A. Description of the Advisory Firm
Trivium Point Advisory LLC (“TPA” or the “Advisor”) is a limited liability company organized
in the State of Delaware, located in the State of Connecticut. TPA became an investment
advisory firm registered with the U.S. Securities and Exchange Commission (“SEC”) in
February 2018. TPA is owned by Trivium Point Financial Holdings LLC. The majority owners
of Trivium Point Financial Holdings LLC are George Gerhard and Ron Pac. The Advisor is
operated by George Gerhard (Managing Partner, Chief Compliance Officer), Ron Pac (Managing
Partner), Lee Rawiszer (Managing Partner), and David Halper (Managing Partner), and Paul
Volpe (Managing Partner).
All statements in this Disclosure Brochure, including those made in the present tense, describe
the prospective business of TPA. If you have any questions regarding the content of this
Disclosure Brochure, please do not hesitate to contact the Advisor’s Chief Compliance Officer,
George Gerhard by telephone at (203) 221-3085.
B. Types of Advisory Services
TPA offers investment advisory services to individuals, high net worth individuals, family
offices, trusts, institutions, businesses, charitable foundations, and retirement/profit-sharing plans
(each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under applicable laws and regulations.
As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client
and seeks to mitigate potential conflicts of interest. TPA’s fiduciary commitment is further
described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics,
please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading.
TPA advises Clients in all areas of financial management, including tax-efficient wealth
accumulation, retirement, estate and gift planning as well as income planning. TPA’s
comprehensive services can include values-based wealth, income and estate planning, assistance
with insurance, real-estate holdings, multigenerational wealth planning and entrepreneurial needs
and philanthropy.
Financial Planning Services
TPA offers its Clients a variety of comprehensive financial planning and consulting services.
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 cash flow
analysis, investment planning, retirement planning, estate planning, personal savings, educational
savings, and other areas of a Client’s financial situation.
A financial plan developed for or financial consultation rendered to the Client will typically
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. TPA may recommend the services of itself and/or other professionals
to implement its recommendations. Depending on Client circumstances, TPA may also offer the
preparation of tax returns as part of its financial planning services. Clients are advised that a
conflict of interest exists if pursuant to a separate financial consultation arrangement, TPA
recommends its own services, as such a recommendation may increase the amount of advisory
fees paid to TPA. The Client is under no obligation to act upon any of the recommendations made
by TPA or its Advisory Persons under a financial planning or consulting engagement to engage
the services of any such recommended professional, including TPA itself.
Investment Management Services
Internal Investment Management – TPA’s portfolio construction process follows five basic
principles that manage risk, maximize diversification, use alternative investments, capitalize on
traditional asset classes and maintain a consistent portfolio process.
In designing and implementing customized models and portfolio strategies, TPA manages, on
either a discretionary or non-discretionary basis, a broad range of investment strategies and
vehicles. TPA primarily allocates Client assets among various mutual funds, exchange-traded
funds (“ETFs”), and individual debt and equity securities in accordance with Clients’ stated
investment goals and objectives. In addition, TPA can design and implement customized
strategies, managing a broad range of investment strategies and vehicles including traditional asset
classes and alternative investments.
Where appropriate and requested by Clients, TPA may also provide advice about positions held in
their portfolios prior to engaging TPA. Clients may also engage TPA to manage and/or advise on
certain investment products that are not maintained at their primary custodian, including, but not
limited to, variable life insurance and annuity contracts, assets held in employee sponsored
retirement plans and qualified tuition plans (for example, 529 plans). In those situations, TPA
directs or recommends the allocation of Client assets among the various investment options
available with the product. These assets are generally maintained at the underwriting insurance
company or the custodian designated by the product’s provider. Certain external managers utilized
by TPA may use custodians other than the primary custodian recommended by TPA.
Use of External Managers – TPA also recommends to Clients that all or a portion of their
investment portfolio be managed on a discretionary basis by one or more unaffiliated money
managers or investment platforms (“External Managers”). The Client may be required to enter into
a separate agreement with the External Manager[s], which will set forth the terms and conditions
of the Client’s engagement of the External Manager or will receive a Statement of Investment
Selection in a single contract relationship. TPA generally renders services to the Client relative to
the discretionary selection of External Managers. TPA will assist in establishing the Client’s
investment objectives for the assets managed by External Managers, monitors and reviews the
account performance and defines any restrictions on the account[s]. TPA will perform initial and
ongoing oversight and due diligence over the selected External Manager[s] to ensure the External
Managers’ strategies and target allocations remain aligned with its Clients’ investment objectives
and overall best interests. The investment management fees charged by the designated External
Manager[s], together with the fees charged by the corresponding designated broker-
dealer/custodian of the Client’s assets, are exclusive of, and in addition to, the annual advisory fee
charged by TPA.
Institutional Intelligent Portfolios® Platform – For certain Clients, TPA may recommend that all or
a portion of a Client’s investment portfolio be established through an automated investment
program offered by TPA and made available through the Custodian, Charles Schwab & Co., Inc.
(“Schwab”). Under this service, Clients will engage TPA through
an investment management
agreement for these advisory services and utilize the Institutional Intelligent Portfolios® Platform
(“IIP”) offered by Schwab Performance Technologies, a software provider affiliated with Schwab.
IIP is an automated investment engine through which TPA manages the Client’s portfolio on an
ongoing basis through automatic rebalancing and tax-loss harvesting. TPA will have the
discretionary authority to instruct IIP with respect to portfolio construction, consisting of only
exchange-traded funds (“ETFs”) and asset allocation, subject to the limitations described herein.
IIP will implement the portfolio and will have discretionary authority to automatically rebalance
the portfolio back to the Client’s target allocation.
IIP utilizes ETFs, representing various asset classes for the construction of investment portfolios.
TPA will work with each Client to select a portfolio to meets the needs of the Client. The Client
has limited ability to put restrictions on its account[s]. The portfolios cannot contain investments
that are not included in the IIP universe of available ETFs.
TPA will delegate limited investment discretion to IIP to implement trading and rebalancing within
the parameters of the Advisor’s investment strategies. The Advisor’s investment philosophy is
long-term, but the Advisor may make such tactical overrides to take advantage of market pricing
anomalies or strong market sectors. Client portfolios must maintain a minimum balance of $5,000
to be eligible for automatic rebalancing. Prior to engagement, the Advisor will provide the Client
with the Schwab Intelligent Portfolios Sweep Program Disclosure Statement. The Advisor shall
only earn its fees as described in Item 5 below.
Schwab Bank Pledged Asset Line® - The Advisor may introduce certain Clients to a Pledged Asset
Line®, a non-purpose revolving line of credit available offered through Charles Schwab Bank,
secured by eligible assets held in an account maintained at the Custodian. (“Lending Program”). In
such instances, the Client’s assets in their account[s] at the Custodian will be utilized as collateral
for a non-purpose revolving line of credit. The recommendation of a Lending Program presents a
conflict of interest as the Advisor will continue to receive investment advisory fees for managing
the collateralized assets in the Client’s account[s]. Clients are not obligated to engage the Advisor
for the Lending Program. For additional information related to the risks involved non-purpose
loans, please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss.
Participant Account Management- As part of the Advisor’s Investment Management Services,
when appropriate, the Advisor will use a third party platform to facilitate management of held
away assets such as defined contribution plan participant accounts, with discretion. The platform
allows the Advisor to avoid being considered to have custody of Client funds since the Advisor
does not have direct access to Client log-in credentials to affect trades. The Advisor is not affiliated
with the platform in any way and do not receive compensation from them for using their platform.
A link will be provided to the Client allowing them to connect an account(s) to the platform. Once
Client account(s) is connected to the platform, the Advisor will review the current account
allocations. When deemed necessary, the Advisor will rebalance the account considering client
investment goals and risk tolerance, and changes in allocations will take into account current
economic and market trends. The goal is to improve account performance over time, minimize loss
during difficult markets, and manage internal fees that harm account performance. Client
account(s) will be reviewed at least quarterly and allocation changes will be made as deemed
necessary.
Retirement Accounts- When the Advisor provides investment advice to Clients regarding ERISA
retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within
the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the
Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts.
When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a
Client regarding a distribution from an ERISA retirement account or to roll over the assets to an
IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g.
commission-based account to fee-based account). Such a recommendation creates a conflict of
interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the
transaction. No client is under any obligation to roll over a retirement account to an account
managed by the Advisor.
Retirement Plan Advisory Services
TPA provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a
“Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services
are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its
Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor.
Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Oversight Services
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
These services are provided by TPA serving in the capacity as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA
Section 408(b)(2), the Plan Sponsor is provided with a written description of TPA’s fiduciary
status, the specific services to be rendered and all direct and indirect compensation the Advisor
reasonably expects under the engagement.
C. Client-Tailored Advisory Services
Each Client’s needs are different. TPA tailors its investment advisory services to the specific
needs of each Client. Each investment advisory Client is provided an Advisory Person whose
role is to facilitate the provision of investment advisory services that are tailored to the Client’s
unique circumstances. TPA consults with Clients on an initial and ongoing basis to assess their
specific risk tolerance, time horizon, income tax issues, liquidity constraints and other related
factors relevant to the management of their portfolios. If a Client’s financial situation changes, or
if their investment objectives or risk tolerance changes, Clients are advised to promptly advise
TPA of such changes or if they wish to place any limitations on the management of their
portfolios. Clients may impose reasonable restrictions on the management of their accounts if
TPA determines, in its sole discretion, that the conditions would not materially impact the
performance of a management strategy or prove overly burdensome for TPA’s management
efforts.
D. Assets Under Management
As of December 31, 2023, TPA has $716,160,443 in regulatory assets under management,
$617,768,767 of which are managed on a discretionary basis and $98,391,676 on a non-
discretionary basis. Clients can request more recent information at any time by contacting the
Advisor.