A. Firm Information
Thrivent Advisor Network, LLC (“TAN,” “our,” "us," or “we”) is organized as a limited liability company (“LLC”) under the
laws of the State of Delaware and is a registered investment adviser with the SEC offering investment advisory services
since 2019. TAN is a wholly owned subsidiary of Thrivent Financial Holdings, Inc., a Delaware Corporation, which is in
turn a wholly owned subsidiary of Thrivent Financial for Lutherans.
B. Advisory Services
TAN serves as the portfolio manager for the investment advisory services under this Disclosure Brochure, whereby we
provide discretionary and non-discretionary investment advisory services to individuals, high-net-worth individuals,
families, trusts, estates, businesses, and retirement plans through our Advisory Persons. Clients receive ongoing
investment advice, but separately pay for securities transactions and brokerage-related fees (i.e., “non-wrap” account).
Advisory Persons may recommend the use of affiliated and non-affiliated Independent Managers and Investment
Platforms for investment advisory services. The use of Independent Managers and Investment Platforms offers Clients
the ability to utilize unaffiliated investment managers on a wrap-fee or non-wrap fee basis.
The words “Client,” “you,” and “your” refer to the person(s) who completes and signs the TAN Investment Management
Agreement, whether one or more individuals or entities. Prior to engaging us to provide investment advisory services,
you are required to enter into one or more agreements with us that define the terms, conditions, authority and
responsibilities of us, our Advisory Persons, and you.
Investment advisory services include the following:
• Establishing an Investment Strategy – Advisory Persons, in connection with you, will develop a strategy targeted
to achieve your investment goals and objectives.
• Asset Allocation – Advisory Persons will develop a strategic asset allocation that is targeted to meet your
investment objectives, time horizon, financial situation and risk tolerance.
• Portfolio Construction – Advisory Persons will develop a portfolio that is intended to meet your stated goals and
objectives.
• Investment Management and Monitoring – Advisory Persons will provide investment management and ongoing
monitoring of your portfolio.
C. Client Account Management
Advisory Persons will provide you with customized investment advisory solutions through continuous personal contact,
on-demand access, and interaction, while providing discretionary and non-discretionary investment management and
related advisory services. Advisory Persons will work closely with you to identify your investment goals and objectives,
risk tolerance, and financial situation in order to develop an appropriate investment strategy for you. Advisory Persons
will then implement an investment portfolio that seeks to achieve the outcome(s) of your investment strategy. Advisory
Persons may recommend internal investment management by its staff and/or the use of independent managers or
investment platforms (please see below). For discretionary investment management accounts, you will have the
opportunity to place reasonable restrictions on the types of investments to be held in your portfolio(s), subject to
acceptance by TAN.
Internal Investment Management – Advisory Persons will seek to utilize low-cost, diversified mutual funds and
exchange-traded funds (“ETFs”) for your portfolio. Advisory Persons may also utilize individual equities, individual bonds,
complex investments, brokered certificates of deposits (“CDs”), fee-based annuity sub-accounts, and other types of
investments including cash equivalent investments, as appropriate, to meet your needs. Advisory Persons may retain
certain legacy positions for you based on portfolio fit and/or tax considerations. The legacy position(s) you hold will be
included as part of the investment advisory service and advisory fee billing unless you notify us in writing to exclude the
legacy position(s). Note that neither TAN nor its Advisory Persons provide legal or tax advice.
Our investment approach is primarily long-term focused, but Advisory Persons may buy, sell or re-allocate investments
that have been held for less than one year to meet your objectives or due to market conditions. Advisory Persons will
construct, implement and monitor your portfolio to ensure it meets your goals, objectives, circumstances, and risk
tolerance.
Advisory Persons evaluate and select investments for inclusion in Client portfolios only after applying its internal due
diligence process. Advisory Persons may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Advisory Persons may recommend specific positions to increase sector or asset class weightings. Advisory
Persons may also recommend employing cash positions as an asset class and as possible hedge against market
movement. Advisory Persons may recommend selling positions for reasons that include, but are not limited to, harvesting
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capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or
overweighting of the position(s) in the portfolio, change in risk tolerance of the Client, generating cash to meet Client
needs, or any risk deemed unacceptable for the Client’s risk tolerance. It is more profitable for TAN to sell products
issued by Thrivent Financial for Lutherans and its affiliates than those issued by other companies. As a result, TAN has a
financial incentive to recommend them over other companies’ products. Client portfolio assets may include one or more
Thrivent Mutual Funds and/or Thrivent Exchange Traded Funds (Thrivent ETFs). When Clients invest in Thrivent Mutual
Funds and/or Thrivent ETFs, our affiliate Thrivent Asset Management, LLC receives fees (including revenue sharing) for
serving as the Investment Manager for the mutual funds and ETFs and for providing administrative and accounting
services to the funds pursuant to an Administrative Services Agreement. A conflict of interest exists
when Advisory
Persons recommend or elect to purchase a Thrivent Mutual Fund and/or Thrivent ETF in Client portfolios. We mitigate
this conflict by training our Advisory Persons on their responsibilities as a fiduciary and the duty of care owed to Clients
under the Investment Advisers Act of 1940, as amended (the “Advisers Act”).
Fee-based annuities - Advisory Persons will provide investment advice in connection with one or more fee-based
annuities (each a "Contract"). Each Contract is an annuity issued by an insurance company (the “Fee-Based Annuity
Sponsor”). Each Contract allows you to allocate your contract purchases (less any charges) to sub-accounts and
corresponding underlying investment funds the Fee-Based Annuity Sponsor has designated as eligible for its annuity
separate account (the "Funds"). The selection of Funds provides an opportunity to design a diversified investment
portfolio in a specified asset class or achieve a specific investment strategy. Each of the Funds will have unique expense
ratios based on the allocation within the Contract. Additional information about the Funds is available in the Contract's
prospectus.
At no time will we accept or maintain custody of a Client’s funds or securities, except for the limited authority as detailed
in Item 15 – Custody. All Client assets will be managed within their designated account(s), pursuant to the Investment
Management Agreement. Please see Item 12 – Brokerage Practices.
Independent Managers and Investment Platforms – An Advisory Person may recommend that you utilize the investment
advisory services and/or model portfolios of one or more investment managers or investment platforms (collectively
“Independent Managers”) for all or a portion of your investment portfolio, based on your needs and objectives.
Investment Managers include our affiliate Thrivent Asset Management, LLC, third-party money managers, third-party
sub-advisors, and/or third-party investment platforms.
The use of an Independent Manager may require your authorization by entering into an investment management
agreement with the Independent Manager(s) that defines the terms in which the Independent Manager(s) will provide
investment management and related services. Advisory Persons will assist in developing investment policy
recommendations and managing ongoing Client relationships. TAN will perform initial and ongoing oversight and due
diligence over the selected Independent Manager(s) to ensure the strategy remains aligned with your investment
objectives and overall best interests.
Prior to entering into an investment management agreement with an Independent Manager, you will be provided with the
Independent Manager's Form ADV 2A Disclosure Brochure (or a brochure that provides information about the
Independent Manager and the advisory services it provides, conflicts of interests and other important information). When
an Independent Manager serves as a sub-advisor (“Sub-Advisor”), the Sub-Advisor will have the authority to provide
discretionary investment advisory services with respect to the assets held in your specified account. This means placing
trade orders for transactions without first contacting you and obtaining your permission. The Sub-Advisor will provide
these services in accordance with the direction of Advisory Persons through the selection of one or more model
portfolios, the selection of individual securities, or a combination of model portfolios and individual securities by the
Advisory Persons.
Clients must inform us in writing of the investment objectives of the account(s) and of any changes or modifications
therein as well as any specific investment restrictions, guidelines or limitations which are included in a trust, plan or
similar document or are imposed by law or regulations. We and any Independent Managers will rely on: (a) information
the Client has provided; (b) any restrictions on the management of the account(s) imposed by the Client; and (c) any
written investment policies or guidelines provided by the Client. Any of these may cause us and/or any Independent
Managers to make investment decisions or recommendations it otherwise would not make in managing or advising the
account(s).
You may dedicate certain cash/cash equivalents or securities in your account to be held as non-managed assets (“Non-
Managed Assets”). Any Non-Managed Assets held in your account will not be part of the investment advisory services for
purposes of calculating your Advisor Management Fee, and TAN and your Advisory Person will not provide investment
advice or other related investment management services on these assets.
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D. Other Investment Advisory Services
We also offer wrap fee investment advisory services on a discretionary and non-discretionary basis. Clients in the wrap
fee program receive ongoing investment advice, brokerage and related services—including performance, custody and
transaction reporting for a single asset-based fee. Depending on the level of trading required for the Client’s account(s)
in a particular year, the Client may pay more or less in total fees than if the Client paid his or her own transaction fees.
Review the Wrap Fee Program Brochure for a full description of the respective investment management services.
In addition, TAN offers Financial Planning and Consulting Services and Retirement Plan Advisory Service to clients. The
financial planning and consulting services may encompass one or more areas of need, including, but not limited to
investment planning, retirement planning, estate planning, personal savings, education savings, insurance needs, and
other areas of a client’s financial situation. The Retirement Plan Advisory Service is offered to retirement plans pursuant to
The Employee Retirement Income Security Act of 1974 and includes both fiduciary and non-fiduciary services to the sponsor
of the Plan and the participants of the Plan. This service is provided on a non-discretionary basis.
E. Assets Under Management
As of December 31, 2023, TAN had $6,094,285,085 in discretionary assets and $69,501,427 in nondiscretionary assets.