Description of Firm
TrueWealth Advisors, LLC is a registered investment adviser based in Hoover, Alabama. We are
organized as a limited liability company ("LLC") under the laws of the State of Alabama. We have been
providing investment advisory services since October 2018. We are owned by Larry J. Sims and Paul
B. Marks. TrueWealth Advisors, LLC offers the same services under the following DBAs;
TrueWealth Advisors, LLC of Huntsville, Grant Wealth Management, Williamson Financial
Services, and Benefit Planners, Inc.
The following paragraphs describe our services and fees. Refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual
needs. As used in this brochure, the words "we," "our," and "us" refer to TrueWealth Advisors, LLC and
the words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
Portfolio Management Services
We offer discretionary and non-discretionary portfolio management services. Our investment advice is
tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio
management services, we will meet with you to determine your investment objectives, risk tolerance,
and other relevant information at the beginning of our advisory relationship. We will use the information
we gather to develop a strategy that enables our firm to give you continuous and focused investment
advice and/or to make investments on your behalf. As part of our portfolio management services, we
may customize an investment portfolio for you according to your risk tolerance and investing
objectives. Once we construct an investment portfolio for you, we will monitor your portfolio's
performance on an ongoing basis and will rebalance the portfolio as required by changes in market
conditions and in your financial circumstances.
If you participate in our discretionary portfolio management services, we require you to grant our firm
discretionary authority to manage your account. Discretionary authorization will allow us to determine
the specific securities, and the amount of securities, to be purchased or sold for your account without
your approval prior to each transaction. Discretionary authority is granted in the investment advisory
agreement you sign with our firm and the appropriate trading authorization forms. You may limit our
discretionary authority (for example, limiting the types of securities that can be purchased or sold for
your account) by providing our firm with your restrictions and guidelines in writing with the exception of
securities purchased in our models.
As part of our portfolio management services, in addition to other types of investments (see
disclosures below in this section), we may invest your assets according to one or more
model portfolios developed by our firm. These models are designed for investors with varying degrees
of risk tolerance ranging from a more aggressive investment strategy to a more conservative
investment approach. Clients whose assets are invested in model portfolios may not set restrictions on
the specific holdings or allocations within the model, nor the types of securities that can be purchased
in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of
securities in their account. In such cases, this may prevent a client from investing in certain models
that are managed by our firm.
We may also provide portfolio management using model portfolios available on a platform operated by
Orion Communities. Orion Communities offers our firm access to models from well-known asset
managers and institutional strategists through a robust model marketplace. Through Orion
Communities, we are able to analyze and subscribe to various model portfolios to be utilized in our
client accounts. Once we assign a model to a client’s account, we will receive an initial model
allocation and will determine the trades to place in our client’s account. As model managers update
their allocation, we will receive model allocation changes to any model we have subscribed to. We will
either trade our client account to the new model or maintain the current allocation. The third party
model manager does not have discretion or the ability to trade our client’s account. We retain
discretion to select and change the model for our client’s account and the securities to be traded in the
account.
Clients who have engaged us for portfolio management services may receive complimentary financial
planning at no additional cost.
We may also offer non-discretionary portfolio management services. If you enter into non-discretionary
arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf
of your account. You have an unrestricted right to decline to implement any advice provided by our firm
on a non-discretionary basis.
We provide an additional service for accounts not directly held at the custodian but where we do have
discretion and may leverage an Order Management System to implement asset allocation or
rebalancing strategies on behalf of the client. These are primarily 401(k) accounts, 403(b), and other
retirement plans, and other assets we do not custody. We regularly review the current holdings and
available investment options in these accounts, monitor the accounts, rebalance, and implement our
strategies as necessary. We charge an annual fee for services provided to held away accounts, which
is deducted from an account under our portfolio management service on a monthly basis in arrears or
by other means such as invoicing. Fees are based on the assets within these accounts, and are
charged according to our standard fee schedule, according to the average daily balance of the
previous month as valued by the account custodian.
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.
We offer recommendations on ESG (Environmental, Social and Governance issues) investing for
clients who require such objectives and outcomes.
Financial Planning Services and Consulting Services
We offer financial planning and consulting services which typically involve providing a variety of
advisory services to clients regarding the management of their financial resources based upon an
analysis of their individual needs. The areas we address may include, but are not limited to: education
planning, asset allocation, debt management, distribution planning, tax planning, business succession
planning, accumulation goals, financial planning, retirement planning, estate planning, and budget and
cash flow analysis.
Our recommendations are based on your stated goals, objectives, time horizon, and financial
information you provide to our firm. You have the right to accept or reject our recommendations, and
you may choose any firm to assist you with implementing our recommendations.
While we endeavor at
all times to offer our clients specialized services at reasonable costs, the fees charged by other
advisers for comparable services may be lower than the fees charged by our firm.
Selection of Other Advisers
We may recommend that you use the services of a third-party money manager ("TPMM") to manage
all, or a portion of, your investment portfolio. After gathering information about your financial situation
and objectives, we may recommend that you engage a specific TPMM or investment program. Factors
that we take into consideration when making our recommendation(s) include, but are not limited to, the
following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals,
risk tolerance, and investment objectives. We will monitor the TPMM(s)' performance to ensure its
management and investment style remains aligned with your investment goals and objectives.
The TPMM(s) will actively manage your portfolio and will assume discretionary investment authority
over your account. We will assume discretionary authority to hire and fire TPMM(s) and/or reallocate
your assets to other TPMM(s) where we deem such action appropriate.
Solicitor (Referral) Program
We may act in a “solicitor” capacity for a TPMM program available to our clients. When acting as a
solicitor for the TPMM Program neither TrueWealth nor its investment advisor representative provides
investment advisory services in relation to the TPMM program. Instead, the investment advisor
representative will assist the client in selecting one or more TPMM programs believed to be suitable
based on the client’s stated financial situation, investment objectives, and financial goals. In the
solicitor program we maintain an agreement with the TPMM for providing client referrals. In these
cases, we receive referral fees for making the referral, which are generally referred to as “Solicitor
Fees”. In most cases the solicitor fees are calculated as a percentage of the client assets that the
TPMM manages; however, there may be instances where the Solicitor Fees are determined in some
other fashion. The solicitor fees are disclosed to clients and prospective clients in accordance with
Rule 206(4)-1 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), which
governs the payment of fees for client referrals.
When we act as a solicitor for a TPMM program, the client will receive a written solicitor disclosure
statement describing the nature of our relationship with the TPMM program, if any; the terms of our
compensation arrangement with the TPMM program, including a description of the compensation we
will receive for referring a client to the TPMM program; and the amount, if any, the client will be
charged, in addition to the advisory fee the client pays to the TPMM as a result of our referral to the
TPMM program, if applicable. As of the date of this brochure, we currently hold a solicitation
arrangement with City National Rochdale
Pension Consulting Services
When delivering ERISA fiduciary services, TrueWealth will perform those services to the plan as a
fiduciary under ERISA Section 3(21) and will act in good faith and with the degree of diligence, care
and skill that a prudent person rendering similar services would exercise under similar circumstances.
When providing any ERISA fiduciary services, TrueWealth will make recommendations to the Sponsor
and the Sponsor retains full discretionary authority or may outsource to another provider (as defined by
ERISA Section 3(38)) or control over assets available in the plan. ERISA fiduciary services can be
provided to plan participants; the plan participants maintain full discretionary authority and control over
their personal retirement accounts.
Sponsors may engage TrueWealth to perform the Retirement Plan Services by completing an ERISA
application that describes how TrueWealth will serve the plan and the fees to be charged for those
services. The application describes additional terms of the arrangement between TrueWealth and the
Sponsor, including services in addition to the retirement plan. By signing the application, the Sponsor
represents they have received sufficient information and determined that the Retirement Plan Services
selected are: (i) necessary for the operation of the plan and (ii) reasonable and appropriate based
upon the compensation to be paid for the Services. The Plan Sponsor must sign and complete the
application before TrueWealth performs any Retirement Plan Services.
In providing Retirement Plan Services, TrueWealth may establish a separate client relationship with
one or more plan participants, beneficiaries, or Sponsors. TrueWealth will not solicit services from plan
participants or beneficiaries when providing Retirement Plan Services to the plan. If TrueWealth is
providing Retirement Plan Services to a plan, TrueWealth may, when requested by a plan participant,
beneficiary, or Sponsor, arrange to provide services through a separate agreement that excludes any
investment advice on plan assets. If a plan participant or beneficiary desires to affect an IRA Rollover,
TrueWealth will obtain a signed disclosure from the plan participant. The plan participant retains final
authority to determine whether to affect the rollover.
TrueWealth benefits from the compensation paid to TrueWealth and will directly or indirectly receive a
portion of the fees and other compensation paid by Retirement Plan Services clients. Those clients
may also use other products or services available from or through TrueWealth and in such case pay
additional compensation. This practice creates a conflict of interest that gives TrueWealth an incentive
to recommend Retirement Plan Services based on the compensation received. TrueWealth addresses
these conflicts through disclosure(s) in this brochure and additional disclosures concerning
compensation we receive, directly or indirectly. TrueWealth will also offset or refund additional
compensation when required by law.
As part of our investment advisory services, TrueWealth can make recommendations to plan
participants regarding the rollover of employer-sponsored retirement plan assets. In the case where
TrueWealth recommends a retirement plan rollover into a TrueWealth advisory account, TrueWealth
will earn a portion of the advisory fee. This presents a conflict of interest because TrueWealth has an
economic incentive to recommend you rollover your retirement plan into an advisory program account.
Plan participants are under no obligation to rollover retirement plan assets to an IRA and should
carefully consider all relevant factors, such as penalty-free withdrawals, whether loans are permitted,
legal protections, required minimum distributions, fees and expenses, service levels, available
investment options, employer stock considerations, and state taxes. Participants of employer-
sponsored retirement plans typically have four options upon termination of service from the sponsoring
company: (1) leave the assets in the current employer’s plan, if permitted; (2) rollover assets to a new
employer’s retirement plan, if available and rollovers are permitted; (3) rollover assets to an Individual
Retirement Account (IRA); and (4) withdraw funds from employer plan (subject to taxes and penalties).
Plan participants may implement a combination of available options.
Wrap Fee Program
We do not participate in any wrap fee program.
Types of Investments
We offer advice on equity securities, mutual funds, exchange traded funds ("ETFs"), variable
annuities. Additionally, we may advise you on various types of investments based on your stated goals
and objectives. We may also provide advice on any type of investment held in your portfolio at the
inception of our advisory relationship.
As of December 2022, we provide continuous management services for $306,522,968in client assets
on a discretionary basis.