Truist Advisory Services, Inc. (“TAS”) is an investment adviser registered with the U.S. Exchange Commission (“SEC”) and
a separate, wholly owned, non-bank subsidiary of Truist Financial Corporations (“TFC”) and an affiliate of Truist Bank (“TB”).
TAS became an investment adviser under the Investment Advisers Act of 1940 (“the Advisers Act” or “the Act”), as amended
in April, 2016. TAS is a fiduciary under the Investment Advisers Act of 1940 and is subject to the fiduciary standard imposed
by the Act, SEC Regulations and other applicable laws and regulations.
This brochure covers the following TAS advisory services: Consulting Plan Sponsor Services, Plan Participant Services,
and the AMC Advantage Program.
Unless otherwise expressly permitted by the terms of the AMC Advantage Program, investment in the AMC Advantage
Program described in this brochure requires that Client separately maintain or open an underlying brokerage account with
TAS’s affiliated broker-dealer and insurance agency, Truist Investment Services, Inc. (“TIS”). Client’s TIS brokerage account
and brokerage relationship is governed by Client’s TIS Brokerage Account Customer Agreement (“Brokerage Agreement”).
TIS is a member of the Financial Industry Regulatory Authority (“FINRA”) and Securities Investor Protection Corporation
(“SIPC”). TIS is an introducing broker-dealer clearing its trades through National Financial Services LLC (“NFS”). TIS also
acts as Non-Bank Custodian for most IRA accounts which are advised and/or managed by TAS and through NFS, currently
acting as TIS’s agent, has custody of securities held by AMC Program accounts. Fidelity Management Trust Company, an
affiliate of NFS, serves as Non-Bank Custodian for all AMC Program IRA accounts not presently serviced by TIS in this
capacity (“FMTC Custodian Accounts”).
The requirement to open a brokerage account with an affiliated broker is made by TAS for purposes of efficiently
administering its AMC Advantage Program and this requirement also provides additional benefits to TAS and its affiliates which
create additional conflicts of interest with respect to TAS’s management of AMC Program Accounts. See Conflicts of Interest
–Use of Affiliated Broker Dealer Section below.
Clients retain ownership of all cash, securities, and other investments in their AMC Advantage Program Accounts.
Investment Consulting Services, including Plan Sponsor and Plan Participant Services Accounts, require that Client open
a record account with TIS for anti-money laundering (“AML”) purposes. The record brokerage account cannot be an existing
TIS brokerage or TAS advisory program account, will not have trading effected and no statements will be generated.
Clients have the option to purchase investment products that we recommend through other broker-dealers or agents that
are not affiliated with TIS.
Key Third Party Service Providers
TAS has contracted with Envestnet Asset Management, Inc. a SEC registered investment adviser (“Envestnet” or “Platform
Manager”) for administrative services related to the AMC Advantage Program.
TAS has contracted with Envestnet Retirement Solutions, LLC (“ERS”), a SEC registered investment adviser and affiliates
of Envestnet for services related to the Plan Sponsor Services including access to their platform system for servicing
retirement plans. Plan Sponsors can also elect ERS as Investment Manager. Clients should review ERS’ Form ADV 2A
Brochure related to these services. ERS also provides the standard Investment Policy Statement (“IPS”) utilized.
Client Service Structure
TAS generally provides investment managed and investment advisory services utilizing one of the following business
channels:
Self-Directed Brokerage Accounts – Client Investible Assets Below $50,000.
Client Advisory Center (“CAC”)
Brokerage and Investment Advisory Accounts -– Client Investible Assets between $50,000 and $100,000; and
Full-Service Brokerage and Investment Advisory – Client Investible Assets Above $100,000.
Services and Program Described in this Brochure
Consulting Services
Asset Allocation Analysis and Investment Policy. TAS provides services which typically involve analyzing Client liquidity
requirements, performance goals and risk tolerance levels as described to TAS by Client. As a result of the review asset
allocation and diversification recommendations may be made.
Recommendations as to the Investment and Reinvestment of Assets. TAS provides recommended transactions (buy, sell,
exchange), related to assets in Client’s accounts and include, but not limited to, common and preferred stocks, shares in
mutual funds, closed-end funds, exchange traded funds, separately managed accounts, options, warrants, rights and
corporate, municipal or government bonds, notes or bills.
Fund Performance Monitoring and Evaluation. TAS will monitor mutual funds and/or managed accounts on a periodic basis
based upon custodial statements for Client accounts and information obtained and analyzed from a wide variety of public
and private sources. Although the information collected by us is believed to be reliable, TAS does not independently verify
this information nor does TAS guarantee the accuracy or validity of such information.
Consulting Services program accounts are prohibited on TIS brokerage accounts.
Plan Sponsor Services
TAS and ERS act as 3(21) co-fiduciaries for these plans in non-discretionary capacities. Specific services of TAS and its
Advisors include providing the Plan Sponsor with the ERS Investment Policy Statement (“IPS”); providing non-discretionary
advice to Plan Sponsor with respect to recommendations related to record keepers and/or third-party administrators
(“TPAs”), the initial and ongoing investment selections within the universe provided by the record keeper; and/or conducting
employee educational meetings and providing quarterly reports and fee benchmarking reports. Our standard service
includes up to four (4) hours related to educational meetings. Additional meetings are available and subject to additional
charges, see Fees and Compensation section for details below.
ERS provides the Investment Policy Statements and conducts the ongoing due diligence related to the universe of
investments on the record keeper’s platform selected by the Plan Sponsor and Advisor, see ERS’ Form ADV 2A Brochure
related to these services.
TAS’ Retirement Plans Consulting Group (“RPCG”)
oversees the Plan Sponsor Services and reports changes to the
services to the TAS AMC Managed Accounts and Product Working Groups on an as needed basis. Changes are reported
to the TAS Policy Committee for ratification.
If an Advisor is unable to manage Client accounts or leaves the firm, TAS will continue to render such services and will
assign a new Advisor to the account.
Depending upon the needs of plan sponsors, Advisor can also recommend ERS 3(38) Advisory services which gives
Envestnet ERS full discretion over the fund lineup and any changes. The TAS Advisor will continue to communicate changes
to the Client. See ERS’ Form ADV 2A Brochure related to these services.
Plan Participant Services
TAS offers discretionary and non-discretionary plan participant services; however, advising participants of plan sponsors
who are Clients of TAS is prohibited. Discretionary services apply to the Truist 401k and Deferred Compensation Plans. All
other retirement and deferred compensation plans are offered on a non-discretionary basis.
Truist 401k plan participant assets are held at Fidelity Capital Management, Inc., an affiliate of NFS, TAS’ affiliate’s, Truist
Investment Services, Inc. (“TIS”), clearing and executing broker-dealer. Other 401k plan participant assets are held away
from TIS on other custodial platforms.
TAS Advisors perform the following services:
• Provide advice to Plan Participant regarding the design of Plan Participant’s investment policy statement (“IPS”) as
it relates to all of the Client’s investments, specifically the qualified plan assets;
• provide advice to Plan Participant with respect to the investment selection process; Design and maintain asset
allocation models for the Plan Participant’s use. The asset allocation models will apply to the Client’s qualified and
non-qualified assets;
• Provide advice relative to rebalancing the Plan Participant’s qualified assets to a pre-determined level as it relates
to the overall projected target;
• Provide quarterly reviews and monitoring of Plan Participant’s investment options to examine compliance with the
Investment Policy Statement (“IPS”). Investment options not in adherence to the IPS will be brought to the attention
of the Plan Participant.
• Provide educational input regarding deferral percentage and “what if” scenarios regarding retirement goals.
TAS’ Retirement Plans Consulting Group (“RPCG”) oversees the Plan Participant Services and reports changes to the
services to the TAS AMC Managed Accounts and Product Working Group on an as needed basis. Changes are reported
to the TAS Policy Committee for ratification.
If an Advisor is unable to manage Client accounts or leaves the firm, TAS will continue to render such services and will
assign a new Advisor to the account.
AMC Advantage Program
AMC Advantage (the “Program”) is a program that allows the Client, with our TAS Advisers assistance and consultation, to
choose one or more Investment Managers (“Managers”), which may or may not participate in the Firm’s separate AMC
Premier Program, to manage the Client’s assets on a discretionary basis. The Program is currently closed to new Clients,
requiring an exception. AMC Advantage allows the Client to define his or her investment objectives, develop an asset
allocation strategy to match those goals and objectives, and monitor investment performance. TAS does not exercise
investment discretion for the Client; instead, may make recommendations that the Client may or may not follow. The ultimate
selection of Manager is made by, and is the sole responsibility of, the individual Client. The Client will contract directly with
a Manager in addition to and separately from the Client’s contract with TAS.
Information about the Manager will be prepared by the Manager and is made available through the Manager. The Manager’s
Brochure describes its processes for the Program and should be read by the Client along with this TAS Brochure before
investing in the Program.
TAS will collect financial information from Clients using an investment questionnaire and based on that information, assist
Clients in establishing appropriate goals and objectives and an investment strategy for their investment portfolio(s).
It is the Client’s duty to inform TAS of any changes in the Client’s financial circumstances or if the Client wishes to change
or impose new instructions for the management of the Client’s account. TAS will notify each Client in writing quarterly,
requesting the Client to contact us about any changes in the Client’s financial circumstances or investment objectives.
Through a TAS Advisor, TAS will request consultation with the Client at least annually to determine if there have been any
changes in the Client’s financial situation or investment objectives, and whether the Client wishes to change, or impose
new, instructions for the management of the Client’s account. If the Client’s financial situation, investment objectives, or
instructions do change, we will consult with the Client on how those changes affect the Client’s account.
While most Managers are not offered in the AMC Sentry Program or AMC Premier Programs (see specific brochure for
program details), Clients may select a Manager that is affiliated with TAS or offered in these other AMC Programs.
Managers hired by a Client are sent information on the Client’s financial circumstances, investment goals and objectives,
and any special instructions the Client may wish to give the Manager regarding the account. As discussed below, AMC
Advantage Clients generally pay separate investment management fees to the Managers on a basis agreed to between the
Client and the Manager. Any investment management fee paid to a Manager is in addition to the Program Fee described
below or other compensation paid to TAS.
TAS provides portfolio management for AMC Fund Select Tactical, AMC Fund Select Tactical – Focus, AMC Pinnacle and
certain model accounts in the AMC Premier Program at the firm level and receives a portion of the management fee for that
service. The firm does not manage any other Client accounts; its Advisors, however, do manage Client accounts either on
a discretionary or non-discretionary basis.
Total TAS AMC Program Assets Under Management as of December 31. 2023
Accounts AUM
Discretionary 109,523 $ 48,528,680,981
Non-Discretionary 14,678 $ 12,841,175,564
124,201 $ 61,369,856,745