A. Description of the Advisory Firm Gordon Asset Management, LLC, hereinafter called in this document "we", "our", "GAMLLC", "firm" or "adviser" is a SEC Registered Investment Adviser with its principal place of business in North Carolina. Gordon Asset Management, LLC began conducting business in 2001. Joseph M. Gordon maintains a majority ownership stake in Gordon Asset Management, LLC and a breakdown of ownership is below:
• The Jodaddy Revocable Trust dated March 2002 (82%),
• Gibraltar Financial, LLC (15%),
• Zempel Investments, LLC (3%).
B. Types of Advisory Services Portfolio Management Services Our firm provides continuous advice to our clients regarding the discretionary and non-discretionary investment management of client funds based on the individual needs of the client. Through personal discussions and questionnaires designed to assess a client’s risk using qualitative and quantitative questions relating to behavior aversion to risk, timeline to and through retirement and the amount of current and projected assets, goals and objectives based on a client's circumstances are established. We develop a client's personal Investment Policy Statement (IPS), which formalizes the investment policy for all the accounts under management and create and manage a portfolio based on that policy. Further description of Discretionary and Non-Discretionary engagements is included in Item 16 further below. Portfolio management services include, but are not limited to, the following:
• Investment strategy,
• Asset allocation,
• Risk tolerance,
• Personal investment policy,
• Asset selection,
• Regular portfolio monitoring.
GAMLLC seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of GAMLLC’s economic, investment or other financial interests. To meet its fiduciary obligations, GAMLLC attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, GAMLLC’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 GAMLLC’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. GAMLLC 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, GAMLLC will always ensure those other advisers are properly licensed or registered as an investment adviser. GAMLLC 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. GAMLLC then makes investments with a third-party investment adviser by referring the client to the third-party adviser. GAMLLC may also allocate to one or more private equity funds or private equity fund advisers. GAMLLC will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Portfolio Management by Betterment GAMLLC has engaged Betterment for Advisors as a third-party Sub-Advisor to provide services and portfolio management to some clients. Betterment for Advisors is a digital wealth management platform generally serving independent investment advisory firms and advisors. Betterment LLC (“Betterment”), a registered investment advisor, serves as sub-advisor to some of GAMLLC’s clients. MTG LLC, dba Betterment Securities (“Betterment Securities”), a registered broker-dealer and member of FINRA and SIPC, serves as broker-dealer and custodian. Under the Sub-Advisory Agreement between Betterment LLC and each GAMLLC client, Betterment has the authority to manage each client account on a discretionary basis and to buy, sell and otherwise effect investment transactions on the client’s behalf in accordance with the client’s Investment Policy Statement and any other elections or instructions provided by clients and GAMLLC advisors on their behalf via Betterment’s website. Any GAMLLC client who engages Betterment will be presented with the Betterment Advised Client Agreements (which includes the Sub Advisory Agreement, Brokerage agreement, and consent to electronic delivery of documents, among other items) between Betterment and the client, as well as Betterment’s Privacy Notice, Form ADV, and Form CRS. The services provided by Betterment include: ● Goal-Based Investment Management: Betterment’s goal-based investment platform allows Advisors and Clients to identify multiple investment goals for each Client, each with specific portfolio allocations; ● Portfolio Construction Tools: GAMLLC and its clients who engage Betterment have access to a set of Betterment constructed portfolio strategies, third-party model portfolio strategies, or, if applicable, Advisor constructed custom portfolio strategies (described below), each of which is comprised of low cost, index-tracking exchange-traded funds or mutual funds, and are able to customize the risk-level for each investment goal; ● Automated Investment Management Services: Betterment’s algorithms automate back-office tasks such as trading, portfolio management, and account rebalancing; ● Website and Mobile Application: Betterment’s website and mobile application provide a platform

for account access and monitoring and delivery of account documentation and notices; and ● Advisor Dashboard: Advisors have access to a dashboard for purposes of monitoring and managing accounts.
GAMLLC may construct Custom Portfolios using its own investment methodologies, and clients can use Betterment’s automated advice features, including automatic rebalancing, dividend reinvestment, tax loss harvesting, and asset location services. GMLLC, not Betterment, manages any goal for which a Custom Portfolio is chosen based on a client’s financial situation and investment objectives. Betterment will not evaluate whether any Custom Portfolio is suitable for any Client’s individual investment objectives, either at the time of election or on an ongoing basis. Betterment offers several account types to Advisors and their Clients, such as taxable investing accounts, individual retirement accounts (IRAs), and cash management accounts (Cash Reserve). Pension Consulting Services GAMLLC offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans. Pension consulting may include, but is not limited to:
• Serving as a plan fiduciary as described by ERISA § 3(38) and/or 3(21)A(ii),
• Identifying investment objectives and restrictions,
• Providing guidance on various asset classes and investment options,
• Recommending money managers to manage plan assets in ways designed to achieve objectives,
• Monitoring performance of money managers and investment options and making recommendations for changes,
• Portfolio management for defined benefit and/or trustee directed defined contribution plans,
• Recommending other service providers, such as custodians, administrators, and custodians and/or benchmarking their fees,
• Providing administrative support such as plan design analysis, participant education & enrollment, fiduciary record maintenance, and
• Creating a written pension consulting plan.
These services are based on the goals, objectives, demographics, time horizon and/or risk tolerance of the plan and its participants. Envestnet -Managed Individual 401(k) Accounts GAMLLC offers clients with 401(k) accounts the opportunity to have them managed by Envestnet Retirement Solutions. Envestnet offers an integrated retirement practice management platform suite of technology services to retirement plans and the advisors serving those clients. Client assets are invested into risk-based model portfolios, managed for a fee of 0.50% fee based on assets under management in the account. Outsourced ERISA 3(38) Plan Fiduciary Service GAMLLC selects and monitors plan investment offerings to participant-directed defined contribution plans as described under ERISA section 3(38). Financial Planning Financial plans and financial planning services may include, but are not limited to:
• investment planning,
• life, disability and long-term care insurance,
• tax concerns,
• retirement planning,
• estate planning,
• college cost analysis, and
• debt/credit planning.
Services Limited to Specific Types of Investments Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include, but are not limited to, the following types of securities:
• Individual stocks (Exchange listed, over the counter or ADR),
• Exchange traded funds (ETFs),
• Open End Mutual Funds (Mutual Funds),
• Closed End Funds (CEFs),
• Interval Funds,
• Private investments (limited partnerships, hedge funds, private equity, venture capital, other commingled vehicles),
• Business Development Companies (BDCs),
• Leveraged and Inverse ETFs, ETNs and mutual funds,
• Real Estate Investment Trusts (REITs),
• Master Limited Partnerships (MLPs),
• Options,
• Corporate debt securities (other than commercial paper),
• Municipal securities,
• United States governmental securities.
Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. C. Client Tailored Services and Client Imposed Restrictions GAMLLC will tailor a program for each individual client. During our data-gather process, we determine the client’s individual risk and return objectives, time horizon(s), tax considerations, legal requirements, liquidity needs and any unique circumstances that are necessary. As appropriate, we also review and discuss a client’s prior investment history. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. 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. GAMLLC does not participate in any wrap fee programs. E. Assets Under Management When calculating regulatory assets under management, an Investment Adviser must include the value of any advisory account over which it exercises continuous and regular advisory or management services.
• Date Calculated: 12/31/2023
• Total AUM: $212,153,656.47
• Additional assets under advisement for the period totaled $989,117,840