TCWP offers a variety of advisory services, which include financial planning, consulting, and
investment management services. Prior to TCWP rendering any of the foregoing advisory services,
clients are required to enter into one or more written agreements with TCWP setting forth the relevant
terms and conditions of the advisory relationship (the "Advisory Agreement").
TCWP allows its investment adviser representatives ("IARs") autonomy in managing client assets.
Each IAR will determine the recommended investments in client accounts and will have his or her own
methods of analysis and investment strategies.
TCWP offers services through its network of IARs. IARs may use D/B/A names ("doing business as"
names) and such names and logos are used for marketing purposes and may appear on marketing
materials or client statements. The IARs are under the supervision of TCWP, and the advisory services
of the IAR are provided through TCWP. For a complete list of D/B/A names please refer to the Firm's
ADV Part 1, accessible through the SEC's website,
www.adviserinfo.sec.gov, or in certain instances
the D/B/A name is listed on the IAR's ADV Part 2B Brochure.
TCWP filed for registration as an investment adviser in July 2019. The Firm is owned by MGO/OS
Holdings, LLC.
As of December 31, 2023, TCWP had $100,511,738 in total assets under regular and continuous
management, of which $99,034,093 was managed on a discretionary basis and $1,477,645 was
managed on a non-discretionary basis.
While this brochure generally describes the business of TCWP, certain sections also discuss the
activities of its Supervised Persons, which refer to the Firm's officers, partners, directors (or other
persons occupying a similar status or performing similar functions), employees or other persons who
provide investment advice on TCWP' behalf and are subject to the Firm's supervision or control.
Financial Planning and Consulting Services
TCWP offers clients a broad range of financial planning and consulting services. These services can
include asset allocation recommendations of assets not managed by the Firm (including alternative
investments) and preliminary financial planning advice. These services are included with the Firm's
investment management services as described below. The Firm may also be engaged to provide more
substantial financial planning and consulting services as part of a separate agreement.
In performing these services, TCWP is not required to verify any information received from the client or
from the client's other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to
rely on such information provided by the client or client's other professionals. TCWP expects to
recommend certain clients engage the Firm for additional related services, its Supervised Persons in
their anticipated individual capacities as insurance agents or registered representatives of a broker-
dealer and/or other professionals to implement its recommendations. Clients are advised that a conflict
of interest exists for the Firm to recommend that clients engage TCWP or its affiliates to provide (or
continue to provide) additional services for compensation, including investment management services.
Clients retain absolute discretion over all decisions regarding implementation and are under no
obligation to act upon any of the recommendations made by TCWP under financial planning or
consulting advice. Clients are advised that it remains their responsibility to promptly notify the Firm of
any change in their financial situation or investment objectives for the purpose of reviewing, evaluating
or revising TCWP's recommendations and/or services.
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Investment and Wealth Management Services
TCWP manages client investment portfolios on a discretionary or non-discretionary basis. TCWP
primarily allocates client assets among various mutual funds, exchange-traded funds ("ETFs"),
individual debt and equity securities, options and independent investment managers ("Independent
Managers") in accordance with the client's stated investment objectives.
Clients can engage TCWP to manage and/or advise on certain investment products that are not
maintained at their primary custodian, such as variable life insurance and annuity
contracts, and assets
held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these
situations, TCWP 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.
TCWP tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a
continuous basis, that client portfolios are managed in a manner consistent with those needs and
objectives. TCWP consults with clients on an initial and ongoing basis to assess their specific risk
tolerance, time horizon, liquidity constraints and other related factors relevant to the management of
their portfolios. Clients are advised to promptly notify TCWP if there are changes in their financial
situation or if they wish to place any limitations on the management of their portfolios. Clients can
impose reasonable restrictions or mandates on the management of their accounts if TCWP
determines, in its sole discretion, the conditions would not materially impact the performance of a
management strategy or prove overly burdensome to the Firm's management efforts.
Use of Independent Managers
As mentioned above, TCWP selects certain Independent Managers to actively manage a portion of its
clients' assets. The specific terms and conditions under which a client engages an Independent
Manager may be set forth in a separate written agreement with the designated Independent Manager.
In addition to this brochure, clients may also receive the written disclosure documents of the respective
Independent Managers engaged to manage their assets.
TCWP evaluates a variety of information about Independent Managers, which includes the
Independent Managers' public disclosure documents, materials supplied by the Independent Managers
themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm
seeks to assess the Independent Managers' investment strategies, past performance and risk results
in relation to its clients' individual portfolio allocations and risk exposure. TCWP also takes into
consideration each Independent Manager's management style, returns, reputation, financial strength,
reporting, pricing and research capabilities, among other factors.
TCWP continues to provide services relative to the discretionary or non-discretionary selection of the
Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts
being managed by Independent Managers. TCWP seeks to ensure the Independent Managers'
strategies and target allocations remain aligned with its clients' investment objectives and overall best
interests.
Rollover Recommendations
For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02")
where applicable, we are providing the following acknowledgment to you. 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
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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 benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.