimum of 50% in fixed income securities and
cash or cash equivalents. Equity investments are diversified primarily in mid‐ to large capitalization
companies. Accounts are rebalanced no less frequently than quarterly to the target allocation to
maintain a minimum allocation not less than 5% below the target.
Risks
Investing in securities involves risk of loss that clients should be prepared to bear. Pacific Global’s discretionary
management styles include equity, fixed income, and balanced (a mix of fixed income and equity) options which
may be subject to some or all of the following risks.
Equity Securities – Equity securities include common stocks, preferred stocks, convertible securities,
mutual funds and ETFs that invest in these securities. Stock prices rise and fall based on changes in an
individual company’s financial condition and overall market conditions. Stock prices can decline
significantly in response to adverse market conditions, company‐specific events, and other domestic and
international political and economic developments.
Investing in small capitalization and micro‐capitalization companies (i.e., companies with market
capitalizations of up to the largest market cap of companies in the Russell Microcap® Index3) generally
involves greater risks than investing in larger companies. The market may value companies according to
size or market capitalization rather than financial performance. As a result, if small cap or micro‐cap
investing is out of favor, small cap and micro‐cap holdings may decline in price even though their
fundamentals are sound. In comparison to companies with larger market capitalizations, small and
micro‐cap companies may be more difficult to buy and sell, subject to greater business risks, and more
sensitive to market changes.
We seek to reduce these risks by buying stocks of companies that have established operating histories,
strong or improving financials, and growth potential. In addition, we seek to diversify each client’s
equity investments in a variety of stocks and industry sectors.
Fixed Income Securities – Fixed income securities include corporate bonds, municipal bonds, other debt
instruments and mutual funds that invest in these securities and cash. Issuers generally pay a fixed,
variable, or floating interest rate, and must repay the amount borrowed at maturity. Some debt
instruments, such as zero‐coupon bonds, do not pay current interest, but are purchased at a discount
from their face value. Bond prices generally decline when interest rates rise and rise when interest rates
fall. Longer‐term debt and zero‐coupon bonds are more sensitive to interest rate changes than debt
instruments with shorter maturities.
Whenever Pacific Global purchases fixed income securities, we compare prices from various brokerage
firms to identify bonds that offer the best combination of price, credit quality, yield and maturity for
the desired purchase amount. However, due to trade settlement complexities at various custodians
and brokerage firms, and fees typically charged by custodians to execute trades through an unaffiliated
2 As of its most recent reconstitution (April 2024), the highest market capitalization of companies in the Russell 2000® Index was
$7.1 billion; the Index is an unmanaged, market‐weighted measure of stock market performance containing stocks of the 2,000
smallest publicly traded companies of the Russell 3000® Index.
3 As of its most recent reconstitution (April 2024), the highest market cap in the Russell Microcap® Index was $1.4 billion; the Index
is an unmanaged, market capitalization weighted measure of stock market performance consisting of the stocks of the 1,000
smallest publicly traded companies within the Russell 2000® Index, plus the next smallest 1,000 U.S. based listed stocks.
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brokerage firm, such bond transactions may not provide a price benefit for the client. To benefit from
any price advantage provided by purchasing a greater quantity of each bond we select, we may look to
aggregate orders for multiple accounts whenever possible. Based on the account size, the amount of
each bond holding in a client’s account is most likely an “odd lot” that is, a holding of less than $1
million. Odd lot bonds may be more expensive to purchase and, in most cases, are less valuable to sell
than “round lots” of $1 million or more.
We select fixed income securities of various maturities and/or call features with the intention of
holding each bond until its maturity or call. Once trades have settled, the price of each holding is
provided by independent pricing services. Unlike stock prices, which are based on current market
activity, the bond prices provided by these services are not firm bids or offers, and may not reflect
current activity or all the factors which affect the value of the security. In particular, bond prices are
typically based on minimum amounts of $1 million. As a result, the value of a bond holding may differ
from its purchase price and may not closely reflect the value at which the security may be sold prior to
maturity. The sale of any fixed income security sold prior to maturity may result in a loss.
Fixed income securities are subject to credit risk, which is the chance that a bond issuer will fail to pay
interest or principal on time. Changes which lower the credit strength of an issuer may reduce the
credit rating of its debt investments and may affect their value. High‐quality debt instruments are
rated at least A or its equivalent by any Nationally Recognized Statistical Rating Organization (NRSRO)
or, if unrated, are determined to be of equivalent quality by Pacific Global. Issuers of high‐grade debt
instruments are considered to have a very strong capacity to pay principal and interest. Investment
grade debt instruments are rated at least BBB or its equivalent by any NRSRO or, if unrated, are
determined to be of equivalent quality by Pacific Global. BBB rated securities are considered to have
adequate capacity to pay principal and interest, although they also have speculative characteristics.
Lower rated debt securities are more likely to be adversely affected by changes in economic conditions
than higher rated debt securities.
U.S. Government securities include securities issued or guaranteed by the U.S. Treasury; issued by a
U.S. Government agency; or issued by a GSE. U.S. Treasury securities include direct obligations of the
U.S. Treasury (i.e., Treasury bills, notes and bonds). U.S. Government agency bonds are backed by the
full faith and credit of the U.S. Government or guaranteed by the U.S. Treasury (such as securities of
the Government National Mortgage Association (GNMA or Ginnie Mae)). GSE bonds are issued by
certain federally‐chartered but privately‐owned corporations, but are neither direct obligations of, nor
backed by the full faith and credit of, the U.S. Government. GSE bonds include bonds issued by Federal
Home Loan Banks (FHLB), Federal Farm Credit Banks (FCS), Federal Home Loan Mortgage Corporation
(FHLMC or Freddie Mac) and the Federal National Mortgage Association (FNMA or Fannie Mae).
Foreign Securities ‐ Investments in foreign securities involve certain risks that differ from the risks of
investing in domestic securities. Adverse political, economic, social or other conditions in a foreign
country may make the stocks of that country difficult or impossible to sell. It is more difficult to obtain
reliable information about some foreign securities. The costs of investing in some foreign markets may
be higher than investing in domestic markets. Investments in foreign securities also are subject to
currency fluctuations.
We seek to reduce these risks by investing in foreign securities typically through American Depositary
Receipts (“ADRs”). ADRs are certificates deposited with a U.S. bank that represent the right to own a
foreign security. Since ADRs are traded in U.S. markets and the issuers are subject to the same auditing,
accounting and financial reporting standards as domestic securities, owning ADRs has advantages over
owning other foreign securities.
Investment Companies ‐ Investment companies include open‐end and closed‐end investment
companies. Shares in investment companies represent interests in professionally managed portfolios.
These investments involve substantially the same risks as investing directly in the underlying
instruments; in addition, the return from such an investment will be reduced by the operating expenses
and fees of the investment company, including applicable advisory fees. Certain types of investment
companies, such as closed‐end funds, issue a fixed number of shares that trade on a stock exchange or
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over‐the‐counter at a premium or discount to their net asset value (“NAV”) per share. This premium or
discount may change from time to time. Other investment companies are continuously offered at NAV,
but are also traded in the secondary market.
ETFs are open‐end investment companies, unit investment trusts or depository receipts that hold
portfolios of stocks, commodities and/or currencies that commonly are designed to closely track, before
expenses, the performance and dividend yield of (i) a specific index, (ii) a basket of securities,
commodities or currencies, or (iii) a particular commodity or currency. The types of indices sought to be
replicated by ETFs most often include domestic equity indices, fixed income indices, sector indices and
foreign or international indices. ETF shares are traded on exchanges and are traded and priced
throughout the trading day. ETFs permit an investor to purchase a selling interest in a portfolio of stocks
throughout the trading day. Because ETFs trade on an exchange, they may not trade at NAV. The prices
of ETFs may vary significantly from the NAVs of the ETFs’ underlying securities. Additionally, if an
investor decides to redeem ETF shares rather than selling them on a secondary market, the investor may
receive the underlying securities which must be sold in order to obtain cash.
Non‐diversified Risk ‐ Because the portfolios may invest a greater portion of their assets in securities of
a single issuer or a limited number of issuers than a portfolio with diversification requirements, they
may be more susceptible to a single adverse economic or political occurrence affecting one or more of
these issuers.
Cybersecurity Risk ‐ Investment advisers, such as Pacific Global, and their service providers may be
subject to operational and information security risks resulting from cyberattacks. Cyberattacks include,
among other behaviors, stealing or corrupting data maintained online or digitally, denial of service
attacks on websites, the unauthorized release of confidential information or various other forms of
cybersecurity breaches. Cyberattacks affecting investment advisers, client custodians, or other third‐
party service providers may adversely impact a client’s experience and/or investments. For instance,
cyberattacks may interfere with the processing of client transactions, cause the release of non‐public
personal or company information, impede trading, subject an adviser to regulatory fines or financial
losses, and cause reputational damage. Pacific Global may also incur additional costs for cybersecurity
risk management. While Pacific Global and our service providers have established business continuity
plans and risk management systems designed to prevent or reduce the impact of cyberattacks, such
plans and systems have inherent limitations due in part to the ever‐changing nature of technology and
cyber‐attack tactics, and there is the possibility that certain risks have not been adequately identified or
mitigated. Furthermore, Pacific Global cannot control the cybersecurity plans or systems implemented
by our service providers. Issuers of the securities in which Pacific Global invests are subject to similar
types of cybersecurity risks which could result in material adverse consequences for Pacific Global
and/or our clients.
Item 9 Disciplinary Information
We are required to disclose all material facts regarding any legal or disciplinary events that would be material to
the evaluation of Pacific Global or the integrity of Pacific Global’s management. Neither Pacific Global nor any of
its management personnel has been subject to any legal or disciplinary events that would require disclosure
under applicable SEC rules.
Item 10 Other Financial Industry Activities and Affiliations
This section of our brochure describes the activities and relationships in which Pacific Global and our
management engage or maintain with other financial industry participants.
A.
Broker/Dealer or registered representative Relationships
Pacific Global is not registered, and has no application pending to register, as a broker/dealer; further, none of
its management persons is an associated person of any such entity.
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B.
Other Registrations
Pacific Global is not registered, and has no application pending to register, as a futures commission merchant,
commodity pool operator, a commodity trading advisor; further, none of its management persons is an
associated person of any such entities.
C.
Other Material Relationships or Arrangements
Pacific Global policies prohibit our related persons from accepting any form of compensation, including cash,
sales awards or other prizes, from a non‐client in conjunction with the advisory services we provide to our
clients. See Item 11 for a discussion of our “Code of Ethics.”
Pacific Global and/or our management persons do not currently have any material relationships or arrangements
with any of the categories of persons below. To the extent that we establish any such relationships or
arrangements which are material to our advisory business, they would be disclosed in this brochure:
investment company or pooled investment vehicle;
accountant or accounting firm;
lawyer or law firm;
insurance company or agency;
Broker/dealer or municipal securities dealer;
other investment adviser;
banking or thrift institution;
pension consultant;
real estate broker or dealer;
futures commission merchant, commodity pool operator, or commodity trading advisor; or
sponsor or syndicator of limited partnerships.
D.
Conflicts of Interest
Pacific Global provides investment management services to various clients; the fees for investment management
services are based on assets under management. We may reduce or waive fees for financial planning clients
who engage us for investment management or other services. This creates a potential conflict of interest to
recommend our investment management or other services based on compensation rather than client need; we
believe that our review and oversight processes ensure that our recommendations are made in the best
interests of the client.
E.
Business Continuity Plan and Cybersecurity Policy
Pacific Global maintains a comprehensive Business Continuity Plan (BCP) which addresses a variety of business
interruptions and recognizes the firm’s operational dependency on computer systems and infrastructure,
internet, and email. Our BCP identifies critical functions and response activities to maintain essential services
during a disaster or pandemic and facilitate timely recovery. The Chief Compliance Officer or designated
Compliance Officers are responsible for updating BCP at least annually and coordinating periodic tests to ensure
the viability of the Plan.
Pacific Global has also adopted Cybersecurity Policies & Procedures to identify cybersecurity risks, protect critical
infrastructure, and to detect, respond to and recover from cybersecurity events. These policies and procedures
are designed to protect sensitive and valuable information about the firm and its clients. The firm’s policies and
procedures are periodically reviewed by senior management to identify changes in the risks to the firm
and/or its clients.
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Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Pacific Global maintains a Code of Ethics (the “Code”) which complies with the requirements of Rule 204A‐1
under the Advisers Act. All officers, directors, employees and registered persons of Pacific Global (collectively
“access persons”) are subject to the Code and must acknowledge the terms of the Code annually, or as
amended. The Code of Ethics includes standards of business conduct requiring access persons to comply with
the federal securities laws and the fiduciary duties an investment adviser owes to its clients. Clients or
prospective clients may request a copy of Pacific Global's Code free of charge by contacting Client Services.
The Code permits access persons to trade in securities, including those that could be purchased or sold in client
accounts. However, it contains safeguards, such as requirements to report, and to obtain prior approval for
particular transactions, designed to protect clients from abuses in this area. Under the Code, certain types of
securities and trading activities have been designated as exempt transactions, based upon the determination
that these would not materially interfere with the best interest of our clients. For example, access persons may,
subject to daily limitations on the number of shares and the dollar amount, trade in securities which may be
held, purchased or sold in client accounts. The Code specifically prohibits the use of insider information and
requires pre‐clearance of access persons’ investments in initial public offerings and private placements.
Nonetheless, because the Code would, in some circumstances, permit access persons to invest in the same
securities as clients, there is a possibility that access persons might benefit from market activity by a client in a
security held by an access person. Access person trading is continually monitored under the Code to reasonably
prevent conflicts of interest between Pacific Global and its clients.
Among other policies, the Code also contains certain restrictions on the misuse of client/prospective client
information; and disclosure of gifts given and received; and conflicts of interest.
Pacific Global also maintains a separate policy concerning the misuse of material non‐public information
("Insider Trading Policy"). From time to time, Pacific Global may, as a result of its business activities, come into
possession of confidential or privileged information about issuers of securities, or other persons or entities and
their securities. In such cases, we may be restricted from executing certain trades if doing so could violate our
Insider Trading Policy or applicable legal requirements/laws. Pacific Global’s Insider Trading Policy addresses its
treatment of such confidential or privileged information in a manner that Pacific Global believes to be
reasonable.
There are times when a portfolio manager is managing assets for multiple clients with the same or similar
investment style or strategy. In these situations, when selecting securities for these various clients, consistent
with each client’s investment objectives, policies and limitations, we take into account a variety of factors,
including, without limitation, general management techniques, cash flows, permissible investments and
restrictions, and applicable regulatory requirements. In these situations, Pacific Global has procedures in place
that are designed to address potential conflicts of interest and protect client interests. Pacific Global's policy is
not to systematically favor one client over another and to select securities for investment consistent with each
client’s investment policies and limitations and, in certain cases, directed trading instructions.
Pacific Global maintains a policy to prohibit conduct in violation of Rule 206(4)‐5 under the Investment Advisers
Act, so‐called “pay‐to‐play” arrangements, by the firm and certain designated employees of the firm and comply
with the recordkeeping requirements under amended Rule 204‐2(a)(18)(i)(B). The Rule prohibits an adviser from
providing investment services for compensation to a government entity within two years after a contribution to
an official of the government entity is made by the firm or certain designated employees of the firm.
Pacific Global accepts accounts on a directed brokerage basis. Pacific Global does not have commission sharing
arrangements with any broker/dealer.
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Item 12 Brokerage Practices
Factors Considered in Selecting or Recommending Broker/Dealers
Unless a client directs Pacific Global to use a particular broker/dealer to execute transactions for the client’s
account, we select broker/dealers to effect client transactions to seek the best combination of net price and
execution. The best net price, including any brokerage commission, is an important factor in this decision.
However, a number of other factors may also enter into the decision including:
Pacific Global’s knowledge of negotiated commission rates currently available and other current
transaction costs;
the nature of the security being purchased or sold;
the size of the transaction;
the desired timing of the transaction;
the activity existing and expected in the market for the particular security;
managing the extent of information known by the broker/dealer of Pacific Global’s trading activity;
the execution, clearance and settlement capabilities of the broker/dealer selected and others
considered;
Pacific Global’s knowledge of the financial condition of the broker/dealer selected and such other
broker/dealers; and
Pacific Global’s knowledge of actual or apparent operation problems of any broker/dealer.
Recognizing the value of these factors, we may cause a client to pay a brokerage commission in excess of that
which another broker/dealer might have charged for effecting the same transaction.
SMA transactions can be executed with a broker/dealer unaffiliated with the client’s custodian (a “trade away”)
only after a trading account has been established with the unaffiliated broker/dealer. The client’s custodian
typically charges the client a processing fee on each trade away. In addition, unaffiliated brokers/dealers may be
reluctant to open a client trading account based on the anticipated trading activity and the administrative
burden associated with establishing and maintaining the trading account(s). Trade settlement complexities at
the broker/dealer, as well as at the custodian, may result in significant administrative burdens for trade aways.
Considering the charges and other administrative issues, trade aways may not result in the best net price.
Pacific Global has established internal policies to provide guidance to its trading personnel regarding the duty to
seek best execution. These policies specify the minimum and maximum commissions to be paid for various
types and sizes of transactions effected for clients for which Pacific Global has discretion to select the
broker/dealer through which the transaction is to be executed. Transactions which vary from the guidelines are
subject to periodic supervisory review. These guidelines are reviewed and may be revised periodically. Also,
Pacific Global periodically reviews the general level of brokerage commissions paid.
Pacific Global maintains and periodically updates a list of approved broker/dealers which are, in Pacific Global’s
judgment, generally capable of providing best price and execution and are financially stable. Pacific Global’s
trading personnel are directed to use only broker/dealers on the approved list, except in cases where a client has
designated broker/dealers to effect transactions for the client’s account.
Research and Other Soft Dollar Benefits
In selecting a broker/dealer, we exercise our best judgment to choose the broker/dealer most capable of
providing the brokerage services necessary to obtain the best available price and most favorable execution. In
determining whether the broker/dealers selected can offer the services needed to obtain the best available price
and most favorable execution, we may take into consideration the fact that a particular broker can also supply
research services.
Pacific Global does not make commitments to any broker/dealer that would bind Pacific Global to compensate a
broker/dealer, directly or indirectly, for client referrals. However, in determining whether to enter into any
agreement with a broker/dealer, Pacific Global may consider any past referral by such broker/dealer of the
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particular client for which the transaction is being executed, or of other clients, or in recognition of possible
future referrals from the broker/dealer.
Pacific Global’s authority to directly exercise brokerage discretion and the factors we consider in selecting
brokers are in compliance with Section 28(e) of the Securities and Exchange Act of 1934. Section 28(e) of the
Securities Exchange Act of 1934 permits an investment adviser to cause an account to pay commission rates in
excess of those another broker/dealer would have charged for effecting the same transaction if the adviser
determines in good faith that the commission paid is reasonable in relation to the value of the brokerage and
research services provided. The determination may be viewed in terms of either the particular transaction
involved or the overall responsibilities of the adviser with respect to the accounts over which it exercises
investment discretion. Thus, such research furnished by the broker/dealer may be used to service one or more
accounts other than those that pay commissions to the broker/dealer providing the research. If and when
Pacific Global receives such research services in return for “soft dollar” commissions and such services are also
used by Pacific Global for administrative purposes, a reasonable allocation would be made by Pacific Global so
that the value of the research service in making investment decisions is borne by the client accounts and the
value attributable to administrative functions is borne by Pacific Global. Pacific Global does not accept soft
dollar benefits that are not permissible under Section 28(e) of the Exchange Act.
Where more than one broker/dealer is believed to be capable of providing a combination of best net price and
execution with respect to a particular transaction, we often select a broker/dealer which furnishes to Pacific
Global investment research products or services, such as:
economic, industry or company research reports or investment recommendations;
statistical information;
information on accounting and tax law interpretations and political developments affecting portfolio
securities;
credit analysis;
risk measurement analysis;
performance analysis and analysis of corporate responsibility issues;
access to financial publications or research data compilations;
seminars;
research or analytical services; or services of economic and other consultants.
Such research services are received primarily in the form of written reports, telephone contacts and personal
meetings with securities analysts. In addition, such research services may be provided in the form of access
arranged with corporate and industry spokespersons, economists, academicians and government
representatives. Given our limited internal research capabilities, as a practical matter, it would not be possible
for us to generate all of the information presently provided by broker/dealers. To the extent that research
services of value would be provided by a broker, Pacific Global may be relieved of expenses that it might
otherwise bear.
Such selections are not pursuant to any agreement or understanding with any of the broker/dealers. However,
Pacific Global does, in some instances, request a broker/dealer to provide specific research products or services
which may be proprietary to the broker/dealer or produced by a third party and made available by the
broker/dealer and, in such instances, the broker/dealer in agreeing to provide the research product or service
may indicate its expectation to Pacific Global for commissions by reason of the broker/dealer’s provision of the
product or service. Pacific Global does not agree with any broker/dealer to direct a minimum amounts of
commissions. However, Pacific Global may endeavor to direct sufficient commissions on client transactions to
ensure the continued receipt of research products and services the firm finds useful. In return for research
products or services, Pacific Global does not pay brokerage commissions that are higher than those paid to other
broker/dealers. Research products or services provided by broker/dealers may be used in servicing any or all of
the clients of Pacific Global. Such research products or services may not necessarily be used in connection with
the client accounts which paid.
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Pacific Global participates in the Charles Schwab (“Schwab”) Institutional program Schwab is a SEC‐registered
broker/dealer. The firm is separate from and unaffiliated with Schwab. Schwab offers to independent
investment advisors services which include custody of securities, trade execution, clearance and settlement of
transactions. Pacific Global receives some benefits from its participation in the Schwab program. (Please see
the disclosure under Item 14 below.)
Client‐Directed Brokerage Arrangements
Pacific Global does not routinely recommend, request or require a client to direct us to execute transactions
through a specified broker/dealer. Our clients maintain the right to direct us to use a specified broker/dealer to
execute all or a portion of their securities transactions. When this occurs, a client directs Pacific Global in writing
(subject to certain conditions which may from time to time be imposed by Pacific Global) to effect portfolio
transactions for the client’s account through particular broker/dealers (“restricted brokerage”). Such a direction
may be conditioned upon a broker/dealer being competitive as to net price and execution of each transaction, or
may be subject to varying degrees of “restriction." For example, a client may instruct us to use the particular
broker/dealer whether or not competitive as to net price and execution, or at specified commission rates which
are less favorable than those we might obtain.
Before restricting brokerage to a particular broker/dealer, including designating a broker/dealer as custodian for
the client’s assets, a client should consider whether such designation may result in certain costs or
disadvantages. For example, the client may pay higher commissions than might otherwise be obtainable by
Pacific Global and/or may receive less favorable net prices and executions on some transactions or the value of
the custodial services may be diluted. A client who restricts our discretion in choosing broker/dealers to effect
transactions for the client’s account(s) may also be subject to the disadvantages described below regarding
priority of execution, allocation of new issues, purchases, and aggregation of orders. More information on
Pacific Global’s trade aggregation policies and procedures is provided under “Trade Aggregation” below.
If a client designates in writing to Pacific Global a specific broker/dealer acceptable to us through which trades
are to be executed, the client is required to execute a trading instruction letter in the form of an Exhibit to the
IMA. The client also acknowledges that (1) we generally will not be in a position to select broker/dealers on the
basis of best execution, negotiate commission rates or spreads, obtain volume discounts, commingle, batch, or
aggregate orders for purposes of execution or otherwise seek to obtain best execution; and (2) that directed
transactions may result in less favorable net prices and execution on the purchase and sale of securities than
might be the case if we were to select broker/dealers solely on the basis of best execution. In addition, a client
considering a directed brokerage arrangement should be aware that, when the client does not specify the
commission rate to be paid in directed brokerage transactions, such an arrangement may create a potential
conflict of interest between the client’s interest in having Pacific Global negotiate a lower commission rate and
our interest in obtaining referrals from the broker/dealer.
Trade Aggregation
When a portfolio manager intends to place an order for the purchase or sale of the same security for one or
more SMA portfolios at the same time, the portfolio manager may aggregate the trades for the SMA portfolios
as a single transaction with the same broker/dealer. The aggregated trade orders may result in obtaining lower
commission rates. If orders are aggregated as a single trade, the SMA portfolios receive equal treatment. We
would not aggregate transactions unless we believe such aggregation is consistent with our duty to seek best
execution (which includes best price) for Pacific Global’s clients and consistent with the terms of the firm’s IMA
with each client involved. No SMA is favored over any other SMA; and each portfolio that participates in an
aggregated order participates at the average share price for the transaction, with all transaction costs, except
account‐specific costs charged by the custodian, if any, shared on a pro rata basis. Individual investment advice
and treatment are accorded to each client.
In the case of a client who has restricted transactions to a particular broker/dealer, however, such client’s
account generally would be unable to participate in aggregated orders unless executed with the client’s
designated broker/dealer. Even where an aggregated transaction is executed with the client’s designated
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broker/dealer, if the client also has specified a particular commission rate to be paid on the transaction, that
specification may preclude the client from receiving the benefit, if any, of a lower commission resulting from the
aggregation; and the accounts of other clients participating in the aggregation order may receive a
correspondingly greater benefit.
Pacific Global will not receive additional compensation or remuneration of any kind as a result of the proposed
aggregation.
Before entering an aggregated order, we prepare a written statement (the “Allocation Statement”) specifying
the participating SMAs and how we intend to allocate the order among the participants. Aggregated orders that
are filled in their entirety are allocated among the participants in accordance with the Allocation Statement. A
partially filled order is allocated pro rata based on the Allocation Statement. De minimis orders may be allocated
at the discretion of the portfolio manager to prevent any participant from incurring unnecessary transaction
costs. Notwithstanding the foregoing, the order may be allocated on a basis different from that specified in the
Allocation Statement if all participants receive fair and equitable treatment; and the reason for the different
allocation is documented by the portfolio manager in writing to a Pacific Global compliance officer no later than
one hour after the market open on the trading day following the day the order was executed. Pacific Global’s
IMA discloses that, in instances when we determine not to aggregate orders, transactions in a specific security
may not be accomplished for all client accounts at the same time or at the same price.
Funds and securities of the SMAs whose orders are aggregated would be deposited with one or more banks or
broker/dealers. Neither the SMAs’ cash nor their securities would be held collectively any longer than is
necessary to settle the purchase or sale in question on a delivery versus payment basis. Cash or securities held
collectively for clients would be delivered out to the custodian bank or broker/dealer as soon as practicable
following the settlement.
Employees are permitted to maintain managed accounts with Pacific Global and may participate in firm‐directed
trade aggregation orders simultaneously with other clients, provided that Pacific Global does not believe that
non‐employee clients will be harmed by such participation and the transactions are consistent with each client’s
objectives and the firm’s policies.
Pacific Global annually reviews its trade aggregation procedures to ensure that they are adequate to prevent any
account from being systematically disadvantaged as a result of the aggregation of orders. If we discover any
non‐adherence to aggregation policies, we would take whatever corrective measures are necessary, including
revising the procedures. Pacific Global’s books and records separately record the securities held by, and bought
and sold for, each SMA whose orders are aggregated. We disclose these policies concerning the aggregation of
transactions to our existing clients and to broker/dealers through which such orders are placed.
Item 13 Review of Accounts
A.
Account Reviews
SMAs
Pacific Global assigns one or more portfolio managers (who may be principal executive officers) to manage each
client account. All accounts are subject to periodic and continuous review and monitoring by the assigned
portfolio manager(s). Client accounts are also reviewed by Pacific Global’s principal executive officers. Overall
portfolio policy, as well as the allocation of assets among market sectors, individual securities, mutual funds and
cash reserves, is reviewed on an ongoing basis in the context of the client’s stated investment objectives and any
account‐specific guidelines. Balanced and Fixed Income accounts are rebalanced no less frequently than
quarterly to maintain a minimum fixed income allocation not less than 5% below the target allocation. Changes
in general market conditions, as well as changes in relative price performance in market sectors or individual
securities typically result in changes to portfolio strategy. The firm maintains a recommendation list for equities;
the active buy portion of this list typically contains contain approximately 50 small and micro‐cap stocks, 60 mid‐
cap and 200 large cap stocks; fixed income securities are individually selected based on market conditions, credit
rating and availability among other considerations. Portfolio managers tailor each account based on the client’s
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needs and objectives by selecting approximately 30 to 50 securities for each portfolio that present the best
opportunities at a given time. Significant additions to, or withdrawals from, an account would result in an
individual review of that account to determine what action, if any, may be appropriate.
Financial Plans
Pacific Global reviews financial plans when a client engages the firm for a one‐time review or on‐going reviews.
On‐going reviews, which typically occur annually, update the income, expense and other components of the
plan. Plan updates are prepared by a certified financial planner and reviewed by a compliance officer.
B.
Account Reports
SMA clients receive monthly account statements from their custodians detailing account activity, positions held
and market values. Clients should contact us directly if they believe that there may be an error in their
statement. SMA clients also receive quarterly reports from Pacific Global which include a market valuation,
account performance and Pacific Global’s economic and market outlook. We also provide detailed account
information as specifically requested by the client, or when significant economic factors warrant. Clients should
carefully review their custodial statements, verify their accuracy and compare them with portfolio reports they
receive from us. From time to time, Pacific Global’s statements may vary from custodial statements based on
accounting procedures, reporting dates, or valuation methodologies for certain securities.
At the end of each calendar year, each SMA client receives a tax accounting summary of gains, losses and income
generated by the account from the account’s custodian. Clients should consult their tax adviser and rely upon
tax accounting information provided by their custodians when preparing their tax returns. Further, clients
should rely upon cost basis reporting information provided by their custodian when preparing their tax returns.
All reports discussed under this Section 13B, and any other notices, documents or other communications given
or required to be given to any client pursuant to an Agreement with Pacific Global, may be sent by mail or, as
authorized by a client, by electronic delivery to the client’s last known e‐mail address provided to Pacific Global
by the client.
Item 14 Client Referrals and Other Compensation
Pacific Global may pay cash referral fees to independent persons or firms (“solicitors”). Each such referral
agreement and the related activities of Pacific Global will be in compliance with Rule 206(4)‐3 of the Advisers Act
and the related SEC staff interpretations and other applicable laws and regulations. Rule 206(4)‐3 specifies
certain standards that must be met by an investment adviser and any person who solicits any client for, or refers
any client to, an investment adviser prior to payment of a cash fee directly or indirectly, for client solicitation or
referral.
As discussed in Item 12, in certain cases, when we believe a broker/dealer is capable of providing the best price
and most favorable execution with respect to a particular portfolio transaction, we may select that
broker/dealer in recognition of the broker/dealer’s past referral of the particular client for which the transaction
is being executed, or other clients, or in recognition of possible future referrals from that broker/dealer.
Pacific Global maintains an internal bonus compensation plan which rewards officers and employees of Pacific
Global for new investment advisory client accounts developed by them.
Schwab Institutional Program
As disclosed under Item 12 above, Pacific Global participates in the Schwab institutional customer program and
Pacific Global may recommend Schwab to clients for custody and brokerage services. Although there is no direct
link between Pacific Global’s participation in the program and the investment advice the firm gives to its clients,
Pacific Global receives economic benefits through its participation in the program that are typically not available
to Schwab retail investors. These benefits include the following products and services (provided without cost or
at a discount): receipt of duplicate client statements and confirmations; research related products and tools;
consulting services; access to a trading desk serving Pacific Global participants; access to block trading (which
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provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares
to client accounts); the ability to have advisory fees deducted directly from client accounts; access to an
electronic communications network for client order entry and account information; access to mutual funds with
no transaction fees and to certain institutional money managers; and discounts on compliance, marketing,
research, technology, and practice management products or services provided to Pacific Global by third party
vendors. Schwab may also have paid for business consulting and professional services received by Pacific
Global’s related persons. Some of the products and services made available by Schwab through its program may
benefit Pacific Global but may not benefit its client accounts. These products or services may assist Pacific
Global in managing and administering client accounts, including accounts not maintained at Schwab. Other
services made available by Schwab are intended to help Pacific Global manage and further develop its business
enterprise. The benefits received by Pacific Global or its personnel through participation in the program do not
depend on the amount of brokerage transactions directed to Schwab. As part of its fiduciary duties to clients,
Pacific Global endeavors at all times to put the interests of its clients first. Clients should be aware, however,
that the receipt of economic benefits by Pacific Global or its related persons in and of itself creates a potential
conflict of interest and may indirectly influence the firm’s choice of Schwab for custody and brokerage services.
Item 15 Custody
Pacific Global does not maintain actual physical custody of the assets that we manage for our clients. However,
under SEC rules, we are deemed to have custody of our SMA client assets to the extent that clients authorize us
to instruct the custodian to deduct our advisory fees directly from their accounts.
Item 16
Investment Discretion
As described in Item 4, Pacific Global provides discretionary advisory services with respect to SMAs. Before
assuming this authority, the types and amounts of securities traded, and the manner of execution, is generally
determined by each client’s IMA. Therefore, we have authority to supervise and direct the investments of and
for the client’s account without prior consultation with the client. We approve and accept accounts only after
the client has provided all of the required new account paperwork including, but not limited to, a Pacific Global
IMA and personal profile and a limited power of attorney for the client’s custodial account. We assume
discretionary authority once an account is accepted.
Pursuant to this discretionary authority, we determine which securities are bought or sold for the account and
the total amount of such purchases and sales. Pacific Global’s authority may be made subject to conditions
imposed in writing by the client and accepted by us. For example, a client may restrict or prohibit purchases of
certain types of securities, or direct that transactions be effected through specific brokers/dealers, or impose
other limitations.
Item 17 Voting Client Securities
Pacific Global has adopted a written Proxy Voting Policy detailing procedures and guidelines to be used when
voting shareholder proxies for those clients for which we have been granted proxy voting authority (the “Proxy
Policy”). The Proxy Policy complies with Rule 206(4)‐6 of the Investment Advisers Act of 1940, as amended, and
relies, in large part, on guidance provided by the SEC effective as of September 10, 2019. Our policy is to vote
proxy issues in the best interests of our clients; any potential conflicts of interest are resolved by considering
only the interests of our clients.
We do not anticipate that conflicts will arise frequently because Pacific Global does not engage in the types of
business activities (such as underwriting, banking or insurance services, or benefit plan administration) that
would give rise to potential conflicts affecting proxy voting.
We generally support management’s recommendations unless we believe such recommendations would not be
in our clients’ best interests. We do not intend to exercise voting authority on certain types of matters if the
exercise of voting would not reasonably be expected to have a material effect on the value of the client’s
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investment. For example, if the cost of voting, including administration and record maintenance, would be high,
or the benefit to clients would be low.
In general, we intend to focus voting resources only on particular types of proposals and non‐recurring matters
such as (mergers and acquisitions, tender offers, dissolutions, conversions or consolidations). We carefully
examine, on a case‐by‐case basis, such matters as well as proposals regarding changes in a company’s state of
incorporation or other corporate restructuring. We may seek to obtain independent outside evaluations,
including research analyses, in determining the best interests of our clients.
Clients can contact Pacific Global Client Services at (800) 404‐6693 with questions about proxy solicitation.
Clients cannot direct Pacific Global’s vote in any solicitation. However, clients can request that their custodians
provide proxies and other solicitations to them by submitting instructions directly to their custodians.
Pacific Global’s Proxy Policy is available without charge, upon written request, by contacting Client Services at
101 N. Brand Blvd., Suite 1950, Glendale, CA 91203. Clients may contact Client Services to request a report
showing how Pacific Global voted shares held in their account.
Item 18 Financial Information
Pacific Global is not required to include a balance sheet for our most recent fiscal year because we do not
require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. In this Item,
we are required to disclose that Pacific Global has no financial commitment that impairs its ability to meet
contractual and fiduciary commitments to clients. Additionally, Pacific Global has not been the subject of a
bankruptcy petition during the past ten years.
Privacy Policy
We respect our clients’ right to privacy. We understand that clients expect us to act in an accurate and efficient
manner. To do so, we must collect and maintain certain personal information about each client from account
forms provided by the client and from the client’s transactions with us or the custodian of the client’s account(s).
We do not disclose any nonpublic personal information about any client or any former client to anyone, except
(1) our affiliates and service providers, (2) pursuant to the client’s written authorization (so long as such
authorization has not been revoked), or (3) or as permitted by law. We also may collect and maintain certain
personal information about a client’s attorneys‐in‐fact and others authorized to act with respect to a client’s
account (“Authorized Representatives”). We treat such Authorized Representatives’ personal information under
our policies in a similar manner to the way we treat client personal information.
To protect the personal information of clients and their Authorized Representatives, we permit access to client
and Authorized Representative’s personal information only to authorized employees who need to know the
information to provide products and services to the client. We maintain physical, electronic and procedural
safeguards that comply with federal standards to guard clients’ such personal information.
We are authorized, in our sole discretion, to engage agents and independent contractors, including, but not
limited to, outsourcers and other persons or entities (collectively, "Service Providers"), to perform, or to advise
or assist us in the performance of our duties under the investment management agreements.
17
EXHIBIT A
Notification to Existing Clients
101 North Brand Boulevard Suite 1950
Glendale, California 91203
(800) 989‐6693
www.pacificglobal.us
March 31, 2025
Pacific Global Investment Management Company is a registered investment
adviser. Registration as an Investment Adviser does not, by itself, imply a specific
level of skill or training.
This brochure provides information about the qualifications and business practices
of Pacific Global Investment Management Company. If you have any questions
about the contents of this brochure, please contact us at 1‐800‐989‐6693. The
information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission (“SEC”) or by any state securities
authority.
Additional information about Pacific Global Investment Management Company
also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search
this site using a CRD, a unique identifying number; our firm’s CRD number is
106962.
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EXHIBIT A
Notification to Existing Clients
PACIFIC GLOBAL FORM ADV PART 2.A
AS OF MARCH 31, 2025
Item 2 Material Changes
There have been no material changes to this brochure since the last version as of March 28, 2024.
We will ensure that clients receive a summary of any material changes to this and subsequent brochures within
120 days of the close of our fiscal year on December 31st. Furthermore, we will provide clients with other
interim disclosure information about any material changes.
Clients or prospective clients may request a copy of our brochure, free of charge, by contacting Pacific Global
Client Services at (800) 404‐6693 or clientservices@pgimc.com. Our brochure is also available on our website at
www.pacificglobal.us.
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