Zales Investment Management, Inc

The firm provides fee‑only, discretionary portfolio management to individual clients and trusts, operating on an asset‑based billing model common among independent advisers. It manages approximately $22 million across a very small client roster and recommends custodians for client accounts while not taking physical custody of client funds.

Investment decisions are driven by fundamental, company‑level analysis — including review of filings, research reports and, when possible, company visits — and the strategy emphasizes long‑term holdings, generally planning to hold positions for at least ten years with a relatively small number of investments. Because the firm typically concentrates positions and allocates meaningful portions of a client’s net worth to each holding, the approach is suited to clients with higher tolerance for volatility and who seek concentrated, long‑horizon exposure.

Compared with peers, the firm is notable for its unusually small client base relative to assets under management, which can produce larger position sizes per client, and for the principal’s long tenure running the advisory practice. Other distinguishing operational features include a policy not to vote client proxies, no performance‑based or wrap fee programs, no soft‑dollar arrangements, and reliance on custodial account statements rather than firm‑calculated performance reporting.