Trust Advisors, LLC (“Advisor”) is a privately-held corporation that began providing investment advisory
services in 2018. Advisor’s parent company is Sheaff Brock Capital Management, LLC, whose principal
owners are:
• David Sheaff Gilreath, Managing Director, and
• Ronald Robert Brock, Managing Director.
This Brochure provides important information about Advisor, its services and compensation, the costs of
its advisory services, and situations where its interests may conflict with the interests of its clients.
Clients should pay particular attention to the discussions about the various potential conflicts of interest
because these can affect Advisor’s judgment in managing client’s account, in recommending the
custodian to hold account assets, and in choosing the broker to execute trades for the account, among
other important considerations. Clients should consider that Advisor will have the authority to invest in
shares of the Auer Growth Fund whose investment adviser, SBAuer Funds, LLC, is partially owned by
our parent company. Advisor will have the authority to invest in shares of the Dividend Performers ETF
and Preferred-Plus ETF whose investment adviser, Innovative Portfolios, LLC (IP) is wholly owned by
our parent company. For certain Portfolios, Advisor will also have the authority to allocate management
of account assets to a subadvisers, IP and Sheaff Brock Investment Advisors, LLC (SBIA), Salzinger
Sheaff Brock, LLC ("SSB"), which are owned or partially owned by our parent company. Our parent
company will benefit economically from advisory fees earned by SBAuer Funds, SBIA, SSB and IP,
from client assets managed by them. This benefit provides an incentive to invest a client’s account in
the SBAuer Funds, IP managed ETFs or allocate assets to IP, SBIA or SSB, based on the economic
benefit our parent will receive rather than the investment needs of the client.
If you have questions about the information in this Brochure, you can reach your investment adviser
representative (the “Portfolio Consultant”) at the email address, telephone number, or street address
shown on the Brochure Supplement he or she gives you.
As used in this brochure, the words "we," "our," and "us" refer the Advisor and the words "you," "your,"
and "client" refer to you as either a client or prospective client of our firm.
SERVICES ADVISOR OFFERS
Advisor offers a range of investment advisory programs and services ("Program"), including the
following:
• Individual Portfolio Management Services (“IPM Services”)
• Model Portfolio Management Services (“MPM Services”)
• Consulting Services
Please note that the information in this Brochure is necessarily general and does not address all details
of Advisor’s services. Because certain terms of a client’s Advisory Agreement are negotiable, clients
should always refer to their individual Advisory Agreement for terms that apply specifically to them.
INDIVIDUAL PORTFOLIO MANAGEMENT SERVICES ("IPM")
Through our IPM Services, we offer individualized portfolio management services for clients seeking a
customized approach, rather than one based on a “Model Portfolio” (see below for a description of our
Model Portfolios Management).
Suitability Information
Through the IPM Services, the Portfolio Consultant will work with the client to identify the client’s
personal and financial situation, and the investment objective, tolerance for risk, liquidity needs, and
investment time horizon (all the "Suitability Information") for the account that will be managed through
the IPM Services.
Based on the Suitability Information and any other information the Portfolio Consultant determines
appropriate under the circumstances, the Portfolio Consultant will work with the client to develop a
portfolio of investments which is suitable for initial investment of the assets to be managed through the
IPM Services. The portfolio will provide for allocation of the assets among various asset classes, to be
managed by the Portfolio Consultant on a fully discretionary basis according to an investment style and
strategy consistent with the account's Suitability Information.
Portfolio Investments
For IPM Services accounts, Portfolio Consultants typically develop a portfolio comprised of a diversified
mix of investments consistent with the Suitability Information. The investments are drawn from the
Securities About Which We Offer Advice described below, as the Portfolio Consultant determines
suitable for the account. The investment strategy and any liquidity needs and investment restrictions
imposed by the client will affect the specific types of investments we purchase for the account. When
suitable for the account, a Portfolio Consultant may develop a portfolio and manage an account based
on investment strategy ideas or investment selections from the Model Portfolios (discussed below),
adapted to the individual needs and objectives of the account. At times, specific investments can
include the Auer Growth Fund or use a portfolio designed by SBIA, SSB or IP as an allocation based
upon the investment objectives. These offerings are managed by affiliated companies. Tax
considerations are recognized, but not the driving force in portfolio management decisions.
MODEL PORTFOLIO MANAGEMENT SERVICES ("MPM")
Through our MPM Services, we offer portfolio management services based on our Model Portfolios.
Each Model Portfolio is designed to meet a particular investment objective. Model Portfolios can be
used to build an appropriate mix of income and growth potential for the client. Following are the current
Model Portfolios we offer:
Value Equity - This model consists of about 30 to 35 diversified equity positions. The Value Equity
portfolio invests primarily in securities of large-capitalization companies that have the potential for long-
term capital appreciation. Stock selection considers factors such as security prices that reflect a market
valuation that is judged to be below the estimated present or future value of the company; favorable
earing prospects and dividend yield. The portfolio seeks to select securities that it believes are
undervalued in relation to their intrinsic value as indicated by multiple factors. The investment objective
of the portfolio is capital appreciation. The Value Equity portfolio does not attempt to time the market.
The portfolio has a goal to be fully invested at all times.
Income Equity - This model consists of about 25 - 30 diversified equity positions. The Income Equity
portfolio strives to select companies that provide high, steady and consistent dividend income.
Additionally, the portfolio seeks companies that have the ability to increase dividends and provide long
term capital appreciation over time. The investment objective of the portfolio is income and capital
appreciation. The Income Equity portfolio does not attempt to time the market. The portfolio has a goal
to be fully invested at all times.
Growth Equity - This model consists of about 30 to 35 diversified equity positions. The Growth Equity
portfolio invests in companies that have the potential for revenue and earnings to grow faster than the
overall market. The primary objective of the strategy is capital appreciation. The Growth Equity portfolio
does not attempt to time the market. The portfolio has a goal to be fully invested at all times.
Covered Call - This model consists of covered call option contracts written (sold) to correspond with
existing securities held in a portfolio (as described above). A premium is received from writing/selling a
covered call contract for agreeing to sell an underlying security at a specific price (strike price) by a
specific date (expiration date). Turnover is very high
and short-term capital gains are common. The
portfolio objective is income and secondarily capital appreciation.
Preferred Income - This portfolio consists of about 20 - 25 positions in preferred stocks and corporate
bond trusts that trade as preferred stocks. Generally, the stocks are NYSE listed and have a par value of
$25 per share, although institutional $1,000 par securities can be used. The objective is income and
capital preservation. Capital appreciation is generally minimal.
CUSTODIAN
Clients who wish to participate in the IPM Services or MPM Services must maintain their assets with a
qualified custodian (Custodian) acceptable to Advisor, in its sole discretion.
Please refer to Item 8 for information about Advisor’s methods of analysis and investment strategies, the
types of investments Advisor generally recommends, and the material risks involved with respect to the
IPM Service and MPM Service. Refer to Item 12 for information regarding brokerage.
CONSULTING SERVICES
Advisor provides a range of consulting services addressing a variety of investment and non-investment
related matters, such as investment consultations. The scope of these project-based services varies, as
each engagement is individually negotiated and tailored to accommodate the specific needs of a
particular client. In these cases, the services we provide will be included in a consulting agreement
negotiated by Advisor and the client. We will charge a project or consulting fee, which will vary
depending on the scope of the services to be provided. Advice is based on objectives communicated,
either orally or in writing, by the client or the client’s advisors. Advice may be provided through individual
consultations or a written plan document, as agreed between Advisor and client.
INFORMATION REGARDING OUR SERVICES
Changes in Client Circumstances
Clients are advised that changes in their personal or financial situation, investment objectives, tolerance
for risk, or investment time horizon may cause the strategy or portfolio designated for the client’s
account to become no longer suitable. In the event of any material change in client’s personal or
financial circumstances, client should contact the Portfolio Consultant or Advisor promptly so that we
may assist in identifying another program, strategy or other investments that better meet the client’s
needs.
Deposit Cash or Cash Equivalents
Generally, for the IPM Services and MPM Services, client is expected to deliver only cash or cash
equivalents to the Custodian. With Advisor’s consent, client may transfer securities to the Custodian, but
the securities will be liquidated to cash as soon as reasonably practical, unless Advisor agrees that such
assets may be retained in the account. Client may not transfer or deposit to the account any securities
that are not publicly traded or that cannot be promptly sold, except upon our agreement.
Client will grant us and the Custodian the authority, in our respective discretion, to liquidate securities
transferred into the account or to require client to transfer such securities out of the account upon
request.
Clients may withdraw account assets on notice to Advisor, subject to usual and customary securities
settlement procedures. Advisor designs its portfolios as long-term investments and the withdrawal of
assets may impair the achievement of a client’s investment objectives. Advisor may consult with its
clients about the options and implications of transferring securities. Clients are advised that when
transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the
mutual fund level (i.e. early redemption or contingent deferred sales charges) and tax ramifications, for
example.
Differences Among Portfolio Consultants’ Accounts
Portfolio Consultants develop different Portfolios for clients participating in the IPM Services and MPM
Services, follow different investment strategies and styles, and have different policies and practices for
developing, rebalancing, and adjusting portfolios in view of the Suitability Information of the accounts
they are managing. Consequently, it is expected that the portfolios, levels of volatility, fees, expenses,
returns, and performance will vary significantly among accounts from one Portfolio Consultant to
another, as well as among the accounts of each Portfolio Consultant. The Portfolio Consultant will be
acting on behalf of Advisor; and any discretion granted by the client to the Portfolio Consultant will be
deemed to be granted to, and may be exercised by, Advisor. Advisor, as the Portfolio Consultant’s
supervisor, will have the authority to direct any act of the Portfolio Consultant in the performance of any
service. Although the Portfolio Consultants act under the general supervision of Advisor and Advisor
monitors the accounts of each Portfolio Consultant, Advisor does not direct or mandate the investment
strategy or style followed by a Portfolio Consultant.
SECURITIES ABOUT WHICH WE OFFER ADVICE
We offer advice regarding a wide variety of securities, including:
• exchange-listed or over-the-counter, common, preferred, or convertible securities of domestic or
foreign issuers;
• warrants;
• certificates of deposit;
• corporate debt securities;
• municipal securities;
• securities issued by the US Treasury, agencies, or government sponsored enterprises;
• shares of money market funds, open-end investment companies (mutual funds), closed-end
funds, unit investment trusts, and exchange-traded funds (“ETFs”); and
• option contracts on securities.
However, with respect to any individual client’s account and Portfolio, our advice will be limited to those
securities with respect to which the client has requested advice and those which the Portfolio Consultant
determines are suitable for the account. This list is more extensive than the investments we recommend
for a typical client’s account. Please refer to the discussion in Item 4 with respect to the IPM Service and
MPM Service and in Item 8 for information about the investments we typically recommend.
IRA and Retirement Plan Clients
When the Advisor provides 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 interests
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 recommendation to roll over your assets from a retirement account to an account to be managed by
the Advisor creates a conflict of interest, as we will earn additional advisory fees as a result of the roll
over. There is no obligation for you to roll over your retirement account to an account managed by the
Advisor.
ASSETS UNDER MANAGEMENT
As of December 31, 2023, Advisor managed $0 on a discretionary basis and $0 of non-discretionary
assets of clients' assets.