Leeb Capital Management, Inc.
Part 2A of Form ADV
The Brochure
Item 2: Material Changes
Item 4: Advisory Business
Leeb Capital Management, Inc. ("LCM") was founded in 1984 and is owned by Dr. Stephen Leeb and his wife, Donna Alison Leeb. LCM provides investment supervisory services to various types of clients, including individuals, institutions, trusts, pensions, and profit sharing plans.
LCM offers investment supervisory services which involves LCM providing you with continuous and ongoing supervision over your specified accounts.
You must appoint our firm as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account.
The Account is managed by us based on your financial situation, investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account.
We will need to obtain certain information from you to determine your financial situation and investment objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account.
You have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities.
It is important that you understand that we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you, or actions taken for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts.
Conflicts can arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit.
LCM’s investment supervisory services focus on the selection of domestic and foreign stocks but also may include, bonds, options, mutual funds, annuities and money markets. LCM currently offers the following investment strategies:
- Large-Cap Growth
- Income and Growth
- Peak Resources and Energy
Client accounts are managed on an individual basis based upon the specific investment objectives and constraints of the client. This means, for example, that when we provide investment supervisory services, you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information.
We will not enter into an investment adviser relationship with a prospective client whose investment objectives are considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines.
Beginning in January 2025, Dr. Stephen Leeb offers a paid subscription to a newsletter called Turbulent Times Investor (TTI) from his personal website, stephenleeb.com. This activity is separate and distinct from the investment supervisory services of LCM. Clients of LCM are not required to subscribe to TTI. Portfolio manager Kuen (Scott) Chan also contributes to this newsletter. Dr. Leeb and Mr. Chan expect to spend approximately 10% of their time writing and editing TTI.
LCM’s clients may, however, acquire securities that are discussed in a publication. LCM, at all times, strives to act in the best interest of clients and to treat all clients in a fair and equitable manner.
As of December 31, 2025, LCM managed $111,945,919 on a discretionary basis.
Item 5: Fees and Compensation
LCM believes that our annual fees are reasonable in relation to: (1) services provided and (2) the fees charged by other investment advisers offering similar services/programs. However, our annual investment advisory fee may be higher than that charged by other investment advisers offering similar services/programs.
LCM may negotiate advisory fees at its discretion based on the complexity of the client's situation, the relationship of the client with the investment adviser representative, and the total amount of assets under management for the client. As a result, clients with similar assets can have differing fee schedules and pay different fees. In general, the annual fees for LCM’s advisory services are as follows:
- Retail Growth Accounts
Up to $500,000.00: 1.50% Over $500,000.00: 1.00%
- Institutional Growth Accounts
|
$5,000,000 to $10,000,000: |
0.90% |
|
$10,000,001 to $20,000,000: |
0.85% |
|
$20,000,001 to $25,000,000: |
0.80% |
|
$25,000,001 to $50,000,000: |
0.75% |
|
Over $50,000,000: |
Negotiable |
- Income and Growth Accounts
Accounts are charged 1.0%.
- Peak Resources and Energy Accounts
Accounts are charged 2.0%.
LCM charges a different fee rate or schedule based upon asset classes (e.g., equities, fixed income) or investment product types (e.g., mutual funds, ETFs, stocks and bonds) invested in the client’s account. This creates a conflict of interest in that there is an economic incentive for LCM and its investment adviser representatives to recommend certain asset classes or investment product types which have a higher fee rate or schedule compared to other asset classes or investment product types with a lower fee rate or schedule. LCM has taken steps to manage its conflict of interest arising from its use of different fee rates/schedules through its code of ethics, whereby LCM and its investment adviser representatives will not exercise investment discretion with respect to changing asset classes or investment product types and will only recommend the change of asset classes or investment products when in the best interest of the client and without regard to the financial interest of LCM.
Clients may choose to be invoiced for the advisory fees or have the advisory fees deducted from their advisory accounts. Annual fees are divided and prepaid on a quarterly basis for the ensuing three-month period. The quarterly fee for a given account is calculated based on the market value of that account on the final day of the preceding quarter. For example, fees for the April-to-June quarter for an account are calculated based on that account’s ending market value on March 31.
Fees are refundable on a pro-rata basis, in the event of termination of the advisory contract by the client.
If fees are deducted from your account, you must authorize the qualified custodian(s) of your account to deduct fees from your account and pay such fees directly to LCM.
You should review your account statements received from the qualified custodian(s) and verify that appropriate investment advisory fees are being deducted. The qualified custodian(s) will not verify the accuracy of the investment advisory fees deducted.
If you pay fees directly to our firm via a billing invoice, fees are due upon your receipt of the invoice sent directly to you. The billing notice will detail the formula used to calculate the fee and the time period covered.
Brokerage expenses and/or transaction ticket fees charged by your qualified custodians are billed directly to you by the qualified custodians. LCM does not receive any portion of such expenses or fees from you or the qualified custodians. Moreover, LCM recommends open-ended, closed-end, exchange traded funds (“ETFs”) and exchange traded notes (“ETNs”) in managing clients’ accounts. These funds and notes charge fees that are separate from and in addition to LCM’s management fee including, but not limited to, mutual fund sales loads, 12b-1 fees and surrender charges, IRA and qualified retirement plan fees, and charges imposed by the qualified custodian(s) of your account. Management fees charged by LCM are separate and distinct from the fees and expenses charged by investment company securities recommended to you. A description of these fees and expenses are available in each investment company security’s prospectus. LCM does not receive any portion of such third-party expenses or fees.
LCM and our supervised persons do not accept or receive compensation based on the sale of securities or other investment products such as asset-based sales charges or service fees from the sale of mutual funds.
Item 6: Performance Based Fees and Side-by-Side Management
Item 7: Types of Clients
LCM provides investment supervisory services to various types of clients, including individuals, institutions, trusts, pensions, and profit-sharing plans.
There is an investment minimum of $250,000 for new accounts in the Growth and Income & Growth strategies and $100,000 in the Peak Resources and Energy strategy. However, at its discretion, LCM may waive this investment minimum.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Large Cap Growth Portfolio
The Growth strategy combines a disciplined “top-down” analysis with a detailed fundamental, “bottom-up” security selection process.
LCM’s top-down analysis aims to identify macroeconomic trends that represent growth opportunities in the global economy – this macro analysis helps to determine our internal growth rates for sectors, as well as for the companies within those sectors.
A variety of data sources is used to establish relative value expectations of growth sectors that are likely to benefit from these broad themes and outperform over the next 12 to 24 months. Growth sectors are defined as those with higher potential revenue and profit growth than that of the US economy.
LCM’s top-down approach helps to focus the firm’s bottom-up security selection process into the growth sectors and industries identified by the Investment Committee. Portfolio managers identify securities from the S&P 500 and other sources that are consistent with the firm’s investment philosophy. The result of the analyses is a “watch-list” of approximately 50 companies.
These stocks should possess some, if not all, of the following characteristics:
- Market dominance
- A superior operating record and balance sheet
- Projected growth rate greater than the market
- Reasonable price: defined as having a forward PEG less than that of the market
The Investment Committee will perform in-depth research on these companies in order to determine the ones to be included in the Large Cap Growth model portfolio. LCM’s fundamental research process incorporates the following inputs:
- “DCA” Analysis (Dominant & Competitive Analysis)
- Growth Factors
- Quality Analysis
- Valuation
LCM employs strict sell disciplines to protect its clients’ portfolios. Positions will generally be reduced or sold if a stock:
- Becomes overpriced
- Can be replaced with better risk/reward opportunity
- Changes occur that affect a stock’s fundamentals
- Position weight reaches 8%*
*For especially small accounts where it’s not feasible to purchase a full slate of securities in accordance with our investment strategies, and we have to purchase a small number of securities, this condition is waived. Additionally, an exception is made for funds that track the spot price of gold or silver. For such assets, the upper limit is 20% each. Beginning in February 2026, another exception is made for funds that have historically shown to be strong contrarian plays vis-à-vis the stock market, such as inverse ETFs and zero-coupon bond funds. For such funds, the upper limit is also 20% each. While we strongly believe gold, silver, and related securities should be long-term core investment holdings, we view the contrarian funds as strictly short-term holdings in the event of unusually high stock market risks.
Income & Growth Portfolio
The Income & Growth Portfolio core strategy is based on generating current income and long-term capital appreciation. We look to hold positions as long as possible in order to capture the maximum in distributions, as well as the capital appreciation that invariably comes from a rising stream of dividends.
This approach is bottom up. We look at companies’ operations first, focusing on sustainable yields and businesses that are becoming more valuable over time. We pay careful attention to all the earnings numbers, with the intent of determining whether those businesses are still on track.
The key is to find healthy businesses that can thrive over the course of varying points in economic cycles. Companies should be able to weather tight credit conditions as well as high and rising raw material costs. These businesses should not only be able to maintain a steady payout, but also be positioned to increase the dividend over time.
We think quality always wins out eventually, and thus stocks and preferred shares backed by strong underlying businesses should recover from short-term price dips. Our holdings are also broadly diversified over a wide range of industries, which has proven to be a reliable strategy to grow principal and provide portfolio stability over the years.
The Income & Growth portfolio will consist primarily of common stocks, preferred stocks, master limited partnerships, and bonds with an objective to minimize the following risks:
- Inflation risk which diminishes purchasing power
- Credit risk by focusing the majority of holdings in investment grade securities
- Market risk by diversifying between various income sectors such as REITs, utilities and preferred stocks.
LCM employs strict sell disciplines to protect its clients’ portfolios. Positions will generally be reduced or sold if a stock:
- Becomes overpriced
- Can be replaced with better risk/reward opportunity
- Changes occur that affect a stock’s fundamentals
- Position weight reaches 8%*
*For especially small accounts where it’s not feasible to purchase a full slate of securities in accordance with our investment strategies, and we have to purchase a small number of securities, this condition is waived. Additionally, an exception is made for funds that track the spot price of gold or silver. For such assets, the upper limit is 20% each. Beginning in February 2026, another exception is made for funds that have historically shown to be strong contrarian plays vis-à-vis the stock market, such as inverse ETFs and zero-coupon bond funds. For such funds, the upper limit is also 20% each. While we strongly believe gold, silver, and related securities should be long-term core investment holdings, we view the contrarian funds as strictly short-term holdings in the event of unusually high stock market risks.
Peak Resources & Energy Portfolio
The Peak Resources & Energy Portfolio (“PREP”) is based on LCM’s belief that the global economy is in the midst of an era of increasing global resource and energy scarcity and unprecedented inflationary pressures driven by the emergence of developing nations, spearheaded by China, despite historical cyclicality in the commodities markets. We believe the fact that a significant portion—in some cases, the lion’s share—of critical resources are controlled by countries deemed to be adversaries of the U.S. (such as China and Russia) only adds to inflationary pressures, as well as market risks.
In selecting equity securities for the PREP portfolio, LCM starts by reviewing U.S. and foreign companies engaged in the natural resources industry, including those listed on the S&P Global Energy indices or the S&P Alternative Energy indices, the Philadelphia Gold & Silver Index, energy and natural resources sector ETFs and ETNs, ETFs and ETNs linked to commodities such as gold, silver, oil or agricultural products, or a commodity index; and companies engaged in alternative energy or conservation-related activities. This universe is then screened for market capitalization greater than $250 million, a projected Price/Earnings to Growth (“PEG”) ratio less than that of the S&P 500 Index, and a high free cash-flow yield. However, at its discretion, LCM will select companies that do not meet the screening requirement. For example, LCM may invest in junior miners that own large precious metals assets that it judges to have significantly above-market growth potential. Due to the nature of small companies, they may not meet some or all of the requirements set forth in this paragraph.
The PEG is an indicator of a stock’s potential value. A lower PEG means that the stock is more undervalued. The resulting watch list of approximately 50 to 75 companies is further reduced by the Adviser, using a rigorous fundamental research process described below, to select approximately 30-40 equity securities for the portfolio. However, the Portfolio Managers have discretion to select stocks that we believe offer extraordinary potential upside even if they do not meet one or more of the cited criteria. The Adviser’s analysis focuses on the following factors:
- Dominant & Competitive Analysis
- Growth Factors
- Company & Quality Analysis
Once investments are identified, the portfolio is constructed under general weighting guidelines. These include but are not limited to:
- A split between energy & materials (including precious metals)
- Typical diversification among 30-40 positions
- An 8% maximum weighting for any single company*
- Including investments in other sectors that could be beneficiaries of resource scarcity (defense, cyber-security, etc.)
*For especially small accounts where it’s not feasible to purchase a full slate of securities in accordance with our investment strategies, and we have to purchase a small number of securities, this condition is waived. Additionally, an exception is made for funds that track the spot price of gold or silver. For such assets, the upper limit is 20% each. Beginning in February 2026, another exception is made for funds that have historically shown to be strong contrarian plays vis-à-vis the stock market, such as inverse ETFs and zero-coupon bond funds. For such funds, the upper limit is also 20% each. While we strongly believe gold, silver, and related securities should be long-term core investment holdings, we view the contrarian funds as strictly short-term holdings in the event of unusually high stock market risks.
LCM may invest in ETFs or ETNs linked to commodities such as gold, silver, oil or agricultural products, or a commodity index. A typical commodity-related ETF or ETN may seek to achieve economic exposure to commodity prices through direct investment in a commodity, such as gold bullion; or by investing in the securities of issuers who are primarily engaged in production of specific commodities. The Adviser’s research suggests that commodity-related investments offer the potential for inflation protection, capital appreciation and returns that are not highly correlated to those of the equity markets. In a typical commodity-related ETF or ETN, the net asset value of the ETF is linked to the value of an individual commodity, or the performance of commodity indices. Commodity ETFs and ETNs may use derivatives which expose them to further risks, including counterparty risk (i.e., the risk that the institution on the other side of the trade will default).
LCM may sell a portfolio security to the extent that the Portfolio Managers have determined that it has become over-priced, or it could be replaced with a security that offers a better risk/reward opportunity, or if changes occur that affect a company’s fundamentals and its future growth prospects appear weak.
From time to time, the Portfolio Managers may take temporary defensive positions that are inconsistent with the portfolio’s principal investment strategies, in attempting to respond to adverse market, economic, political or other conditions. For example, portfolios may hold cash, money market mutual funds, investment grade short-term money market instruments, U.S. Government and agency securities (including zero coupon bonds), commercial paper, certificates of deposit, repurchase agreements and other cash equivalents.
In addition to its three active investment strategies, LCM manages a limited number of advisory client accounts that are invested mainly in mutual funds. LCM designs this mutual fund strategy based on its screening process utilizing Morningstar data when selecting funds; portfolio composition is based on target sector weights according to LCM’s philosophy and client objectives. The mutual fund portfolios may be constructed with no-load funds, front-end load funds, back-end load funds, or contingent-deferred load funds. Such load fees, if any, are paid from the clients’ accounts and are paid in addition to LCM’s advisory fees. In addition, managers of mutual funds charge management fees that are exclusive of those charged by LCM to its clients.
Investment Risks. Investments in LCM’s investment strategies may entail a significant degree of risk and therefore should be undertaken only by individuals capable of evaluating the risks of the applicable investment strategy and bearing the risks it represents. Set forth below is a non-exhaustive list of such risks. However, prospective clients are advised as necessary, to request from an eligible LCM representative, a more comprehensive discussion of these risks prior to investing with LCM:
Commodities-Related Securities. LCM’s Investment Strategies may invest indirectly in commodities through instruments that invest in or are a derivative of commodities, such as commodity-related ETFs and ETNs. In a typical commodity-related ETF, the net asset value of the ETF is linked to the value of an individual commodity, or the performance of commodity indices. Therefore, these securities are “commodity-linked” or “commodity-related.” To the extent that LCM’s strategies invest in commodities-related investments, it will be subject to additional risks. For example, the value of ETFs that invest in commodities, such as gold, silver, oil or agricultural products, are highly dependent on the prices of the related commodity. The demand and supply of these commodities may fluctuate widely based on such factors as interest rates, investors’ expectation with respect to the rate of inflation, currency exchange rates, the production and cost levels of the producing countries and/or forward selling by such producers, global or regional political, economic or financial events, purchases and sales by central banks, and trading activities by hedge funds and other commodity funds. Commodity-related ETFs may use derivative instruments, such as futures, options, swaps and structured notes, which exposes them to further risks, including counterparty risk (i.e., the risk that the institution on the other side of the trade will default).
Foreign Securities Risk. Foreign securities can be more volatile than domestic (U.S.) securities. Securities markets of other countries are generally smaller than U.S. securities markets. Many foreign securities may also be less liquid than U.S. securities, which could affect the investments LCM’s makes on your behalf.
Small and Medium Cap Company Risk. Stocks of small- and mid-cap companies are more risky than stocks of larger companies. Many of these companies are young and have a limited track record. Their securities may trade less frequently and in more limited volume than those of more mature companies. As a result, small- and mid-cap stocks may be significantly more volatile than larger-cap stocks. Small- and mid-cap companies also may lack the managerial, financial or other resources necessary to implement their business plans or succeed in the face of competition. The prospects for a company or its industry may deteriorate because of a variety of factors, including disappointing operating results or changes in the competitive environment. It may be difficult to sell a small- or mid-cap stock, and this lack of market liquidity can adversely affect LCM’s ability to realize the market price of a stock, especially during periods of rapid market decline.
Sector Risk. From time to time, LCM’s strategies may invest a significant amount of its total assets in certain sectors, which may be subject to specific risks. These risks include governmental regulation of the sector and governmental monetary and fiscal policies that impact interest rates and currencies and affect corporate funding and international trade. Certain sectors may be more vulnerable than others to these factors. In addition, market sentiment and expectations toward a particular sector could affect a company’s market valuation and access to equity funding.
Other risks. While the following list is not meant to be exhaustive, LCM has identified the following additional risks that Clients should consider when investing with LCM.
- Portfolio Turnover
- Market Risk
- Style Risk
- Value Risk
- Company Risk
- Dependence on LCM’s key personnel
Risk of Loss. Investments in LCM’s investment strategies may be highly speculative. LCM may not be successful in meeting their performance objectives. Clients should not invest with LCM unless they can bear the risk of a substantial loss of their assets. There is no assurance that LCM will be able to generate returns or that the returns will be commensurate with the risks inherent in their investment strategies. The past investment performance of LCM cannot be taken to guarantee future results.
Item 9: Disciplinary Information
- LCM may trade for its clients in securities that are included in the newsletters. However, despite such policy, LCM is aware of the conflicts of interest that may arise when trading securities for advisory clients that are recommended in the newsletters. LCM will, at all times, strive to act in the best interest of its advisory.
- Leeb and Mr. Chan will only cover securities in the publications that they believe fit within the objectives of certain model portfolios that are developed solely for publications. The securities recommended in the newsletters will not be based solely on investments LCM has made on behalf of its advisory clients.
Item 10: Other Financial Industry Activities and Affiliations
LCM is not and does not have a related person that is a broker/dealer, municipal securities dealer, government securities dealer or broker, an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), another investment adviser or financial planner, a futures commission merchant, commodity pool operator, or commodity trading advisor, a banking or thrift institution, an accountant or accounting firm, a lawyer or law firm, an insurance company or agency, a pension consultant, a real estate broker or dealer, and a sponsor or syndicator of limited partnerships.
We are an independent registered investment adviser and only provide investment advisory services. We are not engaged in any other business activities and offer no other services except those described in this Disclosure Brochure.
Dr. Stephen Leeb is the Editor of the Turbulent Times Investor (TTI) online newsletter. Dr. Leeb and Portfolio Manager Kuen Chan contribute content to the newsletters on a regular basis. The following policies and procedures have been adopted by LCM with respect to the potential conflict that may arise between managing client assets and contributing to a financial advisory newsletter:
Noting that the investment parameters of newsletter subscribers may differ from those of LCM’s clients, it is possible that LCM may act on behalf of LCM’s clients in a manner contrary to the recommendations provided in the newsletter subscribers.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
The LCM Code of Ethics (the “Code”) is designed to ensure that LCM upholds its fiduciary duty to clients and that no LCM employee will improperly trade ahead of client accounts or take an investment opportunity which could otherwise go to a client. The Code requires that all employee trades, unless specifically exempted by the Code, be approved prior to execution by LCM’s Chief Compliance Officer or his designee. The Chief Compliance Officer or his designee may reject any proposed trade that (i) involves a security which is being purchased or sold by LCM on behalf of any of its clients or is being considered for purchase or sale; (ii) involves a security of limited availability which may be suitable for a client account, (iii) is a prohibited trade (as discussed below); (iv) is otherwise inconsistent with applicable law; or (v) creates an appearance of impropriety. The Chief Compliance Officer or his designee may consider whether the trade creates an appearance of impropriety if such trade involves: (i) an initial public offering; (ii) a private placement; (iii) short-term trading; or (iv) other factors the Chief Compliance Officer deems relevant.
Prohibited trades are designed to prevent employees from improperly trading ahead of client accounts. An employee is subject to restrictions when purchasing (or selling) a security if that security or a related security is being recommended for purchase (or sale) in a newsletter published by an affiliated company of LCM, but only if an LCM employee is directly responsible for the recommendation. No employee shall cause or attempt to cause any client to purchase, sell or hold any security in a manner intended to create any personal benefit to the employee.
Certain trades are not subject to specific reporting provisions of the Code. These transactions are (i) purchases or sales effected in any account over which the employee has no direct or indirect influence or control; (ii) purchases that are part of an automatic dividend reinvestment plan; and (iii) purchases and sales of certain securities (shares of any open-end mutual fund not advised or underwritten by LCM, United States Government securities, bankers’ acceptances, repurchase agreements, bank certificates of deposit, and commercial paper).
LCM has adopted a Statement of Policy on Material Non-Public Information (“Statement”) which addresses the Insider Trading and Securities Fraud Enforcement Act of 1988, a law that provides significant sanctions for all abuses of material, non-public information. The Statement applies to all employees of LCM and any natural person who obtains information concerning recommendations made to any of LCM’s clients’ accounts with regard to the purchase or sale of a security. The Statement forbids any LCM employee, while in possession of material, non-public information, from trading securities or recommending transactions, either personally or on behalf of others (including any LCM client account), or from communicating material, non-public information to others in violation of applicable securities laws.
The Code is available to clients upon request by contacting LCM at the address or telephone number listed on the first page of this document.
Item 12: Brokerage Practices
a. Directed Brokerage Arrangements
There is one form of directed brokerage utilized by LCM clients, as set forth below.
Client selects a broker-dealer for execution of transactions
Certain clients direct LCM to utilize a specified broker-dealer for all securities transactions in that client's account. LCM generally does not negotiate commission rates with broker-dealers when a client directs LCM to execute securities transactions. Clients should be aware that the broker-dealer to which they direct their brokerage transactions may charge commissions that are higher than those available to other clients of LCM. Therefore, a client may pay higher commission rates, and may not receive the best executions, depending upon his or her arrangement with the broker-dealer.
b. Brokerage/Custodial Relationships Maintained by LCM
LCM has entered into arrangements with Charles Schwab & Co., Inc., which provide institutional custody and brokerage services to independent money managers like LCM. Under the arrangements, Schwab provides LCM’s clients with custodial, brokerage and reporting capabilities. Accordingly, LCM recommends the aforementioned custodians/brokers to clients that are seeking such services.
However, in each case, the client is empowered to determine the custodian/broker of their choice. Advisory accounts are generally solely traded through the brokers that custody each account (provided that the custodians are also broker-dealers), including fixed-income securities. When trading fixed-income securities solely through the custodian of an advisory account, the custodian may not have the security in its inventory, and therefore may be required to purchase the security in the market (or find a buyer for the security in the market) which would generally increase the costs associated with the transaction.
c. Schwab Brokerage/Custodial Relationship
As noted, LCM recommends, as one of their custodian choices, that clients establish brokerage accounts with Schwab, a registered broker-dealer, Member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. LCM is independently owned and operated and not affiliated with Schwab. Schwab provides LCM with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the advisor’s clients' assets are maintained in accounts at Schwab Institutional, and are not otherwise contingent upon Advisor committing to Schwab any specific amount of business (assets in custody or trading). Schwab services include brokerage, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment.
For LCM’s client accounts maintained in its custody, Schwab generally does not charge separately for custody but is compensated by account holders through commissions or other transaction-related fees for securities trades that are executed through Schwab or that settle into Schwab accounts.
Schwab also makes available to LCM other products and services that benefit LCM but may not benefit its clients’ accounts. Some of these other products and services assist LCM in managing and administering clients’ accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of LCM’s fees from its clients’ accounts, and assist with back-office functions, recordkeeping and client reporting. Many of these services generally may be used to service all or a substantial number of LCM’s accounts, including accounts not maintained at Schwab. Schwab also makes available to LCM other services intended to help LCM manage and further develop its business enterprise. These services may include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. Schwab may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to LCM.
While as a fiduciary, LCM endeavors to act in its clients’ best interests, LCM’s recommendation that clients maintain their assets in accounts at Schwab may be based in part on the benefit to LCM of the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest.
d. Order Aggregation
Transactions made in managed accounts are generally affected independently, unless we decide to purchase or sell the same securities for multiple clients at approximately the same time. This process is referred to as aggregating orders, batch trading or block trading and may be used when we believe such action may prove advantageous to clients. LCM, however, shall not aggregate transactions unless it believes such aggregation will result in the best overall execution for all participating clients and is consistent with the terms of the applicable investment advisory agreement. Furthermore, no client account will be favored by LCM over any other account.
LCM may place aggregate orders with multiple broker-dealers during a given trading day. Clients will receive the average price obtained by their respective broker-dealer through which their transaction was placed and pay their pre-negotiated commission rate (or minimum ticket charge). Multiple aggregate orders may be placed through a broker-dealer on any given day; in such cases clients will generally receive the average price of each aggregate order.
LCM’s books and records will separately reflect, for each account of a client whose orders are aggregated, the securities held by, and bought and sold for, each account. Funds and securities of clients whose orders are aggregated will be deposited with one or more banks or broker-dealers, and neither the clients’ cash nor their securities will be held collectively for the clients 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 will be delivered out to the bank or broker-dealer having custody of the client’s account as soon as practicable following settlement. LCM will receive no additional compensation or remuneration of any kind as a result of the aggregation procedure.
e. Partial Fills
LCM will compose, before entering an aggregated order, a written statement (the “Allocation Statement”). If the aggregated order is filled in its entirety, it shall be allocated among the accounts in accordance with the Allocation Statement. If the order is partially filled, it shall not be allocated pro rata based on the Allocation Statement. Instead, LCM will first distribute stocks to clients with less than 500 shares to prevent odd lots and increased confirmation and commission fees. The remainder of clients will have their orders filled when the rest of the trade is executed. The order may be allocated on a basis different from that specified in the Allocation Statement if all accounts of clients whose orders are allocated receive fair and equitable treatment and the reason for such different allocation is explained in writing and is approved in writing by the LCM’s Chief Compliance Officer no later than one (1) hour after the opening of the markets on the trading day following the day on which the order is executed. If an aggregated order is partially filled and allocated on a basis different from that specified in the Allocation Statement, no account that is benefited by such different allocation may affect any purchase or sale, for a reasonable period following the execution of the aggregated order, that would result in it receiving or selling more shares than the amount of shares it would have received or sold had the aggregated order been completely filled.
f. Trade Errors
LCM’s trade error correction policy specifies that advisory clients are not responsible for the payment of trade errors committed by LCM in relation with its management of client accounts. Certain client custodians, such as Schwab, have developed policies whereby the custodian/broker pays for client trade error losses below $100, and keeps any gains that result from trade errors in LCM client accounts. In such instances, neither LCM nor LCM’s advisory clients will be entitled to gains that result from trade errors, instead the gains would be kept by the client’s custodian/broker. LCM is responsible for covering trade error losses of more than $100.
g. Trading Costs
Clients should be aware that trading costs will vary depending on their brokerage/custodial arrangements. LCM periodically reviews its brokerage arrangements to ensure that clients are receiving benefits that are commensurate with the trading and custodial costs. Finally, clients should be aware that over-the-counter transactions may result in the payment of commissions in addition to mark-ups/mark-downs.
h. Timing of Transactions Relative to Newsletter Publications
As noted, certain employees of LCM write content for Turbulent Times Investor that may discuss/recommend companies that also may be appropriate for investment by LCM’s clients. When trading securities of companies that are discussed/recommended in the newsletters to which LCM employees contribute content, in keeping with its fiduciary duty owed to advisory clients, LCM will generally transact in the securities prior to the release of the newsletter content.
Item 13: Review of Accounts
Client accounts are typically monitored on a daily basis by LCM’s Portfolio Managers and are regularly reviewed by Dr. Leeb and Chan using a variety of techniques. In addition, on a periodic basis, client securities are reviewed fundamentally and technically and upon the occurrence of any significant developments with respect to the issuer or its industry.
In addition to the monthly statement provided to each client by the broker that holds the client’s funds and securities, LCM typically provides clients with information regarding their accounts through written reports. The frequency of the reporting is normally quarterly but varies depending upon the client’s wishes. The information provided to clients by LCM may include portfolio appraisals, account performance information and other information that may be requested by a client from time to time.
Item 14: Client Referrals and Other Compensation
a. Additional Compensation
As noted in the Brokerage Practices section above, LCM participates in and recommends to clients the brokerage/custodial service programs of Schwab. While there is no direct linkage between the investment advice given and participation in the programs, economic benefits are received which would not be received if LCM did not participate in the programs. These benefits may include: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk serving program participants exclusively; the ability to have investment advisory fees deducted directly from client accounts; access to an electronic communication network for client order entry and account information; receipt of various publications; proprietary research; and participation in broker/custodian-sponsored conferences. LCM understands that the benefits received through its participation in the programs generally do not depend upon the amount of transactions directed to, or amount of assets custodied by, the service program sponsors.
b. WiserAdvisor
LCM has entered into an agreement with WiserAdvisor to be listed on their electronic referral and listing service through its website located at https://www.wiseradvisor.com. Through this website users can research and be contacted by qualified financial professionals, such as financial advisors, financial planners, accountants, investment advisors, and insurance professionals, including LCM.
WiserAdvisor does not recommend one specific financial professional to a user. Instead, it provides users with one or more financial professionals who meet the user’s criteria. Users must evaluate and choose on their own the financial professional with whom they would like to work after reviewing the information provided by WiserAdvisor about the financial professional or by reviewing the financial professional’s credentials through the WiserAdvisor website. WiserAdvisor is not responsible for determining or reviewing any advice a financial professional provides to a user.
For WiserAdvisor services, WiserAdvisor charges LCM a monthly membership subscription as well as a per-lead fee for each qualified lead containing user contact information. A link to this Form ADV Part 2A can be found on our WiserAdvisor profile, and the link is also emailed by WiserAdvisor to users interested in our services and can also be found on our WiserAdvisor directory-profile. There are no charges for users to use the services of WiserAdvisor.
WiserAdvisor users are never required or obligated to work with or use the services of LCM. The selection of an investment adviser is important and should not be based solely on marketing or referrals, including introductions from WiserAdvisor. Individuals that find us through WiserAdvisor are free to work with any investment adviser or financial professional of their own choosing.
c. Solicitors
Other than our arrangement with WiserAdvisor, LCM does not directly or indirectly compensate any other person for client referrals.
Item 15: Custody
Custody, as it applies to investment advisors, has been defined by regulators as having access or control over clients’ funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment advisor has the ability to access or control client funds or securities, the investment advisor is deemed to have custody and must ensure proper procedures are implemented.
LCM is deemed to have custody of client funds and securities whenever LCM is given the authority to have fees deducted directly from client accounts. However, this is the only form of custody we will ever maintain. It should be noted that authorization to trade in client accounts is not deemed by regulators to be custody.
For accounts in which we are deemed to have custody, the Firm has established procedures to ensure all client funds and securities are held at qualified custodian in a separate account for each client under the client’s name. You, or an independent representative of yours, will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. You should carefully review those statements and are urged to compare the statements against reports received from LCM. When you have questions about your account statements, you should contact us, or the qualified custodian preparing the statement.
Item 16: Investment Discretion
LCM generally manages client accounts on a fully discretionary basis, which is granted to LCM through the execution of a limited power of attorney included in LCM’s advisory agreement.
When discretionary authority is granted, we will have the authority to determine the type of securities and the amount of securities that can be bought or sold for your portfolio without obtaining your consent for each transaction.
Provisions for discretionary trading will be memorialized, in writing, in our Asset Management Services-client agreement.
Notwithstanding, LCM may manage a limited number of client accounts on a non-discretionary basis. If you decide to grant trading authorization on a non-discretionary basis, we will be required to contact you prior to implementing changes in your account. Therefore, you will be contacted and required to accept or reject our investment recommendations including:
- The security being recommended
- The number of shares or units
- Whether to buy or sell
Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing of buying or selling an investment and the price at which the investment is bought or sold. If your accounts are managed on a non-discretionary basis, you need to know that if we are not able to reach you or you are slow to respond to our request, it can have an adverse impact on the timing of trade implementations, and we may not achieve the optimal trading price.
As always, client assets are managed on an individual basis based upon the specific investment objectives and constraints of the client. You will have the ability to place reasonable restrictions on the types of investments that can be purchased in your Account. You can also place reasonable limitations on the discretionary power granted to LCM so long as the limitations are specifically set forth or included as an attachment to the client agreement.
Item 17: Voting Client Securities
LCM does not vote proxies on behalf of Clients. We have determined that taking on the responsibilities for voting client securities does not add enough value to the services provided to you to justify the additional compliance and regulatory costs associated with voting client securities. Therefore, it is your responsibility to vote all proxies for securities held in Account.
You will receive proxies directly from the qualified custodian or transfer agent; we will not provide you with the proxies. You are encouraged to read through the information provided with the proxy-voting documents and make a determination based on the information provided.
Although we do not vote client proxies, if you have a question about a particular proxy feel free to contact us. However, you will have the ultimate responsibility for making all proxy-voting decisions.
Item 18: Financial Information
Leeb Capital Management, Inc.
Form ADV Part 3: Relationship Summary
The Brochure Supplement
Introduction
Leeb Capital Management, Inc. (“LCM”) is registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser. Clients and prospective clients should be aware that services and fees differ between investment advisers and broker-dealers and it is important for retail investors to understand the differences. Free tools are available to research advisory firms at investor.gov/CRS, which also provides educational materials about broker-dealers, investment advisers and investing.
What investment services and advice can you provide me?
LCM offers investment supervisory services which involves LCM providing you with continuous and ongoing supervision over and management of your specified accounts (collectively, the “Account”). As part of the service, we actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account, and we execute trades.
LCM offers its services on a discretionary basis, meaning we will have the authority to determine the type and amount of securities that can be bought or sold for your portfolio without obtaining your consent for each transaction. You must appoint our firm as your investment adviser of record on the Account and grant us the authority to determine the assets to purchase or sell in the Account. However, you will have the ability to place reasonable restrictions on management of the Account, such as the types of investments that can be purchased in your Account. The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. The Account is managed by us based on your financial situation, investment objectives and risk tolerance.
LCM’s investment supervisory services focus on the selection of domestic and foreign stocks but also may include bonds, options, mutual funds, annuities and money market funds. We currently offer three main investment strategies, focused on growth, income, and natural resources. Please refer to LCM’s ADV Part 2A, Item 8 for more information about each strategy.
Requirements to open and maintain an account: LCM generally requires discretionary separately managed accounts to have a minimum account value of $250.000 or $100,000, depending on the strategy. However, in certain cases, at its discretion, LCM will waive this requirement.
Additional Information: Additional information on relationships, fees and services can be found in the LCM Form ADV, Part 2A (items 4-7) which is available on our website at www.leeb.net.
Conversation Starter - Given my financial situation, should I choose an investment advisory service? Why or why not? How will you choose investments to recommend to me? What is your relevant experience including your licenses, education, and other qualifications? What do these qualifications mean?
What fees will I pay?
Principal Fees and Costs: LCM management fees for discretionary accounts are based on a percentage of the value of the assets in your separately managed account for which we are providing services. The annual fee for investment supervisory services will be based upon a fee schedule which generally ranges between 1.00% and 2.00% depending on the strategy used to manage your account. Please refer to LCM’s ADV Part 2A, Item 5 for more information. LCM retains full authority to negotiate the fees it charges for discretionary advisory services. LCM fees are generally payable quarterly in advance, and calculated based on the ending AUM in the preceding quarter.
LCM’s fees are exclusive of brokerage commissions, wrap program fees, transaction fees, custodial fees, deferred sales charges, exchange fees, SEC fees, transfer taxes, wire transfer, electronic fund fees, and other related costs and expenses which are incurred by the client from custodians, brokers, third-party advisor and other third parties.
Additional Information: You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. Additional information can be found in the LCM Form ADV, Part 2A, which is available on our website http://leeb.net.
What are your legal obligations to me when acting as my investment adviser? How else does your firm make money and what conflicts of interest do you have?
Standard of Conduct: When LCM acts as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. Here are some examples to help you understand what this means. For those discretionary accounts for which we also have discretion to select broker-dealers to execute transactions, Form ADV, Part 2A, Item 12 – Brokerage Practices describes the conflict of interest we have with respect to broker- dealers that provide us research and brokerage services. Additionally, because we charge a flat percentage fee based on asset under management, the higher the value of your account, the higher dollar amount in fee we would receive, so there is an incentive for LCM to recommend that you add more assets to your account. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. LCM has adopted a Code of Ethics describing its standards of business conduct, potential conflicts of interest and fiduciary duties. Additionally, Research Chairman Stephen Leeb and Portfolio Manager Kuen (Scott) Chan both write for an online subscription-based newsletter called Turbulent Times Investor, published by a company owned by Stephen Leeb. LCM may trade for its clients in securities that are included in the newsletters. However, despite such policy, LCM is aware of the conflicts of interest that may arise when trading securities for advisory clients that are recommended in the newsletters. LCM will, at all times, strive to act in the best interest of its advisory clients. Please see Form ADV, Part 2A, Item 10 for detailed information.
Conversation Starter - How might your conflicts of interest affect me, and how will you address them?
Additional information: Additional information on conflicts of interest can be found in our Form ADV, Part 2A (Items 7,8,10,11 and 12) which is on our website at www.leeb.net.
How do your financial professionals make money?
LCM personnel are compensated based on a yearly salary or an hourly wage, some are eligible for additional compensation for acquiring new clients for LCM.
Do you or your financial professionals have legal or disciplinary history?
No. LCM has not been subject to any disciplinary events by regulators nor is it a party to any legal events that are material to client evaluation of our advisory business. You can visit Investor.gov/CRS for free and simple search tools to research us and our financial professionals.
| Conversation Starter - As a financial professional, do you have any disciplinary history? For what type of conduct? |
Additional Information About LCM
Additional information about us and a copy of this relationship summary are available on the Internet at http://www.leeb.net/. If you have any questions about our services or if you wish to request a copy of the relationship summary, please contact Kuen (Scott) Chan at 212-400-2241 or schan@leeb.com. Additional information is also available on the SEC’s website at adviserinfo.sec.gov.
Conversation Starter – Who is my primary contact person? Is he or she a representative of an investment adviser or broker- dealer? Who can I talk to if I have concerns about how this person is treating me?
Please contact Esi Abaidoo, Assistant to the Portfolio Manager at (212) 653-1713. If you need further assistance or have concerns, please contact Portfolio Manager Kuen (Scott) Chan (212) 400-2241.
Summary of Changes for Leeb Capital Management ADV, Part 3 (Updated May 2026)
On page 2 of ADV Part 3, in response to how else LCM makes money and what conflicts of interest we have, previously we disclosed that we write for Capitol Information Group as independent contractors, we amended it to disclose that Stephen Leeb and Kuen (Scott) Chan now write for Turbulent Times Investor, an online newsletter published by a company owned by Stephen Leeb. Leeb and Chan no longer have any relationship with Capitol Information Group.
Also on page 2, in response to the question of how LCM’s financial professionals make money, we added that some employees are now eligible to receive additional compensation for acquiring new clients for LCM.
Effective April 2026, Stephen Perkins has retired. His contact information has been removed from ADV, Part 3. Esi Abaidoo, Assistant to the Portfolio Manager, has been added as the primary contact.
