A. Description of the Advisory Firm
Mark Gillam Enterprises or “MGE” is a Corporation organized in the State of California.
MGE was formed in June 1989, and the principal owner is the Trustee of the Chall Trust.
Mark Gillam is the owner of the trust. Mark Gillam is an investment advisor representative
of MGE.
B. Types of Advisory Services
Portfolio Management Services
MGE offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. MGE may choose to employ an
Investment Policy Statement for an advisory client, which outlines the client’s current
situation (income, tax levels, and risk tolerance levels) in coordination of constructing a
plan to aid in the selection of a portfolio that matches each client's specific situation.
Portfolio management services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
MGE evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. Under certain circumstances, MGE will have discretionary
authority on an account through a separately executed document (i.e. an Appointment of
Investment Advisor) in order to select appropriate investments and execute transactions
without permission from the client prior to each transaction. Although, in practice, MGE
will typically discuss the recommendation with the client prior to executing the
transaction. Generally, MGE does not exercise discretion over investment accounts and
client consent is received prior to execution. Further details concerning discretion are
outlined in the Custody section.
MGE seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of MGE’s economic, investment or
other financial interests. To meet its fiduciary obligations, MGE attempts to avoid, among
other things, investment or trading practices that systematically advantage or
disadvantage certain client portfolios, and accordingly, MGE’s policy is to seek fair and
equitable allocation of investment opportunities/transactions among its clients to avoid
favoring one client over another over time. It is MGE’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent among its
clients on a fair and equitable basis over time.
Selection of Other Advisers
MGE may direct clients to third-party investment advisers to manage all or a portion of the
client's assets. Before selecting other advisers for clients, MGE will always ensure those
other advisers are properly licensed or registered as an investment adviser. MGE
conducts due diligence on any third-party investment adviser, which may involve one or
more of the following: phone calls, meetings and review of the third-party adviser's
performance and investment strategy. MGE then makes investments with a third-party
investment adviser by referring the client to the third-party adviser. MGE will review the
ongoing performance of the third-party adviser as a portion of the client's portfolio.
Pension Consulting Services
MGE offers ongoing consulting services to pension or other employee benefit plans
(including but not limited to 401(k) plans) based on the demographics, goals, objectives,
time horizon, and/or risk tolerance of the plan’s participants.
Financial Planning, Analysis, Consulting and Other Services
In addition to portfolio management services, MGE offers personalized financial analysis
and consulting services through one-on-one advice concerning investment products, the
creation of a financial plan for implementation and other advice, as may be appropriate
from time to time. In addition to its core services of investment advice, MGE provides
advice concerning tax planning, risk management through insurance review (we are not
licensed property & casualty agents, however we work with licensed individuals who write
business), evaluation of real estate
portfolios and mortgages, retirement planning, cash
flow management, estate planning, higher education tuition planning, intergenerational
wealth transfer, charitable giving and to what extent, if any, a third party advisor would be
appropriate to manage some of the client’s assets. Additional services may include:
- management of investment advisory accounts not involving investment
supervisory services,
- advice to clients on matters not involving securities, including but not limited to,
life, health and accident insurance (i.e. disability insurance),
- acquisition or disposition of real estate or financial instruments related thereto,
- bill pay and bookkeeping services subject to annual audits,
- income tax preparation assistance,
- management of non-securities income producing assets,
- miscellaneous concierge services on a case-by-case basis,
- general business advice. Financial plans and financial planning may include, but
are not limited to: investment planning; life insurance; tax concerns; retirement
planning; college planning; and debt/credit planning.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. The way we make money
creates some conflicts with your interests, so we operate under a special rule that requires
us to act in your best interest and not put our interest ahead of yours. Under this special
rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
Services Limited to Specific Types of Investments
MGE generally limits its investment advice to mutual funds, fixed income securities, real
estate funds, insurance products including annuities, private placements, equities, ETFs
(including ETFs in the gold and precious metal sectors), treasury inflation
protected/inflation linked bonds and non -U.S. securities. MGE may use other securities as
well to help diversify a portfolio when applicable.
C. Client Tailored Services and Client Imposed Restrictions
MGE will tailor a program for each individual client based on calls or meetings or
responses from clients on questionnaires that will allow MGE to better acquaint itself with
each client’s specific needs and requirements as part of developing a plan that will be
executed by MGE on behalf of the client. Clients may impose restrictions in investing in
certain securities or types of securities in accordance with their values or beliefs.
However, if the restrictions prevent MGE from properly servicing the client account, or if
the restrictions would require MGE to deviate from its standard suite of services, MGE
reserves the right to end the relationship.
Depending on the client, the review can be anywhere from monthly - or more frequently -
to annual, at minimum. Registrant reviews multiple factors including client income levels,
cash flow needs, balance sheet and client's personal circumstances to determine
investment strategy.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and other administrative
fees. MGE does not sponsor any wrap fee programs.
E. Assets Under Management
MGE has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 1,418,807.00 $ 202,979,826.00 As of 12/31/2023
*Discretionary accounts comprise of bank accounts and those accounts managed via
separate agreement appointing MGE as Investment Advisor.