ELEY Financial Management Inc

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ELEY Financial Management Inc
CRD #105057
SEC #801-34761
CIK #0001965267
AUM 409.6 M (2026-03-31)
Employees 5 (80% Investors, 0% Brokers)
Fees
Minimum
Phone802-863-4463
Address99 Swift Street
South Burlington, VT 05403-7360
Source [IAPD] [EDGAR] [Website]
Total AUM ($M)
4503602701809001999200820172027
Fees and Compensation — Form ADV Part 2A (3/31/2026) [Brochure]
Item 5: Fees and Compensation

Broadlake Financial Management is compensated based on the level of assets that we manage.
See our fee schedule below*:
                 Broadlake Financial Management - Adviser Compensation
                          Fee Schedule – Effective February, 2013

           Asset Dollar Amount                              Management Fee
            $0.00 to $500,000                                    1%
          $500,000 to $1,000,000                                .90%
         $1,000,000 to $1,500,000                               .80%
         $1,500,000 to $2,000,000                               .75%
         $2,000,000 to $3,000,000                               .70%
            Above $3,000,000                                  Negotiable

         Asset Dollar Amount                              Management Fee
      Any Non-Profit Organization                     90% of Normal Fee Schedule
  Non-Discretionary Accts. (401(k), etc.)                     Negotiable

*These are our base fee rates and are negotiable under certain circumstances.

Management fees can be debited from client accounts directly, or can be billed separately. In
either case, fees are charged quarterly and are determined by the account value on the last day of
the preceding quarter (12/31, 3/31, 6/30, 9/30). Since fees are paid in advance, we will refund a
prorated portion of these prepaid management fees in the event that our management services are
terminated. See the example below for both a calculation of how our fee is calculated, and a
hypothetical refund.

Example:
Account balance on 12/31/10: $300,000.00
First Quarter fees due: $750 = [.25% * 300,000]
Relationship terminated 1/30/11:
Portion of quarter where service was provided: 1/3 = 30 days / 90 days
Refund Paid: $500 = $750 – ($750 * 1/3)

While this asset based fee is the only fee charged by our firm, the client may pay additional fees
that are charged by other parties. These fees are associated with owning or acquiring certain
types of investments and are not a result of the RIA relationship per se. For example:

   •   Custodians may charge a nominal fee for their record keeping services
   •   Certain investments such as mutual funds contain internal fees (i.e. expense ratios) to
       cover their costs
   •   A commission is often charged to execute trades of certain securities (e.g. stocks,
       Exchanged Traded Funds (ETFs). These fees are charged by the brokerage firm
       executing the trade and are not charged or received by Broadlake Financial
       Management/Eley Financial Management, Inc.

See item 12 of this brochure for a full discussion of our brokerage practices.
Account Minimums and Types of Clients — Form ADV Part 2A (3/31/2026) [Brochure]
Item 7: Types of Clients

We manage both taxable and non-taxable accounts for individuals, companies, and non-profit
entities. We also serve as advisor to the trustees of 401(k) and other employer sponsored
retirement plans. Our account minimum is $50,000, although this minimum account size
requirement can be waived under certain circumstances.
Sector Form 13F Holdings Value ($M)
Apple Inc 8.1
Cummins Inc 7.9
Nvidia Corp 7.4
Alphabet Inc 6.5
Microsoft Corp 6.0
Broadcom Inc 5.7
Amazon Com Inc 5.6
Johnson & Johnson 5.5
Costco Wholesale Corp /NEW 5.1
Lowes Companies Inc 5.1
View All
Holdings by Sector ($M)
3002401801206002022202320252027
AUM Breakdown Accounts AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals) 356 101.2
(b) Individuals (high net worth individuals) 95 290.5
(c) Banking or thrift institutions 0 0.0
(d) Investment companies 0 0.0
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 0 0.0
(g) Pension and profit sharing plans 2 5.3
(h) Charitable organizations 10 12.6
(i) State or municipal government entities 0 0.0
(j) Other investment advisers 0 0.0
(k) Insurance companies 0 0.0
(l) Sovereign wealth funds and foreign official institutions 0 0.0
(m) Corporations or other businesses not listed above 0 0.0
(n) Other 0 0.0
Total 1,166 409.6
By Discretionary
Discretionary 1,166 409.6
Non-Discretionary 0 0.0
Total 1,166 409.6
By Non-United States Persons
Non-United States Persons 0.3
United States Persons 409.3
Total 1,166 409.6
EDGAR Form CIK 2011 - 2026
13F-HR [0001965267]
Firm Profile (Form ADV)
Discretionary AUM$0.2B
ServesInstitutional, Retail
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