# Kaltbaum Capital Management

> Kaltbaum Capital Management is an SEC-registered investment advisory firm, registered since 2025, reporting $100 million to $500 million in regulatory assets under management in its Form ADV filing dated March 27, 2026.

- CRD: 123991
- Filed as: KALTBAUM CAPITAL MANAGEMENT
- Legal name: Kaltbaum Capital Management, LLC
- Registration: SEC-registered investment adviser (status as filed: Approved)
- Filing period: October 2026
- Form ADV filing dated: March 27, 2026
- SEC record (IAPD): https://adviserinfo.sec.gov/firm/summary/123991
- AdvisorCensus page: https://advisorcensus.com/firm/kaltbaum-capital-management-123991

## Quick answers

**How is Kaltbaum Capital Management compensated?**
On its Form ADV (Item 5.E, October 2026), Kaltbaum Capital Management reports these compensation arrangements: a percentage of assets under its management; fixed fees (other than subscription fees); performance-based fees.

**How much does Kaltbaum Capital Management charge?**
Its Form ADV Part 2A brochure dated March 27, 2026 states: Subscription: $750 a quarter (Investment Research Consulting Fees for individuals). Fees can differ by service and may be negotiable; the brochure is the complete statement.

**Is Kaltbaum Capital Management registered with the SEC or a state?**
Kaltbaum Capital Management is an SEC-registered investment advisory firm, registered since 2025. Status as filed: Approved. CRD 123991.

**How much does Kaltbaum Capital Management manage?**
Kaltbaum Capital Management reports $110,895,973 in regulatory assets under management in its Form ADV filing dated March 27, 2026 (99% discretionary).

**How have Kaltbaum Capital Management's assets and staff changed since 2025?**
In the Form ADV data for Kaltbaum Capital Management: Regulatory assets under management: $117,979,814 in the October 2025 data and $110,895,973 in the October 2026 data, down 6%. Total employees: 2 in October 2025 and 2 in October 2026. Assets under management move with markets as well as with clients coming and going.

**What types of clients does Kaltbaum Capital Management serve?**
By number of clients on Form ADV Item 5.D: individuals (other than high net worth individuals) (118); high net worth individuals (109).

**Which custodians does Kaltbaum Capital Management use?**
Kaltbaum Capital Management's most recent Form ADV filing (Schedule D, Section 5.K(3)) lists Charles Schwab & Co., Inc. as a custodian holding 10% or more of its separately managed account assets.

**Does Kaltbaum Capital Management report any disciplinary disclosures?**
Reports 4 disclosure items on Form ADV Item 11: yes answers to 11.D(2) (another regulator's finding of a violation), 11.D(5) (another regulator's denial, suspension, or revocation of a registration or license, bar, or restriction), 11.E(2) (self-regulatory organization's finding of a rule violation), and 11.E(4) (self-regulatory organization's expulsion, suspension, bar, or restriction). Each question covers the firm and its advisory affiliates, and one event can produce several yes answers. The detail of any item is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/123991

**Does Kaltbaum Capital Management state an account minimum?**
Its Form ADV Part 2A brochure dated March 27, 2026 says: "The minimum amount required to establish and maintain an account is generally $500,000. However, the Company reserves the right, in its sole discretion, to reduce the minimum requirement for certain accounts under certain circumstances."

## From the Form ADV filing

### Compensation (Item 5.E)
- A percentage of assets under your management
- Fixed fees (other than subscription fees)
- Performance-based fees

### Fees and minimums (Form ADV Part 2A brochure dated March 27, 2026)

- Account minimum: $500,000 (the brochure says it may be waived or negotiated)

> The minimum amount required to establish and maintain an account is generally $500,000. However, the Company reserves the right, in its sole discretion, to reduce the minimum requirement for certain accounts under certain circumstances.

- Subscription: $750 a quarter (Investment Research Consulting Fees for individuals)

> Investment Research Consulting Fees. For these services, fees are $750 per quarter for individuals.

As stated in the firm's brochure. Fees can differ by service and may be negotiable.

### Custodians (Schedule D, Section 5.K(3))
- Charles Schwab & Co., Inc.

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

### Regulatory assets under management (Item 5.F)
- Total: $110,895,973
- Discretionary: $110,114,412
- Non-discretionary: $781,561

### Clients (Item 5.D)

| Client type | Clients | Assets |
| --- | --- | --- |
| Individuals (other than high net worth individuals) | 118 | $12,677,018 |
| High net worth individuals | 109 | $98,218,955 |

### Advisory services (Item 5.G)
- Portfolio management for individuals and/or small businesses
- Publication of periodicals or newsletters
- Other

### Firm details
- Registered since: 2025 (1 year)
- Employees: 2 total, 1 performing advisory functions
- Wrap fee program participation: No
- States registered or notice-filed: AZ, FL, PA, TX
- Disclosures (Item 11): Reports 4 disclosure items on Form ADV Item 11.

### Item 11 questions answered yes
- 11.D(2): Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was involved in a violation of investment-related regulations or statutes?
- 11.D(5): Has another federal regulator, a state regulator, or a foreign financial regulator ever denied, suspended, or revoked the registration or license of the firm or an advisory affiliate, prevented either by order from associating with an investment-related business, or restricted either one's activity?
- 11.E(2): Has a self-regulatory organization or a commodities exchange ever found that the firm or an advisory affiliate was involved in a violation of its rules, other than a minor rule violation under a plan the SEC approved?
- 11.E(4): Has a self-regulatory organization or a commodities exchange ever disciplined the firm or an advisory affiliate by expelling or suspending it from membership, barring or suspending it from association with other members, or otherwise restricting its activities?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. The detail of each yes answer is on the firm's SEC record: https://adviserinfo.sec.gov/firm/summary/123991

### Websites listed on Form ADV (Item 1.I)
- convictionleaders.com
- garykaltbaum.com
- X @garykaltbaum

## Assets and staff over time

| Data period | Regulatory assets under management | Employees | Filing dated |
| --- | --- | --- | --- |
| October 2025 | $117,979,814 | 2 | May 6, 2025 |
| October 2026 | $110,895,973 | 2 | March 27, 2026 |

Regulatory assets under management: $117,979,814 in the October 2025 data and $110,895,973 in the October 2026 data, down 6%.
Total employees: 2 in October 2025 and 2 in October 2026.

## Source

Form ADV as filed, October 2026. Values appear as filed. Cite as: AdvisorCensus. Kaltbaum Capital Management (CRD 123991): Form ADV filing data as of October 2026.