AJG and GBS, established Gallagher in 2008. Gallagher is the registered investment
adviser subsidiary of Gallagher Benefit Services, Inc. (“GBS”), one of the nation’s
largest employee benefits consulting firms. GBS, in turn, is owned by Arthur J.
Gallagher & Co. (“AJG”), the New York Stock Exchange-listed insurance brokerage and
risk management firm (trading under the symbol “AJG”). Gallagher provides retirement,
investment advice/consulting and decision-making to institutional investors, which
include public and private sector employee benefit plans (including multiemployer
plans), charitable institutions, foundations, endowments, labor organizations, state or
municipal government entities, hospitals, non-profit organizations, private trusts,
corporations or business entities, and individuals. For more information regarding
Gallagher’s institutional investor services, please see our separate ADV 2A Brochure for
institutional investors. This Brochure provides information regarding our investment
services for individuals.
Investment Services
Investment services are provided on a non-discretionary and discretionary basis, at the
direction of the client. Clients engaging us on either basis will be asked to grant such
authority upon signing the Client Agreement. Our investment advice is tailored to meet
our clients' needs and investment objectives. If you retain our firm for investment
services, we will meet with you at the beginning of our advisory relationship to
determine your investment objectives, time horizon, risk tolerance, and other relevant
information. After we meet with you, we will develop a portfolio customized to your
specific needs as we understand them based on our discussions with you. This portfolio
may be comprised of, but is not limited to, equities, mutual funds, fixed income and
exchange-traded funds.
If the client selects a discretionary basis, the client grants Gallagher ongoing and
continuous discretionary authority to make and to enter orders with a broker-dealer for
the execution of its investment recommendations in accordance with the client’s
suitability information without the client’s prior approval of each specific transaction. All
transactions in the clients’ account shall be made in accordance with the directions and
preferences provided to Gallagher by the client.
As part of our investment management services, we may use one or more third-party
money manager(s) to manage a portion of your account on a discretionary basis. While
the chosen third-party money manager(s) will provide advice on specific securities
and/or other investments in connection with this service, our firm has discretionary
authority to hire and fire such managers and reallocate assets among them as deemed
appropriate.
If the client selects a non-discretionary basis, the client grants Gallagher ongoing and
continuous non-discretionary authority to make its investment recommendations in
accordance with the suitability information provided by the client. However, Gallagher
must obtain the client’s approval of each specific recommendation prior to entering
orders with a broker-dealer for the execution of its investment recommendations. We will
monitor your accounts on an ongoing basis to ensure that they are meeting your
investment objectives and other requirements. If any changes are needed to your
investments, we will either make the changes or recommend the changes to you. You
will receive written or electronic confirmations from your account custodian after any
changes are made to your account. You will also receive statements at least quarterly
from your account custodian.
Portfolio Management Services
We also offer risk-adjusted model portfolios and strategies that are designed to meet
the needs of our clients. The model/strategy fee is in addition to your advisory fee and
may cost up to 50 basis points, depending on the model/strategy selected. The
investment management services provided by us may cost more or less than obtaining
the same or similar services through an unaffiliated investment manager. No Client or
advisor is under any obligation to utilize our portfolio management services.
The asset allocation within our models attempts to provide consistent, risk-adjusted
performance, but we cannot make any guarantees that our model allocations will
produce the desired results. Results depend upon a variety of factors and risks, some of
which are outlined below and many of which are beyond our control. Although we
continually monitor our models, client positions are rebalanced not less frequently than
quarterly. We primarily allocate client assets among various mutual funds, exchange-
traded funds (“ETFs”), and individual debt securities in accordance with each client’s
stated investment objectives.
ETF prices, like stocks, can fluctuate over a wide range in the short term or over
extended periods of time. These price fluctuations result from factors affecting individual
companies, sectors or the securities market as a whole. When buying or selling an ETF,
you will pay or receive the current market price, which can be more or less than the
underlying net asset value of its individual holdings. There is no guarantee that the
stock or bond markets or any particular mutual fund, ETF, or other security will increase
in value. We tailor our advisory services to meet the needs of our individual clients and
we seek to ensure, on a continuous basis, that our clients’ portfolios are managed in a
manner consistent with those needs and objectives. We consult with clients initially, at
the outset of our relationship, and continually in an ongoing manner to assess each of
their specific risk tolerance, time horizon, liquidity constraints, and other related factors
relevant to the management of their portfolios as they change over time. Clients are
instructed and encouraged to promptly notify us if there are changes to their financial
situations or if they wish to place any reasonable restrictions or limitations on the
management of their portfolios (so long as we determine that the conditions would not
materially affect the performance of a management strategy or prove overly
burdensome to our ability to provide our services).
Financial Planning and Consulting Services
Gallagher may provide financial planning services to Clients as part of the investment
advisory engagement or as a separate engagement, depending on the Client's financial
situation, goals, and objectives.
Generally, such financial planning services will involve preparing a financial plan or
rendering a financial consultation based on the Client's financial goals and objectives.
This planning or consulting may encompass one or more areas of need, including, but
not limited to investment planning, retirement planning, estate planning, personal
savings, education savings and other areas of a Client's financial situation.
A financial plan developed for or financial consultation rendered to the Client will usually
include general recommendations for a course of activity or specific actions to be taken
by the Client. For example, recommendations may be made that the Client start or
revise their investment programs, commence or alter retirement savings, establish
education savings and/or charitable giving programs. Gallagher may also refer Clients
to an accountant, attorney or other specialist, as appropriate for their unique situation.
For certain financial planning engagements, Gallagher will provide a written summary of
Client's financial situation, observations, and recommendations. For consulting or ad-
hoc engagements, Gallagher may not provide a written summary. Plans or consultations
are typically completed within six months of contract date, assuming all information and
documents requested are provided promptly.
Financial planning and consulting recommendations may pose a potential conflict
between the interests of the Gallagher and the interests of the Client. Clients are not
obligated
to implement any recommendations made by Gallagher or maintain an
ongoing relationship with Gallagher. If the Client elects to act on any of the
recommendations made by Gallagher, the Client is under no obligation to implement the
transaction through Gallagher. Ultimately the Client has the discretion to decide whether
to implement the plan or recommendations, and takes responsibility for this decision.
You are responsible for promptly notifying Gallagher of any material changes in the
information furnished by you regarding your financial situation, investment objectives,
time horizon, risk tolerance and other relevant information. You may at any time place
reasonable restrictions on the management of your account by notifying us of such
restrictions in writing. The Client Agreement outlines the responsibilities of both the
client and Gallagher.
Triad Wealth Management Platform
We offer investment management services through various types of accounts
established by Triad Advisors, LLC (“Triad”) on its Wealth Management Platform
(“WMP”). The Triad WMP - Advisor Managed Portfolios Program (“Advisor Managed
Portfolios”) provides comprehensive investment management of your assets through the
application of asset allocation planning software as well as the provision of execution,
clearing and custodial services through National Financial Services, Inc. (“NFS”).
Advisor Managed Portfolios provides risk tolerance assessment, efficient frontier
plotting, fund profiling and performance data, and portfolio optimization and re-balancing
tools. Utilizing these tools and based on your responses to a risk tolerance
questionnaire (“Questionnaire”) and discussions that you and your investment adviser
representative (“IAR”) have together regarding, among other things, your personal
investment objectives and goals, time horizon, risk tolerance, account restrictions,
needs, personal circumstances and overall financial situation, we construct a portfolio of
investments for you. Your IAR has the option to allocate your portfolio amongst a mix of
stocks, bonds, options, exchange-traded funds (“ETFS”), mutual funds and other
securities (“Program Investments”) which are based on your investment goals,
objectives, and risk tolerance.
Each portfolio is designed to meet your individual needs, stated goals and objectives.
Additionally, you have the opportunity to place reasonable restrictions on the types of
investments to be held in the portfolio.
The Triad WMP - Unified Managed Account Program (“UMA”) provides you with the
opportunity to invest your assets across multiple investment strategies and asset
classes by implementing an asset allocation strategy. UMA is a Wrap Account program
that offers these advisory services along with brokerage and custodial services for a
single, annual, asset-based advisory fee.
After you discuss your financial goals and objectives with your IAR, we will recommend
an asset allocation model (“UMA Model”) to you which will consist of:
a) Investment Strategies serviced and created by investment managers or your
IAR that generally consist of a selection of mutual funds, exchange traded
products, equities, and or bonds;
b) Mutual funds and ETFs (“Funds”);
c) or a combination of the preceding bundled together in an investment asset
allocation model.
We will recommend a UMA Model to you based on your responses to a Questionnaire
and discussion that we have together regarding among other things, your personal
investment objectives and goals, time horizon, risk tolerance, account restrictions,
needs, personal circumstances and overall financial situation. In addition, you can place
reasonable restrictions on investments held within your UMA account. All
recommendations in the UMA are made on a discretionary basis, which means your
IAR can act without your prior approval.
For further details regarding the Advisor Managed Portfolios or UMA, please refer to the
Triad Advisor Managed Portfolios Wrap Fee Program Brochure or the Triad WMP -
Unified Managed Account Wrap Fee Program Brochure. We provide the relevant
brochure to you prior to or concurrent with your enrollment in these programs. Please
read it thoroughly before investing.
Retirement Plan Rollovers
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.
A conflict of interest arises when we advise clients to roll over retirement assets to
accounts under our management or oversight. 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 we recommend that a client roll over their retirement plan
assets into an account under our management or oversight by Gallagher, we have a
conflict of interest as we will earn a new (or increase our current) advisory fee as a
result of the rollover. We address this conflict of interest by reviewing any such
recommendation to ensure it is in the best interest of the client. No client is under any
obligation to roll over retirement plan assets to an account managed by us.
Investment Advisor Representatives
Our firm may offer services through our network of independent investment advisor
representatives (“Reps”). Reps are not Gallagher employees and may have their own
legal business entities whose trade names and logos may be used on separate
marketing materials. The Client should understand that the businesses are legal entities
of the Reps and not of our firm. The Reps are under the supervision of our firm and the
advisory services of the Reps are provided through our firm. A complete listing of the
entities is listed on our ADV Part 1.
Wrap Fee Programs
Some of our accounts are offered through Triad’s wrap fee programs as described
above. Other accounts are offered through our wrap fee program that we sponsor at
fidelity. The advisory fee paid by the client includes advisory services, brokerage
services and custodial services in a single asset-based fee. We believe the charges and
fees offered within each wrap fee program are competitive and reasonable when
compared to alternative programs available through other firms. However, we make no
guarantee that the aggregate cost of a particular program is lower than that which may
be available elsewhere or if you were to receive these services separately. If you
participate in a wrap fee program, we will provide you with a separate Wrap Fee
Program Brochure explaining the program and costs associated with the program.
Assets Under Management
As of December 31, 2023, with respect to retail clients, Gallagher managed, on a
discretionary basis, $867,596,889 in assets.