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Graham, Bordelon, Golson & Gilbert, Inc.
2401 Tower Drive
Monroe, LA 71201
318.322.7157
Disclosure Brochure
February 26, 2025
This brochure provides information about the qualifications and business practices of
Graham, Bordelon, Golson & Gilbert, Inc. If you have any questions about the contents of
this brochure, please contact us at 318.322.7157.
The information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority.
Graham, Bordelon, Golson & Gilbert, Inc. is a registered investment adviser. Registration
of an investment adviser does not imply any level of skill or training. The oral and written
communications of an adviser provide you with information about which you determine to
hire or retain an adviser.
Additional information about Graham, Bordelon, Golson & Gilbert, Inc. also is available
on the SEC’s website at www.adviserinfo.sec.gov
Material Changes
There are no material changes to this ADV part 2A to report at this time.
Graham, Bordelon, Golson & Gilbert, Inc.
CRD Number 104612
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Table of Contents
Advisory Business .................................................................................................................................................... 4
Fees and Compensation .......................................................................................................................................... 5
Performance-Based Fees ....................................................................................................................................... 10
Types of Clients ..................................................................................................................................................... 10
Methods of Analysis, Investment Strategies and Risk of Loss .............................................................................. 10
Disciplinary Information ........................................................................................................................................ 12
Other Financial Industry Activities and Affiliations ............................................................................................... 12
Code of Ethics; Participation or Interest in Client Transactions and Personal Trading ......................................... 12
Brokerage Practices ............................................................................................................................................... 13
Review of Accounts ............................................................................................................................................... 16
Client Referrals and Other Compensation ............................................................................................................ 16
Custody .................................................................................................................................................................. 17
Investment Discretion ........................................................................................................................................... 17
Voting Client Securities ......................................................................................................................................... 17
Financial Information ............................................................................................................................................ 18
Wrap Brochure ...................................................................................................................................................... 19
Brochure Supplements .......................................................................................................................................... 33
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Advisory Business
Graham, Bordelon, Golson & Gilbert, Inc. (“Graham Bordelon, we, us, our”) is a
corporation organized under the laws of the State of Louisiana. Gary Graham and Richard
Bordelon co-founded the Monroe-based investment advisory firm in 1986. J. Clint Rider,
Micheal Gilbert, and Jeffrey Golson are the majority owners. Graham Bordelon is an SEC
registered investment advisory firm.
We offer investment supervisory management, financial planning, and consulting services.
Investment Management Services
We provide investment management services to you either by directly managing your
account ourselves or through Osaic Wealth, Inc. (“Osaic”), an unaffiliated, registered
broker-dealer and registered investment adviser. The Osaic Wealth Management Platform –
Advisor Managed Portfolios Program (“Advisor Managed Portfolios”) provides
comprehensive investment management of your assets through the application of asset
allocation planning software as well as the provision of execution, clearing and custodial
services through National Financial Services, Inc. (“NFS”).
Advisor Managed Portfolios provides risk tolerance assessment, efficient frontier plotting,
fund profiling and performance data, and portfolio optimization and re-balancing tools.
Utilizing these tools and based on your responses to a risk tolerance questionnaire
(“Questionnaire”) and discussions that you and your Advisory Representative have together
regarding, among other things, your personal investment objectives and goals, time
horizon, risk tolerance, account restrictions, needs, personal circumstances and overall
financial situation, we construct a portfolio of investments for you. Your Advisory
Representative has the option to allocate your portfolio amongst a mix of stocks, bonds,
options, exchange-traded funds, mutual funds and other securities (“Program
Investments”) which are based on your investment goals, objectives, and risk tolerance.
Each portfolio is designed to meet your individual needs, stated goals and objectives.
Additionally, you have the opportunity to place reasonable restrictions on the types of
investments to be held in the portfolio.
For further Advisor Managed Portfolios details, please see the Osaic Wealth Management
Platform Program Brochure. We provide this brochure to you prior to or concurrent with
your enrollment in Advisor Managed Portfolios. Please read it thoroughly before investing.
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Financial Planning and Other Consulting Services
We provide financial planning and business consulting services. In addition, we also furnish
advice to you on matters relating to tax matters and employee benefits plans. We will also
render advice to you on matters involving life insurance and disability insurance. In
addition, we will furnish advice on budgeting both business and personal. We will furnish
consulting services relating to your business on an as-needed basis.
In managing your investment portfolio, we consider your financial situation, risk tolerance,
investment horizon, liquidity needs, tax considerations, investment objectives, and any
other issues important to your state of affairs.
You should notify us promptly if there are any changes in your financial situation or
investment objectives or if you wish to impose any reasonable restrictions upon the
management of your account.
Assets Under Management
As of December 31, 2024, we managed $369,900,793 in client assets on a discretionary
basis for 323 accounts and 1 non-discretionary account with $5,102,002 in assets.
Fees and Compensation
We provide investment supervisory services based upon either an hourly fee, flat fee, or as
a percentage of assets under management. Under the hourly fee structure, you are billed at
an hourly rate of $100 - $350 depending on the complexity of the project. Under the flat
fee program, you will be quoted a fee in advance ranging from $250 to $25,000 annually
depending upon numerous factors including, but not limited to, the complexity of your
situation and the scope of the project.
In addition, we may perform investment supervisory services based upon a percentage of
assets being supervised. Our fee is calculated based upon the market value of the assets in
your account on the last day of the previous quarter. Our fees are charged quarterly, in
arrears.
Broker-dealers and other financial institutions that hold client accounts are referred to as
custodians (“custodian/ broker-dealer”). Your custodian/broker-dealer determines the
values of the assets in your portfolio.
Fees for Investment Management Services
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Fees for the initial quarter are based on the value of your cash and securities on the date the
custodian/broker-dealer receives them and are prorated based upon the number of
calendar days in the calendar quarter that our agreement is in effect. Our fee schedule is
described below:
Advisory Fee1
2.50%
2.00%
1.50%
1.00%
Assets under Management
Up to $250,000
$250,001 to $500,000
$500,001 to $1,000,000
Over $1,000,000
1All fees are negotiable at our sole discretion.
Osaic Wealth Management Platform – Advisor Managed Portfolios Program
We offer Advisor Managed Portfolios as an account where no separate transactions charges
apply and a single fee is paid for all advisory services and transactions ("Wrap Account").
The Wrap Account is asset-based pricing.
We also offer Advisor Managed Portfolios with separate advisory fees and transaction
charges (“Non-Wrap Account”). As such, in addition to the quarterly account fee described
below for advisory services, you will also pay separate per-trade transaction charges. The
Non-Wrap Account is transaction-based pricing.
You will pay a monthly or quarterly account fee, in advance, based upon the market value
of the assets held in your account as of the last business day of the preceding calendar
month or quarter. Your account fees are negotiable and will be debited from your account
by our custodian. If you terminate your participation in this program, you will be entitled to
a pro-rata refund of any prepaid monthly or quarterly fees based upon the number of days
remaining in the month or quarter after the date upon which the notice of termination is
received.
Our fee schedules are described below:
Advisory Fee1
2.50%
2.25%
2.00%
1.75%
Wrap Account
Assets under Management
$50,000 to $500,000
$500,001 to $2,000,000
$2,000,000 to $5,000,000
$5,000,001 and up
1All fees are negotiable at our sole discretion.
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Advisory Fee1
2.50%
2.25%
1.75%
1.50%
Non-Wrap Account
Assets under Management
$0 to $250,000
$250,001 to $750,000
$750,001 to $2,000,000
$2,000,001 and up
1All fees are negotiable at our sole discretion.
Mutual funds and ETFs invested in the account have their own internal fees which are
separate and distinct from the program account fees (for more information on these fees,
see the applicable fund prospectus).
Some Fund fees include 12b-1 fees which are internal distribution fees assessed by the
Fund, all or a portion of which are paid to the distributor(s) of the Funds. The Firm and
your Advisory Representative do not retain 12b-1 fees paid by the Funds.
In certain instances, there is opportunity to be eligible to purchase certain mutual funds and
ETFs without incurring transaction charges subject to certain conditions. For details, please
refer to Item 4 (No Transaction Fee Programs) of the Osaic Advisor Managed Portfolios
wrap fee brochure.
For complete fee details, including account fee schedule guidelines and a list of transaction
charges, please see the Osaic Advisor Managed Portfolios Wrap Fee Program Brochure.
You must authorize us to have the custodian/broker-dealer pay us directly by charging your
account. This authorization must be provided in writing. One-fourth of the annual fee is
charged each calendar quarter.
We send a statement that includes the value of your investments, our advisory fee, and how
it is calculated. Your custodian/broker-dealer also provides you with statements that show
the amount paid directly to us. You should compare the statement we send to your
custodian/broker-dealer’s statement and verify the calculation of our fees. Your
custodian/broker-dealer does not verify the accuracy of fee calculations. When
recommending mutual funds that have multiple share classes, we will take into account the
internal fees and expenses associated with each share class, and select the most cost
effective share class that still meets the client’s needs and objectives and is available to the
client.
Fees for Financial Planning and Other Consulting Services
We provide financial planning and business consulting based upon the hourly rate or a flat
fee quoted in advance. You may be asked to deposit an initial retainer for future services to
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be rendered regardless if services are to be rendered on an hourly or flat fee basis. In no
case will the retainer be held for more than six (6) months before services are rendered. If
an hourly rate is charged, services performed beyond the initial retainer will be billed every
30 to 90 days. If a flat fee is quoted, services beyond the initial retainer amount will be
billed at the completion of the engagement.
In addition to our fee, you will be required to pay other applicable charges such as custodial
fees, brokerage commissions, transaction fees, internal fees and expenses charged by
mutual funds or exchange traded funds (“ETFs”), and other fees and taxes on brokerage
accounts and securities transactions.
Mutual fund companies, ETFs, and variable annuity issuers charge internal fees and
expenses for their products. These fees and expenses are in addition to any advisory fees
charged by us. Complete details of these internal fees and expenses are explained in the
prospectuses for each investment. You are strongly encouraged to read these explanations
before investing any money. You may ask us any questions you have about fees and
expenses.
If you purchase mutual funds through the custodian/broker-dealer, you may pay a
transaction fee that would not be charged if the transactions were made directly through
the mutual fund company. Also, mutual funds held in accounts at brokerage firms may pay
internal fees that are different from funds held at the mutual fund company.
While you may purchase shares of mutual funds directly from the mutual fund company
without a transaction fee, those investments would not be part of our advisory relationship
with you unless they are specifically listed as part of the investment advisory agreement.
This means that they would not be included in our investment strategies, investment
performance monitoring, or portfolio reallocations absent an agreement or arrangement
stating otherwise.
Please be sure to read the section entitled “Brokerage Practices,” which follows later in this
brochure.
As noted above, you pay our fees for direct investment management quarterly in arrears.
You may terminate the agreement without penalty within 30 business days after the
execution of the agreement. Thereafter, you may terminate the agreement with us by giving
us written notice. Upon receiving the notice, we will bill you only for those services
rendered through the date the notice is received.
You must pay the advisory fees for the Osaic program in advance of receiving our services.
The advisory agreement for the Osaic program may be terminated by either party at any
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time by written notice. Should you terminate the advisory agreement for the Osaic program
within five (5) business days from the date the agreement is executed, you will receive a full
refund of any fees paid.
Thereafter, should you terminate the advisory agreement for the Osaic program, you will be
entitled to pro-rata refund of any prepaid quarterly fees based upon the number of days
remaining in the quarter upon the date the notice of termination is received. The amount
refunded to you is calculated by dividing the most recent advisory fee you paid by the total
number of days in the quarter. This daily fee is then multiplied by the number of calendar
days in the quarter that our agreement was in effect. This amount, which equals the amount
we earned for the partial quarter, is subtracted from the total fee you paid in advance to
determine your refund.
Retainers paid initially to us for financial planning and other consulting services are
refundable to you upon your giving us thirty (30) days written notice of termination of the
contract. The retainer will be refunded to you based upon our time spent through the
termination date multiplied by the current hourly charge.
Our advisory representatives are also registered representatives of Osaic, a registered
broker/dealer, member FINRA/SIPC, and registered investment adviser. If you choose to
implement your financial plan through Osaic, commissions may be earned by your financial
advisor in addition to any fees paid for advisory services. In addition, the financial advisor
will be entitled to receive a portion of the internal expense fees (such as 12b-1 fees) charged
by mutual funds on assets in a commission-based account. We no longer receive 12b-1
fees on assets subject to an investment management fee and evaluate any mutual funds
transitioned to our firm to ensure that the investment is converted to the lowest-cost share
class for which you are eligible, absent circumstances that dictate otherwise.
Our advisory representatives are also licensed with various insurance companies.
Commissions may be earned by our financial advisors if insurance products are purchased
through these insurance companies.
We may receive benefits such as assistance with conferences and educational meetings from
product sponsors.
Our advisory representatives may also recommend various asset management firms
through their affiliation with Osaic. If you establish an investment advisory relationship
with one of these firms, our financial advisory fee is in addition to fees the asset
management firm charges.
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The above arrangements present a conflict of interest because they create an incentive to
make recommendations based upon the amount of compensation we receive rather than
based upon your needs. We will explain the specific costs associated with any
recommended investments with you upon request. We also recommend no-load and load-
waived mutual funds to further reduce conflicts of interest. Additionally, you have the
option to purchase investment and insurance products through other brokers or agents
who are not affiliated with us.
Performance-Based Fees
Performance-based fees are designed to give a portion of the returns of an investment to
the investment adviser as a reward for positive performance. The fee is generally a
percentage of the profits made on the investments.
We do not charge performance-based fees for any of the services described in this
brochure.
Types of Clients
We provide advisory services primarily to high-net-worth individuals, including their trusts,
estates and retirement accounts. We also provide services to corporations or business
entities including their pension and profit-sharing plans and to charitable organizations.
Account minimums vary by the program used to manage your assets.
We, at our sole discretion, may accept clients with smaller portfolios based upon certain
factors including anticipated future earning capacity, anticipated future additional assets,
account composition, related accounts, and pre-existing client relationships. We may
consider the portfolios of your family members to determine if your portfolio meets the
minimum size requirement.
Methods of Analysis, Investment Strategies and Risk of Loss
We select specific investments for your portfolios through the use of fundamental analysis.
Fundamental analysis is a method of evaluating a company that has issued a security by
attempting to measure the value of its underlying assets. It entails studying overall
economic and industry conditions as well as the financial condition and the quality of the
company’s management. Earnings, expenses, assets, and liabilities are all important in
determining the value of a company. The value is then compared to the current price of the
issuing company’s security to determine whether to purchase, sell or hold the security.
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Cyclical analysis is a form of fundamental analysis that involves the process of making
investment decisions based on the different stages of an industry at a given point in time.
Although we manage your portfolio in a manner consistent with your risk tolerances, there
can be no guarantee that our efforts will be successful. You should be prepared to bear the
risk of loss.
Our investment strategies may include long-term and short-term purchases and sales, and
the use of margin. You may place reasonable restrictions on the strategies to be employed
in your portfolio and the types of investments to be held in your portfolio.
Although we manage your account in a manner we believe is consistent with your specific
investment objectives and risk tolerances, there can be no guarantee that our efforts will be
successful. General economic conditions, current interest rates, the performance of a
particular industry or a particular company, and any number of other factors can affect
investment performance.
You should be prepared to bear the risk of loss. All investments are subject to loss,
including (among other things) loss of principal, a reduction in earnings (including interest,
dividends and other distributions), and the loss of future earnings.
You must also be aware that the use of margin is a higher risk strategy. It is possible to lose
all of the principal you invest, and sometimes more. In a cash account, your risk is limited
to the amount of money that you have invested. In a margin account, your risk includes the
amount of money invested plus the amount that has been loaned to you. We do not use or
recommend the use of margin as part of our account management.
You should also be aware that transactions in the account (including account reallocations
and rebalancing) may trigger a taxable event for you (unless your account is a qualified
retirement account).
You should also be aware that client accounts may have cash balances in excess of
$250,000, which is the insurance limit of the Federal Deposit Insurance Corporation. For
cash balances in excess of that amount, there is an enhanced risk that operation related
counterparty risk related to the account custodian could cause losses in the account. We
mitigate this risk by carrying cash balances in amounts either subject to protection or as
limited as you, the client, directs. You may elect to participate in a “cash sweep” program
through your account custodian which automatically moves excess cash from your
investment account into a cash account and then invests that cash into cash based
investments, such as money market funds. We do not receive compensation of any kinds
for facilitating your participation in such cash sweep accounts.
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Disciplinary Information
Graham, Bordelon, Golson & Gilbert, Inc. was subject to an administrative proceeding as
of September 10, 2020 pertaining to the receipt of 12b-1 fees, mutual fund share class
selection and the appropriate disclosures concerning such items. The SEC accepted a
settlement offer from Graham, Bordelon, Golson & Gilbert, Inc. The full order can be
found at https://www.sec.gov/litigation/admin/2020/ia-5576.pdf.
Other Financial Industry Activities and Affiliations
As explained under “Fees and Conditions” above, our advisory representatives are also
licensed as registered representatives with Osaic. They are also licensed as insurance agent
with various insurance companies. These arrangements present a conflict of interest
because they create an incentive to make recommendations based upon the amount of
compensation your advisory representative can receive rather than based upon your needs.
As previously noted, we will explain the specific costs associated with any recommended
investments with you upon request. We also recommend no-load and load-waived mutual
funds to further reduce conflicts of interest. You have the option to purchase investment
and insurance products through other brokers or agents who are not affiliated with us.
Our advisory representatives may also recommend various asset management firms
through their affiliation with Osaic. If you establish an investment advisory relationship
with one of these firms, our financial advisors may share in the advisory fees you pay to
these asset management firms.
Our principal executive officers and advisory representatives are also registered with
EnTrust Investment Management, LLC (“EnTrust”), a registered investment advisory firm.
They spend approximately 20% of their time on this activity. We own 100% of EnTrust,
which shares space with us and is managed by the same principals. The services offered by
EnTrust are similar to the services we offer.
Code of Ethics; Participation or Interest in Client Transactions and
Personal Trading
We have adopted a Code of Ethics (“Code”) to address the securities-related conduct of
our advisory representatives and employees. The Code includes our policies and procedures
developed to protect your interests in relation to the following:
the duty at all times to place your interests ahead of ours;
that all personal securities transactions of our advisory representatives and
employees be conducted in a manner consistent with the Code and avoid any
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actual or potential conflict of interest, or any abuse of an advisory
representative’s or employee’s position of trust and responsibility;
that advisory representatives may not take inappropriate advantage of their
positions;
that information concerning the identity of your security holdings and financial
circumstances are confidential; and
that independence in the investment decision-making process is paramount.
We will provide a copy of the Code to you or any prospective client upon request.
We do not buy or sell securities for our firm that we also recommend to clients. Our
advisory representatives and employees are permitted to buy or sell the same securities for
their personal and family accounts that are bought or sold for your account(s). The
personal securities transactions by advisory representatives and employees may raise
potential conflicts of interest when they trade in a security that is owned by you or
considered for purchase or sale for you.
We have adopted policies and procedures that are intended to address these conflicts of
interest. These policies and procedures:
require our advisory representatives and employees to act in your best interest,
prohibit favoring one client over another, and
provide for the review of transactions to discover and correct any same-day
trades that result in an advisory representative or employee receiving a better
price than a client.
Advisory representatives and employees must follow our procedures when purchasing or
selling the same securities purchased or sold for you.
Brokerage Practices
We may recommend that the broker-dealer for your account be Osaic as introducing
broker and NFS as executing broker and custodian. Osaic and NFS will assist us in
servicing your accounts. We are independently owned and operated and our firm is not
affiliated with Osaic or NFS. Our use of these firms is, however, a beneficial business
arrangement for us and for them. Information regarding the benefits of this relationship is
described below.
In recommending NFS as the custodian and as the securities brokerage firm responsible for
executing transactions for your portfolios, we consider at a minimum NFS’s existing
relationship with us, financial strength, reputation, breadth of investment products; and, the
cost and quality of custody and brokerage services provided to you and our other clients.
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The determining factor in the selection of NFS to execute transactions for your accounts is
not the lowest possible transaction cost, but whether NFS can provide what is in our view
the best qualitative execution for your account.
Osaic and NFS provide us with access to their institutional trading and custody services,
which 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.
We are not required to effect a minimum volume of transactions or maintain a minimum
dollar amount of client assets to receive these services.
NFS does not charge separately for holding our clients’ accounts, except for IRA accounts,
but may be compensated by you through other transaction-related fees associated with the
securities transactions it executes for your accounts.
Osaic and NFS also make available to us other products and services that benefit us but
may not benefit you directly. Some of these products and services assist us in managing and
administering our client accounts. Other services they may offer are intended to help us
manage and further develop our business.
Osaic and NFS may also make available or arrange for these types of services to be
provided to us by independent third parties. NFS may discount or waive the fees it would
otherwise charge for some of the services it makes available to us. It may also pay all or a
part of the fees of a third party providing these services to us. Thus, we receive economic
benefits as a result of our relationship with NFS, because we do not have to produce or
purchase the products and services listed above.
Because the amount of our compensation or the products or services we receive may vary
depending on the custodian and broker-dealer we recommend to be used by our clients, we
may have a conflict of interest in making that recommendation. Our recommendation of
specific custodian and broker-dealer may be based in part on the economic benefit to us
and not solely on the nature, cost or quality of custody and brokerage services provided to
you and our other clients. We nonetheless strive to act in your best interests at all times.
Commissions and other fees for transactions executed through Osaic and NFS may be
higher than commissions and other fees available if you use another custodian/broker-
dealer firm to execute transactions and maintain custody of your account. We believe,
however, that the overall level of services and support provided to our clients by Osaic and
NFS outweighs the benefit of possibly lower transactions cost which may be available
under other brokerage arrangements.
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Many of the services described above may be used to benefit all or a substantial number of
our accounts, including accounts not maintained at NFS. We do not attempt to allocate
these benefits to specific clients.
Directed Brokerage
You may direct us in writing to use a particular broker-dealer to execute some or all of the
transactions for your account. If you do so, you are responsible for negotiating the terms
and arrangements for the account with that broker-dealer. We may not be able to negotiate
commissions, obtain volume discounts, or best execution. In addition, under these
circumstances a difference in commission charges may exist between the commissions
charged to clients who direct us to use a particular broker or dealer and other clients who
do not direct us to use a particular broker or dealer.
Block Trading
We may engage in block trading, which is the purchase or sale of a security for the accounts
of multiple clients in a single transaction. If a block trade is executed, each
participating client receives a price that represents the average of the prices at which all of
the transactions in a given block were executed. Accounts that participate in the same block
trade will be charged commissions, if applicable, in accordance with their advisory
contracts. Different accounts participating in a block transaction may not be charged the
same commission rates. If the order is not completely filled, the securities purchased or
sold are distributed among participating clients on a pro rata basis or in some other
equitable manner.
Block trades are placed only when we reasonably believe that the combination of the
transactions provides better prices for clients than had individual transactions been placed
for clients. Transactions for nondiscretionary client accounts are not aggregated with
transactions for discretionary client accounts. Transactions for the accounts of our
employees and advisory representatives may be included in block trades. They receive the
same average price and pay the same commissions and other transaction costs, as clients.
Transactions for the accounts of our advisory representatives or employees will not be
favored over transactions for client accounts.
We are not obligated to include any client account in a block trade. Block trades will not be
effected for any client’s account if doing so is prohibited or otherwise inconsistent with that
client’s investment advisory agreement. No client will be favored over any other client.
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Review of Accounts
All client accounts are monitored on an ongoing basis with a formal review conducted at
least annually or as agreed upon with individual clients. The reviews focus on the
consistency of portfolio investments with each client’s stated objectives and risk tolerances.
Reviews also consider investment restrictions requested by individual clients, investment
time horizons, liquidity needs, tax considerations and other circumstances unique to each
client.
On a quarterly basis, the performance of each client account is reviewed to monitor
consistency with market benchmarks that we deem applicable. Account reviews may also
be triggered by other factors such as changes in general economic and market conditions,
analyst reports, issuer news and interest rate movement. Your advisory representative is
responsible for all reviews.
You will receive statements from the custodian/broker-dealer at least quarterly. These
statements identify your current investment holdings, the cost of each of those investments,
and their current market values. If you elect to receive quarterly performance reporting,
you will also receive performance analysis reports prepared by us which describe the
returns realized on the investments in your account.
Client Referrals and Other Compensation
We do not directly or indirectly compensate any person who is not one of our advisory
representatives or employees for client referrals.
We receive certain economic benefits as a result of our participation in NFS’s institutional
program. Those benefits are described in detail in the preceding section entitled “Brokerage
Practices.”
Individuals associated with Graham, Bordelon, Golson and Gilbert, Inc. have received
compensation from the broker-dealer in addition to commissions paid due to the long-time
affiliation with the broker-dealer. This presents a conflict of interest as it incentivizes the
registered representatives affiliated with the broker-dealer to continue to do business with
the broker-dealer because of the personal financial benefit. We attempt to mitigate this
conflict of interest by disclosing it to the public and requiring investment advisor
representatives that are also registered representatives of the broker-dealer to adhere to our
Code of Ethics.
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Custody
Your assets are maintained with a qualified custodian. We do not have physical custody of
your assets but may be deemed to have custody when you authorize us to deduct our fees
from your account. You will receive statements from the custodian/broker-dealer that
holds your investment account on at least a quarterly basis. We urge you to carefully review
these statements and compare them to the account statements that we may provide you.
You should verify that the transactions in your account are consistent with your investment
goals and the objectives for your account.
We also encourage you to contact your advisory representative or our Chief Compliance
Officer should you have any questions or concerns regarding your account.
Investment Discretion
As previously noted, we offer our advisory services on a discretionary basis (meaning that
we do not need advance approval from you to determine the type and amount of securities
to be bought and sold for your account) and on a non-discretionary basis (meaning that we
need advance approval from you to determine the type and amount of securities to be
bought and sold for your accounts).
We may only exercise discretion if you have provided that authority to us in writing. This
authorization is typically included in the investment advisory agreement you enter into with
us.
The discretionary authority you grant to us does not provide us the ability to choose the
custodian through whom transactions for your account will be executed or to negotiate
brokerage fees or expenses. Additionally, our discretionary authority does not provide us
the ability to withdraw funds from your account (other than to withdraw our advisory fees
which may only be done with your prior written authorization).
We will exercise discretion in a manner consistent with the stated investment objectives for
your account.
Voting Client Securities
We do not take any action or give any advice with respect to voting of proxies solicited by
or with respect to the issuers of securities in which your accounts may be invested. In
addition, we do not take any action or give any advice with respect to any securities held in
any accounts that are named in or subject to class action lawsuits. We will, however,
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forward to you any information received by us regarding proxies and class action legal
matters involving any securities held in your accounts.
Financial Information
We have no financial commitment that impairs our ability to meet contractual and fiduciary
commitments to you and we have not been the subject of a bankruptcy proceeding.
On May 5, 2020, Graham, Bordelon, Golson, and Gilbert, Inc. received a Paycheck
Protection Plan Loan through the SBA in the amount of $86,692 in conjunction with the
relief afforded under the CARES Act. GBGG used the PPP loan proceeds in accordance
with the terms of the loan program and the firm did not suffer any interruption of service.
The participation in the PPP did not constitute a material event for GBGG.
18 | P a g e
Graham, Bordelon, Golson & Gilbert, Inc.
2401 Tower Drive
Monroe, LA 71201
318.322.7157
Form ADV Part 2A Appendix 1
Wrap Fee Program Brochure
February 26, 2025
This brochure provides information about the qualifications and business practices of
Graham, Bordelon, Golson & Gilbert, Inc. If you have any questions about the contents of
this brochure, please contact us at 318.322.7157.
The information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority.
Graham, Bordelon, Golson & Gilbert, Inc. is a registered investment adviser. Registration
of an investment adviser does not imply any level of skill or training. The oral and written
communications of an adviser provide you with information about which you determine to
hire or retain an adviser.
Additional information about Graham, Bordelon, Golson & Gilbert, Inc. also is available
on the SEC’s website at www.adviserinfo.sec.gov
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Material Changes
There are no material changes to this ADV part 2A to report at this time.
Graham, Bordelon, Golson & Gilbert, Inc.
CRD Number 104612
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Table of Contents
Item 4: Services, Fees, and Compensation ............................................................................................................ 22
Item 5: Account Requirement and Type of Clients ............................................................................................... 27
Item 6: Portfolio Manager Selection and Evaluation ............................................................................................ 28
Item 7: Client Information Provided to Portfolio Managers ................................................................................. 30
Item 8: Client Contact with Portfolio Managers ................................................................................................... 30
Item 9: Additional Information ............................................................................................................................. 30
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Item 4: Services, Fees, and Compensation
Graham, Bordelon, Golson & Gilbert, Inc. (“Graham Bordelon, we, us, our”) is a
corporation organized under the laws of the State of Louisiana. Gary Graham and Richard
Bordelon co-founded the Monroe-based investment advisory firm in 1986. J. Clint Rider,
Micheal Gilbert, and Jeffrey Golson are the majority owners. Graham Bordelon is an SEC
registered investment advisory firm.
We offer investment supervisory management, financial planning, and consulting services.
A. Description of the Program
Investment Management Services
We provide investment management services to you either by directly managing your
account ourselves or through Osaic Wealth, Inc. (“Osaic”), an unaffiliated, registered
broker-dealer and registered investment adviser. The Osaic Wealth Management Platform –
Advisor Managed Portfolios Program (“Advisor Managed Portfolios”) provides
comprehensive investment management of your assets through the application of asset
allocation planning software as well as the provision of execution, clearing and custodial
services through National Financial Services, Inc. (“NFS”).
Advisor Managed Portfolios provides risk tolerance assessment, efficient frontier plotting,
fund profiling and performance data, and portfolio optimization and re-balancing tools.
Utilizing these tools and based on your responses to a risk tolerance questionnaire
(“Questionnaire”) and discussions that you and your Advisory Representative have together
regarding, among other things, your personal investment objectives and goals, time
horizon, risk tolerance, account restrictions, needs, personal circumstances and overall
financial situation, we construct a portfolio of investments for you. Your Advisory
Representative has the option to allocate your portfolio amongst a mix of stocks, bonds,
options, exchange-traded funds, mutual funds and other securities (“Program
Investments”) which are based on your investment goals, objectives, and risk tolerance.
Each portfolio is designed to meet your individual needs, stated goals and objectives.
Additionally, you have the opportunity to place reasonable restrictions on the types of
investments to be held in the portfolio.
For further Advisor Managed Portfolios details, please see the Osaic Wealth Management
Platform Program Brochure. We provide this brochure to you prior to or concurrent with
your enrollment in Advisor Managed Portfolios. Please read it thoroughly before investing.
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Assets Under Management
As of December 31, 2024, we managed $369,900,793 in client assets on a discretionary
basis for 323 accounts and 1 non-discretionary account with $5,102,002 in assets.
B. Description of the Program
Our Wrap Fees
We provide investment supervisory services based upon either an hourly fee, flat fee, or as
a percentage of assets under management. Under the hourly fee structure, you are billed at
an hourly rate of $100 - $350 depending on the complexity of the project. Under the flat
fee program, you will be quoted a fee in advance ranging from $250 to $25,000 annually
depending upon numerous factors including, but not limited to, the complexity of your
situation and the scope of the project.
In addition, we may perform investment supervisory services based upon a percentage of
assets being supervised. Our fee is calculated based upon the market value of the assets in
your account on the last day of the previous quarter. Our fees are charged quarterly, in
arrears.
Broker-dealers and other financial institutions that hold client accounts are referred to as
custodians (“custodian/ broker-dealer”). Your custodian/broker-dealer determines the
values of the assets in your portfolio.
Fees for Investment Management Services
Fees for the initial quarter are based on the value of your cash and securities on the date the
custodian/broker-dealer receives them and are prorated based upon the number of
calendar days in the calendar quarter that our agreement is in effect. Our fee schedule is
described below:
Advisory Fee1
2.50%
2.00%
1.50%
1.00%
Assets under Management
Up to $250,000
$250,001 to $500,000
$500,001 to $1,000,000
Over $1,000,000
1All fees are negotiable at our sole discretion.
Osaic Wealth Management Platform – Advisor Managed Portfolios Program
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We offer Advisor Managed Portfolios as an account where no separate transactions charges
apply and a single fee is paid for all advisory services and transactions ("Wrap Account").
The Wrap Account is asset-based pricing.
We do not charge our clients higher advisory fees based on their trading activity, but you
should be aware that we may have an incentive to limit our trading activities in your
account(s) because we are charged for executed trades. Additionally, because of the nature
of a wrap program, wherein clients pay one fee for advisory services as well as certain
transactions, the actual fee to the firm will vary as the transaction costs charged to the
program vary. This means that if transaction costs go down, either because the account is
traded less or because the cost per trade goes down, the firm’s fees for the same advisory
services will increase. Likewise, if the costs increase, the firm’s advisory compensation will
decrease.
The intention of the wrap program is to have Graham, Bordelon, Golson and Gilbert, Inc.
absorb the occasional transactional costs associated with trades in the client accounts.
We also offer Advisor Managed Portfolios with separate advisory fees and transaction
charges (“Non-Wrap Account”). As such, in addition to the quarterly account fee described
below for advisory services, you will also pay separate per-trade transaction charges. The
Non-Wrap Account is transaction-based pricing.
You will pay a monthly or quarterly account fee, in advance, based upon the market value
of the assets held in your account as of the last business day of the preceding calendar
month or quarter. Your account fees are negotiable and will be debited from your account
by our custodian. If you terminate your participation in this program, you will be entitled to
a pro-rata refund of any prepaid monthly or quarterly fees based upon the number of days
remaining in the month or quarter after the date upon which the notice of termination is
received.
Our fee schedules are described below:
Wrap Account
Advisory Fee1
2.50%
2.25%
2.00%
1.75%
Assets under Management
$50,000 to $500,000
$500,001 to $2,000,000
$2,000,000 to $5,000,000
$5,000,001 and up
1All fees are negotiable at our sole discretion.
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Advisory Fee1
2.50%
2.25%
1.75%
1.50%
Non-Wrap Account
Assets under Management
$0 to $250,000
$250,001 to $750,000
$750,001 to $2,000,000
$2,000,001 and up
1All fees are negotiable at our sole discretion.
Mutual funds and ETFs invested in the account have their own internal fees which are
separate and distinct from the program account fees (for more information on these fees,
see the applicable fund prospectus).
Some Fund fees include 12b-1 fees which are internal distribution fees assessed by the
Fund, all or a portion of which are paid to the distributor(s) of the Funds. The Firm and
your Advisory Representative do not retain 12b-1 fees paid by the Funds.
In certain instances, there is opportunity to be eligible to purchase certain mutual funds and
ETFs without incurring transaction charges subject to certain conditions. For details, please
refer to Item 4 (No Transaction Fee Programs) of the Osaic Advisor Managed Portfolios
wrap fee brochure.
For complete fee details, including account fee schedule guidelines and a list of transaction
charges, please see the Osaic Advisor Managed Portfolios Wrap Fee Program Brochure.
You must authorize us to have the custodian/broker-dealer pay us directly by charging your
account. This authorization must be provided in writing. One-fourth of the annual fee is
charged each calendar quarter.
We send a statement that includes the value of your investments, our advisory fee, and how
it is calculated. Your custodian/broker-dealer also provides you with statements that show
the amount paid directly to us. You should compare the statement we send to your
custodian/broker-dealer’s statement and verify the calculation of our fees. Your
custodian/broker-dealer does not verify the accuracy of fee calculations. When
recommending mutual funds that have multiple share classes, we will take into account the
internal fees and expenses associated with each share class, and select the most cost
effective share class that still meets the client’s needs and objectives and is available to the
client.
In addition to our fee, you will be required to pay other applicable charges such as custodial
fees, brokerage commissions, transaction fees, internal fees and expenses charged by
mutual funds or exchange traded funds (“ETFs”), and other fees and taxes on brokerage
accounts and securities transactions.
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Mutual fund companies, ETFs, and variable annuity issuers charge internal fees and
expenses for their products. These fees and expenses are in addition to any advisory fees
charged by us. Complete details of these internal fees and expenses are explained in the
prospectuses for each investment. You are strongly encouraged to read these explanations
before investing any money. You may ask us any questions you have about fees and
expenses.
If you purchase mutual funds through the custodian/broker-dealer, you may pay a
transaction fee that would not be charged if the transactions were made directly through
the mutual fund company. Also, mutual funds held in accounts at brokerage firms may pay
internal fees that are different from funds held at the mutual fund company.
While you may purchase shares of mutual funds directly from the mutual fund company
without a transaction fee, those investments would not be part of our advisory relationship
with you unless they are specifically listed as part of the investment advisory agreement.
This means that they would not be included in our investment strategies, investment
performance monitoring, or portfolio reallocations absent an agreement or arrangement
stating otherwise.
Please be sure to read the section entitled “Brokerage Practices,” which follows later in this
brochure.
As noted above, you pay our fees for direct investment management quarterly in arrears.
You may terminate the agreement without penalty within 30 business days after the
execution of the agreement. Thereafter, you may terminate the agreement with us by giving
us written notice. Upon receiving the notice, we will bill you only for those services
rendered through the date the notice is received.
You must pay the advisory fees for the Osaic program in advance of receiving our services.
The advisory agreement for the Osaic program may be terminated by either party at any
time by written notice. Should you terminate the advisory agreement for the Osaic program
within five (5) business days from the date the agreement is executed, you will receive a full
refund of any fees paid.
Thereafter, should you terminate the advisory agreement for the Osaic program, you will be
entitled to pro-rata refund of any prepaid quarterly fees based upon the number of days
remaining in the quarter upon the date the notice of termination is received. The amount
refunded to you is calculated by dividing the most recent advisory fee you paid by the total
number of days in the quarter. This daily fee is then multiplied by the number of calendar
days in the quarter that our agreement was in effect. This amount, which equals the amount
26 | P a g e
we earned for the partial quarter, is subtracted from the total fee you paid in advance to
determine your refund.
Retainers paid initially to us for financial planning and other consulting services are
refundable to you upon your giving us thirty (30) days written notice of termination of the
contract. The retainer will be refunded to you based upon our time spent through the
termination date multiplied by the current hourly charge.
Our advisory representatives are also registered representatives of Osaic, a registered
broker/dealer, member FINRA/SIPC, and registered investment adviser. If you choose to
implement your financial plan through Osaic, commissions may be earned by your financial
advisor in addition to any fees paid for advisory services. In addition, the financial advisor
will be entitled to receive a portion of the internal expense fees (such as 12b-1 fees) charged
by mutual funds on assets in a commission-based account. We no longer receive 12b-1
fees on assets subject to an investment management fee and evaluate any mutual funds
transitioned to our firm to ensure that the investment is converted to the lowest-cost share
class for which you are eligible, absent circumstances that dictate otherwise.
Our advisory representatives are also licensed with various insurance companies.
Commissions will be earned by our financial advisors if insurance products are purchased
through these insurance companies if those purchases are outside of a designated fee based
or advisory that includes such products.
We may receive benefits such as assistance with conferences and educational meetings from
product sponsors.
Our advisory representatives may also recommend various asset management firms
through their affiliation with Osaic. If you establish an investment advisory relationship
with one of these firms, our financial advisory fee is in addition to fees the asset
management firm charges.
The above arrangements present a conflict of interest because they create an incentive to
make recommendations based upon the amount of compensation we receive rather than
based upon your needs. We will explain the specific costs associated with any
recommended investments with you upon request. We also recommend no-load and load-
waived mutual funds to further reduce conflicts of interest. Additionally, you have the
option to purchase investment and insurance products through other brokers or agents
who are not affiliated with us.
Item 5: Account Requirement and Type of Clients
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We provide advisory services primarily to high-net-worth individuals, including their trusts,
estates and retirement accounts. We also provide services to corporations or business
entities including their pension and profit-sharing plans and to charitable organizations.
Account minimums vary by the program used to manage your assets.
We, at our sole discretion, may accept clients with smaller portfolios based upon certain
factors including anticipated future earning capacity, anticipated future additional assets,
account composition, related accounts, and pre-existing client relationships. We may
consider the portfolios of your family members to determine if your portfolio meets the
minimum size requirement.
Item 6: Portfolio Manager Selection and Evaluation
The only fees covered under the wrap fee program are transaction fees associated with the
purchase and sale of securities in an account managed by Graham, Bordelon, Golson and
Gilbert, Inc. as well as asset-based fees. All client accounts managed by Graham,
Bordelon, Golson and Gilbert, Inc., including wrap fee program clients, are managed with
similar processes, although account recommendations may differ.
Methods of Analysis, Investment Strategies and Risk of Loss
We select specific investments for your portfolios through the use of fundamental analysis.
Fundamental analysis is a method of evaluating a company that has issued a security by
attempting to measure the value of its underlying assets. It entails studying overall
economic and industry conditions as well as the financial condition and the quality of the
company’s management. Earnings, expenses, assets, and liabilities are all important in
determining the value of a company. The value is then compared to the current price of the
issuing company’s security to determine whether to purchase, sell or hold the security.
Cyclical analysis is a form of fundamental analysis that involves the process of making
investment decisions based on the different stages of an industry at a given point in time.
Although we manage your portfolio in a manner consistent with your risk tolerances, there
can be no guarantee that our efforts will be successful. You should be prepared to bear the
risk of loss.
Our investment strategies may include long-term and short-term purchases and sales, and
the use of margin. You may place reasonable restrictions on the strategies to be employed
in your portfolio and the types of investments to be held in your portfolio.
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Although we manage your account in a manner we believe is consistent with your specific
investment objectives and risk tolerances, there can be no guarantee that our efforts will be
successful. General economic conditions, current interest rates, the performance of a
particular industry or a particular company, and any number of other factors can affect
investment performance.
You should be prepared to bear the risk of loss. All investments are subject to loss,
including (among other things) loss of principal, a reduction in earnings (including interest,
dividends and other distributions), and the loss of future earnings.
You must also be aware that the use of margin is a higher risk strategy. It is possible to lose
all of the principal you invest, and sometimes more. In a cash account, your risk is limited
to the amount of money that you have invested. In a margin account, your risk includes the
amount of money invested plus the amount that has been loaned to you. We do not use or
recommend the use of margin as part of our account management.
You should also be aware that transactions in the account (including account reallocations
and rebalancing) may trigger a taxable event for you (unless your account is a qualified
retirement account).
You should also be aware that client accounts may have cash balances in excess of
$250,000, which is the insurance limit of the Federal Deposit Insurance Corporation. For
cash balances in excess of that amount, there is an enhanced risk that operation related
counterparty risk related to the account custodian could cause losses in the account. We
mitigate this risk by carrying cash balances in amounts either subject to protection or as
limited as you, the client, directs. You may elect to participate in a “cash sweep” program
through your account custodian which automatically moves excess cash from your
investment account into a cash account and then invests that cash into cash based
investments, such as money market funds. We do not receive compensation of any kinds
for facilitating your participation in such cash sweep accounts.
Voting Client Strategies
We do not take any action or give any advice with respect to voting of proxies solicited by
or with respect to the issuers of securities in which your accounts may be invested. In
addition, we do not take any action or give any advice with respect to any securities held in
any accounts that are named in or subject to class action lawsuits. We will, however,
forward to you any information received by us regarding proxies and class action legal
matters involving any securities held in your accounts.
Performance-Based Fees
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We do not charge performance-based fees.
Item 7: Client Information Provided to Portfolio Managers
Please see response to Item 6, above.
Item 8: Client Contact with Portfolio Managers
Clients may contact Graham, Bordelon, Golson & Gilbert, Inc. at any time.
Item 9: Additional Information
Disciplinary Information
Graham, Bordelon, Golson & Gilbert, Inc. was subject to an administrative proceeding as
of September 10, 2020 pertaining to the receipt of 12b-1 fees, mutual fund share class
selection and the appropriate disclosures concerning such items. The SEC accepted a
settlement offer from Graham, Bordelon, Golson & Gilbert, Inc. The full order can be
found at https://www.sec.gov/litigation/admin/2020/ia-5576.pdf.
Other Financial Industry Activities and Affiliations
As explained under “Fees and Conditions” above, our advisory representatives are also
licensed as registered representatives with Osaic. They are also licensed as insurance agent
with various insurance companies. These arrangements present a conflict of interest
because they create an incentive to make recommendations based upon the amount of
compensation your advisory representative can receive rather than based upon your needs.
As previously noted, we will explain the specific costs associated with any recommended
investments with you upon request. We also recommend no-load and load-waived mutual
funds to further reduce conflicts of interest. You have the option to purchase investment
and insurance products through other brokers or agents who are not affiliated with us.
Our advisory representatives may also recommend various asset management firms
through their affiliation with Osaic. If you establish an investment advisory relationship
with one of these firms, our financial advisors may share in the advisory fees you pay to
these asset management firms.
Our principal executive officers and advisory representatives are also registered with
EnTrust Investment Management, LLC (“EnTrust”), a registered investment advisory firm.
They spend approximately 20% of their time on this activity. We own 100% of EnTrust,
30 | P a g e
which shares space with us and is managed by the same principals. The services offered by
EnTrust are similar to the services we offer.
Code of Ethics; Participation or Interest in Client Transactions and Personal
Trading
A copy of our Code of Ethics is available upon request. Our Code of Ethics
A.
includes discussions of our fiduciary duty to clients, political contributions, gifts,
entertainment, and trading guidelines.
B. Not applicable. GBGG does not recommend to clients that they invest in any
security in which GBGG, or any principal thereof has any financial interest.
C. On occasion, an employee of GBGG may purchase for his or her own account
securities which are also recommended for clients. Our Code of Ethics details rules for
employees regarding personal trading and avoiding conflicts of interest related to trading in
one’s own account. To avoid placing a trade before a client (in the case of a purchase) or
after a client (in the case of a sale), all employee trades must be reviewed by the Compliance
Officer. All employee trades must either take place in the same block as a client trade or
sufficiently apart in time from the client trade, so the employee receives no added benefit.
Employee statements are reviewed to confirm compliance with the trading procedures.
D. On occasion, an employee of GBGGmay purchase for his or her own account
securities which are also recommended for clients at the same time the clients purchase the
securities. Our Code of Ethics details rules for employees regarding personal trading and
avoiding conflicts of interest related to trading in one’s own account. To avoid placing a
trade before a client (in the case of a purchase) or after a client (in the case of a sale), all
employee trades must be reviewed by the Compliance Officer. All employee trades must
either take place in the same block as a client trade or sufficiently apart in time from the
client trade, so the employee receives no added benefit. Employee statements are reviewed
to confirm compliance with the trading procedures.
Review of Accounts
All client accounts are monitored on an ongoing basis with a formal review conducted at
least annually or as agreed upon with individual clients. The reviews focus on the
consistency of portfolio investments with each client’s stated objectives and risk tolerances.
Reviews also consider investment restrictions requested by individual clients, investment
time horizons, liquidity needs, tax considerations and other circumstances unique to each
client.
On a quarterly basis, the performance of each client account is reviewed to monitor
consistency with market benchmarks that we deem applicable. Account reviews may also
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be triggered by other factors such as changes in general economic and market conditions,
analyst reports, issuer news and interest rate movement. Your advisory representative is
responsible for all reviews.
You will receive statements from the custodian/broker-dealer at least quarterly. These
statements identify your current investment holdings, the cost of each of those investments,
and their current market values. If you elect to receive quarterly performance reporting, you
will also receive performance analysis reports prepared by us which describe the returns
realized on the investments in your account.
Client Referrals and Other Compensation
We do not directly or indirectly compensate any person who is not one of our advisory
representatives or employees for client referrals.
We receive certain economic benefits as a result of our participation in NFS’s institutional
program. Those benefits are described in detail in the preceding section entitled “Brokerage
Practices.”
Financial Information
We have no financial commitment that impairs our ability to meet contractual and fiduciary
commitments to you and we have not been the subject of a bankruptcy proceeding.
On May 5, 2020, Graham, Bordelon, Golson, and Gilbert, Inc. received a Paycheck
Protection Plan Loan through the SBA in the amount of $86,692 in conjunction with the
relief afforded under the CARES Act. GBGG used the PPP loan proceeds in accordance
with the terms of the loan program and the firm did not suffer any interruption of service.
The participation in the PPP did not constitute a material event for GBGG.
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Brochure Supplements
Gary G. Graham
Graham, Bordelon, Golson & Gilbert, Inc.
2401 Tower Drive
Monroe, LA 71201
318.322.7157
Brochure Supplement
February 26, 2025
This brochure supplement provides information about Gary G. Graham that supplements the
Graham, Bordelon, Golson& Gilbert, Inc. brochure. You should have received a copy of that
brochure. Please contact Clint Rider, Chief Compliance Officer if you did not receive Graham,
Bordelon, Golson & Gilbert, Inc.’s brochure or if you have any questions about the contents of this
supplement.
Additional information about Gary G. Graham, CRD Number 1173717, is available on the SEC’s
website at www.adviserinfo.sec.gov.
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Educational Background and Business Experience
Gary G. Graham
Year of birth: 1952
Formal education:
Northeast Louisiana University – 1974, B.B.A.
Loyola University Law School – 1977, J.D.
Business background:
Graham, Bordelon, Golson & Gilbert, Inc.
Advisory Representative (1989 – Present)
President (1989 – 06/2016)
Osaic Wealth, Inc. formerly known as Triad Advisors, LLC - Registered
Representative; (1998 – Present)
EnTrust Investment Management, LLC - Member, Advisory Representative;
(1999 – Present)
Gary G. Graham – Attorney (1977 – Present)
Professional Designations:
Certified Public Accountant (CPA). A CPA license is legally required in order to do
particular jobs, such as public accounting (independent auditing). State laws govern what
CPAs can and cannot do with their license. Mr. Graham currently maintains an inactive
CPA license.
Disciplinary Information
Gary G. Graham has not been the subject of any legal or disciplinary event in the last ten
years.
Other Business Activities
In addition to his association with Graham, Bordelon, Golson & Gilbert, Inc., Mr. Graham
is a registered representative of Osaic Wealth, Inc. (“Osaic”), a registered broker/dealer,
member FINRA/SIPC. He is a licensed insurance agent offering insurance products and
services through unaffiliated insurance companies.
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Mr. Graham is a practicing attorney registered with the Louisiana State Bar Association. He
is also registered with EnTrust Investment Management, LLC, a registered investment
advisory firm.
If Mr. Graham performs services for you as a registered representative of a broker-dealer,
insurance agent, or attorney Mr. Graham may receive commissions or other compensation
from the sale of securities and insurance products and services to you.
Mr. Graham may also recommend various asset management firms through his affiliation
with Osaic. If you establish an investment advisory relationship with one of these firms,
Mr. Graham may share in the advisory fees you pay to these asset management firms.
This additional compensation may present a conflict of interest because it creates an
incentive to recommend products and services based upon compensation, rather than on
your needs. Mr. Graham will explain the costs associated with any recommendations he
makes. You have no obligation to do business with Mr. Graham in his other capacities.
Additional Compensation
Mr. Graham receives additional compensation for his activities as a registered
representative of a broker-dealer and as an insurance agent. This may also include
applicable sales awards and other prizes. This compensation is described under “Other
Business Activities” above.
Supervision
Mr. Graham is supervised by Clint Rider, Chief Compliance Officer. Mr. Rider can be
reached at 318.322.7157.
We supervise Mr. Graham by requiring that he adhere to our processes and procedures as
described in our firm’s Code of Ethics. We will monitor the advice that Mr. Graham gives
to you by performing the following reviews:
A review of relevant account opening documentation when the relationship is
established
A daily review of account transactions,
Review custodial information on a quarterly basis to assess account activity,
Perform annual oversight so that Mr. Graham is aware of your current financial
situation, objectives, and individual investment needs
A review of client correspondence on an as needed basis.
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Jeffrey K. Golson
Graham, Bordelon, Golson & Gilbert, Inc.
2401 Tower Drive
Monroe, LA 71201
318.322.7157
Brochure Supplement
February 26, 2025
This brochure supplement provides information about Jeffrey K. Golson that supplements the
Graham, Bordelon, Golson& Gilbert, Inc. brochure. You should have received a copy of that
brochure. Please contact Clint Rider, Chief Compliance Officer if you did not receive Graham,
Bordelon, Golson & Gilbert, Inc.’s brochure or if you have any questions about the contents of this
supplement.
Additional information about Jeffrey K. Golson, CRD Number 1457878, is available on the SEC’s
website at www.adviserinfo.sec.gov.
36 | P a g e
Educational Background and Business Experience
Jeff K. Golson
Year of birth: 1963
Formal education:
Northeast Louisiana University – 1986, B.B.A.
Business background:
Graham, Bordelon, Golson & Gilbert, Inc. –
Advisory Representative (1989 – Present)
CCO (1989 – 12/2021)
President (06/2016 – Present)
Vice President (1989 – 06/2016)
Osaic Wealth, Inc. formerly known as Triad Advisors, LLC - Registered
Representative; (1998 – Present)
EnTrust Investment Management, LLC – Member, President, Advisory
Representative; (1999 – Present)
Professional Designations:
Certified Public Accountant (CPA)
A CPA license is legally required in order to do particular jobs, such as public accounting
(independent auditing). State laws govern what CPAs can and cannot do with their license.
Mr. Golson currently maintains an inactive CPA license.
Disciplinary Information
Jeff K. Golson has not been the subject of any legal or disciplinary event in the last ten
years.
Other Business Activities
In addition to his association with Graham, Bordelon, Golson & Gilbert, Inc., Mr. Golson
is a registered representative of Osaic Wealth, Inc. (“Osaic”), a registered broker/dealer,
member FINRA/SIPC. He is also a licensed insurance agent offering insurance products
and services through unaffiliated insurance companies.
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Mr. Golson is also registered with EnTrust Investment Management, LLC, a registered
investment advisory firm.
If Mr. Golson performs services for you as a registered representative of a broker-dealer or
as an insurance agent, Mr. Golson may receive commissions or other compensation from
the sale of securities and insurance products and services to you.
Mr. Golson may also recommend various asset management firms through his affiliation
with Osaic. If you establish an investment advisory relationship with one of these firms,
Mr. Golson may share in the advisory fees you pay to these asset management firms.
This additional compensation may present a conflict of interest because it creates an
incentive to recommend products and services based upon compensation, rather than on
your needs. Mr. Golson will explain the costs associated with any recommendations he
makes. You have no obligation to do business with Mr. Golson in his other capacities.
Additional Compensation
Mr. Golson receives additional compensation for his activities as a registered representative
of a broker-dealer and as an insurance agent. This may also include applicable sales awards
and other prizes. This compensation is described under “Other Business Activities” above.
Supervision
Mr. Golson is supervised by the firm’s Chief Compliance Officer, Clint Rider. Mr. Rider
can be reached at 318.322.7157.
We supervise Mr. Golson by requiring that he adhere to our processes and procedures as
described in our firm’s Code of Ethics. We will monitor the advice that Mr. Golson gives
to you by performing the following reviews:
A review of relevant account opening documentation when the relationship is
established
A daily review of account transactions,
Review custodial information on a quarterly basis to assess account activity,
Perform annual oversight so that Mr. Golson is aware of your current financial
situation, objectives, and individual investment needs, and
A review of client correspondence on an as needed basis.
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Micheal B. Gilbert
Graham, Bordelon, Golson & Gilbert, Inc.
2401 Tower Drive
Monroe, LA 71201
318.322.7157
Brochure Supplement
February 26, 2025
This brochure supplement provides information about Micheal B. Gilbert that supplements the
Graham, Bordelon, Golson& Gilbert, Inc. brochure. You should have received a copy of that
brochure. Please contact Clint Rider, Chief Compliance Officer if you did not receive Graham,
Bordelon, Golson & Gilbert, Inc.’s brochure or if you have any questions about the contents of this
supplement.
Additional information about Micheal B. Gilbert, CRD Number 4139413, is available on the SEC’s
website at www.adviserinfo.sec.gov.
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Educational Background and Business Experience
Micheal B. Gilbert
Year of birth: 1975
Formal education:
Northeast Louisiana University – 1998, B.B.A.
Business background:
Graham, Bordelon, Golson & Gilbert, Inc. –
Advisory Representative; (1999 – Present)
Secretary (06/2016 – Present)
Treasurer (06/2016 – 05/2020)
Vice President (1999 – 06/2016)
Osaic Wealth, Inc. formerly known as Triad Advisors, LLC - Registered
Representative; (2006 – Present)
EnTrust Investment Management, LLC – Advisory Representative; (1999 –
Present)
Professional Designations:
Mr. Gilbert currently holds an active Certified Public Accountant (CPA) designation. A
CPA license is legally required in order to do particular jobs, such as public accounting
(independent auditing). State laws govern what CPAs can and cannot do with their license.
Disciplinary Information
Micheal Gilbert has not been the subject of any legal or disciplinary event.
Other Business Activities
In addition to his association with Graham, Bordelon, Golson & Gilbert, Inc., Mr. Gilbert
is a registered representative of Osaic Wealth, Inc. (“Osaic”), a registered broker/dealer,
member FINRA/SIPC. He is also a licensed insurance agent offering insurance products
and services through unaffiliated insurance companies.
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Mr. Gilbert is a CPA providing tax consulting, tax preparation and incidental accounting
services. He is also registered with EnTrust Investment Management, LLC, a registered
investment advisory firm.
If Mr. Gilbert performs services for you as a registered representative of a broker-dealer,
insurance agent, or as an accountant, he may receive commissions or other compensation
from the sale of securities and insurance products and services to you.
Mr. Gilbert may also recommend various asset management firms through his affiliation
with Osaic. If you establish an investment advisory relationship with one of these firms,
Mr. Gilbert may share in the advisory fees you pay to these asset management firms.
This additional compensation may present a conflict of interest because it creates an
incentive to recommend products and services based upon compensation, rather than on
your needs. Mr. Gilbert will explain the costs associated with any recommendations he
makes. You have no obligation to do business with Mr. Gilbert in his other capacities.
Additional Compensation
Mr. Gilbert receives additional compensation for his activities as a registered representative
of a broker-dealer and as an insurance agent. This may also include applicable sales awards
and other prizes. This compensation is described under “Other Business Activities” above.
Supervision
Mr. Gilbert is supervised by Clint Rider, Chief Compliance Officer. Mr. Rider can be
reached at 318.322.7157.
We supervise Mr. Gilbert by requiring that he adhere to our processes and procedures as
described in our firm’s Code of Ethics. We will monitor the advice that Mr. Gilbert gives to
you by performing the following reviews:
A review of relevant account opening documentation when the relationship is
established
A daily review of account transactions,
Review custodial information on a quarterly basis to assess account activity,
Perform annual oversight so that Mr. Gilbert is aware of your current financial
situation, objectives, and individual investment needs, and
A review of client correspondence on an as needed basis.
41 | P a g e
James Clint Rider
Graham, Bordelon, Golson & Gilbert, Inc.
2401 Tower Drive
Monroe, LA 71201
318.322.7157
Brochure Supplement
February 26, 2025
This brochure supplement provides information about James Clint Rider that supplements the
Graham, Bordelon, Golson& Gilbert, Inc. brochure. You should have received a copy of that
brochure. Please contact Clint Rider, Chief Compliance Officer if you did not receive Graham,
Bordelon, Golson & Gilbert, Inc.’s brochure or if you have any questions about the contents of this
supplement.
Additional information about James Clint Rider, CRD Number 4758500, is available on the SEC’s
website at www.adviserinfo.sec.gov.
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Educational Background and Business Experience
James Clint Rider
Year of birth: 1974
Formal education:
University of Louisiana – 2000, B.S., Agricultural Business
Business background:
Graham, Bordelon, Golson & Gilbert, Inc. – Advisory representative (03/2011
– Present)
Chief Compliance Officer (01/2022 – Present)
Treasurer (05/2020 – Present)
Osaic Wealth, Inc. formerly known as Triad Advisors, LLC – Registered
Representative (03/11 – Present)
EnTrust Investment Management, LLC – Advisory Representative; (06/2011 –
Present)
Chief Compliance Officer (01/2022 – Present)
Morgan Keegan & Company - Advisory Representative, Registered
Representative, Associate Vice President (03/2005 – 03/2011)
Disciplinary Information
James Clint Rider has not been the subject of any legal or disciplinary event in the last ten
(10) years.
Other Business Activities
In addition to his association with Graham, Bordelon, Golson & Gilbert, Inc., Mr. Rider is
a registered representative of Osaic Wealth, Inc. (“Osaic”), a registered broker/dealer,
member FINRA/SIPC. He is also a licensed insurance agent offering insurance products
and services through unaffiliated insurance companies.
Mr. Rider is also registered with EnTrust Investment Management, LLC, a registered
investment advisory firm.
43 | P a g e
If Mr. Rider performs services for you as a registered representative of a broker-dealer or as
an insurance agent, Mr. Rider may receive commissions or other compensation from the
sale of securities and insurance products and services to you.
Mr. Rider may also recommend various asset management firms through his affiliation with
Osaic. If you establish an investment advisory relationship with one of these firms, Mr.
Rider may share in the advisory fees you pay to these asset management firms.
This additional compensation may present a conflict of interest because it creates an
incentive to recommend products and services based upon compensation, rather than on
your needs. Mr. Rider will explain the costs associated with any recommendations he
makes. You have no obligation to do business with Mr. Rider in his other capacities.
Additional Compensation
Mr. Rider receives additional compensation for his activities as a registered representative
of a broker-dealer and as an insurance agent. This may also include applicable sales awards
and other prizes. This compensation is described under “Other Business Activities” above.
Supervision
Mr. Rider is supervised by Jeffrey K. Golson. Mr. Golson can be reached at 318.322.7157.
We supervise Mr. Rider by requiring that he adhere to our processes and procedures as
described in our firm’s Code of Ethics. We will monitor the advice that Mr. Rider gives to
you by performing the following reviews:
A review of relevant account opening documentation when the relationship is
established
A daily review of account transactions,
Review custodial information on a quarterly basis to assess account activity,
Perform annual oversight so that Mr. Rider is aware of your current financial
situation, objectives, and individual investment needs, and
A review of client correspondence on an as needed basis.
44 | P a g e