GERVAIS CAPITAL MANAGEMENT, LLC

Gervais Capital Management, LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Gervais Capital Management, LLC. If you have any questions about the contents of this brochure, please contact us at (914) 433-5223 or by email at: contact@gervaiscapital.com. 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. Additional information about Gervais Capital Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Gervais Capital Management, LLC’s CRD number is: 299347. 3485 North Pines Way, Suite 105 Wilson, WY 83014 (914) 433-5223 contact@gervaiscapital.com https://GervaisCapital.com Mailing Address: 1  PO Box 465 Teton Village, WY 83025 Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 03/25/2025 2  Item 2: Material Changes The last annual updating amendment of Gervais Capital Management, LLC was on 03/18/2024. Material changes relate to Gervais Capital Management, LLC policies, practices or conflicts of interests only. • Gervais Capital Management, LLC has transitioned to registration with the United States Securities and Exchange Commission from its prior registration at the state level. • Gervais Capital Management, LLC has updated their Office Address. (Cover Page) 3  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... 3 Item 3: Table of Contents ....................................................................................................................................... 4 Item 4: Advisory Business ..................................................................................................................................... 2 A. Description of the Advisory Firm ............................................................................................................... 2 B. Types of Advisory Services .......................................................................................................................... 2 C. Client Tailored Services and Client Imposed Restrictions ....................................................................... 4 D. Wrap Fee Programs ....................................................................................................................................... 4 E. Assets Under Management ........................................................................................................................... 4 Item 5: Fees and Compensation ............................................................................................................................ 4 A. Fee Schedule ................................................................................................................................................... 5 B. Payment of Fees .............................................................................................................................................. 6 C. Client Responsibility For Third Party Fees ................................................................................................ 7 D. Prepayment of Fees ....................................................................................................................................... 7 E. Outside Compensation For the Sale of Securities to Clients .................................................................... 8 Item 6: Performance-Based Fees and Side-By-Side Management ................................................................... 8 Item 7: Types of Clients ......................................................................................................................................... 8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss .............................................................. 9 A. Methods of Analysis and Investment Strategies ......................................................................... 9 B. Material Risks Involved ................................................................................................................ 10 C. Risks of Specific Securities Utilized ............................................................................................. 12 Item 9: Disciplinary Information ........................................................................................................................ 14 A. Criminal or Civil Actions .............................................................................................................. 14 B. Administrative Proceedings ......................................................................................................... 14 C. Self-regulatory Organization (SRO) Proceedings ...................................................................... 14 Item 10: Other Financial Industry Activities and Affiliations ........................................................................ 14 A. Registration as a Broker/Dealer or Broker/Dealer Representative ....................................... 14 4  B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor....................................................................................................... 15 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ........................................................................................................................................... 15 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ......................................................................................................................................... 15 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 15 A. Code of Ethics ................................................................................................................................. 15 B. Recommendations Involving Material Financial Interests ...................................................... 16 C. Investing Personal Money in the Same Securities as Clients ................................................... 16 D. Trading Securities At/Around the Same Time as Clients’ Securities .................................... 16 Item 12: Brokerage Practices ............................................................................................................................... 17 A. Factors Used to Select Custodians and/or Broker/Dealers .................................................... 17 1. Research and Other Soft-Dollar Benefits ................................................................................ 17 2. Brokerage for Client Referrals .................................................................................................. 18 3. Clients Directing Which Broker/Dealer/Custodian to Use ................................................ 18 B. Aggregating (Block) Trading for Multiple Client Accounts .................................................... 18 Item 13: Review of Accounts ............................................................................................................................... 18 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews..................... 19 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts .................................. 19 C. Content and Frequency of Regular Reports Provided to Clients ........................................... 19 Item 14: Client Referrals and Other Compensation ......................................................................................... 20 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ..................................................................................................... 20 B. Compensation to Non – Advisory Personnel for Client Referrals .......................................... 21 Item 15: Custody ................................................................................................................................................... 21 Item 16: Investment Discretion ........................................................................................................................... 22 Item 17: Voting Client Securities (Proxy Voting) ............................................................................................. 22 Item 18: Financial Information ............................................................................................................................ 22 A. Balance Sheet .................................................................................................................................. 22 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ............................................................................................................... 22 5  C. Bankruptcy Petitions in Previous Ten Years .............................................................................. 23 6  1  Item 4: Advisory Business A. Description of the Advisory Firm Gervais Capital Management, LLC (hereinafter “GCMLLC”) is a Limited Liability Company organized in the State of Wyoming. The firm was formed in October 2018, and the principal owner is Donald George Gervais, Jr. B. Types of Advisory Services Portfolio Management Services GCMLLC offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. GCMLLC creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). 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 GCMLLC evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. GCMLLC will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. GCMLLC seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of GCMLLC’s economic, investment or other financial interests. To meet its fiduciary obligations, GCMLLC attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, GCMLLC’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 GCMLLC’s policy to 2  allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Pension Consulting Services GCMLLC 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: • • • identifying investment objectives and restrictions providing guidance on various assets 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 • recommending other service providers, such as custodians, administrators and broker-dealers • 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. Financial Planning 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. Services Limited to Specific Types of Investments GCMLLC generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities and private placements. GCMLLC may use other securities as well to help diversify a portfolio when applicable. 3  C. Client Tailored Services and Client Imposed Restrictions GCMLLC offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). 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 GCMLLC from properly servicing the client account, or if the restrictions would require GCMLLC to deviate from its standard suite of services, GCMLLC reserves the right to end the relationship. 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, and certain other administrative fees. GCMLLC does not participate in wrap fee programs. E. Assets Under Management GCMLLC has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $129,592,051 .00 $4,759,767 .00 December 2024 Item 5: Fees and Compensation 4  A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees All Assets 1.20% GCMLLC uses an average of the daily balance in the client's account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of GCMLLC's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 15 days' written notice. The fixed fees are billed at the standard GCMLLC hourly rate of $500 per hour with a minimum of 3 hours. The fees are paid in arrears upon completion of agreed upon work assignment. Pension Consulting Services Fees Asset-Based Fees for Pension Consulting Total Assets Under Management Annual Fee All Assets 0.50% 5  GCMLLC uses an average of the daily balance in the client's account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of GCMLLC's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the pension consulting agreement generally with 30 days' written notice. GCMLLC uses an average of the daily balance in the client’s account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Financial Planning Fees Hourly Fees The negotiated hourly fee for these services is $500 per hour with a minimum of 3 hours. GCMLLC may include the financial planning fees for portfolio management clients. Clients may terminate the agreement without penalty, for full refund of GCMLLC’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. B. Payment of Fees Payment of Portfolio Management Fees 6  Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a monthly basis. Fees are paid in arrears. Payment of Pension Consulting Fees Asset-based pension consulting fees are withdrawn directly from the client's accounts with client's written authorization on a monthly basis. Fees are paid in arrears. Fixed pension consulting fees are paid via check. These fees are paid in arrears upon completion. Payment of Financial Planning Fees Financial planning fees are paid via check and wire. Hourly financial planning fees are paid in arrears upon completion. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by GCMLLC. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees GCMLLC collects its fees in arrears. It does not collect fees in advance. 7  E. Outside Compensation For the Sale of Securities to Clients Neither GCMLLC nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management GCMLLC does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients GCMLLC generally provides advisory services to the following types of clients: ❖ ❖ ❖ ❖ Individuals High-Net-Worth Individuals Charitable Organizations Corporations or Business Entities There is no account minimum for any of GCMLLC’s services. 8  Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis GCMLLC’s methods of analysis include Cyclical analysis, Fundamental analysis, Modern portfolio theory, Quantitative analysis and Technical analysis. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Technical analysis involves the analysis of past market data; primarily price and volume. 9  Investment Strategies GCMLLC uses long term trading and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. 10  Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Investment Strategies GCMLLC's use of options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 11  C. Risks of Specific Securities Utilized GCMLLC's use of options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of 12  transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Private placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option 13  transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither GCMLLC nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. 14  B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither GCMLLC nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Donald George Gervais Jr. is Board Member - Director at Teton Village Water & Sewer District. Teton Village Water and Sewer District Board of Directors is made up of five members, who serve without compensation. Each is elected to serve a four-year term. According to state statute, officials elected to serve on the Teton Village Water and Sewer District Board of Directors must own property within district boundaries. Donald George Gervais, Jr. is an Ex- Officio Trustee of the board of Franklin & Marshall College. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections GCMLLC does not utilize nor select third-party investment advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics GCMLLC has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, 15  Recordkeeping, Annual Review, and Sanctions. GCMLLC's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests GCMLLC does not recommend that clients buy or sell any security in which a related person to GCMLLC or GCMLLC has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of GCMLLC may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of GCMLLC to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. GCMLLC will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of GCMLLC may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of GCMLLC to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, GCMLLC will never engage in trading that operates to the client’s disadvantage if representatives of GCMLLC buy or sell securities at or around the same time as clients. 16  Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on GCMLLC’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and GCMLLC may also the broker- consider the market expertise and research access provided by dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in GCMLLC's research efforts. GCMLLC will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. GCMLLC will require clients to use Charles Schwab & Co. The broker-dealer/custodian is not affiliated with GCMLLC and does not supervise GCMLLC, its representatives, or its activities. Advisor is not affiliated with the brokerage firm. Broker does not supervise the advisor, its agents or activities. 1. Research and Other Soft-Dollar Benefits (“soft dollar benefits”). GCMLLC may enter While GCMLLC has no formal soft dollars program in which soft dollars are used to pay for third party services, GCMLLC may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and GCMLLC does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. GCMLLC benefits by not having to produce or pay for the research, products or services, and GCMLLC will have an incentive to recommend a broker-dealer based 17  on receiving research or services. Clients should be aware that GCMLLC’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals GCMLLC receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use GCMLLC will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If GCMLLC buys or sells the same securities on behalf of more than one client, it might, but would be under no obligation to, aggregate or bunch, to the extent permitted by applicable law and regulations, the securities to be purchased or sold for multiple clients in order to seek more favorable prices, lower brokerage commissions or more efficient execution. In such case, GCMLLC would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. GCMLLC would determine the appropriate number of shares to place with brokers and will select the appropriate brokers consistent with GCMLLC’s duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Accounts 18  A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for GCMLLC's advisory services provided on an ongoing basis are reviewed at least Monthly by Donald, Jr. G Gervais, Principal, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at GCMLLC are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Donald, Jr. G Gervais, Principal. Financial planning clients are provided a one- time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, GCMLLC’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of GCMLLC's advisory services provided on an ongoing basis will receive a monthly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. GCMLLC will also provide at least quarterly a separate written statement to the client. Each financial planning client will receive the financial plan upon completion. 19  Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) GCMLLC does not receive any economic benefit, directly or indirectly from any third party for advice rendered to GCMLLC's clients. Charles Schwab & Co., Inc. Advisor Services provides GCMLLC with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For GCMLLC client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to GCMLLC other products and services that benefit GCMLLC but may not benefit its clients’ accounts. These benefits may include national, regional or GCMLLC specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of GCMLLC by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist GCMLLC in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other 20  market data, facilitate payment of GCMLLC’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of GCMLLC’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to GCMLLC other services intended to help GCMLLC manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to GCMLLC by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to GCMLLC. GCMLLC is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. B. Compensation to Non – Advisory Personnel for Client Referrals GCMLLC does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, GCMLLC will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Advisor is not affiliated with the custodian. The custodian does not supervise the advisor, its agents or activities. 21  Item 16: Investment Discretion GCMLLC provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, GCMLLC generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. Item 17: Voting Client Securities (Proxy Voting) GCMLLC will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet GCMLLC neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither GCMLLC nor its management has any financial condition that is likely to reasonably impair GCMLLC’s ability to meet contractual commitments to clients. 22  C. Bankruptcy Petitions in Previous Ten Years GCMLLC has not been the subject of a bankruptcy petition in the last ten years. 23