A. Description of the Advisory Firm TCP Asset Management, LLC (hereinafter “TCPAM”) is a Limited Liability Company organized in the State of Ohio. The firm was formed in November 2016, and the principal owners are Phillip J Susi, Joshua Richard Allen, Philip Hunter Bervig and Branda Rhae Allen. B. Types of Advisory Services Portfolio Management Services TCPAM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. TCPAM creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Portfolio management services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring TCPAM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. TCPAM 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. TCPAM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of TCPAM’s economic, investment or other financial interests. To meet its fiduciary obligations, TCPAM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, TCPAM’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 TCPAM’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. TCPAM will also offer Fixed Income SMA strategies seeking to provide income while limiting risk to your investment over the long term. Our strategy will invest clients assets directly in individual bonds. TCPAM may direct clients to third-party investment advisers to manage all or a portion of the client’s assets. Before selecting other advisers for clients, TCPAM will always ensure those other advisers are properly licensed or registered as an investment adviser. TCPAM conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser’s performance and investment strategy. TCPAM then makes investments with a third-party investment adviser by referring the client to the third-party adviser. TCPAM will review the ongoing performance of the third-party adviser as a portion of the client’s portfolio. TCPAM Models TCPAM has entered into an agreement with Orion Portfolio Solutions and SEI to provide its model portfolios as a strategy available to Investment Adviser Representatives (“IAR”) of TCPAM. TCPAM makes investment decisions for the model portfolios and continuously reviews, supervises and administers the model portfolios as outlined in the Fund’s disclosure brochure. TCPAM provides discretionary portfolio management services to Orion Portfolio Solutions and SEI using model asset allocation portfolios. Each model portfolio is designated to meet a particular investment goal. Interested Clients should refer to Orion Portfolio Solutions’ and SEI’s disclosure brochure for important information regarding objectives, investments, time-horizon, risks, fees, and additional disclosures. First Trust Sub-Advised Models IARs of TCPAM have access to the models listed below. The accounts are sub-advised by First Trust but TCPAM initiates the trades. The four models in this fee arrangement are as follows:
• First Trust Alternatives Model Portfolio
• First Trust Conservative Growth Model Portfolio
• First Trust Balanced Growth Model Portfolio
• First Trust Moderate Growth Model Portfolio
• First Trust All Equity Model Portfolio Pension Consulting Services TCPAM 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
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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. Estate Planning TCPAM has partners with Wealth.com to offer Estate Planning services. Wealth.com provides a holistic estate planning solution that allows user to create, manage and administrate estate plans through a technology platform. Weatlh.com facilitates an optional hybrid model where clients can start the process digitally, but still receive a bespoke human experience by consulting live with one of Wealth.com’s local T&E attorney partners for a fee. Advisors purchase access to the Wealth platform as an annual license and can then invite or refer an unlimited number of clients to the platform for estate planning. Wealth.com allows TCPAM clients to create estate planning documents to action the legacy objectives that we have designed together. Once referred to Wealth, TCPAM clients enter the Wealth platform and are guided through the document creation process by Wealth, not by TCPAM. Though TCPAM can refer clients to the platform, TCPAM is not involved with the drafting of the legal documents and does not have the ability to make selections for the client. As the advisor, TCPAM can receive read-only visibility of the client account so that TCPAM can help ensure completion of the process of creating and continue to monitor for optimization opportunities. From a compliance standpoint, offering a Wealth account to a client is no different from any other estate planning referral TCPAM can make. Wealth prioritizes advisor compliance with industry best practices regarding legal ethics and profession rules of conduct. Wealth.com works with attorneys who are nationally recognized experts in advising technology firms seeking to structure ethically compliant relationships with consumers of legal services and governmental regulators. Management of Annuities TCPAM offers management of annuities and assists clients with the investment of the annuity sub accounts. Services Limited to Specific Types of Investments TCPAM generally limits its investment advice to mutual funds, fixed income securities, real estate funds, insurance products including annuities, and equities and ETFs (including ETFs in the gold and precious metal sectors), although TCPAM primarily recommends ETF’s and mutual funds. TCPAM may use other securities as well to help diversify a portfolio when applicable. TCPAM is also limited on what products and services it may offer to clients by an agreement with United Planners. United Planners acts as a broker-dealer for IARs of TCPAM and will only allow IARs and TCPAM to utilize products and services approved by United Planners. TCPAM, from time to time, will utilize the services of Academy Securities and/or Hill Top Securities to purchase bonds for client accounts. The bonds will then be placed in the client’s account at Charles Schwab. United Planners has approved TCPAM’s use of these services. C. Client Tailored Services and Client Imposed Restrictions TCPAM will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by TCPAM on behalf of the client. TCPAM may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. 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 TCPAM from properly servicing the client account, or if the restrictions would require TCPAM to deviate from its standard suite of services, TCPAM 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. TCPAM does not participate in wrap fee programs. E. Assets Under Management TCPAM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $599,787,048.00 $42,003,524.00 December 2023