About Our Firm Guilbault Capital, LLC (“Guilbault Capital”) is a registered investment adviser that provides investment management and financial advisory services to individual and institutional investors to help them achieve their financial needs and goals. Guilbault Capital has been a registered investment adviser since 2024. Charles Guilbault is the sole shareholder of the firm. Guilbault Capital takes pride in providing personalized service to our clients and acknowledges that it is held to a fiduciary standard of care. Types of Advisory Services We Offer Guilbault Capital offers a variety of investment advisory services to individuals, high net worth individuals, pension and profit-sharing plans, and businesses/corporations. These services include:
• Investment and wealth management
• Selection of other advisers
• Financial planning and consulting
• Fiduciary and non-fiduciary services for plan sponsors We work with our clients to determine their investment objectives and risk profile and develop and execute a customized investment plan based on their individual needs and goals. Guilbault Capital utilizes the financial information provided by clients to analyze and develop strategies and solutions to assist clients in meeting their financial goals. Prior to Guilbault Capital rendering any of the foregoing services, clients are required to enter into one or more written advisory agreements with Guilbault Capital setting forth the relevant terms and conditions of the advisory relationship. Investment and Wealth Management Services As part of our investment and portfolio management services, we offer:
• Investment policy development
• Asset allocation analysis
• Product due diligence
• Investment and portfolio monitoring
• Wealth management strategies Guilbault Capital manages our clients’ portfolios on a discretionary and non-discretionary basis. Our investment and portfolio management services are tailored to the needs of our clients and are based on a comprehensive understanding of each client’s current situation, past experiences, and future goals. With this acquired knowledge we create, analyze, strategize, and implement goal- oriented investment solutions. These solutions become our clients’ investment policy. This policy and our matched strategies are designed to be risk appropriate, cost effective and tax efficient. Client assets are primarily allocated among stocks, bonds, exchange-traded funds ("ETFs") and mutual funds in accordance with the client's stated investment objective and risk/volatility parameters. We may also recommend clients allocate a certain portion of their assets to alternative investments and/or fee-based annuities based upon the specific needs and risk tolerance of the client. Clients may also engage Guilbault Capital to manage or provide advice on investment products that are not maintained at the client’s primary custodian (held away accounts), such as variable life insurance and annuity contracts, as well as assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). These assets are generally maintained at the underwriting insurance company or custodian for the plan trustee or administrator and clients typically retain responsibility for effecting trades in these accounts. In certain situations, Guilbault Capital retains discretion to manage held away accounts, such as a management and monitoring of subaccounts in a fee-based variable annuity. You should refer to your advisory agreement for the specific terms of the investment and wealth management services Guilbault Capital provides for your account(s). Guilbault Capital consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. You should promptly notify us if there are changes in your financial situation or if you wish to place any limitations on the management of your account. You may impose reasonable restrictions or mandates on the management of your account if Guilbault Capital determines, in our sole discretion, the conditions will not materially impact the performance of a management strategy or prove overly burdensome to the firm's management efforts. To the extent your assets are invested in a particular fund, those funds will have their own investment practices, which are described in each fund’s prospectus or offering or other disclosure documents. In addition, selected funds typically have discretion to determine the type and amount of securities to be purchased or sold for the portion of the assets managed by the fund. Selection of Third-Party Asset Managers Guilbault Capital may select certain third-party asset managers to actively manage all or a portion of its clients' assets. Pursuant to the terms of the investment advisory agreement, Guilbault Capital shall have the discretion to appoint and terminate these third-party managers. The specific terms and conditions under which a client engages a third-party manager may also be set forth in a separate written agreement with the designated manager. Certain third-party managers require a separate investment advisory agreement directly with the manager, while others do not. In addition to this brochure, clients will also receive the written disclosure documents of the third-party engaged to manage their assets. Guilbault Capital evaluates a variety of information about third-party managers, which may include the manager’s public disclosure documents, materials supplied by the manager and other third-party analyses we believe are reputable. To the extent possible, Guilbault Capital seeks to assess the manager’s investment strategies, past performance, and risk results in relation to its clients' individual portfolio allocations and risk exposure. Guilbault Capital also takes into consideration each manager’s management style, returns, reputation, financial strength, reporting, pricing, and research capabilities, among other factors. Third-party asset managers utilized by Guilbault Capital include:
• Unified managed account managers and a mutual fund advisory program available through Wells Fargo & Company (“Wells Fargo”). Guilbault Capital continues to provide services relative to the discretionary or non-discretionary selection of third-party managers. On an ongoing basis, Guilbault Capital monitors the performance of those accounts being managed by third-party managers. Guilbault seeks to ensure third-party managers’ strategies and target allocations remain aligned with the client's investment objectives and overall best interests. Programs Offered Through Wells Fargo When utilizing third-party managers through Wells Fargo Advisors or managers available through a program offered by Wells Fargo, investment management services are provided through the Personalized Unified Managed Account Program or FundSource Program.

The Wells Fargo programs require clients to sign an investment advisory agreement for access to their programs in addition to our investment management agreement. Financial Planning and Consulting Services Guilbault Capital offers different levels of financial planning and consulting services to help our clients identify, prioritize and work towards their goals and objectives. Our consulting services give our clients the ability to receive a broad range of financial advice and services, including specific security recommendations, for the duration of the advisory agreement. Our process starts with an extensive review of a client's family situation, which includes assets and liabilities, as well as estate, tax, and insurance needs. We then employ a risk tolerance and risk capacity-focused simulation to get a detailed cash flow analysis and proposed asset allocation. Together, this information is analyzed to develop a proposed financial plan, which is designed to be dynamic in nature, evolving overtime due to life changes, along with changes in cash flow needs, risk tolerance, time horizon or investment objectives. Guilbault Capital’s financial planning and consulting services may include any of the following topics:
• Cash Flow Analysis and Forecasting
• Risk Management
• Trust & Estate Planning
• Charitable Giving
• Education Planning
• Business Planning
• Retirement Planning
• Liability Management
• Investment Consulting
• Distribution Planning
• Tax Planning
• Insurance Review
• Next Generation Family
• Retirement Plan Consulting and Employee Benefits Analysis While each of these services is available on a stand-alone basis, certain financial planning services are rendered in conjunction with investment and wealth management services. In performing these services, Guilbault Capital is not required to verify any information received from the client or from the client's other engaged professionals (e.g., attorneys, accountants, etc.), and is expressly authorized to rely on such information. Guilbault Capital may recommend clients engage the firm for additional related services, or we may recommend other professionals to implement our recommendations. These additional services by Guilbault Capital or another professional are provided at an additional cost to you, which is based on the nature, extent, complexity, and other characteristics of the services. This creates a conflict of interest because we will have an incentive to recommend additional services based on the compensation to be received by Guilbault Capital, rather than solely based on your needs, and in some cases, based on the prospect of cross-referrals of advisory clients from the other professional or his or her firm. Implementation of financial planning recommendations is entirely at your discretion. You have complete freedom in selecting another financial adviser to assist you with implementing the recommendations made in your financial plan and are under no obligation to act on the advice of Guilbault Capital. Financial planning recommendations are of a generic nature and are not limited to any specific product or service offered by a broker dealer or insurance company. Should you choose to implement the recommendations contained in the plan, Guilbault Capital suggests you work closely with your attorney, accountant and/or insurance agent. Guilbault Capital will act solely in our capacity as a registered investment adviser and does not provide any legal, accounting or tax advice. You should seek the counsel of a qualified accountant and/or attorney when necessary. As part of our advisory services, from time to time we assist clients with tax loss harvesting and work with the client’s tax specialist to answer any questions related to the client’s portfolio. Any incidental tax discussions on topics, such as required minimum distributions, retirement plan contributions, etc., should be verified with your tax advisor. Fiduciary and Non-Fiduciary Services for Plan Sponsors Retirement plan sponsors may retain our firm to provide advisory and consulting services for plan assets. Fiduciary services available to plan sponsors include:
• Reviewing and assisting in the establishment of investment policies and objectives on behalf of the plan
• Assistance with development of an Investment Policy Statement
• Recommending core investments to be offered to plan participants for selection by the plan sponsor
• Recommending investment managers, within the meaning of ERISA Section 3(38), on behalf of the plan, to be offered as investment options for plan participants
• Monitoring of the plan’s investments or investment managers in accordance with the plan’s Investment Policy Statement or other relevant guidelines Non-fiduciary consulting services available to plan sponsors include:
• Educating plan participants on investment options available within the plan
• Preparation of periodic performance reports for the plan’s investments
• Assistance with monitoring the reasonableness of the fees and expenses of the plan’s investments or investment managers in accordance with the plan’s Investment Policy Statement or other relevant guidelines
• Benchmarking existing plan service providers to industry peers, and where appropriate, conducting a search for new providers for the plan sponsor’s consideration and providing our recommendation Portfolio Management Services for Wrap Fee Program Guilbault Capital offers portfolio management services through a wrap fee program. A bundled or “wrap fee” program is an advisory fee program under which you pay one bundled fee to compensate Guilbault Capital for portfolio management, transaction costs and custodial services. A wrap fee program may not be the lowest cost option if you would like to restrict your investments to open-end mutual funds or other long-term investment products. Amount of Assets We Manage As of April 2024, Guilbault Capital does not have any discretionary or non-discretionary assets under management or advisement. Discretionary assets under management are those for which we have an ongoing responsibility to select and make securities recommendations that are in line with your financial needs and objectives and then effect those securities transactions without first consulting you. Non-discretionary assets under management are those for which we have an ongoing responsibility to select and make securities recommendations that are in line with your financial needs and objectives and then effect those securities transactions only after consulting with you to inform you of the transaction(s) and obtaining your approval to move forward. Assets under advisements are assets of participant-directed 401k plans and other self-directed retirement plans for which Guilbault Capital provides investment advice but are not deemed assets under management.