A. Argent Advisors, Inc. (the “Registrant”) is a corporation formed in January 1996 in the
state of Louisiana. The Registrant became registered as an investment adviser firm in April
2004 and became a registered Municipal Advisor in 2018. The Registrant is principally
owned by Argent Financial Group, Inc. Mike Jones is the Registrant’s President.
B.
INVESTMENT ADVISORY SERVICES
The Registrant provides discretionary investment advisory services on a fee basis. The
Registrant’s annual investment advisory fee is based upon a percentage (%) of the market
value of the assets placed under the Registrant’s management. When consistent with a
client’s stated investment objectives, Registrant may also allocate client’s investment
assets among one or more mutual fund asset allocation programs as fully described in Item
8 below.
Argent Trust Company (“ATC”), and Registrant are wholly owned subsidiaries of Argent
Financial Group. ATC may provide portfolio management services for advisory accounts
custodied at ATC as well as those accounts custodied elsewhere. In addition, Registrant
may utilize the services of other independent investment advisers pursuant to a sub-
advisory agreement between the Registrant and the independent investment adviser.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
The Registrant provides financial planning and/or consulting services (including
investment and non-investment related matters, including estate planning, insurance
planning, etc.) on a stand-alone separate fee basis. Registrant’s planning and consulting
fees are negotiable depending upon the level and scope of the service(s) required and the
professional(s) rendering the service(s).
Prior to engaging the Registrant to provide planning or consulting services, clients are
generally required to enter into a Financial Planning and Consulting Agreement with
Registrant setting forth the terms and conditions of the engagement (including
termination), describing the scope of the services to be provided, and the portion of the fee
that is due from the client prior to Registrant commencing services.
If requested by the client, Registrant may recommend the services of other professionals
for implementation purposes, including certain of the Registrant’s representatives in their
individual capacities as registered representatives of LPL Financial Corporation (“LPL”)
and/or licensed insurance professionals. (See disclosures at Item 10.C. below). Clients are
under no obligation to engage the services of any such recommended professional. Clients
retains absolute discretion over all such implementation decisions and are free to accept or
reject any recommendation from the Registrant.
If a client engages an unaffiliated recommended professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from
and against the engaged professional. At all times, the engaged licensed professional, and
not Registrant, shall be responsible for the quality and competency of the services
provided. The preceding sentence shall not limit or waive any applicable rights under
federal or state law, including securities laws and fiduciary obligations that cannot be
limited or waived.
It remains the client’s responsibility to promptly notify the Registrant if there is ever any
change in their financial situation or investment objectives for the purpose of reviewing,
evaluating or revising Registrant’s previous recommendations and/or services.
RETIREMENT PLAN SERVICES
The Registrant also provides retirement plan consulting/management services, pursuant to
which it assists sponsors of self-directed retirement plans organized under the Employee
Retirement Security Act of 1974 (“ERISA”). The terms and conditions of the engagement
shall be set forth in a Retirement Plan Services Agreement between the Registrant and the
plan sponsor.
If the plan sponsor engages the Registrant in an ERISA Section 3(21) capacity, the
Registrant will assist with the selection and/or monitoring of investment options (generally
open-end mutual funds and exchange traded funds) from which plan participants shall
choose in self-directing the investments for their individual plan retirement accounts. If
the plan sponsor chooses to engage the Registrant in an ERISA Section 3(38) capacity,
Registrant may provide the same services as described above, but may also: create specific
asset allocation models that Registrant manages on a discretionary basis, which plan
participants may choose in managing their individual retirement account; and/or modify
the investment options made available to plan participants on a discretionary basis.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. As indicated above, to the extent requested by a client, the Registrant may
provide financial planning and related consulting services regarding non-investment
related matters, such as estate planning, tax planning, insurance, etc.
The Registrant does not serve as an attorney or accountant, and no portion of our services
should be construed as legal or accounting services. Accordingly, the Registrant does not
prepare estate planning documents or tax returns. To the extent requested by a client, we
may recommend the services of other professionals for certain non-investment
implementation purpose (i.e., attorneys, accountants, insurance, etc.), including
representatives of Registrant in their separate individual capacities as representatives of
LPL and/or as licensed insurance agents. Clients are under no obligation to engage the
services of any such recommended professional. The client retains absolute discretion over
all such implementation decisions and is free to accept or reject any recommendation from
Registrant and/or its representatives.
If the client engages any recommended unaffiliated professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from
and against the engaged professional. At all times, the engaged licensed professional[s],
and not Registrant, shall be responsible for the quality and competency of the services
provided. The preceding sentence shall not limit or waive any applicable rights under
federal or state law, including securities laws and fiduciary obligations that cannot be
limited or waived.
Municipal Advisor. The Registrant is registered with the SEC and MSRB as a municipal
advisor. In such capacity the Registrant can provide consulting services to municipalities,
generally regarding municipal funding needs.
Sub-Advisory Arrangement. The Registrant has entered into a sub-advisory agreement
with ATC. ATC is an affiliated custodian and trust company.
The Registrant has engaged ATC specifically to maintain the Managed Asset Portfolio the
Registrant makes available to its clients (See Item 8 Below). As a sub-advisor, ATC shall
have discretionary authority for the day-to-day management of the assets that are allocated
to it by the Registrant. ATC shall continue in such capacity until the arrangement is
terminated or modified by the Registrant. The Registrant shall pay a portion of the
investment advisory fee received for these allocated assets to the sub-advisor for its sub-
advisory services.
Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or
prospective client leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money in
the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s
plan, if one is available and rollovers are permitted, (iii) roll over to an Individual
Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending
upon the client’s age, result in adverse tax consequences). If the Registrant provides a
recommendation as to whether a client should engage in rollover or not, the Registrant is
acting as an ERISA fiduciary by making such recommendation. Furthermore, if the
Registrant recommends that a client roll over their retirement plan assets into an account
to be managed by the Registrant, such a recommendation creates a conflict of interest if
the Registrant will earn new (or increase its current) compensation as a result of the
rollover. If Registrant provides a recommendation as to whether a client should engage in
a rollover or not, Registrant is acting as a fiduciary 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. No client is under any obligation
to roll over retirement plan assets to an account managed by Registrant, whether it is from
an employer’s plan or an existing IRA.
Use of Mutual and Exchange Traded Funds. Most mutual funds and exchange traded
funds are available directly to the public. Therefore, a prospective client can obtain many
of the funds that may be utilized by Registrant independent of engaging Registrant as an
investment advisor. However, if a prospective client determines to do so, they will not
receive Registrant’s initial and ongoing investment advisory services. In addition to
Registrant’s investment advisory fee described below, and transaction and/or custodial fees
discussed below, clients will also incur, relative to all mutual fund and exchange traded
fund purchases, charges imposed at the fund level (e.g., management fees and other fund
expenses).
Independent Managers. The Registrant may allocate a portion of the client’s investment
assets among unaffiliated independent investment managers in accordance with the client’s
designated investment objective(s). In such situations, the Independent Manager[s] shall
have day-to-day responsibility for the active discretionary management of the allocated
assets, including, to the extent applicable, proxy voting responsibility. Registrant shall
continue to render investment supervisory services to the client relative to the ongoing
monitoring and review of account performance, asset allocation and client investment
objectives. Factors that Registrant shall consider in recommending Independent
Manager[s] include the client’s designated investment objective(s), management style,
performance, reputation, financial strength, reporting, pricing, and research. The
investment management fee charged by the Independent Manager[s] is separate from, and
in addition to, Registrant’s investment advisory fee disclosed at Item 5 below.
Socially Responsible Investing Limitations. Socially Responsible Investing involves the
incorporation of Environmental, Social and Governance
(“ESG”) considerations into the
investment due diligence process. ESG investing incorporates a set of criteria/factors used
in evaluating potential investments: Environmental (i.e., considers how a company
safeguards the environment); Social (i.e., the manner in which a company manages
relationships with its employees, customers, and the communities in which it operates);
and Governance (i.e., company management considerations). The number of companies
that meet an acceptable ESG mandate can be limited when compared to those that do not
and could underperform broad market indices. Investors must accept these limitations,
including potential for underperformance. Correspondingly, the number of ESG mutual
funds and exchange-traded funds are limited when compared to those that do not maintain
such a mandate. As with any type of investment (including any investment and/or
investment strategies recommended and/or undertaken by Registrant), there can be no
assurance that investment in ESG securities or funds will be profitable or prove
successful. Registrant does not maintain or advocate an ESG investment strategy but will
seek to employ ESG if directed by a client to do so. If implemented, Registrant shall rely
upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or
separate account portfolio manager to determine that the fund’s or portfolio’s underlying
company securities meet a socially responsible mandate.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from
account transactions or new deposits, be swept to and/or initially maintained in a
specific custodian designated sweep account. The yield on the sweep account will
generally be lower than those available for other money market accounts. When this
occurs, to help mitigate the corresponding yield dispersion Registrant shall (usually within
30 days thereafter) generally (with exceptions) purchase a higher yielding money market
fund (or other type security) available on the custodian’s platform, unless Registrant
reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day
period to purchase additional investments for the client’s account. Exceptions and/or
modifications can and will occur with respect to all or a portion of the cash balances for
various reasons, including, but not limited to the amount of dispersion between the sweep
account and a money market fund, the size of the cash balance, an indication from the client
of an imminent need for such cash, or the client has a demonstrated history of writing
checks from the account.
The above does not apply to the cash component maintained within a Registrant actively
managed investment strategy (the cash balances for which shall generally remain in the
custodian designated cash sweep account), an indication from the client of a need for access
to such cash, assets allocated to an unaffiliated investment manager and cash balances
maintained for fee billing purposes.
The client shall remain exclusively responsible for yield dispersion/cash balance decisions
and corresponding transactions for cash balances maintained in any Registrant unmanaged
accounts.
Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the
client’s best interest. As part of its investment advisory services, Registrant will review
client portfolios on an ongoing basis to determine if any changes are necessary based upon
various factors, including, but not limited to, investment performance, fund manager
tenure, style drift, account additions/withdrawals, and/or a change in the client’s
investment objective. Based upon these factors, there may be extended periods of time
when Registrant determines that changes to a client’s portfolio are neither necessary nor
prudent. Of course, as indicated below, there can be no assurance that investment decisions
made by Registrant will be profitable or equal any specific performance level(s). Clients
nonetheless remain subject to the fees described in Item 5 below during periods of account
inactivity.
Cash Positions. Registrant continues to treat cash as an asset class. As such, unless
determined to the contrary by Registrant, all cash positions (money markets, etc.) shall
continue to be included as part of assets under management for purposes of calculating
Registrant’s advisory fee. At any specific point in time, depending upon perceived or
anticipated market conditions/events (there being no guarantee that such anticipated market
conditions/events will occur), Registrant may maintain cash positions for defensive
purposes. In addition, while assets are maintained in cash, such amounts could miss market
advances. Depending upon current yields, at any point in time, Registrant’s advisory fee
could exceed the interest paid by the client’s money market fund.
Pontera. The Registrant uses Pontera, a third party platform to facilitate the management
of held away assets such as defined contribution plan participant accounts, with discretion.
Those clients who choose to engage the Registrant to service their held away accounts will
be provided a link to connect their outside accounts to the platform. Once the client’s
account(s) is connected to the platform, Registrant will review the client’s current account
allocations. Registrant will rebalance the connected outside accounts consistent with the
client’s investment goals and risk tolerance. Client account(s) will be reviewed at least
quarterly. Pontera’s fee of 25 basis points, based upon the value of the client’s held away
assets managed through the Pontera platform, is in addition to the Registrant’s investment
management fee.
Interval Funds/Risks and Limitations. Where appropriate, Registrant may utilize
interval funds (and other types of securities that could pose additional risks, including lack
of liquidity and restrictions on withdrawals). An interval fund is a non-traditional type
of closed-end mutual fund that periodically offers to buy back a percentage of outstanding
shares from shareholders. Investments in an interval fund involve additional risk, including
lack of liquidity and restrictions on withdrawals.
During any time periods outside of the specified repurchase offer window(s), investors will
be unable to sell their shares of the interval fund. There is no assurance that an investor
will be able to tender shares when or in the amount desired. There can also be situations
where an interval fund has a limited amount of capacity to repurchase shares, and may not
be able to fulfill all purchase orders. In addition, the eventual sale price for the interval
fund could be less than the interval fund value on the date that the sale was requested.
While an internal fund periodically offers to repurchase a portion of its securities, there is
no guarantee that investors may sell their shares at any given time or in the desired amount.
As interval funds can expose investors to liquidity risk, investors should consider interval
fund shares to be an illiquid investment. Typically, the interval funds are not listed on any
securities exchange and are not publicly traded. Thus, there is no secondary market for the
fund’s shares.
Because these types of investments involve certain additional risk, these funds will only be
utilized when consistent with a client’s investment objectives, individual situation,
suitability, tolerance for risk and liquidity needs. Investment should be avoided where an
investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of
the investment. There can be no assurance that an interval fund investment will prove
profitable or successful. In light of these enhanced risks, a client may direct Registrant, in
writing, not to purchase interval funds for the client’s account.
Client Obligations. In performing its services, Registrant shall not be required to verify
any information received from the client or from the client’s other professionals, and is
expressly authorized to rely thereon. Moreover, each client is advised that it remains their
responsibility to promptly notify the Registrant if there is ever any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating or revising
Registrant’s previous recommendations and/or services.
Cybersecurity Risk. The information technology systems and networks that Registrant
and its third-party service providers use to provide services to Registrant’s clients employ
various controls, which are designed to prevent cybersecurity incidents stemming from
intentional or unintentional actions that could cause significant interruptions in Registrant’s
operations and result in the unauthorized acquisition or use of clients’ confidential or non-
public personal information. Clients and Registrant are nonetheless subject to the risk of
cybersecurity incidents that could ultimately cause them to incur losses, including for
example: financial losses, cost and reputational damage to respond to regulatory
obligations, other costs associated with corrective measures, and loss from damage or
interruption to systems. Although Registrant has established procedures to reduce the risk
of cybersecurity incidents, there is no guarantee that these efforts will always be successful,
especially considering that Registrant does not directly control the cybersecurity measures
and policies employed by third-party service providers. Clients could incur similar adverse
consequences resulting from cybersecurity incidents that more directly affect issuers of
securities in which those clients invest, broker-dealers, qualified custodians, governmental
and other regulatory authorities, exchange and other financial market operators, or other
financial institutions.
Disclosure Brochure. A copy of the Registrant’s written Brochure as set forth on Part 2A
of Form ADV as well as a copy of the Registrant’s Client Relationship Summary as set
forth on Form CRS shall be provided to each client prior to, or contemporaneously with,
the execution of the Investment Advisory Agreement or Financial Planning and Consulting
Agreement.
C. The Registrant shall provide investment advisory services specific to the needs of each
client. Prior to providing investment advisory services, an investment adviser
representative will ascertain each client’s investment objective(s). Thereafter, the
Registrant shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s). The client may, at any time, impose
reasonable restrictions, in writing, on the Registrant’s services.
D. The Registrant does not participate in a wrap fee program.
E. As of December 31, 2023, the Registrant had $ 1,365,398,340 in assets under management
on a discretionary basis.